bluuebunny/crossref_metadata_2025_split huggingface dataset:
On stress accumulation in the lithosphere and interaction between two strike-slip faults
Authors: MAJI MANINDRANATH , SRN SANJAY , PAL BARUN PROSAD , MUKHOPADHYAY ARABINDA 
Published: February 2022

The problem of stress accumulation near locked verti cal strike-slip fa ults in the lithos phere, and the interaction between two parallel strike slip faults arc cons idered. The 1"'0 parall el faults are taken to be situated in a visco-elastic half space. It is assumed that tectonic forces maintain a steady shear stress far away from the fault. Exact solutions are obtained for the displacements and the stresses in the system. It is shown that in the absence of fault slip, there would be a steady accumulation of the shear stress near the fau lts, which would lead to a sudden slip on one of the faults. resulting in an earthquake. The subsequen t chan ges in shea r stress in the neighbourhood of the fault system are investigated and exact solutions are obtained for the displacements and stresses.
It is seen that the fau lt slip On one fault affects the accumulation of shear stress on the ot her and the effect leads to significant changes in the ra te of stre ss accumulation in the neighbo urhood of fault s if the fault s are close to each other. This int urn, affects significantly the return time bet ween co nsecutive slips on the fault. It is sho wn that the theoretical results obtained may be useful in the estima tion of seismic ris k and also in eart hqua ke prediction.
RATIONAL DRUG THERAPY OF PEPTIC ULCER DISEASE IN PATIENTS ADMITTED TO GASTROENTEROLOGY WARD OF LRH PESHAWAR KHYBER PAKHTUNKHWA, PAKISTAN
Authors: Shams Farrah , Samoo Nawaz , Ali Fawad , Nawaz Faiza , Nawaz Faiza , Gul Alia 
Published: February 2022

The present study was conducted from 12 Sep.2019 to 10 Nov. 2019 at the Gastroenterology ward, Lady Reading Hospital Peshawar Pakistan, aiming to accurately investigate the Peptic Ulcer Disease state, signs and symptoms, to ensure complete information about drug therapy and patients response. Peptic ulcer disease is defined as an upper gastric mucosal rupture due to acid hat results in the formation of ulcers that extend beyond the muscular mucosa to the submucosa. Peptic ulcer is characterized by abdominal pain, change in appetite, unexplained weight loss, nausea, vomiting, heart burn and dark, tarry stools. Spicy and acidic foods, Stress and restless lifestyle were considered to be the leading causes of peptic ulcer. However the Helicobacter pyloribacterium is responsible for up to 60% stomach ulcers. Frequent use of painkillers, old age, obesity Smoking, excessive alcohol use, too little sleep, type O blood and chronic stress, are the risk factors of peptic ulcers. Acute peptic ulcers results from taking aspirin or anti-inflammatory drugs. Chronic peptic ulcer represents a profound loss of substance. Data from a total of10 patients (6 female and 4 male)of all age, having various peptic ulcer diseases were involved in this study. It was concluded that most of the female patients (60%) were having peptic ulcers as compared to male patient (40%). It was found that 30-40 years old peptic ulcer patient percentage was 20%.Moreover it was observed that frequent use of Nonsteroidal Anti-inflammatory Drugs has been found to be the main causes of peptic ulcers
Risk Factors Causing Ankle Sprain among undergraduate female students
Authors: Arslan Hafiz Rana Muhammad , Subhani Ali Hammad , Shahzad Hamza , Salik Sumbal , Khan Laila Niaz , Tariq Fatima , Ijaz Bushra 
Published: February 2022

High heeled shoes align the foot in planter flexion, modifying the relative orientation of the skeletal structures of ankle, metatarsal, and metatarsophalangeal joints, and alter the insertion angles of the foot and gliding joint muscles, therefore increasing the risk factor for ankle sprain. Objective: Study conducted to determine Risk Factors Causing Ankle Sprain among undergraduate female students. Methods: Cross-Sectional study was conducted among 500 female students (Between ages 18-26 years) at Sargodha Medical College and completed in 06 months (June 2019-December 2019). Non-probability convenient sampling technique was used to collect data and then entered to SPSS-25 for further statistical analysis. Result: Among 500 participants, Age 19.65±1.416 years. Mean height (m) 1.61±0.073, mean weight (kg) 57.37±10.4, Mean BMI was 22.02±3.6. Female experience ankle sprain (54%), not experienced ankle sprain (46%) Significant association found between Ankle Sprain and body mass index (BMI) as the P value was 0.014 which was <0.05. Female wearing high heel have 1.082 times greater chance of developing ankle sprain (OR 1.082). Female wearing high heel for long duration (4-6 hrs.) have 1.271 times greater chance of developing ankle sprain (OR 1.271), female wearing high heel (3-4 inches) have 1.072 times greater chance of developing ankle sprain (OR 1.072), female using Pencil heel have 1.281 times greater chance of developing ankle sprain (OR 1.281). Conclusion: Significant association found between Ankle Sprain and body mass index (BMI). Female wearing, high heel for long duration (4-6 hrs.), high heel (3-4 inches height), using Pencil heel have greater chance of developing ankle sprain.
DIVERSIFIKASI IKAN NILA (Oreochromis niloticus) UNTUK PRODUK DIVERSIFIKASI FISH NUGGET DI DESA ULUNG PELIANG (UPEL)
Authors: Cahyono Eko , Wodi Stevy Imelda Murniati , Salele Meylan Joiske , Baeruma Apriani Onisye , Turambi Agus , Tondais Jumardi 
Published: February 2022

Fish nugget merupakan produk diversifikasi berbahan dasar surimi yang dibentuk menjadi bulat, kotak dan persegi panjang. Dilapisi tepung roti lalu digoreng, atau dilapisi tepung roti mentah dan disimpan. Fish nugget dapat diolah dari berbagai jenis ikan air laut maupun air tawar. Salah satu komoditas perikanan air tawaryang potensial adalah ikan Nila. Ikan nila merupakan hasil budidaya yang memiliki daging berwarna putih dan kenyal, namun kelemahannya mengandung senyawa geosmin yang menyebabkan bau bit. Tujuan Program Kemitraan Masyarakat Stimulus adalah melakukan deversifikasi melalui produk fish nugget yang berbahan dasar ikan nila di Desa Upel. Metode yang digunakan meliputi ceramah, tanya jawab, diskusi serta simulasi dan praktek pembuatan fish nugget. Hasil dari kegiatan ini mitra mampu memilih bahan baku produk olahan yang berkualitas dan dapat menyusun formulasi bahan-bahan olahan hasil perikanan. Mampu mengembangkan keterampilan dalam hal olahan ikan Nila dan diversifikasi olahan bahan baku ikan Nila sehigga memperluas jaringan pemasaran. Mampu mengelola keuangan menjadi lebih baik melalui transfer pengetahuan

Fish nuggets are a diversified product made from surimi which is formed into rounds, squares and rectangles. It is breaded then fried, or breaded raw and stored. Fish nuggets can be processed from various types of sea and freshwater fish. One of the potential freshwater fishery commodities is Tilapia. Tilapia is a cultivated product that has white and chewy flesh, but the weakness is that it contains geosmin compounds which cause the smell of beets. The aim of the Stimulus Community Partnership Program is to carry out diversification through fish nuggets made from tilapia in Upel Village. The methods used include lectures, questions and answers, discussions as well as simulations and practice of making fish nuggets. The results of this activity partners are able to select quality raw materials for processed products and can compile the formulation of ingredients for processed fishery products. Able to develop skills in the processing of tilapia and diversification of the raw material for tilapia, thus expanding the marketing network. Able to better manage finances through knowledge transfer.
PENDIDIKAN KESEHATAN TENTANG PERILAKU SEKSUAL BERISIKO HIV/AIDS PADA REMAJA
Authors: Silalahi Veronica 
Published: February 2022

Perilaku seksual pada remaja perlu diperhatikan karena rasa ingin tahu remaja pada halhal baru sangat tinggi, dan ini sangat berisiko saat remaja mulai mencoba untuk melakukanhubungan seksual tanpa mengetahui akibatnya di waktu yang akan datang. Kelompok remajamerupakan kelompok yang rentan terkena HIV/AIDS karena mereka memiliki kecenderunganuntuk mencoba dan mencari tahu kegiatan apa yang dilakukan oleh orang dewasa, termasukkegiatan yang berhubungan dengan seksualitas. Tujuan pengabdian masyarakat ini untukmemberikan edukasi kepada remaja dan meningkatkan pengetahuan tentang perilaku seksualberesiko HIV/AIDS pada remaja katolik di Gereja Sakramen Maha Kudus Surabaya. Kegiatanini dilakukan dengan memberikan pendidikan kesehatan secara online melalui zoom meetingkepada remaja katolik, yang dilakukan pada tanggal 26 Juni 2021 pada 30 remaja. pemberian pretestposttest dan evaluasi kegiatan. Hasil kegiatan ini didapatkan sebelum diberikan pendidikan kesehatan47% pengetahuan cukup, 33% pengetahuan kurang, dan 20% pengetahuan baik. Setelah diberikanpendidikan kesehatan didapatkan 100% pengetahuan baik. Pelaksanaan kegiatan pengabdianmasyatakat dalam bentuk pemberian pendidikan kesehatan dilakukan untuk memberikaninformasi kesehatan dan kegiatan ini meningkatkan pengetahuan remaja tentang perilaku seksualberesiko HIV/AIDS

Sexual behavior in adolescents needs to be considered because adolescent curiosityabout new things is very high, and this is very risky when teenagers begin to try to have sexualintercourse without knowing the consequences in the future. Teenagers are vulnerable toHIV/AIDS because they tend to try and figure out what activities adults are doing, includingactivities related to sexuality. The purpose of this community service is to provide education toadolescents and improve understanding/knowledge about sexual behavior at risk of HIV / AIDSin Chatolic Teenagers At Sakramen Mahakudus Church Surabaya. This activity is carried out byproviding health education online through zoom meetings to catholic youth that held on June 26Juni, 2021 on 30 teenagers, and pretest-posttest giving, and evaluation of activities. The results of thisactivity were obtained before being given health education 47% average knowledge, 33% poorknowledge, and 20% good knowledge. After being given health education obtained 100% goodknowledge. The implementation of community service activities in the form of providing healtheducation is carried out to provide health information and this activity improves the knowledgeand understanding of adolescents about sexual behaviors risk of HIV/AIDS.
PENGURANGAN RISIKO BENCANA DI SDN INPRES BEHA KECAMATAN TABUKAN UTARA
Authors: Pramardika Dhito Dwi , Lalombo Agneta Sartika , Kasaluhe Meityn Disye 
Published: February 2022

Sekolah merupakan komunitas kecil yang dapat dijadikan sebagai wadah memberikan efek tular informasi dari siswa kepada keluarga dan masyarakat pada umunya dalam upaya pengurangan risiko terhadap bencana alam dan non alam. SDN Inpres Beha Kecamatan Tabukan Utara mempunyai potensi menghadapi bencana alam dikarenakan letaknya tidak jauh dari gunung Awu yang merupakan gunung berapi aktif di Indonesia dan termasuk wilayah dengan intensitas gempa yang sering terjadi dan risiko bencana non alam berupa risiko tertular COVID-19. Kegiatan ini bertujuan untuk mengurangi risiko bencana alam dan non alam pada siswa di SDN Inpres Beha. Kegiatan yang dilakukan berupa dukungan dan edukasi. Kegiatan ini dilaksanakan hari Sabtu, 28 Agustus 2021 yang dihadiri 24 siswa dengan penerapan protokol pencegahan Covid-19. Dari hasil evaluasi peluang risiko bencana alam telah dikurangi baik itu yang bersumber geofisika dalam hal ini gempa bumi dan bencana non alam yang bersumber biologis seperti pandemic COVID-19 dibuktikan dengan tersedianya sarana pencegahan bencana alam dan peningkatan pengetahuan dan keterampilan siswanya dalam kesiapsiagaan menghadapi bencana alam. Target luaran yang dihasilkan pada kegiatan ini berupa publikasi media massa online SastalPos.com pada tanggal 28 Agustus 2021 dan artikel ilmiah di jurnal Tetengkorang serta video di youtube chanel P3M POLNUSTAR

Schools are small communities that can be used as a place to transmit information from students to families and the community in general to reduce disaster risk. SDN Inpres Beha, Tabukan Utara District, has the potential to face disasters because it is located not far from Mount Awu, which is an active volcano in Indonesia and includes areas with frequent earthquakes. This activity aims to reduce natural disaster risk at SDN Inpres Beha and the risk of non-natural disasters in the form of the risk of contracting COVID-19. Activities carried out are in the form of support and education. This activity was held on Saturday, August 28, 2021, which was attended by 24 students with the implementation of the Covid-19 prevention protocol. From the results of the evaluation of disaster risk, both natural disasters such as earthquakes and non-natural disasters such as the COVID-19 pandemic have been proven by the availability of disaster prevention facilities and increasing students' knowledge and skills in disaster preparedness. The output targets for this activity are the publication of online mass media SastalPos.com on August 28, 2021, and scientific articles in the Tetengkorang journal and videos on the P3M POLNUSTAR YouTube channel
Conference Report: History of Double Taxation Conventions, Rust, 4–7 July 2008
Authors: Rentzsch Daniel P. , Huber Matthias 
Published: February 2022

The history of double tax conventions is a topic that has not generally gained much scientific attention in the past. But as the current state of the international tax law is also a product of historic developments starting at the latest in the nineteenth century, a look at the past can help to better understand the present und thus help to solve the problems that the international tax lawyer encounters today and in the future.
To begin this endeavour, international tax law scholars from the Vienna University of Economics and Business Administration and the co–hosting Universities of Bonn, Heidelberg, Mainz and Zurich met together with many scholars and international tax lawyers from around the world to a first conference on the history of double taxation conventions (DTC) from the 4–7 July in Rust, Austria. The conference was friendly supported by the German and the Austrian Branch of the International Fiscal Association.
National Courts’ Treatment of Tax Rules that Conflict with the EC Treaty
Authors: Ståhl Kristina 
Published: February 2022

How is a national court to proceed when it finds that a national tax rule conflicts with the EC Treaty provisions on free movement? The answer may seem obvious. Since the Treaty provisions on free movement have direct effect, they prevail over conflicting national legislation, and therefore the court must set aside the conflicting rule. But precisely what is meant by ‘setting aside’ a tax rule? Does the rule lose all force, and is taxation to take place as if the rule did not exist at all? If so, may one replace the rule with other tax rules or is there quite simply a ‘gap’in the rules? Or, when applying the law, is it permissible instead — at least in some cases — to modify the requirements and/or the fiscal consequences prescribed by the conflicting rule so that it may still be applied, but in a manner compatible with EC law? And, if so, how far may judges go without becoming legislators?
These are examples of questions that are raised and discussed in the article. The issues are illustrated by some judgments from, for the most part, Swedish courts in which national tax rules have been appraised in the light of the Treaty.
Changes in the Application of Tax Treaties in Sweden
Authors: Hilling Maria 
Published: February 2022

In 2008, the Swedish Supreme Administrative Court gave precedence to controlled foreign corporation (CFC) legislation over a tax treaty without consulting the tax treaty. Since then, the relationship between domestic law and tax treaties has been a highly debated issue in Sweden. The Court's reasoning was based on an identified conflict between domestic law and a tax treaty, which was solved through reference to general principles on derogation. In a recent judgment in a similar situation, the same Court deviated in principle from the 2008 judgment by giving priority to the tax treaty over domestic law, thereby creating a welcome return to established principles of tax treaty application. Because the Court introduced a rule of exception from the rule that Swedish tax treaties prevail over domestic law, however, this recent decision introduces changes for the application of tax treaties in Sweden. In such situations, the main rule of tax treaty precedence over domestic law is set aside, and the principles of derogation will be applied. This article is divided into four sections, in which I examine and analyse the recent case and its implications for tax treaty application in Sweden. As the 2008 decision is of central importance, I briefly present this case in section 1. In section 2, I turn to the 2010 decision. Conclusions on the effects of the Court's adjudication on tax treaty application in Sweden are presented in section 3, in which I analyse the situations to which the rule of exception is applicable. A significant legal issue following the aftermath of the 2010 decision is presented in section 4.
Dividend Withholding Tax Planning Techniques: Part 2
Authors: Merks Paulus 
Published: February 2022

Although there is a confounding variety of cross-border dividend withholding tax planning techniques available to the modern corporate taxpayer, this study has sought to identify, analyse and categorize these techniques in abstracto and, unless stated otherwise, without linking these techniques to particular countries. Whereas Part 1 of this two-part study focused on the so-called formal dividend withholding tax planning techniques, the underlying Part 2 identifies, analyses and categorizes the so-called substantive dividend withholding tax planning techniques. In addition, this Part 2 provides a framework whereby the various dividend withholding tax planning techniques can be categorized in a consistent and universal manner.
Fiscal Aid Review and Cross-Border Tax Distortions
Authors: Rossi-Maccanico Pierpaolo 
Published: February 2022

International taxation was never the focus of the state aid prohibition foreseen by Article 107(1) TFEU. Indeed, the European judicature has made it clear that the application of state aid rules to measures relating to business taxation was essentially aimed at intra-state rather inter-state tax preferences. However, this does not preclude certain cross-border distortions of competition deriving from direct business tax measures to fall under the scrutiny of state aid rules. Under its effect-based doctrine, the European judicature has consistently held that the notion of state aid includes tax preferences having the effect of indirectly favouring certain undertakings by favouring certain productions or arrangements, except where the preference is justified from the nature and general scheme of the system. Moreover, the Commission practice first and the Court of Justice later have confirmed that the notion of selective aid includes certain tax preferences being selective irrespective of whether these are internationally harmful or not. Starting with his 1998 Notice on the application of state aid rules to direct tax measures, the Commission has been active in policing the tax regimes relating to the 1997 Code of Conduct on business taxation to tackle international tax competition. Against this background, the article provides a reasoned review of the application of state aid rules to international tax preferences and of the selectivity criterion. There is no reason not to carry out the analysis under the same criteria than the ones developed by the Court in reviewing tax discriminations or restrictions hindering the exercise of fundamental freedoms in the internal market, save where competition between undertakings is not affected. This parallel shall not, however, bring prejudice to the different nature and scope of state aid review. In examining the compatibility of fiscal aids with the internal market, the Commission enjoys a broader discretion, provided that it never produce results that limit or restrict the application of specific provisions of the TFEU such as the fundamental freedoms.
Like-kind Exchanges Pursuant to Section 1031 Internal Revenue Code and their Consequences under German CFC-rules
Authors: Kraft Gerhard , Zielinski Sigrid 
Published: February 2022

On the basis of sound economic reasoning, numerous tax systems have provisions that allow for tax-free exchanges of like-kind property. When the property is sold after the exchange the gain will usually be taxed so that it is in fact not a tax-free exchange but rather a deferral of taxation until the sale of the property. After a brief overview of the basic like-kind exchange rules under the US Internal Revenue Code (IRC) and the basic concepts of the German Controlled Foreign Corporations (CFC-) rules, this article discusses the possible consequences of a like-kind exchange of US property by a US corporation, owned and controlled by shareholders resident in Germany under German CFC-rules. As a few examples will demonstrate, a like-kind exchange under US law could - if certain conditions are met - lead to the application of German CFC-rules thereby reversing the non-recognition event. In these instances, German CFC legislation overreaches the basic purpose of CFC-rules - to prevent or reduce abuse and designs for tax evasions.
Corporate Financing, Interest Deduction and Tax Controversies
Authors: Martins António 
Published: February 2022

This article focuses on a general tax principle: the usual corporate income tenet that, for being deductible, costs have to be necessary or indispensable to generate revenue or to maintain the corporation as a going concern. After exposing its possible meaning, we analyze its impact on court decisions and legal controversies regarding some intra-group financing operations. These controversies have, in our view, been a major reason for the recent introduction of quantitative limitations to interest deduction in the Portuguese corporate income tax code. The Portuguese tax law already had several ways of restricting interest expenses without recurring to the new clause of quantitative automatic limitation. In the light of such a set of legal avenues for restricting interest deduction, the new clause inserted in the tax code is a move in the direction of abandoning principles in favour of rules.
Financial Transaction Tax: Pan-European Market for Master-Feeder Structures  or Part of It  Smothered?
Authors: Adema Raymond P.C. 
Published: February 2022

The European Commission (EC) published a revised version of the proposal for a common system for the levy of a Financial Transaction Tax (FTT) on 14 February 2013.1 The FTT is a tax imposed on financial institutions handling for transactions in financial instruments. The proposal lacks specific provisions master-feeder structures as referred to in the UCITS Directive. As yet little is known about the consequences of a lack of such provisions. This contribution describes the author's research into whether the proposal sufficiently takes account of the objectives of the UCITS Directive. It shows the EC's proposal to have insufficiently considered master-feeder structures. This, hence, distorts the competition between these structures. The proposal should be adapted in places to eliminate or reduce such distortion.