bluuebunny/crossref_metadata_2025_split huggingface dataset:
Debate: International Company Tax Developments And Some Reflections On Ways Forward For The African Continent
Authors: Wilde M.F. (Maarten) de 
Published: August 2022

The article comments on the contribution in this edition entitled ‘Unilateral Digital Services Tax in Africa; Legislative Challenges and Opportunities’. The current paper also serves as an independent reflection on contemporary developments in company taxation and potential ways forward in this regard for the African continent. With a view to submitting suggestions that could cater to the needs and revenue mobilization interests of African countries and – building on the observations of the commented paper’s author – the current paper proposes some suggestions for potential tax policy approaches for Africa. These are based on securing two objectives: (1) maintain and/or attract investment while (2) devising ways and means to further securing sustainable revenue mobilization policies. The first objective could be pursued by prudently continuing to compete for investment to the extent possible considering the available scope for such under the envisaged Pillar Two approach and on a regionally coordinated basis. Meeting the second objective could occur by furthering the market-based tax base division agenda that has emerged in recent years along with the spread of digital services taxes and in the context of developments towards the construction of the Amount A concept in Pillar One. Such a policy direction could also be pursued if the envisaged Pillars collapse.
Corporate Income Tax, base erosion and profit shifting (BEPS), Pillar One, Pillar Two, tax competition, special tax zones, tax incentive regimes, developing countries, developing world, Africa, capacity building, human resource development, fairness.
Article: The Fundamental Freedoms and the Taxation of Dividends Received by Non-resident Investment Funds: Some Thoughts on Non-discrimination With a Special Focus on Recent ECJ Case Law
Authors: Scherleitner Moritz 
Published: August 2022

This objective of this article is to discuss outbound cases involving investment funds focusing particularly on the issue of discrimination. The motivation to engage in this inquiry is two-fold. On the one hand, the fund taxation systems in Fidelity and Köln-Aktie Deka Funds include requirements not found in those fund taxation regimes subject to ECJ scrutiny long ago. It is of interest to analyse to what extent this can make a difference. Secondly, the opinions of AG Saugmandsgaard Øe in A SCPI and AG Kokott in Allianzgi merit a closer examination. In the case of the former, it is the AG’s unique approach to comparability that necessitates analysis. In the latter case, it is the variety of far-reaching questions raised by this complex case.
EU law, comparability, ECJ, investment funds, fundamental freedoms, Allianzgi, A SCPI, Fidelity, Köln-Aktie Deka Funds.
Policy Note: Is the Inheritance and Gift Tax a Reasonable Alternative for the Net Wealth Tax?: A Legal and Economic Analysis Across OECD Countries
Authors: Anderwald Anna-Maria , Niemann Rainer 
Published: August 2022

Net wealth taxes are one of the most controversial topics in taxation. Strained government finances due to the Covid-19 pandemic and the increasing inequality in the distribution of wealth are fuelling this debate. While some countries (especially France: The net wealth tax – referred to as the ISF (impôt sur la fortune) – was abolished in 2017) have abolished net wealth taxes, their (re)introduction is being considered in others (for example, Austria, Germany, and the United States). Unfortunately, legal and economic arguments are rarely brought together in the public discussion, and the academic tax community has remained relatively quiet. Given the politically delicate nature of net wealth taxes, an interdisciplinary discussion seems necessary.
This policy note focuses on the policy discussion on net wealth taxes from both economic and legal perspectives. It begins by identifying the characteristics of a net wealth tax compared to related taxes, such as property taxes and inheritance and gift taxes (Chapter I.). This is followed by an overview of the status quo of net wealth taxes and wealth-related taxes in the OECD (Organisation for Economic Cooperation and Development) countries (Chapter II.). Building on this, the article deals with the main arguments proposed in the literature in favour of and against the (re)introduction of net wealth taxes (Chapter III.). Since a net wealth tax has far-reaching effects on economic decision-making and on taxpayer compliance, a purely legal analysis is necessarily incomplete and requires an economic counterpart. Likewise, economically motivated tax reform proposals require an analysis of their legitimacy. A comprehensive discussion therefore requires a simultaneous legal and economic analysis.
Since net wealth taxes are predominantly justified with distributional reasons, this note also discusses whether an inheritance and gift tax represents a reasonable alternative to a net wealth tax (Chapter IV.). After all, an inheritance and gift tax could also counteract the inequality of wealth. The objective of this article is to provide an interdisciplinary basis for the tax policy debate on wealth-related taxes.
Wealth tax, gift tax, inheritance tax, wealth-related tax, valuation, enforcement, compliance cost, redistribution, international comparison, competitive advantage
Debate: Is There A Need for A Directive on Pillar 2? A Few Normative Comments
Authors: Haslehner Werner 
Published: August 2022

Poland’s request to link the entry into force of the Pillar 2 Directive to an international agreement on Pillar 1 raises fundamental questions about the European constitutional structure. Beyond the mere legality of such a link, this contribution seeks to respond to some normative concerns related to the creation of such secondary legislation.
Pillar 2 Directive, principle of autonomy, principle of primacy, European sovereignty, EU legal order, international tax agreement, treaty override, EU external relations, EU competence, subsidiarity, proportionality
EVALUASI KEBIJAKAN PPKM DARURAT COVID-19 DALAM PERSPEKTIF LHKP PP MUHAMMADIYAH
Authors: Nurul Nurul Sepfiatin , Mahendra Gerry Katon 
Published: August 2022

Pemerintah pada masa pandemi sudah mengalami beberapa perubahan kebijakan. Diawali kebijakan social distancing, PSBB, PPKM Mikro, hingga PPKM Darurat. Kebijakan PPKM Darurat menuai berbagai pro dan kontra. LHKP dalam hal ini merupakan lembaga di bawah Pimpinan Pusat Muhammadiyah yang mempunyai fokus kerja di kebijakan publik ikut meresponnya. Penelitian ini akan mengkaji tentang evaluasi kebijakan PPKM Darurat Covid-19 dalam perspektif LHKP PP Muhammadiyah. Tujuannya untuk mengetahui, menganalisis evaluasi kebijakan PPKM Darurat dalam perspektif LHKP PP Muhammadiyah dan memberikan rekomendasi kebijakan yang akan diterapkan kedepannya. Penelitian ini menggunakan penelitian deskriptif kualitatif. Teknik pengumpulan data yang digunakan adalah observasi, wawancara, dan dokumentasi. Analisis data dilakukan dengan reduksi data, penyajian data, dan menarik kesimpulan. Hasil penelitian ini menunjukkan bahwa: (1) Efektiftivitas kebijakan PPKM Darurat ini dinilai efektif, (2) Efisiensi dalam indikator ini dinilai tidak efisien. Hal ini dilihat dari lima faktor yang mempengaruhi; manusia, dana, metode, sarana dan prasarana, serta mesin, (3) Kecukupan kebijakan PPKM Darurat ini dinilai cukup, (4) Perataan kebijakan PPKM Darurat nasional dalam perspektif LHKP dinilai belum merata dalam penerapannya, (5) Responsifitas kebijakan PPKM Darurat dinilai tidak responsif, terakhir (6) Ketepatan kebijakan dinilai sudah tepat. Pemerintah dalam kebijakan PPKM Darurat belum bersungguh-sungguh menjalankan peraturan dan respon pemerintah pun agak lambat.
ProAll-D: protein allergen detection using long short term memory - a deep learning approach
Authors: M Shanthappa Pallavi , Kumar Rakshitha 
Published: August 2022

Background: An allergic reaction is the immune system's overreacting to a previously encountered, typically benign molecule, frequently a protein. Allergy reactions can result in rashes, itching, mucous membrane swelling, asthma, coughing, and other bizarre symptoms. To anticipate allergies, a wide range of principles and methods have been applied in bioinformatics. The sequence similarity approach's positive predictive value is very low and ineffective for methods based on FAO/WHO criteria, making it difficult to predict possible allergens. Method: This work advocated the use of a deep learning model LSTM (Long Short-Term Memory) to overcome the limitations of traditional approaches and machine learning lower performance models in predicting the allergenicity of dietary proteins. A total of 2,427 allergens and 2,427 non-allergens, from a variety of sources, including the Central Science Laboratory and the NCBI are used. The data was divided 80:20 for training and testing purposes. These techniques have all been implemented in Python. To describe the protein sequences of allergens and non-allergens, five E-descriptors were used. E1 (hydrophilic character of peptides), E2 (length), E3(propensity to form helices), E4(abundance and dispersion), and E5 (propensity of beta strands) are used to make the variable-length protein sequence to uniform length using ACC transformation. A total of eight machine learning techniques have been taken into consideration. Results: The Gaussian Naive Bayes as accuracy of 64.14 %, Radius Neighbour's Classifier with 49.2 %, Bagging Classifier was 85.8 %, ADA Boost was 76.9 %, Linear Discriminant Analysis has 76.13 %, Quadratic Discriminant Analysis was 84.2 %, Extra Tree Classifier was 90%, and LSTM is 91.5 %. Conclusion: As the LSTM, has an AUC value of 91.5 % is regarded best in predicting allergens. A web server called ProAll-D has been created that successfully identifies novel allergens using the LSTM approach. Users can use the link https://doi.org/10.17632/tjmt97xpjf.1 to access the ProAll-D server and data.
©2022 by the authors. This article is an open-access article distributed under the terms and conditions of the Creative Commons Attribution license (http://creativecommons.org/licenses/by/4.0/).
Keywords
Allergen prediction; ACC transformation; LSTM model; Gaussian naive bayes; Classifier; Extra tree classifier; Bagging classifier; ADA boost; Linear discriminant analysis; Quadratic discriminant analysis
INFLUENCE OF BUDGETARY PARTICIPATION, DECENTRALIZATION, ORGANIZATIONAL COMMITMENT, AND INTERNAL CONTROL SYSTEMS ON THE MANAGERIAL PERFORMANCE OF REGIONAL GOVERNMENT APPARATUSES
Authors: Nugrahaeni Indina Dhesta , Palahiyah Palahiyah , Febriyani Shoma 
Published: August 2022

This study aims to determine the effect of budgetary participation, decentralization, organizational commitment, and internal control systems on the managerial performance of regional government apparatuses. This study uses quantitative research methods, The population in this study was Structural officials of the Regional Apparatus Work Unit (SKPD) in Banten Province, Indonesia, The sample selection in this study was based on purposive sampling. This study distributed 170 questionnaires. Of these, 87 questionnaires were returned of respondents returned. Data were analyzed based on multiple regression and path analysis (Analysis Path) utilizing the SPSS program. Data were analyzed used the Statistical Package for Social Science (SPSS). The data processed were respondents' answers related to Budgetary Participation (PA), Decentralization (D), Organizational Commitment (KO), Internal Control System (SPI), and Managerial Performance (KM). Based on the results obtained in hypothesis 1, there is a significant effect of budgetary participation on managerial performance of regional government apparatuses, the result of tcount> ttable (2,136> 1,456) with a significance level of 0.36 (0.00 <0,05) this means that if budgetary participation increases it will improve managerial performance, hypothesis 2 there is a significant influence of decentralization on managerial performance in Structural officials of the Regional Apparatus Work Unit (SKPD) in Banten Province, Indonesia, the result of tcount> ttable (1,999> 1,456) with a significance level of 0.049 (0.00 <0.05) this means that if decentralization increases it will improve managerial performance, hypothesis 3 there is a significant effect of organizational commitment on managerial performance of regional government apparatuses, the result of tcount> ttable (2,409> 1,456) with a significance level of 0.18 (0.00 <0,05) this means that if organizational commitment increases it will improve managerial performance, and hypothesis 4 there is a significant effect of internal control system on managerial performance of regional government apparatuses, the result of tcount> ttable (3,038> 1,456) with a significance level of 0.03 (0.00 <0,05) this means that if internal control system increases it will improve managerial performance.
Discrepant expressive language lateralization in children and adolescents with epilepsy
Authors: Pasichnik Alisa , Tsuboyama Melissa , Jannati Ali , Vega Clemente , Kaye Harper L. , Damar Ugur , Bolton Jeffrey , Stone Scellig S. D. , Madsen Joseph R. , Suarez Ralph O. , Rotenberg Alexander 
Published: August 2022

AbstractNeuronavigated transcranial magnetic stimulation (nTMS) has emerged as a presurgical language mapping tool distinct from the widely used functional magnetic resonance imaging (fMRI). We report fMRI and nTMS language‐mapping results in 19 pediatric‐epilepsy patients and compare those to definitive testing by electrical cortical stimulation, Wada test, and/or neuropsychological testing. Most discordant results occurred when fMRI found right‐hemispheric language. In those cases, when nTMS showed left‐hemispheric or bilateral language representation, left‐hemispheric language was confirmed by definitive testing. Therefore, we propose nTMS should be considered for pediatric presurgical language‐mapping when fMRI shows right‐hemispheric language, with nTMS results superseding fMRI results in those scenarios.
CYLD variants identified in Alzheimer's disease and frontotemporal dementia patients
Authors: Xiao Xuewen , Xu Tianyan , Liu Hui , Liu Xixi , Liao Xinxin , Zhou Yafang , Zhou Lu , Wang Xin , Zhu Yuan , Yang Qijie , Hao Xiaoli , Liu Yingzi , Jiang Hong , Guo Jifeng , Wang Junling , Tang Beisha , Li Jinchen , Shen Lu , Jiao Bin 
Published: August 2022

AbstractObjectivesCYLD was a novel causative gene for frontotemporal dementia (FTD) and amyotrophic lateral sclerosis. Given the clinical and pathological overlap of FTD and Alzheimer's disease (AD), it is necessary to screen CYLD in AD patients and FTD patients in the Chinese population.MethodsIn our study, using a targeted sequencing panel, we sequenced the CYLD gene in a large cohort of 2485 participants in the Chinese population, including 1008 AD patients, 105 FTD patients, and 1372 controls.ResultsIn the present study, the average onset age of AD and FTD patients was 66.84 ± 30.42 years old and 60 ± 10.00 years old, respectively. Our study reported three novel CYLD variants: p.Phe288Leu (patient No. 1, AD), p.Tyr485Phe (patients No. 6–9, all AD) and p.Thr951Ala (patient No. 10, AD), plus a previously reported variant: p.Arg397Ser (patient No. 2–5, AD and No. 11, FTD). These variants were absent in our in‐house controls and predicted to be deleterious according to the MutationTaster. The variant carriers were composed of 10 AD patients and one FTD patient, and the average onset age was 61.2 ± 10.9 years. The frequency of CYLD variants in AD was similar to that in FTD, which was 0.99% (10/1008) and 0.95% (1/105), respectively.InterpretationOur finding extended the genotype and phenotype of the CYLD gene and demonstrated that CYLD rare damaging variants may be implicated in AD and FTD pathogenesis.
Characteristics and Outcomes of People With Gout Hospitalized Due to COVID‐19: Data From the COVID‐19 Global Rheumatology Alliance Physician‐Reported Registry
Authors: Jatuworapruk Kanon , Montgomery Anna , Gianfrancesco Milena , Conway Richard , Durcan Laura , Graef Elizabeth R. , Jayatilleke Aruni , Keen Helen , Kilian Adam , Young Kristen , Carmona Loreto , Cogo Adriana Karina , Duarte‐García Alí , Gossec Laure , Hasseli Rebecca , Hyrich Kimme L. , Langlois Vincent , Lawson‐Tovey Saskia , Malcata Armando , Mateus Elsa F , Schafer Martin , Scirè Carlo Alberto , Sigurdardottir Valgerdur , Sparks Jeffrey A. , Strangfeld Anja , Xavier Ricardo M. , Bhana Suleman , Gore‐Massy Monique , Hausmann Jonathan , Liew Jean W. , Sirotich Emily , Sufka Paul , Wallace Zach , Machado Pedro M. , Yazdany Jinoos , Grainger Rebecca , Robinson Philip C. 
Published: August 2022

ObjectiveTo describe people with gout who were diagnosed with coronavirus disease 2019 (COVID‐19) and hospitalized and to characterize their outcomes.MethodsData on patients with gout hospitalized for COVID‐19 between March 12, 2020, and October 25, 2021, were extracted from the COVID‐19 Global Rheumatology Alliance registry. Descriptive statistics were used to describe the demographics, comorbidities, medication exposures, and COVID‐19 outcomes including oxygenation or ventilation support and death.ResultsOne hundred sixty‐three patients with gout who developed COVID‐19 and were hospitalized were included. The mean age was 63 years, and 85% were male. The majority of the group lived in the Western Pacific Region (35%) and North America (18%). Nearly half (46%) had two or more comorbidities, with hypertension (56%), cardiovascular disease (28%), diabetes mellitus (26%), chronic kidney disease (25%), and obesity (23%) being the most common. Glucocorticoids and colchicine were used pre‐COVID‐19 in 11% and 12% of the cohort, respectively. Over two thirds (68%) of the cohort required supplemental oxygen or ventilatory support during hospitalization. COVID‐19‐related death was reported in 16% of the overall cohort, with 73% of deaths documented in people with two or more comorbidities.ConclusionThis cohort of people with gout and COVID‐19 who were hospitalized had high frequencies of ventilatory support and death. This suggests that patients with gout who were hospitalized for COVID‐19 may be at risk of poor outcomes, perhaps related to known risk factors for poor outcomes, such as age and presence of comorbidity.
A finite‐time adaptive fuzzy backstepping control for multiple‐input multiple‐output coupled nonlinear systems with tracking error constraints
Authors: Wang Chao , Zhang Cheng , Liu Liyan , Ao Lei , He Dan 
Published: August 2022

SUMMARYIn this study, a finite‐time adaptive fuzzy backstepping control strategy with tracking error constraints is designed for a class of multiple‐input multiple‐output (MIMO) coupled nonlinear systems with uncertainties. First, the uncertainty of the system is approximated by adaptive fuzzy logic systems (AFLSs), then, the rapidity of the state tracking of the control system are ensured by backstepping and finite time theory. The problem of error constraints is solved by the combination of performance function and simplified barrier Lyapunov function (SBLF). It is proved that the states of a closed‐loop adaptive control system are semi‐globally practical finite‐time stable (SGPFS) by the finite‐time Lyapunov function, and in a finite time, the tracking error of the system state converges to a narrow block of origin with the prescribed bounded. Finally, the scheme's effectiveness is verified by the simulation.
Advancing Engineered Heart Muscle Tissue Complexity with Hydrogel Composites
Authors: Dickerson Darryl A. 
Published: August 2022

AbstractA heart attack results in the permanent loss of heart muscle and can lead to heart disease, which kills more than 7 million people worldwide each year. To date, outside of heart transplantation, current clinical treatments cannot regenerate lost heart muscle or restore full function to the damaged heart. There is a critical need to create engineered heart tissues with structural complexity and functional capacity needed to replace damaged heart muscle. The inextricable link between structure and function suggests that hydrogel composites hold tremendous promise as a biomaterial‐guided strategy to advance heart muscle tissue engineering. Such composites provide biophysical cues and functionality as a provisional extracellular matrix that hydrogels cannot on their own. This review describes the latest advances in the characterization of these biomaterial systems and using them for heart muscle tissue engineering. The review integrates results across the field to provide new insights on critical features within hydrogel composites and perspectives on the next steps to harnessing these promising biomaterials to faithfully reproduce the complex structure and function of native heart muscle.
Bio‐Mimicking Brain Vasculature to Investigate the Role of Heterogeneous Shear Stress in Regulating Barrier Integrity
Authors: Mehta Ami , Desai Anal , Rudd David , Siddiqui Ghizal , Nowell Cameron J. , Tong Ziqiu , Creek Darren J. , Tayalia Prakriti , Gandhi Prasanna S. , Voelcker Nicolas H. 
Published: August 2022

AbstractA continuous, sealed endothelial membrane is essential for the blood–brain barrier (BBB) to protect neurons from toxins present in systemic circulation. Endothelial cells are critical sensors of the capillary environment, where factors like fluid shear stress (FSS) and systemic signaling molecules activate intracellular pathways that either promote or disrupt the BBB. The brain vasculature exhibits complex heterogeneity across the bed, which is challenging to recapitulate in BBB microfluidic models with fixed dimensions and rectangular cross‐section microchannels. Here, a Cayley‐tree pattern, fabricated using lithography‐less, fluid shaping technique in a modified Hele‐Shaw cell is used to emulate the brain vasculature in a microfluidic chip. This geometry generates an inherent distribution of heterogeneous FSS, due to smooth variations in branch height and width. hCMEC/D3 endothelial cells cultured in the Cayley‐tree designed chip generate a 3D monolayer of brain endothelium with branching hierarchy, enabling the study of the effect of heterogeneous FSS on the brain endothelium. The model is employed to study neuroinflammatory conditions by stimulating the brain endothelium with tumor necrosis factor‐α under heterogeneous FSS conditions. The model has immense potential for studies involving drug transport across the BBB, which can be misrepresented in fixed dimension models.
Visible Light Induced Ag–Polyoxometalate Coassembly into Single‐Cluster Nanowires
Authors: Liu Qingda , He Shiqing , Yu Biao , Cheng Xijun , Shi Wenxiong , Wang Xun 
Published: August 2022

Abstract1D superlattices with long‐ranged periodicity present extraordinary application properties due to their unique electronic structures. Here, the visible light driven synthesis of 1D single‐cluster chains constructed by polyoxometalate (POM) and Ag clusters is reported, where two types of clusters align alternatively along the nanowire. Low symmetrical POM clusters of [P2W17O61]10–, [P2W15O56]12–, and [EuW10O36]9– can be used as building blocks. The directly bonding cluster units result in interactive electronic structures of Ag and POM clusters, as well as the greatly promoted electron transfer during the redox reaction. The Ag–P2W17 nanowires perform significantly enhanced activities in both electrochemical sensing and catalytic gasoline desulfurization compared with individual building blocks, demonstrating the extraordinary application properties and promising potentials of cluster‐based heteroconstructions.