bluuebunny/crossref_metadata_2025_split huggingface dataset:
Current Trends in Counteracting Thin (Insufficient) Capitalization in the Russian Legal System
Authors: A. Tsindeliani Imeda , T. Anisina Karina , V. Migacheva Elena , I. Lyutova Olga , Lesina Lyudmila 
Published: February 2022

The purpose of this study is to theoretically substantiate the stages of development of judicial approaches to the application of thin (insufficient) capitalization rules in the tax relations of Russian taxpayers with foreign companies, including transnational corporations, operating in Russia. The development of legal regulation and the corresponding judicial approaches regarding thin (insufficient) capitalization is retrospectively considered.
In particular, the possibility of applying this rule, provided double taxation avoidance, was studied as well as its correlation with the application of other anti-evasive norms of tax law in Russia. In addition, the following was performed: (1) periodization of the stages of judicial practice development on the application of thin (insufficient) capitalization rules by Russian courts; (2) formulation of new approaches contained in the Decision of the Supreme Court of the Russian Federation dated 14 September 2020 in case No. A60-29234/2019 (Mega-Invest Limited liability company (LLC)).
The practical significance of this article consists of proposals for eliminating the inadequacies of judicial practice in the aspect of thin capitalization as well as a recommendation to take into account the direction of development of such judicial practice in the preparation of tax regulatory acts and to prevent illegal methods of tax minimization.
Tax relations, taxpayer, judicial practice, interest rate, dividends.
Case Law Note: Tax Treaty Exemption Benefits for Students, Trainees, Scholars, and Teachers: An Analysis
Authors: Mohi Uddin Mohammed , S. Caselton Paul 
Published: February 2022

Tax treaties signed between the United States of America and other countries do not define various terms used in the treaties. Absences of such definitions contribute to creating disputes between tax payers and the Internal Revenue Service (IRS). Some of those disputes end up in tax courts. This article critically analyses various income tax exemption benefits available to nonresident alien students, scholars, trainees, and teachers in light of select income tax treaties/conventions. We also evaluate select tax court precedents interpreting various tax treaty benefits and the terms used in these tax treaties as interpreted by the US tax courts.
Tax treaty, nonresident alien, federal tax exemption benefit, case law precedents.
Value-Added Tax (VAT) and Sustainability in the European Union: A Radical Proposal Design Issues, Legal Aspects, and Policy Alternatives
Authors: Traversa Edoardo , Timmermans Benoît 
Published: February 2022

This article aims to examine how the implementation of environmental taxes could build on the success of value-added tax (VAT) to become more efficient and consistent. This is not to increase the overall tax burden on citizens but to reorganize existing indirect taxation differently by better taking into account European Union (EU) environmental objectives, in particular regarding the circular economy. With its broad tax base, its systemic structure based on neutrality (which does not exclude differentiation), its wide acceptance among taxpayers, and its proven compliance process, the VAT has some features that could inspire environmental policymakers. It indeed impacts consumer choices at the broadest possible level while avoiding distortions.
The authors begin by identifying the reasons for the success and robustness of VAT. A new concept of ‘green VAT’ will then be proposed based not on the classical instrument of reduced rates for specific transactions as is already done and advocated by EU institutions (European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, A new Circular Economy Action Plan. For a cleaner and more competitive Europe, COM(2020) 98 final (11 Mar. 2020). See also Opinion of the European Committee of the Regions – New Circular Economy Action Plan (2020/C 440/18), OJ C 440/107 (18 Dec. 2020), para. 23.) but on a coherent life cycle approach to all goods and services. This new approach identifies negative externalities by following the same value chain as the VAT. It aligns as much as possible with the administration and compliance methods already implemented by the VAT.
Finally, a possible virtual use of the new green VAT concept will be presented. It does not require any legislative changes. It takes the form of a ‘virtual tax’ that appears on the price tag of every product without being effectively paid and may be used as an indicator for the actual environmental cost of production.
VAT, EU harmonization, environmental taxation, sustainability, life-cycle assessment.
Country Note: Abolition Of Ddt In India: A Treat For Foreign Investors?
Authors: Raghuwanshi Himanshu 
Published: February 2022

The Indian government eliminated the much maligned dividend distribution tax (DDT) through Finance Act 2020. The abolishing of the DDT marks a return to the shareholder regime of dividend taxation (hereinafter ‘shareholder regime’). Foreign enterprises (generally multinational corporations) aiming to do business in India through subsidiaries or enterprises that already have subsidiaries in India can benefit from this change. This article analyses the tax impact of this change when an Indian subsidiary distributes its profits to its parent or holding company. Thus, the paper presents a tabular representation of taxation in the DDT regime and the shareholder regime and compares them. To present the complete scenario, the paper also analyses different profit distributing mechanisms other than dividends that are used by companies – specifically, the buyback of shares and share capital reduction. Finally, limited liability partnership (LLP) firms offer another vehicle for companies to conduct business in India. Thus, the paper also analyses the taxation aspects of an LLP distributing profits to its partner company.
The return to the shareholder regime will allow non-residents to avail beneficial tax rates provided for dividend taxation in double taxation avoidance agreements (DTAAs) signed by India with other countries. Thus, the final section of this article discusses the mechanisms that are in force to prevent treaty shopping. The principal purpose test (PPT) brought in by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) (Multilateral Instrument or MLI), the threshold of beneficial owners found in most DTAAs, and India’s domestic general anti-avoidance rule (GAAR) are analysed to determine the essential requirements of these mechanisms.
CFC, Individuals, BEPS, Action 3, Brazil.
كيف نسخر تقنية التحسس النائي الجوي لخدمة العمل الآثاري
Authors: زيدان رؤى زهير 
Published: February 2022

لجأ العالم منذ أواخر القرن الماضي الى توجيه اغلب بحوثه الى كل ما هو غير محسوس أو ملموس مثل الإشعاعات والموجات الكهرومغناطيسية، وقد كان التطور السريع لتقنيات التحسس
Hubungan Dukungan Keluarga Terhadap Kepatuhan Diet Penderita Hipertensi di Desa Ngompro Kecamatan Pangkur Kabupaten Ngawi
Authors: Nur’aini Elvya Yuni , Nisak Raudhotun 
Published: February 2022

Latar belakang: Hipertensi adalah suatu keadaan dimana kondisi tekanan darah pada pemeriksaan berulang seseorang memiliki >140mmHg (sistolik) dan >90 mmHg (diastolik). Tekanan darah penderita hipertensi dapat diturunkan dengan pola makan yang teratur, kegiatan fisik yang cukup dan dapat dikontrol dengan diet. Kepatuhan pasien dalam menjalankan dietnya sangat erat kaitannya dengan dukungan dari keluarga. Tujuan: untuk menganalisis Hubungan Dukungan Keluarga Terhadap Kepatuhan Diet Penderita Hipertensi Di Desa Ngompro Kecamatan Pangkur Kabupaten Ngawi.
Metode: Desain yang digunakan adalah korelasi dengan pendekatan cross sectional. Jumlah responden dalam penelitian sebanyak 50 responden. Pengumpulan data dengan menggunakan kuisioner dan uji rank spearman. Hasil: hasil penelitian diperoleh mayoritas responden (72%) mendapat dukungan keluarga baik sejumlah 36 orang, lebih dari setengahnya (62%) responden patuh terhadap diet hipertensi sejumlah 31 orang. Hasil uji rank spearman memperoleh nilai signifikan p=0,000 dan korelasi koefisien sebesar 0,657. Kesimpulan: berdasarkan hasil penenlitian menunjukkan H1 diterima, artinya ada hubungan dukungan keluarga terhadap kepatuhan diet penderita hipertensi di desa Ngompro Kecamatan Pangkur Kabupaten Ngawi.
Motivasi Gap-Year pada Mahasiswa Akper Pemkab Ngawi
Authors: Yati Nur , Sandi Yudisa Diaz Lutfi , Hidayah Nurul 
Published: February 2022

Pendahuluan : Gap-year menjadi salah satu pilihan mahasiswa Akper Pemkab Ngawi sebelum mereka melanjutkan pendidikan kejenjang yang lebih tinggi dengan didasari berbagai alasan. Penelitian ini bertujuan untuk menggali motivasi gap-year pada mahasiswa Akper Pemkab Ngawi. Metode : Penelitian ini menggunakan metode deskriptif kualitatif, partisipan berjumlah 7 orang yang dipilih sesuai kriteria inklusi menggunakan purposive sampling. Pengumpulan data menggunakan wawancara semi terstruktur. Tahap analisis data pada penelitian ini menggunakan teknik colaizzi yang di dukung software Nvivo 11 untuk menghindari missing data. Hasil : Pada penelitian ini di dapatkan 5 tema besar : (1) tidak lolos seleksi masuk perguruan tinggi, (2) desakan ekonomi, (3) ikut keputusan orang tua, (4) memperluas pengetahuan, (5) peningkatan soft skill. Kesimpulan : Motivasi gap-year pada mahasiswa Akper Pemkab Ngawi didasari dengan berbagai alasan yang nantinya akan menjadi pendorong mahasiswa Akper Pemkab Ngawi lebih memilih gap-year untuk sementara waktu sebelum mereka melanjutkan pendidikannya ke jenjang yang lebih tinggi.
Pathology Engagement in Global Health: Survey Data of Global Pathology Interest and Barriers
Authors: Razzano Dana , Gardner Jerad M. , Hall Allison , Jiang Xiaoyin “Sara” 
Published: February 2022

Context.—
Although pathology is essential to almost every practice in medicine, laboratory medicine professionals do not routinely volunteer in global health practice.

Objective.—
To gather information about the experience and interest levels of the pathology community in global health work.

Design.—
Data were analyzed from an 8-question, online, anonymous survey directed toward anyone working in the field of pathology and laboratory medicine. The survey collected data from respondents on their interest level in participating in global health pathology, potential barriers to participation, and the types of volunteer opportunities that would be of interest.

Results.—
A total of 267 people participated in the survey, of whom 142 (53%) were American citizens. One hundred seventy (64%) indicated that they had never volunteered in a low-resource setting. The majority of respondents (237; 89%) indicated interest in global pathology opportunities. More than half of the 267 respondents indicated interest in short-term trips (136; 51%), digital education opportunities (138; 52%), and reviewing slides/cases digitally (160; 60%). Lack of time to travel and lack of financial support were the 2 most cited reasons for lack of participation. One hundred nine respondents (41%) indicated that they were “willing and able, but do not know where to start.”

Conclusions.—
Our data demonstrate that laboratory medicine professionals are highly interested in global pathology efforts, but factors such as lack of time, lack of funding, and lack of knowledge of potential volunteer opportunities are barriers to participation. A significant number of respondents were willing and able to participate, indicating that pathology and laboratory medicine professionals may be an untapped resource for global health volunteers.
Animal trait variation at the within-individual level: erythrocyte size variation and malaria infection in a tropical lizard
Authors: Cruz Virnaliz , Cruz-Pantoja Omar , Tremblay Raymond , Acevedo Miguel 
Published: February 2022

High levels of within-individual variation (WIV) in reiterative components in plants such as leaves, flowers, and fruits have been shown to increase individual fitness by multiple mechanisms including mediating interactions with natural enemies. This relationship between WIV and fitness has been studied almost exclusively in plant systems. While animals do not exhibit conspicuous reiterative components, they have traits that can vary at the individual level such as erythrocyte size. It is currently unknown if WIV in animals can influence individual fitness by mediating the outcome of interactions with natural enemies as it has been shown in plants. To address this issue, we tested for a relationship between WIV in erythrocyte size, hemoparasite infection status, and body condition (a proxy for fitness) in a Caribbean anole lizard. We quantified the coefficient of variation of adult erythrocytes size in $n = 95$ infected and $n = 107$ non-infected lizards. We found higher degrees of erythrocyte size variation in infected lizards than in non-infected individuals. However, we found no significant relationship between infection status or erythrocyte size variation, and lizard body condition. These results suggest that higher WIV in erythrocyte size in infected lizards is not necessarily adaptive but likely a consequence of the host response to infection. Many hemoparasites destroy their host cells as part of their life cycle. To compensate, the host lizard may respond by increasing production of erythrocytes resulting in higher WIV. Our results emphasize the need to better understand the role of within-animal variation as a neglected driver or consequence of ecological and evolutionary interactions.
A comparison of virtual and in-person instruction in a physical examination course during the COVID-19 pandemic
Authors: Zhang Niu , He Xiaohua 
Published: February 2022

ABSTRACT

Objective
To compare virtual and in-person physical examination (PE) learning among chiropractic students.

Methods
Preexisting assessment data from 69 students enrolled in a Head and Neck PE course were analyzed for this study. The course comprised three 50-minute labs and one 50-minute lecture each week. Students had the option to attend the lab class in person or online. The virtual classroom was broadcasted simultaneously with the in-person class. Relevant class materials, including slides and videos, were available to all students on the learning management system. Student performance was evaluated through 8 weekly quizzes and 2 objective structured clinical examinations (OSCEs). Data for after-school practice and learning for each topic were also collected.

Results
Our results indicated that OSCE and weekly quiz scores were positively correlated with in-person class attendance (p = .000, r = .619 and p = .000, r = .488, respectively). Participants were broken down into 2 groups: (1) higher than 50% attendance rates and (2) 50% or lower attendance rates. The mean OSCE (p = .000) and quiz scores (p = .001) for group 1 (49.41 ± .72 and 22.48 ± 1.06) were significantly higher than those for group 2 (48.13 ± 1.30 and 21.22 ± 1.29). By contrast, the mean number of videos watched was lower for group 1 compared with group 2 (3.23 ± 2.61 vs 5.70 ± 3.35, p = .011). There were no significant differences in the number of practices between the 2 groups (p = .18).

Conclusion
Students who participated in in-person PE learning outperformed those in virtual learning in this study.
The Effect of Café Atmosphere on Generation Y (Millennials) Purchase Decisions on Oase Cafe
Authors: Masniadi Rudi 
Published: February 2022

Aims: The purpose of this study is to investigate the impact of cafe ambiance (outside, general interior, interior display, and store layout) on generation Y (Millennials) purchasing decisions at OASE Café.
Study Design: Using quantitative approaches, this form of research is causative.
Place and Duration of Study: Sumbawa Region at OASE Bakery & Lounge Café, November 2021-December 2021
Methodology: Multiple linear regression analysis was utilized to analyze the data in this study. The data used are primary data acquired from the field through interviews and questionnaires given to respondents who have made purchases and consumed products at OASE Bakery & Lounge Café. This study also makes use of secondary data to supplement primary data, which is supposed to be in the form of company profile data. Data was collected through distributing questionnaires to respondents, assessing data using a Likert scale with four points, and employing documentation procedures to obtain data from multiple sources. Non-probability sampling is utilized in the data collection process. Purposive sampling was employed in conjunction with convenience sampling. There were 100 samples used.
Results: The findings revealed that the exterior had no and no significant effect on purchasing decisions, while general interiors had a significant and positive effect, interior displays had a significant effect on purchasing decisions, and store layout had a significant effect on purchasing decisions.
Conclusion: From the analysis of research results on the variables that influence purchasing decisions at OASE Café, the following conclusions are based on the results of calculations that have been done exterior, variables do not affect purchasing decisions, meanwhile the other variable affected purchasing decisions.
Psychological Barriers of Vietnam High School Students in Online Learning Due to the COVID-19 Pandemic: A Quantitative Study
Authors: Ngo Thanh-Thuy , Nguyen Xuan-An , Nguyen Hong-Lien , Thi Hien Nguyen , Mai Mai Thi , Nguyen Thi-Thuong-Thuong 
Published: February 2022

The outbreak of the COVID-19 pandemic has strongly influenced on education system in Vietnam. Schools' closure was one solution to prevent the spread of the virus that has forced these institutions to transition from traditional learning methods to online learning methods. This circumstance has brought many difficulties for high school students who have not been familiar with online learning methods before. Therefore, this study was conducted to identify some psychological barriers in online learning of Vietnam high school students. On the other hand, the study also found the relationship between these barriers. The differences in gender, areas, feelings and learning outcomes were determined in all three psychological barriers. Data were collected online from high school students. The intent was to get about 310 responses, and 309 returned usable responses. Several analytical methods used to analyze the data include the descriptive statistical analysis method, the Spearman correlation analysis, and the one-way ANOVA. The results provided information on some psychological barriers with their correlation. The significant relationship among three psychological barriers: social interaction, technical skills, and learner motivation attributed the difficulties to Vietnam high school students in online learning, especially in the Covid-19 pandemic context. The differences in gender, areas, feelings and learning outcomes were considered the related factors in the online learning environment. These findings could support further studies for researchers, education administrators, teachers, and related stakeholders such as parents, enterprises, and the community to propose solutions to issues affecting the high school students' learning effectiveness and outcomes.
Response of Juvenile Clarias gariepinus to Varying Dietary Levels of Ionotropic Gelated Chitosan Nanoparticles Synthesized from Wasted Crab Shells
Authors: Udo I. U. , Umoren S. K. , Umanah S. I. 
Published: February 2022

Background: Crab shells lie wasted globally after the extraction of the edible soft tissues. Chitosan nanoparticles (CNPs) derived from these shells have the potentials to revolutionized aquaculture.
Aims: Evaluated the effects of CNPs on water quality parameters, growth performance, feed utilization and survival rate of African catfish (Clarias gariepinus).
Study Design: The experimental diets were incorporated with chitosan nanoparticles at the rate of 0, 2.5 5.0 and 7.5 g kg-1 representing Treatments CNP00, CNP2.5, CNP5.0 and CNP7.5 respectively and replicated thrice.
Place and Duration of Study: Department of Fisheries and Aquatic Environmental Management, University of Uyo, Uyo – Nigeria from August to November 2021.
Methodology: We synthesized CNPs by ionic gelation method. Dried flour of FM, SBM, Wheat bran and yellow maize meal were analyzed for proximate composition used in the formulation of experimental diets. These were milled at 2 mm pellets, CNPs were dissolved in 0.3 liters of water and sprayed on the pellets. These were stored at 10% moisture content, in black polythene bags. Diets were fed to two hundred and sixteen fingerlings of African catfish (C. gariepinus) with mean body weight 23.86±3.11. Growth performance, feed utilization and survival rate parameters were calculated and statistically compared.
Results: Ammonia was significantly (p<0.05) low in CNP7.5. The highest daily weight gain (6.98±0.81 g) was recorded in CNP7.5 while the lowest (1.02±0.01 g) was recorded in the control (CNP00). SGR, DWG, FCR, PER followed the same pattern. However, there was no difference in percentage survival rate.
Conclusion: Chitosan nanoparticles supplemented at the rate of 7.5 g k-1 diet can give a better water quality, growth performance and feed utilization of C. gariepinus juvenile. Incorporation of CNPs in diet of C. gariepinus at a concentration of 7.5 g kg-1 is recommended for more profitable and sustainable culture of this fish species.
Socio- demographic Factors Influencing the Ownership and Utilization of Long Lasting Insecticide Nets among Endemic Sub-counties in Kisii County, Kenya
Authors: Bwogo Pacifica Chepchumba , Mong’are Samuel , Masai Rael , Nyabayo Josephat , Ingonga Johnstone , Kimani Francis , Kamau Luna , Mwangi Milkah , Cirindi Josyline , Matoke Damaris 
Published: February 2022

Aim: To access the socio-demographic factors which are influencing the ownership and utilization of Long Lasting Insecticidal nets (LLINs) among endemic Sub-Counties in Kisii County, Kenya.
Study design: A descriptive cross-sectional study.
Place and Duration of Study: The study was carried out in Kisii County where study subjects were drawn from Bonchari, Kitutu Chache North and South Mugirango Sub-Counties between January to May 2021.
Methodology: Leading hospitals in the Sub-Counties with malaria cases without referrals were selected for the study. A total of 422 study participants who attended Kiaruta and Nyamagiri dispensaries, Eramba, Sieka, Moticho and Suguta health centers with signs of malaria were the targeted population. Structured and open ended questionnaires were used to collect data. Associations between variables were tested using Pearson’s chi-square test through the Statistical Package for Social Sciences (SPSS) version 21.
Results: From the total study participants, 68.69% were having LLINs. From the total number with LLINs, 33.18% had torn LLINs. 61.61% study participants were sleeping under the LLINs. Of the participants who were sleeping under LLINs, 46.92% had torn LLINs. Positive association was seen between ownership of LLINs and age (P = 0.008), ownership of LLINs and level of education (P = 0.011), ownership of LLINs and household membership (P < 0.001) and ownership of LLINs and location (P < 0.001), also there was a statistical significance between use of LLINs and age (P < .001), use of LLINs and level of education (P < .001), use of LLINs and gender (P = .024), use of LLINs and location (P = .002), and use of LLINs and the last year when each participant received LLINs (P < .001),
Conclusion: Despite coverage of LLINs being high its usage was low and this means that socio-demographic factor has shown to be having a great influence on the ownership and utilization of LLINs. Therefore regular training must be done on LLINs and malaria transmissions with the urge to reduce malaria incidences.