Planejamento tributário e o direito de imagem de jogadores de futebol

Por fim, o presente trabalho demonstra o posicionamento do Conselho Administrativo de Recursos Fiscais por meio do julgamento de três casos de jogadores de futebol autuados pela cessão da exploração econômica da imagem, bem como a pesquisa expõe analisa criticamente os casos julgados pelo CARF e suas decisões. O direito de imagem tem características próprias que lhe tornam um direito com caráter personalíssimo, que visa a proteção da honra, sendo que a doutrina conceitua de imagem retrato, como também tem caráter patrimonial, que diante da importância social da pessoa, lhe garante a capacidade de exploração econômica de sua imagem, conceitualmente exposta como imagem-atributo, sendo que ambas as características são protegidas constitucionalmente. Assim, os jogadores de futebol, através da notoriedade do esporte no Brasil, bem como a fácil conexão da imagem de desportistas, tanto com seus clubes, quanto com terceiros interessados na vinculação de suas marcas, passaram a explorar economicamente sua imagem. Diante da permissibilidade do ordenamento jurídico, que previamente não proibia a cessão de atos e serviços personalíssimos para pessoas jurídicas explorarem a licença de uso, e posteriormente com a criação legislativa do art. 129, da Lei n. 11.196/05, os jogadores de futebol passaram a explorar a licença de uso do direito de imagem, através de pessoas jurídicas. O presente trabalho analisa os requisitos necessários para que o planejamento tributário da exploração econômica do direito de imagem do jogador de futebol ocorra de forma lícita, através do propósito negocial que visa a economia tributária, bem como atos realizados pelo contribuinte que possam impedir a realização de tal prática, como a simulação, abuso de direito e fraude à lei. Ademais, é analisado o posicionamento do Supremo Tribunal Federal na Ação Declaratória de Constitucionalidade n. 66 e Ação Direta de Inconstitucionalidade n. 2.446, que julgaram o art. 129, da Lei n. 11.196/05 e parágrafo único do art. 116, do Código Tributário Nacional, respectivamente.Finally, this paper demonstrates the position of the Administrative Council of Tax Appeals through the trial of three cases of soccer players assessed for the assignment of economic exploitation of the image, and the research critically analyzes the cases judged by the CARF and its decisions. The image right has the characteristics that make it a right with a very personal character, which aims at protecting honor, being that the doctrine conceptualizes as portrait-image, as well as it has patrimonial character, which before the social importance of the person, guarantees him the capacity of economical exploitation of his image, conceptually exposed as attribute-image, being that both characteristics are constitutionally protected. Thus, soccer players, due to the notoriety of the sport in Brazil, as well as the easy connection of the athletes' image, both with their clubs and with third parties interested in the linking of their brands, started to economically exploit their image. Given the permissibility of the legal system, which previously did not prohibit the assignment of very personal acts and services to legal entities to explore the license of use, and later with the legislative creation of art. 129, of Law no. 11.196/05, soccer players started exploring the license of use of image rights, through legal entities. The present work analyzes the requirements for the tax planning of the economic exploitation of the soccer player's image rights to occur lawfully, through the business purpose that aims at tax economy, as well as acts performed by the taxpayer that may prevent the realization of such practice, such as simulation, abuse of right and fraud against the law. Furthermore, the position of the Federal Supreme Court is analyzed in the Declaratory Action of Constitutionality n. 66 and Direct Action of Unconstitutionality n. 2.446, which judged the art. 129, of Law 11.196/05 and sole paragraph of art. 116, of the National Tax Code, respectively

Potential Application of Photo-thermal Volumetric Ignition of Carbon Nanotubes in Internal Combustion Engines

In internal combustion engines, an ignition source is required to initiate the combustion process. This is commonly obtained either through an electric spark generation or by physical act of compression-ignition. In order to improve performance and lower pollutants levels, researchers have proposed alternatives to conventional ignition or combustion processes, such as homogeneously-charge compression-ignition (HCCI) combustion, whose critical operational requirement is precise control of the autoignition timing within the engine operating cycle. In this work, an innovative volumetrically-distributed ignition approach is proposed to control the onset of the autoignition process, by taking advantage of the optical ignition properties of carbon nanotubes when exposed to a low-consumption light source. It is shown that this ignition method enhanced the combustion of methane, hydrogen, LPG, and gasoline (injected to chamber in liquid phase). The results for this new ignition method show that pressure gradient and combustion efficiency are increased, while combustion duration and ignition delay time are decreased. A direct observation of the combustion process indicates that these benefits are due to the spatially-distributed ignition followed by a faster initial consumption of the air/fuel mixture. The use of this ignition system is therefore proposed as a promising technology for the combustion management in internal combustion engines, specifically for the HCCI engines

photo induced ignition phenomenon of carbon nanotubes by xenon pulsed light ignition tests analysis automotive and new potential applications future developments

Abstract The possibility to use carbon nanotubes (CNTs) enriched with a certain amount of metal nanoparticles for photo-inducing the combustion of liquid fuel sprays, gaseous and solid fuels was investigated in different research works. CNTs photo-ignition phenomenon has been used to trigger the combustion of different fuel typologies, demonstrating better features compared with those obtained by employing a traditional spark-plug. These improvements are due to the presence of distributed ignition nuclei inside the combustion chamber, so obtaining better values of the peak pressure, ignition delay and combustion duration. In this work, the CNTs photo-ignition phenomenon has been analyzed in order to find the minimum energy values needed to trigger the ignition, by varying the light pulse parameters and the nanoparticles concentration, Multi Wall CNTs (MWCNTs) – ferrocene, by weight. Afterwards, the results of combustion processes, triggered by using the nanoparticles, are shown comparing them with those obtained by means the spark plug and with results already published related to other fuel typologies. Hence, an overview of the possible applications of this photo-ignition phenomenon, beside that of the automotive field, is presented, also considering the disadvantages of the Xe-lamp based triggering system. Therefore, after a critical discussion on the light source typology until now used (Xenon lamp), by reporting the possible contraindications deriving from the use of this light source in most of the applicative fields, a solution is here proposed. It involves the substitution of the Xe lamp with LED sources, showing also the related experimental setup. This solution is also strengthened by the our experimental observations of CNTs photo-ignition by using high-power white LEDs as light source, never reported up to now in the literature, and by better characteristics of adaptability, robustness, easy driving and benefits provided by the LEDs rather than the Xenon lamp

Light-Induced ignition of Carbon Nanotubes and energetic nano-materials: a review on methods and advanced technical solutions for nanoparticles-enriched fuels combustion

Abstract Aim of the present manuscript is to provide an overview of all possible methods and light source typologies used by the different research groups for obtaining the energetic nano-materials' photo-ignition, showing the latest progress related to such phenomenon employing, also, alternative radiation sources to the common Xe lamp. In fact, the employment of a different source typology can open new usage prospects respect to those enabled by the Xe lamp, mainly due to its technological limitations. Therefore, several studies are faced to test light sources, such as lasers and LEDs, for igniting the nano-energetic materials (as CNTs mixed with metallic catalyzers, Al / CuO nano-particles, etc); these nano-materials are usefully employed for starting, in volumetric and controlled way, the combustion of air-fuel mixtures inside internal combustion engines, leading to significant benefits to the combustion process also in terms of efficiency, reliability, and emissions of pollutants. Several research works are presented in literature concerning the ignition of liquid / gaseous fuels, without nano-particles, employing laser sources (i.e laser-based plugs in place of the common spark plugs); therefore, an innovative solution is proposed that employs multi-point laser-plugs for inducing the ignition of nano-materials dispersed into the air-fuel mixture inside the cylinder, so further improving the combustion of the fuel in an internal combustion engine

Photo-ignition process of multiwall carbon nanotubes and ferrocene by continuous wave Xe lamp illumination

none8noThis work aims to investigate and characterize the photo-ignition phenomenon of MWCNT/ferrocene mixtures by using a continuous wave (CW) xenon (Xe) light source, in order to find the power ignition threshold by employing a different type of light source as was used in previous research (i.e., pulsed Xe lamp). The experimental photo-ignition tests were carried out by varying the weight ratio of the used mixtures, luminous power, and wavelength range of the incident Xe light by using selective optical filters. For a better explanation of the photo-induced ignition process, the absorption spectra of MWCNT/ferrocene mixtures and ferrocene only were obtained. The experimental results show that the luminous power (related to the entire spectrum of the Xe lamp) needed to trigger the ignition of MWCNT/ferrocene mixtures decreases with increasing metal nanoparticles content according to previously published results when using a different type of light source (i.e., pulsed vs CW Xe light source). Furthermore, less light power is required to trigger photo-ignition when moving towards the ultraviolet (UV) region. This is in agreement with the measured absorption spectra, which present higher absorption values in the UV–vis region for both MWCNT/ferrocene mixtures and ferrocene only diluted in toluene. Finally, a chemo-physical interpretation of the ignition phenomenon is proposed whereby ferrocene photo-excitation, due to photon absorption, produces ferrocene itself in its excited form and is thus capable of promoting electron transfer to MWCNTs. In this way, the resulting radical species, FeCp2+∙ and MWCNT−, easily react with oxygen giving rise to the ignition of MWCNT/ferrocene samples.openVisconti, Paolo; Primiceri, Patrizio; Longo, Daniele; Strafella, Luciano; Carlucci, Antonio Paolo; Lomascolo, Mauro; Cretì, Arianna; Mele, GiuseppeVisconti, Paolo; Primiceri, Patrizio; Longo, Daniele; Strafella, Luciano; Carlucci, Antonio Paolo; Lomascolo, Mauro; Creti', Arianna; Mele, Giuseppe Agostin

Dual-fuel injection fundamentals: experimental – numerical analysis into a constant-volume vessel

Abstract Dual-fuel combustion mode in compression ignition engines has been tested thoroughly, showing high potential for the reduction of emissions (especially nitric oxides and particulate matter) while keeping unchanged the fuel conversion efficiency compared with conventional Diesel engines. Controlling the reactivity of the secondary fuel is crucial for this kind of application. To this aim, a combined experimental/numerical approach is proposed in this study to provide, on one side, experimental data in controlled conditions for the calibration of the numerical models; on the other side, a numerical framework for the accurate simulation of the dual-fuel injection in engine-like operating conditions. More in detail, a constant-volume combustion vessel has been used to simulate and analyze the injection process varying the characteristic control parameters. Detailed high-resolution images of the injection and combustion processes were acquired for the validation of the numerical framework. Numerical simulations, carried out by means of the CONVERGE CFD code using a Reynolds Average Navier Stokes (RANS) approach allow for understanding the key differences between the nominal and off-design settings. Results have been compared with the experimental data in terms of liquid spray penetration. A comparison with high resolution images has also been done to prove the accuracy of the model to describe the spray evolution in terms of spray characteristics. In the provided picture, this contribution aims at demonstrating the robustness of the experimental/numerical framework that is essential for further development of such engine solution

Effects of low-grade gas composition on the energy/exergy performance of a polygeneration system (CH2HP) based on biomass gasification and ICE

Bio-hydrogen from sustainable biomass (i.e. agro-industrial residues) gasification can play a relevant role in the hydrogen economy, providing constant hydrogen from renewable sources. Nowadays, most hydrogen production systems integrate one or more water-gas shift (WGS) units to maximize the hydrogen yield that, however, needs additional syngas treatments, investment and operational costs. Besides, different electricity inputs are needed along the process to power the compression of raw syngas, shifted syngas, and pure hydrogen to the desired pressure. This common process integration with WGS generates a kind of off-gas from the hydrogen separation unit whose composition may or may not be suitable for power production, depending on the operating conditions of the gasification unit. In this regard, this work proposes a different approach in which no WGS reactors are involved and the off-gas is used to generate heat and power to provide the energy input needed by the system. In particular, the authors tested the bio-syngas and the corresponding off-gas in a 4-cylinders, spark ignition natural gas internal combustion engine operated in cogeneration mode with the aim to analyse the effect of removing the hydrogen from the original bio-syngas on mechanical/electric and thermal power, on fuel efficiency and CO2 specific emission

A comprehensive study on the effect of pilot injection, EGR rate, IMEP and biodiesel characteristics on a CRDI diesel engine

Although many studies have concerned effect of different kind of biodiesel fuel on engine, there are no information about the comparison between different biodiesels in a comprehensive study and with consideration of pilot injection and EGR system. Therefore, the aim of this study is to have a comprehensive investigation of the effect of pilot injection timing and EGR system, as common ways to reduce engine emissions, on engine combustion, emissions and performance while using of different kind of the biodiesel. The brassica, cardoon, coffee, waste cooking oil biodiesels and standard diesel fuels were evaluated fuels. However, the results of the study depicted that different characteristics of the considered fuels had changed the engine response to variation of injection strategy and EGR application. The maximum reduction of combustion duration compare to diesel fuel (17.7%) was related to coffee biodiesel. Moreover, Coffee biodiesel has lowest pressure rise rate. On the other hand, cardoon had shortest ignition delay and highest combustion temperature. In addition, maximum retardation of combustion position was for brassica biodiesel fuel (19.07%). Although the NOx emission has decreased due to application of EGR (up to 86%) and pilot injection (up to 29.3%), high EGR rate in high IMEP has changed the combustion quality due to sewer changes in the combustion quality. In this condition, CO and THC emission increased severely. Higher viscosity and lower oxygen content of the coffee and cardoon biodiesel than diesel fuel decreased combustion quality and caused the higher THC, CO and soot emissions and lower NOx emissions than brassica and WCO biodiesel fuels in higher EGR rates and IMEPs. It can be stated that pilot injection and EGR are two parameters which are effective significantly on the engine characteristics and the adjusting of these parameters should be done properly specially according to the used fuel properties