EVOLUTION OF THE ARM\u27S LENGTH STANDARD IN THE US TRANSFER PRICING LEGISLATION AND RUSSIAN ARM\u27S LENGTH PERSPECTIVE

This thesis analyzes the evolution of the arm\u27s length standard (ALS) as the key element of the transfer pricing control system in the US. This thesis also addresses some issues on creation of transfer pricing legislation in the Russian Federation and focuses on three sets of problems. First, it provides the general outline of the legislative history of the ALS as well as the history of the ALS\u27 application in the US, including an overview of landmark cases, which revealed some conceptual problems with respect to the ALS. Secondly, the thesis addresses core problems associated with the ALS, such as disability of the ALS to cope with the taxation of income in the absence of comparable transactions, difficulties of the application of the ALS with respect to e-commerce issues and problems of tax base allocation in cases involving multiple tax jurisdictions. The analysis of the place of the ALS in the modem tax legislation is also made from the angle of what alternative approaches can be plausibly applied instead of the ALS. Finally, the thesis explores the set of problems with regard to the development of the ALS in the emerging transfer pricing legislation of Russia, where the potential impact of the US transfer pricing rules and international trends should not be overlooked. This part of the thesis is not a comparative analysis, but rather an attempt to find out which parallels may be drawn and which lessons may be learned from the evolution of the ALS in the US in order to determine how the Russian legislature may finally address the ALS in Russia and to what extent it shall be developed

Reconstruction of the Steroid 1(2)-Dehydrogenation System from <i>Nocardioides simplex</i> VKM Ac-2033D in <i>Mycolicibacterium</i> Hosts

Microbial 1(2)-dehydrogenation of 3-ketosteroids is an important basis for the production of many steroid pharmaceuticals and synthons. When using the wild-type strains for whole cell catalysis, the undesirable reduction of the 20-carbonyl group, or 1(2)-hydrogenation, was observed. In this work, the recombinant strains of Mycolicibacterium neoaurum and Mycolicibacterium smegmatis were constructed with blocked endogenous activity of 3-ketosteroid-9α-hydroxylase, 3-ketosteroid-1(2)-dehydrogenase (3-KSD), and expressing 3-KSD encoded by the gene KR76_27125 (kstD2NS) from Nocardioides simplex VKM Ac-2033D. The in vivo activity of the obtained recombinant strains against phytosterol, 6α-methyl-hydrocortisone, and hydrocortisone was studied. When using M. smegmatis as the host strain, the 1(2)-dehydrogenation activity of the constructed recombinant cells towards hydrocortisone was noticeably higher compared to those on the platform of M. neoaurum. A comparison of the strengths of inducible acetamidase and constitutive hsp60 promoters in M. smegmatis provided comparable results. Hydrocortisone biotransformation by M. smegmatis BD/pMhsp_k expressing kstD2NS resulted in 95.4% prednisolone yield, and the selectivity preferred that for N. simplex. Mycolicibacteria showed increased hydrocortisone degradation at 35 °C compared to 30 °C. The presence of endogenous steroid catabolism in Mycolicibacterium hosts does not seem to confer an advantage for the functioning of KstD2NS. The results allow for the evaluation of the prospects for the development of simple technological methods for the selective 1(2)-dehydrogenation of 3-ketosteroids by growing bacterial cells

Spectroscopy of heavy elements at Dubna

In 2004, the GABRIELA (Gamma Alpha Beta Recoil Investigation with the Electromagnetic Analyzer VASSILISSA) collaboration started a twofold scientific program at the FLNR (Dubna) laboratory: (a) the systematic study of the behaviour of single particle states within isotopic and isotonic chains with Z = 100-104 as N varies from 152 to 162 and (b) the study of isotopes for which very little spectroscopic information is known. After discussing the Physics motivations and the experimental setup, some new results concerning the structure of 249Fm and 253No nuclei, and some preliminary results on the decay of 217Pa decay are presented.SCOPUS: cp.pinfo:eu-repo/semantics/publishe

Gamma and electron spectroscopy of heavy nuclei at FLNR JINR

Detailed spectroscopic information of excited nuclear states in deformed transfermium nuclei is scarce. Most of the information available today has been obtained from investigations of fine structure α decay. Although α decay gives access to hindrance factors and lifetimes which are strongly correlated to shell/subshell closures and the presence of isomers, only the combined use of γ and conversion electron spectroscopy allows the precise determination of excitation energy, spin and parity of nuclear levels. In particular, the study of odd isotopes gives crucial information on the single particle states available at and around the Fermi surface. In the following, the preliminary results of decay studies using α - γ and α - beta coincidences at the focal plane of the VASSILISSA recoil separator are presented. © 2007 American Institute of Physics.SCOPUS: cp.pinfo:eu-repo/semantics/publishe

High-K,t1/2=1.4(1) ms, isomeric state in Lr255

An isomeric state in Lr255 with a half-life of t1/2=1.4(1) ms and Ex>720-keV has been observed for the first time using the GABRIELA setup at the focal plane of the VASSILISSA separator. Based on its K-forbiddeness, the configuration of the state is most probably formed by coupling the valence proton to a two quasiparticle neutron excitation. Possible three quasiparticle configurations are discussed. © 2008 The American Physical Society.SCOPUS: ar.jinfo:eu-repo/semantics/publishe

Detailed spectroscopy in 249^{249}Fm

Excited states in 249Fm were populated via the alpha decay of 253No and the subsequent decay was observed with the GABRIELA detection system installed at the focal plane of the VASSILISSA recoil separator. The energies, spins, and parities of these states could be established through combined alpha, gamma, and conversion-electron spectroscopy. The first members of the ground-state rotational band were identified. Their excitation energies as well as the observation of a cross-over E2 transition confirm the assignment of 7/2+[624] for the ground state of 249Fm. Two excited states were also observed and their decay properties suggest that they correspond to the particle excitation 9/2-[734] and hole excitation 5/2+[622]. The analysis suggests that the 279-keV transition de-exciting the 9/2- state has anomalous E1 conversion coefficients

Isomeric states in 253No

Isomeric states in 253No have been investigated by conversion electron and γ -ray spectroscopy with the GABRIELA detection system. The 31μs isomer reported more than 30 years ago is found to decay to the ground state of 253No by the emission of a 167keV M2 transition. The spin and parity of this low-lying isomeric state are established to be 5/2 + .The presence of another longer-lived isomeric state is also discussed. © Società Italiana di Fisica and Springer-Verlag 2007.SCOPUS: ar.jinfo:eu-repo/semantics/publishe