The tax system and the financial crisis

This paper investigates the effects of the tax system on the economic factors that triggered the financial crisis. We examine three cases in which the tax regime interacted with these factors, reinforcing them. First, we focus on the taxation of residential building: while the importance of capital gains taxes is disputed, the deductibility of mortgage interest may have contributed to the financial crisis by creating some of the raw materials for the securitization industry. Second, a narrow perspective on the tax treatment, together with specific provisions, may have fostered performance-based remuneration of managers, resulting in overemphasis of short-term profitability and incentive to excessive risk-taking. Third, the securitization process, which played a key role in the outbreak of the financial crisis, was accompanied by opportunities for tax arbitrage and reduction of the overall tax wedge paid by investors, through offset of incomes that are ordinarily taxed at different rates; a de facto exemption of CDS premiums received by non-residents supplemented the tax arbitrage.taxation, financial crisis, housing market, stock options, securitization, credit default swaps

Quantitative analysis of CT-perfusion parameters in the evaluation of brain gliomas and metastases

<p>Abstract</p> <p>Background</p> <p>The paper reports a quantitative analysis of the perfusion maps of 22 patients, affected by gliomas or by metastasis, with the aim of characterizing the malignant tissue with respect to the normal tissue. The gold standard was obtained by histological exam or nuclear medicine techniques. The perfusion scan provided 11 parametric maps, including Cerebral Blood Volume (CBV), Cerebral Blood Flow (CBF), Average Perfusion (P_mean) and Permeability-surface area product (PS).</p> <p>Methods</p> <p>The perfusion scans were performed after the injection of 40 ml of non-ionic contrast agent, at an injection rate of 8 ml/s, and a 40 s cine scan with 1 s interval was acquired. An expert radiologist outlined the region of interest (ROI) on the unenhanced CT scan, by using a home-made routine. The mean values with their standard deviations inside the outlined ROIs and the contralateral ROIs were calculated on each map. Statistical analyses were used to investigate significant differences between diseased and normal regions. Receiving Operating Characteristic (ROC) curves were also generated.</p> <p>Results</p> <p>Tumors are characterized by higher values of all the perfusion parameters, but after the statistical analysis, only the <it>PS</it>, <it>Pat</it>_{<it>Rsq </it>}(Patlak Rsquare) and <it>T</it>_{<it>peak </it>}(Time to Peak) resulted significant. ROC curves, confirmed both <it>Pat</it>_{<it>Rsq </it>}and <it>PS </it>as equally reliable metrics for discriminating between malignant and normal tissues, with areas under curves (AUCs) of 0.82 and 0.81, respectively.</p> <p>Conclusion</p> <p>CT perfusion is a useful and non invasive technique for evaluating brain neoplasms. Malignant and normal tissues can be accurately differentiated using perfusion map, with the aim of performing tumor diagnosis and grading, and follow-up analysis.</p

FOOT: a new experiment to measure nuclear fragmentation at intermediate energies

Summary: Charged particle therapy exploits proton or 12C beams to treat deep-seated solid tumors. Due to the advantageous characteristics of charged particles energy deposition in matter, the maximum of the dose is released to the tumor at the end of the beam range, in the Bragg peak region. However, the beam nuclear interactions with the patient tissues induces fragmentation both of projectile and target nuclei and needs to be carefully taken into account. In proton treatments, target fragmentation produces low energy, short range fragments along all the beam range, which deposit a non negligible dose in the entry channel. In 12C treatments the main concern is represented by long range fragments due to beam fragmentation that release their dose in the healthy tissues beyond the tumor. The FOOT experiment (FragmentatiOn Of Target) of INFN is designed to study these processes, in order to improve the nuclear fragmentation description in next generation Treatment Planning Systems and the treatment plans quality. Target (16O and 12C nuclei) fragmentation induced by –proton beams at therapeutic energies will be studied via an inverse kinematic approach, where 16O and 12C therapeutic beams impinge on graphite and hydrocarbon targets to provide the nuclear fragmentation cross section on hydrogen. Projectile fragmentation of 16O and 12C beams will be explored as well. The FOOT detector includes a magnetic spectrometer for the fragments momentum measurement, a plastic scintillator for ΔE and time of flight measurements and a crystal calorimeter to measure the fragments kinetic energy. These measurements will be combined in order to make an accurate fragment charge and isotopic identification. Keywords: Hadrontherapy, Nuclear fragmentation cross sections, Tracking detectors, Scintillating detector

Il fenomeno crypto-asset. Aspetti regolamentari, civilistici e fiscali

Il fenomeno delle cripto-valute o, più, correttamente, cripto-attività, emerso da oltre un decennio, ha assunto ormai dimensioni di tutto rilievo. Ciononostante, sono ancora poco esplorate le sfide di inquadramento giuridico e fiscale che ne derivano. A livello europeo, è in corso di discussione una proposta di Regolamento che potrebbe introdurre una disciplina uniforme per l’emissione di cripto-attività e la prestazione di servizi che le hanno ad oggetto. Sebbene non chiarisca del tutto il rapporto tra cripto-attività e altri prodotti finanziari già regolamentati (come gli strumenti finanziari), la proposta potrebbe avere un impatto significativo su molti ordinamenti nazionali, compreso quello italiano, nei quali non esiste una disciplina ad hoc e vi sono diversi, e spesso contrastanti, orientamenti dottrinali e giurisprudenziali sulla natura giuridica del fenomeno. In questo quadro normativo in rapida evoluzione, anche in campo fiscale i singoli paesi non hanno ancora adottato, salvo eccezioni, normative specifiche, ma si sono limitati a fornire orientamenti generali o indicazioni puntuali in risposta a richieste degli operatori. Nell’Unione Europea, alcune linee comuni sul trattamento Iva delle operazioni in crypto-asset sono emerse dalla storica decisione della Corte di Giustizia sul caso Hedqvist, cui i singoli Stati membri si sono adeguati. In Italia, le risposte sinora fornite dall’Amministrazione finanziaria disegnano nei fatti un quadro non troppo penalizzante, che esclude gli oneri fiscali e di compliance almeno per i piccoli investitori. Tuttavia, le indicazioni di prassi risultano frammentarie e non sempre coerenti tra loro o in linea con la seppure non univoca giurisprudenza civile e amministrativa e con le poche indicazioni normative della disciplina antiriciclaggio. Inoltre, esse non sembrano tenere il passo con il ritmo incessante di evoluzione del fenomeno e non forniscono risposte chiare sul regime tributario da riservare ai sempre più numerosi operatori che ruotano intorno al mondo dei crypto-asset, né quello, non meno rilevante, di come applicare obblighi fiscali agli smart contract, tra cui quelli adottati nell’ambito della cosiddetta Decentralized Finance – DeFi. A fronte della peculiarità delle tecnologie e dei modelli operativi sottostanti a questi nuovi prodotti, sembra sempre più necessaria la definizione di un quadro normativo ad hoc sulle cripto-attività, anche in materia fiscale, a livello europeo e nazionale. Al riguardo, sul piano fiscale utili spunti di riferimento potranno essere le prime indicazioni fornite dall’OCSE nell’ottobre 2020 e le scelte già adottate nelle normative di altri paesi

The tax system and the financial crisis

This paper investigates the effects of the tax system on the economic factors that triggered the financial crisis. We examine three cases in which the tax regime interacted with these factors, reinforcing them. First, we focus on the taxation of residential building: while the importance of capital gains taxes is disputed, the deductibility of mortgage interest may have contributed to the financial crisis by creating some of the raw materials for the securitization industry. Second, a narrow perspective on the tax treatment, together with specific provisions, may have fostered performance-based remuneration of managers, resulting in overemphasis of short-term profitability and incentive to excessive risk-taking. Third, the securitization process, which played a key role in the outbreak of the financial crisis, was accompanied by opportunities for tax arbitrage and reduction of the overall tax wedge paid by investors, through offset of incomes that are ordinarily taxed at different rates; a de facto exemption of CDS premiums received by non-residents supplemented the tax arbitrage

The tax system and the financial crisis

This paper investigates the effects of the tax system on the economic factors that triggered the financial crisis. We examine three cases in which the tax regime interacted with these factors, reinforcing them. First, we focus on the taxation of residential building: while the importance of capital gains taxes is disputed, the deductibility of mortgage interest may have contributed to the financial crisis by creating some of the raw materials for the securitization industry. Second, a narrow perspective on the tax treatment, together with specific provisions, may have fostered performance-based remuneration of managers, resulting in overemphasis of short-term profitability and incentive to excessive risk-taking. Third, the securitization process, which played a key role in the outbreak of the financial crisis, was accompanied by opportunities for tax arbitrage and reduction of the overall tax wedge paid by investors, through offset of incomes that are ordinarily taxed at different rates; a de facto exemption of CDS premiums received by non-residents supplemented the tax arbitrage.taxation, financial crisis, incentives, housing, bonuses

Taxation and the financial crisis

The financial crisis has opened up a global debate on the taxation of the financial sector. A number of international policy initiatives, most notably by the G20, have called for major changes in the tax treatment of financial institutions and transactions as well as individuals working in the financial sector. This book examines how tax policies contributed to the financial crisis and whether taxation can play a role in the reform efforts under way to establish a sounder and safer financial system. The book looks at the pros and cons of various tax initiatives, including limiting the tax advantages to debt financing, special taxes on the financial sector and financial transactions taxes.Copyright 2012 Oxford University Press. Chapter 3 & 5 copyright 2012 European Union. Chapter 9 copyright 2009 Bank for International Settlements. This publication is available as an open access version through OUP, as part of the OAPEN-UK project. Re-use of this article is permitted in accordance with the Terms and Conditions set out at http://creativecommons.org/licenses/by-nc-nd/3.0

The FOOT (Fragmentation Of Target) Experiment

International audienceParticle therapy uses protons or 12C beams for the treatment of deep-seated solid tumors. Due to the features of the energy deposition of charged particles in matter, a limited amount of dose is released to the healthy tissue in the beam entrance region, while the maximum of the dose is released to the tumor at the end of the beam range, in the Bragg peak region. However nuclear interactions between beam and patient tissues induce fragmentation both of projectile and target. This has to be carefully taken into account since different ions have different effectiveness in producing a biological damage. In 12C treatments the main concern are long range forward emitted secondary ions produced in projectile fragmentation that release dose in the healthy tissue after the tumor. Instead, in a proton treatment, the target fragmentation produces low energy, short range fragments along all the beam range. The FOOT experiment (FragmentatiOn Of Target) is designed to study these processes. Target nuclei (16O,12C) fragmentation induced by 150-250 MeV proton beam will be studied by means of the inverse kinematic approach. 16O,12C therapeutic beams, at the quoted kinetic energy per nucleon, collide on graphite and hydrocarbons target. The cross section on Hydrogen can be then extracted by subtraction. This configuration explores also the projectile fragmentation of these 16O,12C beams, or other ions of therapeutic interest, such as 4He for instance. The detector includes a magnetic spectrometer based on silicon pixel and strip detectors, a scintillating crystal calorimeter able to stop the heavier produced fragments, and a ∆E detector, with TOF capability, to achieve the needed energy resolution and particle identification. In addition to the electronic apparatus, an alternative setup based on the concept of the “Emulsion Cloud Chamber”, coupled with the interaction region of the electronic FOOT setup, will provide the measurement of lighter charged fragments: protons, deuterons, tritons and Helium nuclei. The FOOT data taking is foreseen in the available experimental rooms existing in the presently operational charged particle therapy facilities in Europe, and possibly at GSI. An initial phase with the emulsion setup will start in early 2018, while the complete electronic detector will take data starting in 2019. In this work a general description of the FOOT experiment and of its expected performances is presented

The FOOT FragmentatiOn Of Target Experiment

International audienceIn proton-therapy clinical practice a constant RBE equal to 1.1 is adopted, regardless of the demonstrated RBE variations, which depends on physical and biological parameters. Among other mechanisms, nuclear interactions might influence the proton-RBE due to secondary heavier particles produced by target fragmentation that can significantly contribute to the total dose: an un-wanted and undetermined increase of normal tissues complications probability may occur. The FOOT experiment is designed to study these processes. Target ($^{16}$O,$^{12}$C) fragmentation induced by 150 − 250 M eV proton beam will be studied via inverse kinematic approach, where $^{16}$O and $^{12}$C therapeutic beams, with the same kinetic energy per nucleon of the proton, collide on graphite and hydrocarbons target to provide the cross section on Hydrogen (to explore also the projectile fragmentation). The detector design, the performances and expected resolution results obtained form Monte Carlo study, based on the FLUKA code will be presented