1,641 research outputs found

    Numerically efficient algorithm for model development of high-order systems

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    A technique for estimating transfer functions in partial fraction expansion form from frequency response data for a high-order system is presented. The problem formulation avoids many of the numerical difficulties associated with high-order polynomials and has the advantage of having the option to fix the camping and frequency of a mode, if known, during the estimation process. The resulting transfer function(s) may be converted to Jordan-Form time domain equations directly. During the implementation of this technique, a frequency and amplitude normalizing window was developed that maximized the efficiency of the optimization algorithm. The combination of estimating the transfer function in factored form, the ability to fix preciously determined parameters and the effectiveness of the normalizing window led to a progressive approach to synthesizing transfer functions from frequency response data for high-order systems

    Hybrid Entity Mismatches and the International Trend of Matching Tax Outcomes: A Critical Approach

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    The international tax debate as regards hybrid entities has certainly changed after the OECD BEPS Project. Since then, the trend has been focused exclusively on matching transactions involving hybrids and reverse hybrid entities and double non-taxation, however without questioning whether these two elements are necessarily interconnected or whether they should serve each other in the design of domestic anti-hybrid provisions. This is particularly evident as regards the notion of ‘hybrid (entity) mismatch arrangements’ the design of which is based on the assumption that income should be taxed somewhere – no matter where – and as regards the complex set of domestic solutions proposed (‘linking rules’) the true efficacy of which is nevertheless still unknown. In this vein, this article adopts a critical approach both as regards the diagnosis of the problems and as regards the solutions proposed. As to the diagnosis, the author argues that the artificial attempt to match transactions involving hybrid entities and double non-taxation not only disregards the fundamental issue as regards hybrid entity mismatches (i.e. the disparate tax characterization of the same entity by two different states), but also carries with it the risk of creating presumptions of abusive practices in all those cases in which a hybrid entity structure is simply not taxed at all. As to the remedies, the author argues against the complexity, excessive reliance on foreign laws and potential economic double taxation issues that the implementation of linking rules might cause from a tax policy perspective. From a practical perspective, the author questions the proper interaction between linking rules and other anti-base erosion provisions, such as interest limitations and CFC rules. This article ultimately concludes that a re-orientation in the international debate regarding hybrids and reverse hybrid entities is crucial in order to open the door for more fundamental – and perhaps also more coordinated – solutions

    Hybrid Entity Mismatches: Exploring Three Alternatives for Coordination

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    The OECD pragmatic approach regarding hybrid entity mismatches is, without doubt, questionable. However, equally questionable is the absence of alternatives solutions proposed by either academics or tax policymakers, which demonstrates a sort of conformism as regards both the diagnosis of the problems and the solutions thereto, as if matching tax outcomes and taxing income somewhere – no matter where – were indeed the only possible path to deal with hybrid entity mismatches. In an attempt to break this inertia, this article argues for coordination in the tax characterization of entities as a straightforward and suitable alternative to replace the current OECD linking rules, and perhaps also, the consequentialist OECD approach to hybrid entity mismatches. For this purpose, three specific alternatives are explored for coordination in the tax characterization of entities, which include (1) supremacy of the tax characterization rules of the source state, (2) supremacy of the tax characterization rules of the residence state and (3) supremacy of the tax characterization rules of the home state. The analysis of these alternatives includes both hypotheticals and specific examples from domestic and supranational laws that are used to illustrate and support their effectiveness. The ultimate aim of this article is to demonstrate that coordination in the tax characterization of entities appears to be not only a more preferable path when compared to the OECD approach of matching tax outcomes, but also a more coherent and less costly alternative for both taxpayers and tax administrations

    The INPE handouts to the 6th LANDSAT Technical Working Group (LTWG) Meeting

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    LANDSAT receiving and processing system in its present configuration and status are described, as well as the experience already obtained with LANDSATs 4 and 5. The revised table of station plans for TM reception and products and of implementation schedule for data formats employing superstructure conventions is updated. Standardization of the worldwide reference systems is proposed. The INPE preliminary TM products price list is included. A TM image received and processed is shown to illustrate the appearance of the products offered

    The Brazilian report to the 7th LANDSAT Technical Working Group (LTWG) meeting

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    Described is the current status of the INPE LANDSAT receiving and processing facilities, as well as the experience in the related activities during the period from June 1984 to February 1985

    The effects of solar incidence angle over digital processing of LANDSAT data

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    A technique to extract the topography modulation component from digital data is described. The enhancement process is based on the fact that the pixel contains two types of information: (1) reflectance variation due to the target; (2) reflectance variation due to the topography. In order to enhance the signal variation due to topography, the technique recommends the extraction from original LANDSAT data of the component resulting from target reflectance. Considering that the role of topographic modulation over the pixel information will vary with solar incidence angle, the results of this technique of digital processing will differ from one season to another, mainly in highly dissected topography. In this context, the effects of solar incidence angle over the topographic modulation technique were evaluated. Two sets of MSS/LANDSAT data, with solar elevation angles varying from 22 to 41 deg were selected to implement the digital processing at the Image-100 System. A secondary watershed (Rio Bocaina) draining into Rio Paraiba do Sul (Sao Paulo State) was selected as a test site. The results showed that the technique used was more appropriate to MSS data acquired under higher Sun elevation angles. Topographic modulation components applied to low Sun elevation angles lessens rather than enhances topography

    Evaluation of SIR-A (Shuttle Imaging Radar) images from the Tres Marias region (Minas Gerais State, Brazil) using derived spatial features and registration with MSS-LANDSAT images

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    Two image processing experiments are described using a MSS-LANDSAT scene from the Tres Marias region and a shuttle Imaging Radar SIR-A image digitized by a vidicon scanner. In the first experiment the study area is analyzed using the original and preprocessed SIR-A image data. The following thematic classes are obtained: (1) water, (2) dense savanna vegetation, (3) sparse savanna vegetation, (4) reforestation areas and (5) bare soil areas. In the second experiment, the SIR-A image was registered together with MSS-LANDSAT bands five, six, and seven. The same five classes mentioned above are obtained. These results are compared with those obtained using solely MSS-LANDSAT data. The spatial information as well as coregistered SIR-A and MSS-LANDSAT data can increase the separability between classes, as compared to the use of raw SIR-A data solely

    Variability in Catheter-Associated Asymptomatic Bacteriuria Rates Among Individual Nurses in Intensive Care Units: An Observational Cross-Sectional Study

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    Catheter-associated asymptomatic bacteriuria (CAABU) is frequent in intensive care units (ICUs) and contributes to the routine use of antibiotics and to antibiotic-resistant infections. While nurses are responsible for the implementation of CAABU-prevention guidelines, variability in how individual nurses contribute to CAABU-free rates in ICUs has not been previously explored. This study’s objective was to examine the variability in CAABU-free outcomes of individual ICU nurses. This observational cross-sectional study used shift-level nurse-patient data from the electronic health records from two ICUs in a tertiary medical center in the US between July 2015 and June 2016. We included all adult (18+) catheterized patients with no prior CAABU during the hospital encounter and nurses who provided their care. The CAABU-free outcome was defined as a 0/1 indicator identifying shifts where a previously CAABU-free patient remained CAABU-free (absence of a confirmed urine sample) 24–48 hours following end of shift. The analytical approach used Value-Added Modeling and a split-sample design to estimate and validate nurse-level CAABU-free rates while adjusting for patient characteristics, shift, and ICU type. The sample included 94 nurses, 2,150 patients with 256 confirmed CAABU cases, and 21,729 patient shifts. Patients were 55% male, average age was 60 years. CAABU-free rates of individual nurses varied between 94 and 100 per 100 shifts (Wald test: 227.88, P\u3c0.001) and were robust in cross-validation analyses (correlation coefficient: 0.66, P\u3c0.001). Learning and disseminating effective CAABU-avoidance strategies from top-performers throughout the nursing teams could improve quality of care in ICUs

    The Proposal for an EU Anti-Avoidance Directive: Some Preliminary Thoughts

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    On 28 January 2016 the European Commission made public a package of measures aimed to tackle tax avoidance and abusive practices in the European internal market. The package includes a detailed proposal for a new EU Anti-Avoidance Directive addressing six main issues: deductibility of interest; exit taxation; switch-over clause; General Anti-Avoidance Rule (GAAR); Controlled Foreign Corporation (CFC) rules; and hybrid mismatches. This paper provides a critical analysis of the Proposal for a Directive taking into consideration some of the implications of its implementation at stake. The final aim of this work is to contribute with some elements that can improve the future debate on these matters
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