94 research outputs found
The Impact of Tax Treaties on Foreign Direct Investment: The Evidence Reconsidered
This paper reconsiders the empirical evidence of the relationship between tax treaties and FDI using U.S. outbound FDI to 78 countries over the period of 2007–2018. Unlike previous studies, we explicitly consider differences in the tax environments of recipient economies, including their tax-haven status, transfer pricing rules, CFC rules and anti-avoidance regulations, in our estimations. Our results confirm the importance of controlling for country-specific tax environments, especially the tax-haven status and transfer pricing rules. We find that tax treaties positively contribute to FDI inflows in developing countries, while they have no statistically significant impacts on OECD countries.
Recently signed tax treaties still foster FDI but less than older ones do.
Finally, our results indicate, all other things being equal, that the weaker the transfer pricing regulations, the greater the amount of U.S.
direct investment into a non-OECD economy
The Impact of Tax Treaties on Foreign Direct Investment: the Evidence Reconsidered
The existing empirical literature often reports a non-significant or even negative impact of tax treaties on foreign direct investment. Such mixed evidence stokes controversy over the validity of tax treaties. This paper reconsiders the empirical evidence for the relationship between tax treaties and FDI, using U.S. outbound FDI to 78 countries over the period 2007–2018. Unlike previous studies, this one explicitly controls for differences in the tax environments of recipient economies, including tax haven status, transfer pricing rules, CFC rules, anti-avoidance regulations and corporate income tax rates, in the estimation. Our results confirm the importance of controlling for country-specific tax environments, especially tax haven status and transfer pricing rules, to avoid omitted variable bias. We find that tax treaties positively contribute to FDI inflow in developing countries, while they have no statistically significant impacts to OECD countries. Recently-signed tax treaties still foster FDI but less than older ones do. Finally, our results indicate that, other things being equal, the weaker the transfer pricing regulations, the greater the amount of U.S direct investment into a recipient country
Experimental Study on Electromagnetic Forming of High Strength Steel Sheets with Different Dimensions of Aluminum Driver Plate
Recently, the potential of the electromagnetic forming process has been introduced to
form the shallow longitudinal reinforcement ribs in the lateral walls of roll formed parts,
made of high strength steel sheets of 340MPa tensile stress grade [1]. However, it seems
that the application may not be easy for high strength steel sheet because of its high
tensile strength and low electric conductivity. In order to overcome this difficulty, aluminum
driver plate could be considered to enhance the formability of high strength steel sheets in
the electromagnetic forming process. In this paper, in order to investigate the effect of
aluminum driver plate on forming height of high strength steel sheet in electromagnetic
forming process, DP780 workpiece sheets were formed into a hemi elliptical protrusion
shape with Al1050 driver plate of various thicknesses and sizes. Experiments were
performed with a flat spiral coil actuator connected to an electromagnetic forming system.
The results, the aluminum driver plate helps to increase the forming height of high
strength steel sheets. In addition, the forming height of high strength steel sheet increases
as the thickness and size of a driver plate increases
Gallbladder pseudolithiasis caused by ceftriaxone in young adult
Ceftriaxone is a commonly used antibiotic due to some of its advantages. Reversible gallbladder (GB) sludge or stone has been reported after ceftriaxone therapy. Most of these patients have no symptom, but the GB sludge or stone can sometimes cause cholecystitis. We experienced two patients who had newly developed GB stones after ceftriaxone therapy for diverticulitis and pneumonia, and this resolved spontaneously 1 month after discontinuation of the drug. Awareness of this complication could help to prevent unnecessary cholecystectomy
Application of Explainable Artificial Intelligence (XAI) in Urban Growth Modeling: A Case Study of Seoul Metropolitan Area, Korea
Unplanned and rapid urban growth requires the reckless expansion of infrastructure including water, sewage, energy, and transportation facilities, and thus causes environmental problems such as deterioration of old towns, reduction of open spaces, and air pollution. To alleviate and prevent such problems induced by urban growth, the accurate prediction and management of urban expansion is crucial. In this context, this study aims at modeling and predicting urban expansion in Seoul metropolitan area (SMA), Korea, using GIS and XAI techniques. To this end, we examined the effects of land-cover, socio-economic, and environmental features in 2007 and 2019, within the optimal radius from a certain raster cell. Then, this study combined the extreme gradient boosting (XGBoost) model and Shapley additive explanations (SHAP) in analyzing urban expansion. The findings of this study suggest urban growth is dominantly affected by land-cover characteristics, followed by topographic attributes. In addition, the existence of water body and high ECVAM grades tend to significantly reduce the possibility of urban expansion. The findings of this study are expected to provide several policy implications in urban and environmental planning fields, particularly for effective and sustainable management of lands
Effect of oxidation on mechanical properties of Ni/Cu interface: A density functional theory study
Nickel/Copper (Ni/Cu) interfaces are applied in various fields such as manufacturing of thermoelectric modules and soldering applications. Therefore, the bond strength and mechanical properties of the Ni/Cu interfaces were investigated using spin-polarized density functional theory calculations. Compressed Cu slabs were utilized to model coherent Ni/Cu interfaces. The bond strength of the Ni/Cu interface was evaluated by calculating the work of separation for the (100), (110), and (111)-oriented interfaces. The mechanical properties of the most stable Ni/Cu interface configurations in each orientation were studied along the normal direction using rigid grain shift and homogeneous lattice extension methods. During homogeneous stretching of the Ni/Cu structures along the [100]-, [110]-, and [111]-directions, fracture was initiated in the Cu region because of its smaller work of separation than that of the interface. In the (110)-and (111)-oriented interfaces, the interlayer was separated by the addition of an oxygen (O) atom in the Ni/Cu interface. This oxidation results in a significant decrease in the work of separation at the interface. However, oxidation at the interface does not significantly change the me-chanical properties of the Ni/Cu structure, resulting in a fracture strain similar to that before the insertion of the O atom
M1726 The Role of Osteopontin in D-Galactosamine-Induced Liver Injury in Genetically Obese Mice
Study on the Growth of Monoclinic VO<sub>2</sub> Phase Applicable for Thermochromic Ceramic Tile
Strain rate dependent tensile behavior of advanced high strength steels: Experiment and constitutive modeling
High strain rate tensile tests were conducted for three advanced high strength steels: DP780. DP980 and TRIP780. A high strain rate tensile test machine was used for applying the strain rate ranging from 0.1/s to 500/s. Details of the measured stress-strain responses were comparatively analyzed for the DP780 and TRIP780 steels which show similar microstructural feature and ultimate tensile strength, but different strengthening mechanisms. The experimental observations included: usual strain rate dependent plastic flow stress behavior in terms of the yield stress (YS), the ultimate tensile strength (UTS), the uniform elongation (CUE) and the total elongation (TE) which were observed for the three materials. But, higher strain hardening rate at early plastic strain under quasi-static condition than that of some increased strain rates was featured for TRIP780 steel, which might result from more active transformation during deformation with lower velocity. The uniform elongation that explains the onset of instability and the total elongation were larger in case of TRIP steel than the DP steel for the whole strain rate range, but interestingly the fracture strain measured by the reduction of area (RA) method showed that the TRIP steel has lower values than DP steel. The fractographs using scanning electron microscopy (SEM) at the fractured surfaces were analyzed to relate measured fracture strain and the microstructural difference of the two materials during the process of fracture under various strain rates. Finally, constitutive modeling for the plastic flow stresses under various strain rates was provided in this study. The proposed constitutive law could represent both Hollomon-like and Voce-like hardening laws and the ratio between the two hardening types was efficiently controlled as a function of strain rate. The new strength model was validated successfully under various strain rates for several grades of steels such as mild steels, DP780, TRIP780, DP980 steels. (C) 2012 Elsevier B.V. All rights reserved.X1146sciescopu
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