pinecone/core-2020-05-10-deduplication huggingface dataset:
Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?

In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By contrast, we study the conditions under which one or the other tax system is preferable from the perspective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the\ud
tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves advantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract
A theory of nonvertical triplet energy transfer in terms of accurate potential energy surfaces: The transfer reaction from π,π* triplet donors to 1,3,5,7 -cyclooctatetraene

Triplet energy transfer (TET) from aromatic donors to 1,3,5,7-cyclooctatetraene (COT) is an extreme case of "nonvertical" behavior, where the transfer rate for low-energy donors is considerably faster than that predicted for a thermally activated (Arrhenius) process. To explain the anomalous TET of COT and other molecules, a new theoretical model based on transition state theory for nonadiabatic processes is proposed here, which makes use of the adiabatic potential energy surfaces (PES) of reactants and products, as computed from high-level quantum mechanical methods, and a nonadiabatic transfer rate constant. It is shown that the rate of transfer depends on a geometrical distortion parameter у=(2g²/κ₁)1/2 in which g stands for the norm of the energy gradient in the PES of the acceptor triplet state and κ₁ is a combination of vibrational force constants of the ground-state acceptor in the gradient direction. The application of the model to existing experimental data for the triplet energy transfer reaction to COT from a series of π,π* triplet donors, provides a detailed interpretation of the parameters that determine the transfer rate constant. In addition, the model shows that the observed decrease of the acceptor electronic excitation energy is due to thermal activation of CC bond stretchings and C–C bond torsions, which collectively change the ground-state COT bent conformation (D2d) toward a planar triplet state (D8h).Work financed by\ud
Projects BQU2000/1500, BQU2000/0646, BQU2001/2926\ud
from the Spanish Ministry of Science and Technology\ud
~MCyT!. L.M.F. is grateful to the Ministry of Education,\ud
Culture and Sport ~Spain! for a Doctoral Fellowship.Peer reviewe
Extended Hückel theory for band structure, chemistry, and transport. II. Silicon

8 pages, 9 figures, 4 tables.In this second paper, we develop transferable semiempirical extended Hückel theoretical (EHT) parameters for the electronic structure of another technologically important material, namely, silicon. The EHT parameters are optimized to experimental target values of the band dispersion of bulk silicon. We quantitatively benchmark our parameters to bulk electronic properties such as band edge energies and locations, effective masses, and spin-orbit coupling parameters, competitive with a nearest-neighbor sp3d5s* orthogonal tight-binding model for silicon of T. Boykin et al. [Phys. Rev. B 69, 115201 (2004)] that has been widely used to model silicon-based devices (see, e.g., A. Rahman et al. [Jpn. J. Appl. Phys. Part I 44, 2187 (2005)] and J. Wang et al. [Appl. Phys. Lett. 86, 093113 (2005)]). The transferability of the parameters is checked for multiple physical and chemical configurations, specifically, two different reconstructed surfaces, Si(100)-(2×1) and Si(111)-(2×1). The robustness of the parameters to different environments is demonstrated by comparing the surface band structures with density functional theory GW calculations and photoemission/inverse photoemission experiments. We further apply the approach to calculate the one-dimensional band dispersion of an unrelaxed rectangular silicon nanowire and explore the chemistry of surface passivation by hydrogen. Our EHT parameters thus provide a quantitative model of bulk silicon and silicon-based interfaces such as contacts and reconstructed surfaces, which are essential ingredients towards a quantitative quantum transport simulation through silicon-based heterostructures.The authors acknowledge the support of the Army Research\ud
Office through the Defense University Research Initiative\ud
in Nanotechnology (DURINT) program, the Defense\ud
Advanced Research Projects Agency-Air Force Office of\ud
Scientific Research (DARPA-AFOSR), and the Network for\ud
Computational Nanotechnology (NCN). One of the authors (J. C.) acknowledges support from the Spanish DGICyT under\ud
Contract No. MAT2004-05348-C04-2.Peer reviewe
How journal rankings can suppress interdisciplinary research: A comparison between Innovation Studies and Business & Management

41 p., 4 tablas, 10 figuras, material suplementario.This study provides quantitative evidence on how the use of journal rankings can disadvantage interdisciplinary research in research evaluations. Using publication and citation data, it compares the degree of interdisciplinarity and the research performance of a number of Innovation Studies units with that of leading Business & Management schools in the UK. On the basis of various mappings and metrics, this study shows that: (i) Innovation Studies units are consistently more interdisciplinary in their research than Business & Management schools; (ii) the top journals in the Association of Business Schools’ rankings span a less diverse set of disciplines than lower-ranked journals; (iii) this results in a more favourable assessment of the performance of Business & Management schools, which are more disciplinary-focused. This citation-based analysis challenges the journal ranking-based assessment. In short, the investigation illustrates how ostensibly ‘excellence-based’ journal rankings exhibit a systematic bias in favour of mono-disciplinary research. The paper concludes with a discussion of implications of these phenomena, in particular how the bias is likely to affect negatively the evaluation and associated financial resourcing of interdisciplinary research organisations, and may result in researchers becoming more compliant with disciplinary authority over time.IR and AO were funded by the US NSF (Award no. 0830207, http://idr.gatech.edu/) and the EU FP7 project FRIDA (grant 225546, http://www.fridaproject.eu).Peer reviewe
Neuropsychological predictors of response to randomized treatment in obsessive-compulsive disorder

Objective: To identify neuropsychological predictors of treatment response to cognitive-behavioral therapy (CBT) and fluoxetine in treatment-naive adults with obsessive-compulsive disorder (OCD).Method: Thirty-eight adult outpatients with OCD underwent neuropsychological assessment, including tasks of intellectual function, executive functioning and visual and verbal memory, before randomization to a 12-week clinical trial of either CBT or fluoxetine. Neuropsychological measures were used to identify predictors of treatment response in OCD.Results: Neuropsychological measures that predicted a better treatment response to either CBT or fluoxetine were higher verbal IQ (Wechsler Abbreviated Scale of Intelligence) (p = 0.008); higher verbal memory on the California Verbal Learning Test (p = 0.710); shorter time to complete part D (Dots) (p<0.001), longer time to complete part W (Words) (p = 0.025) and less errors on part C (Colors) (p<0.001) in the Victoria Stroop Test (VST). Fewer perseverations on the California Verbal Learning Test, a measure of mental flexibility, predicted better response to CBT, but worse response to fluoxetine (p = 0.002).Conclusion: in general, OCD patients with better cognitive and executive abilities at baseline were more prone to respond to either CBT or fluoxetine. Our finding that neuropsychological measures of mental flexibility predicted response to treatment in opposite directions for CBT and fluoxetine suggests that OCD patients with different neuropsychological profiles may respond preferentially to one type of treatment versus the other. Further studies with larger samples of OCD patients are necessary to investigate the heuristic value of such findings in a clinical context. (C) 2012 Elsevier Inc. All rights reserved.Conselho Nacional de Desenvolvimento Científico e Tecnológico (CNPq)Fundação de Amparo à Pesquisa do Estado de São Paulo (FAPESP)Univ São Paulo, Sch Med, Dept Psychiat, Obsess Compuls Disorder Spectrum Project Clin, BR-78505453 São Paulo, BrazilUniv São Paulo, Inst Math & Stat, BR-78505453 São Paulo, BrazilHarvard Univ, Sch Med, Dept Psychiat, Massachusetts Gen Hosp, Boston, MA 02115 USAUniv Fed Minas Gerais, Inst Biol Sci, Grad Program Neurosci, Belo Horizonte, MG, BrazilFed Univ São Paulo UNIFESP, Dept Psychiat, Interdisciplinary Lab Clin Neurosci LiNC, São Paulo, BrazilFed Univ São Paulo UNIFESP, Dept Psychiat, Interdisciplinary Lab Clin Neurosci LiNC, São Paulo, BrazilCNPq: 521369/96-7CNPq: 475919/2006-8CNPq: 481791/2004-3FAPESP: 05/55628-08FAPESP: 05/04206-6FAPESP: 06/61459-7FAPESP: 06/50273-0FAPESP: 06/58286-3Web of Scienc
Effect of thermal inhomogeneity for terahertz radiation from intrinsic Josephson junction stacks of Bi[2]Sr[2]CaCu[2]O[8]+δ

Terahertz radiation from the mesa structures of Bi[2]Sr[2]CaCu[2]O[8]+ δ is detected in samples with thin electrodes <100 nm. In samples with thick electrodes≃400 nm, neither radiations nor voltage jumps in current-voltage characteristics are detected. This suggests that the thin electrode helps excite the Josephsonplasma oscillation as a result of the poor heat flow through the electrode. The shielding effect by the electrode is not essential. We consider that the local temperature rise is the origin of the synchronization of the phase kink for terahertz radiation
Detection of H3+ auroral emission in Jupiter’s 5-micron window

We use high-resolution ground-based observations from the VLT CRIRES instrument in December 2012 to identify sixteen previously undetected H 3 + emission lines from Jupiter’s ionosphere. These emission lines are located in Jupiter’s 5-micron window (4.5-5.2 m m), an optically-thin region of the planet’s spectrum where the radiation mostly originates from the deep troposphere. The H 3 + emission lines are so strong that they are visible even against this bright background. We measure the Doppler broadening of the H 3 + emission lines in order to evaluate the kinetic temperature of the molecules, and we obtain a value of 1390 ± 160 K. We also measure the relative intensities of lines in the ν 2 fundamental in order to calculate the rotational temperature, obtaining a value of 960 ± 40 K. Finally, we use the detection of an emission line from the 2 ν 2 (2)- ν 2 overtone to measure a vibrational temperature of 925 ± 25 K. We use these three independent temperature estimates to discuss the thermodynamic equilibrium of Jupiter’s ionosphere.Peer-reviewedPublisher Versio
Frustration index and Cheeger inequalities for discrete and continuous magnetic Laplacians.

We discuss a Cheeger constant as a mixture of the frustration index and the expansion rate, and prove the related Cheeger inequalities and higher order Cheeger inequalities for graph Laplacians with cyclic signatures, discrete magnetic Laplacians on finite graphs and magnetic Laplacians on closed Riemannian manifolds. In this process, we develop spectral clustering algorithms for partially oriented graphs and multi-way spectral clustering algorithms via metrics in lens spaces and complex projective spaces. As a byproduct, we give a unified viewpoint of Harary’s structural balance theory of signed graphs and the gauge invariance of magnetic potentials
University students’ perceptions of summative assessment : the role of context.

We report on a mixed-method study that compared students’ perceptions of summative assessment across two distinct disciplines – education and mathematics, at two research-intensive institutions in the UK. The disciplines chosen represent opposing positions in Biglan’s classification of academic disciplines, as well as having very different assessment practices. Results suggest that these education students prefer to be assessed by methods they perceive to discriminate on the basis of academic abilities. Moreover, they perceive the traditional closed-book examination as inadequate to assess the capabilities which are key to being successful in their subject, which fits some but not all of the general findings in the literature. However, comparing these results with those of an identical study with mathematics students, we find that the perceptions of summative assessment are very different. We account for that difference by suggesting that students’ epistemic beliefs play a role in shaping these perceptions and conclude that, in designing summative assessment in higher education, generalised and centralised forces for change need to be tempered by contextual and disciplinary factors
Influence of non-potential coronal magnetic topology on solar-wind models.

By comparing a magneto-frictional model of the low-coronal magnetic-field to a potential-field source-surface model, we investigate the possible impact of non-potential magnetic structure on empirical solar-wind models. These empirical models (such as Wang–Sheeley–Arge) estimate the distribution of solar-wind speed solely from the magnetic-field structure in the low corona. Our models are computed in a domain between the solar surface and 2.5 solar radii, and they are extended to 0.1 AU using a Schatten current-sheet model. The non-potential field has a more complex magnetic skeleton and quasi-separatrix structures than the potential field, leading to different sub-structure in the solar-wind speed proxies. It contains twisted magnetic structures that can perturb the separatrix surfaces traced down from the base of the heliospheric current sheet. A significant difference between the models is the greater amount of open magnetic flux in the non-potential model. Using existing empirical formulae this leads to higher predicted wind speeds for two reasons: partly because magnetic-flux tubes expand less rapidly with height, but more importantly because more open-field lines are further from coronal-hole boundaries
Improved light-cone sum rules for the electromagnetic form factors of the nucleon.

We calculate the electromagnetic form factors of the nucleon within the light-cone sum rule approach. In comparison to previous work [Phys. Rev. D 65 (2002) 074011] we suggest to use a pure isospin-1/2 interpolating field for the nucleon, since the Chernyak–Zhitnitsky current leads to numerically large, unphysical, isospin violating contributions. The leading-order sum rules are derived for the form factors and the results are confronted with the experimental data. Our approach tends to favor the nucleon distribution amplitudes that are not far from the asymptotic shape
Convex hulls of random walks and their scaling limits

For the perimeter length and the area of the convex hull of the first n steps of a planar random walk, we study n→∞ mean and variance asymptotics and establish non-Gaussian distributional limits. Our results apply to random walks with drift (for the area) and walks with no drift (for both area and perimeter length) under mild moments assumptions on the increments. These results complement and contrast with previous work which showed that the perimeter length in the case with drift satisfies a central limit theorem. We deduce these results from weak convergence statements for the convex hulls of random walks to scaling limits defined in terms of convex hulls of certain Brownian motions. We give bounds that confirm that the limiting variances in our results are non-zero
Characterization of foreground emission at degree angular scale for CMB
  B-modes observations. Thermal Dust and Synchrotron signal from Planck and
  WMAP data

We quantify the contamination from polarized diffuse Galactic synchrotron and
thermal dust emissions to the B-modes of the CMB anisotropies on the degree
angular scale, using data from the Planck and WMAP satellites. We compute power
spectra of foreground polarized emissions in 352 circular sky patches located
at Galactic latitude |b|>20{\deg}, each of which covering a fraction of the sky
of about 1.5%. We make use of the spectral properties derived from Planck and
WMAP data to extrapolate, in frequency, the amplitude of synchrotron and
thermal dust B-modes spectra in the multipole bin centered at $\ell\simeq80$.
In this way we estimate, for each analyzed region, the amplitude and frequency
of the foreground minimum. We detect both dust and synchrotron signal, at
degree angular scale and at 3 confidence level, in 28 regions. Here the minimum
of the foreground emission is found at frequencies between 60 and 100 GHz with
an amplitude,expressed in terms of the equivalent tensor-to-scalar ratio, r_FG,
between ~0.06 and ~1. Some of these regions are located at high Galactic
latitudes, in areas close to the ones which are being observed by sub-orbital
experiments.In all the other sky patches, where synchrotron or dust B-modes are
not detectable with the required confidence, we put upper limits on the minimum
foreground contamination and find values of r_FG between ~0.05 and ~1.5, in the
frequency range 60-90 GHz. Our results indicate that, with the current
sensitivity at low frequency, it is not possible to exclude the presence of
synchrotron contamination to CMB cosmological B-modes at the level requested to
measure a gravitational waves signal with r~0.01, at frequency <100 GHz,
anywhere. Therefore, more accurate data are essential in order to better
characterize the synchrotron polarized component, and eventually, remove its
contamination to CMB signal through foreground cleaning.Comment: 10 pages, 7 figure
Study of $D^{(*)+}_{sJ}$ mesons decaying to $D^{*+} K^0_{\rm S}$ and
  $D^{*0} K^+$ final states

A search is performed for $D^{(*)+}_{sJ}$ mesons in the reactions $pp \to
D^{*+} K^0_{\rm S} X$ and $pp \to D^{*0} K^+ X$ using data collected at
centre-of-mass energies of 7 and 8 TeV with the LHCb detector. For the $D^{*+}
K^0_{\rm S}$ final state, the decays $D^{*+} \to D^0 \pi^+$ with $D^0 \to K^-
\pi^+$ and $D^0 \to K^- \pi^+ \pi^+ \pi^-$ are used. For $D^{*0} K^+$, the
decay $D^{*0} \to D^0 \pi^0$ with $D^0 \to K^- \pi^+$ is used. A prominent
$D_{s1}(2536)^+$ signal is observed in both $D^{*+} K^0_{\rm S}$ and $D^{*0}
K^+$ final states. The resonances $D^*_{s1}(2700)^+$ and $D^*_{s3}(2860)^+$ are
also observed, yielding information on their properties, including spin-parity
assignments. The decay $D^*_{s2}(2573)^+ \to D^{*+} K^0_{\rm S}$ is observed
for the first time, at a significance of 6.9 $\sigma$, and its branching
fraction relative to the $D^*_{s2}(2573)^+ \to D^+ K^0_{\rm S}$ decay mode is
measured.Comment: 26 pages, 9 figures, Submitted to JHEP, All figures and tables, along
  with any supplementary material and additional information, are available at
  https://lhcbproject.web.cern.ch/lhcbproject/Publications/LHCbProjectPublic/LHCb-PAPER-2015-052.htm
Single and double inclusive forward jet production at the LHC at
  $\sqrt{s}$ = 7 and 13 TeV

We provide a description of the transverse momentum spectrum of single
inclusive forward jets produced at the LHC, at the center-of-mass energies of 7
and 13 TeV, using the high energy factorization (HEF) framework. We
subsequently study double inclusive forward jet production and, in particular,
we calculate contributions to azimuthal angle distributions coming from double
parton scattering. We also compare our results for double inclusive jet
production to those obtained with the Pythia Monte Carlo generator. This
comparison confirms that the HEF resummation acts like an initial state parton
shower. It also points towards the need to include final state radiation
effects in the HEF formalism.Comment: 14 pages, 5 figures, version accepted for PL
Relativistic corrections to the pair $B_c$-meson production in $e^+e^-$
  annihilation

Relativistic corrections to the pair $B_c$-meson production in
$e^+e^-$-annihilation are calculated. We investigate a production of pair
pseudoscalar, vector and pseudoscalar+vector $B_c$-mesons in the leading order
perturbative quantum chromodynamics and relativistic quark model. Relativistic
expressions of the pair production cross sections are obtained. Their numerical
evaluation shows that relativistic effects in the production amplitudes and
bound state wave functions three times reduce nonrelativistic results at the
center-of-mass energy s=22 GeV.Comment: 15 pages, 2 figures. arXiv admin note: text overlap with
  arXiv:1308.399
Search for an Isospin I =3 Dibaryon

Various theoretical calculations based on QCD or hadronic interactions
predict that in addition to the recently observed dibaryon resonance
$d^*(2380)$ with $I(J^P) = 0(3^+)$ there should also exist a dibaryon resonance
with mirrored quantum numbers $I(J^P) = 3(0^+)$. We report here on a search for
such a $NN$-decoupled state in data on the $pp \to pp\pi^+\pi^+\pi^-\pi^-$
reaction. Since no clear-cut evidence has been found, we give upper limits for
the production cross section of such a resonance in the mass range 2280 - 2500
MeV
The nature of LINER galaxies: Ubiquitous hot old stars and rare accreting black holes

Context. Galaxies, which often contain ionised gas, sometimes also exhibit a so-called low-ionisation nuclear emission line region (LINER). For 30 years, this was attributed to a central mass-accreting supermassive black hole (more commonly known as active galactic nucleus, AGN) of low luminosity, making LINER galaxies the largest AGN sub-population, which dominate in numbers over higher luminosity Seyfert galaxies and quasars. This, however, poses a serious problem. While the inferred energy balance is plausible, many LINERs clearly do not contain any other independent signatures of an AGN. Aims. Using integral field spectroscopic data from the CALIFA survey, we compare the observed radial surface brightness profiles with what is expected from illumination by an AGN. Methods. Essential for this analysis is a proper extraction of emission lines, especially weak lines, such as Balmer H beta lines, which are superposed on an absorption trough. To accomplish this, we use the GANDALF code, which simultaneously fits the underlying stellar continuum and emission lines. Results. For 48 galaxies with LINER-like emission, we show that the radial emission-line surface brightness profiles are inconsistent with ionisation by a central point-source and hence cannot be due to an AGN alone. Conclusions. The most probable explanation for the excess LINER-like emission is ionisation by evolved stars during the short but very hot and energetic phase known as post-AGB. This leads us to an entirely new interpretation. Post-AGB stars are ubiquitous and their ionising effect should be potentially observable in every galaxy with the gas present and with stars older than ~1 Gyr unless a stronger radiation field from young hot stars or an AGN outshines them. This means that galaxies with LINER-like emission are not a class defined by a property but rather by the absence of a property. It also explains why LINER emission is observed mostly in massive galaxies with old stars and little star formation