Formulary Apportionment and International Tax Rules

Any proposal to adopt unitary taxation (UT) of multinationals has to contend with whether such taxation is compatible with existing international tax rules, and, in particular, with the bilateral tax treaty network. Indeed, some researchers have argued that the separate accounting (SA) method and the arm’s length standard (ALS), introduced in the early twentieth century, are so embodied in the treaties that they form part of customary international law, and are binding even in the absence of a treaty. We disagree, because the unitary approach is just as widely embodied in most of the current international tax treaties, and, where there are no treaties, national laws allow for a unitary approach to taxation. In this chapter we will argue that UT can be compatible with most existing tax treaties, and that developing countries, in particular, can implement it in most cases with or without a tax treaty and in accordance with their domestic laws

Red rust disease occurring in some fruits species in Cameroon

The knowledge of the red rust disease remains limited in Cameroon, with a view to developing a control method. This work consisted in studying red rust on some fruit species such as Annona muricata (soursop), Dacryodes edulis (safou), Psidium guajava (guava) and Theobroma cacao (cocoa). Diseased leaves were collected in the field in the Maham site, in west region of Cameroon.The symptomatology of disease (colour, number and diameter of lesions) was studied. Coefficient of variation ( %) was calculated. The incidence and severity of the disease was assessed in the different orchards surveyed. The measurement of the different structures of the thallus (length, width of sporangia and sporangiophores) was carried out using a microscope with a micrometer. The disease is characterized by circular orange to orange-brown spots on the upper surfaces and rarely on the lower surface. Number of lesions, varied from 245–510 respectively with D. edulis and T cacao. Lesion diameters varied from 0.1−1 cm, 0.1−7 cm, 0.1−1.5 cm in safou (African pear), guava and soursop respectively. The length and width of sporangiophores varied from 280.5−714×10.2−25.5 µm for A. muricata, 408−612×15.3−25.5 µm for Dacryodes edulis, 433.3−663×15.3−20.4 µm for P. guajava and 484.5−612×20.4−35.7 µm for T. cacao. The number of sporangiophores varied from 1 to 11 at the maximum threshold. But, number of sporangia was the same in the four species, 1−9. The pathogenicity test was negative. The data measurements show that the specie observed is Cephaleurus virescens which is a parasitic alga. The data obtained are a basis for the development of an integrated control strategy against this emerging diseas

Changes in quality of life and disease-related symptoms in patients with polycythemia vera receiving ruxolitinib or standard therapy

Objectives Polycythemia vera (PV)-related symptoms may not be adequately controlled with conventional therapy. This current analysis of the RESPONSE trial evaluated the effects of ruxolitinib compared with standard therapy on quality of life (QoL) and symptoms in patients with PV who were hydroxyurea resistant/intolerant. Methods In the previously reported primary analysis, ruxolitinib achieved the primary composite endpoint of hematocrit control and ≥35% reduction in spleen volume at Week 32. The current analysis evaluated patient-reported outcomes using the European Organisation for Research and Treatment of Cancer Quality of Life Questionnaire-Core 30 (EORTC QLQ-C30), the Myeloproliferative Neoplasm Symptom Assessment Form (MPN-SAF), the Pruritus Symptom Impact Scale (PSIS), and the Patient Global Impression of Change (PGIC). Results Compared with standard therapy, ruxolitinib was associated with greater improvements in global health status/QoL, functional subscales, and individual symptom scores of the EORTC QLQ-C30. At Week 32, more patients in the ruxolitinib arm (44%) achieved a ≥10-point improvement in global health status/QoL vs. standard therapy (9%). Improvements in MPN-SAF symptom scores were consistent with improvements in EORTC QLQ-C30, PSIS, and PGIC scores. Conclusions Ruxolitinib provides clinically relevant improvements in QoL and ameliorates symptom burden in patients with PV who are hydroxyurea resistant/intolerant

Determination of work of adhesion of biological cell under AFM bead indentation

Hertz contact theory has been widely used for the determination of cell elasticity based on AFM indentation experiments. In light of the adhesive contact between AFM tip and cell, this study applied Johnson–Kendall–Roberts (JKR) model to fit the indentation force–displacement (F–D) curves reported previously. A MIN6 cell has been modeled as first a sphere and then a flattened cell with different thicknesses. The results have shown that both basic JKR model and “generalized” JKR model can best describe the unloading force–displacement behaviors of the indentation curves. The Young׳s modulus of the cell and the work of adhesion of the cell–indenter interface are obtained. In comparison to the Hertzian contact model, the JKR model provides obviously better fitting to the experimental results, indicating that the adhesion is significant in the cell interaction

Effect of Arbuscular Mycorrhizal Fungi (AMF) on development of brown spot disease of corn (Zea mays L.) due to Physoderma maydis in Far North Cameroon

Corn (Zea mays L.) is affected by a number of diseases that lead to yield loss. One of them is brown spot caused by the soil-borne fungus Physoderma maydis. In this study, the bioprotective potential of arbuscular mycorrhizal fungi (AMF) against this disease was carried out in the nursery and field. In a completely randomized block design, two maize varieties namely CMS9015 (V1) and CMS8704 (V2) were used. In the field, two mycorrhizal treatments (V1AMF, V2AMF) and two controls (CV1, CV2) were developed. In the nursery, the treatments consisted of sterilized and mycorrhized soil with disease inoculation (AMF+DI+SS:V1,V2), sterilized soil without mycorrhization with disease inoculation (DI+SS:V1,V2) and non-sterilized soil (NSS:V1,V2).  Disease incidence and severity, plant height and leaf area, root density, root colonization, nitrogen and phosphorus levels were assessed. In the field, the root colonization by the fungus was 63% as compared to 33% for the mycorrhized plants and the controls. Disease incidence and severity were reduced by 33.7% and 35%, respectively, in the mycorrhized plots in the field. The highest levels of phosphorus (0.74 mg g-1) and nitrogen (9.2 mg g-1) were obtained in the mycorrhized field treatments. In the nursery, disease incidence and severity were 0% in pots containing sterilized soil with or without mycorrhizal fungi. In the nursery, the phosphorus level of 1.07 mg g-1 was recorded in the mycorrhizal treatments and the nitrogen level of 7 mg g-1 was recorded in the leaves of the pots on unsterilized soil. This study provides that AMF can be used for the control of P. maydis in corn. &nbsp

Macrocytosis may be associated with mortality in chronic hemodialysis patients: a prospective study

<p>Abstract</p> <p>Background</p> <p>Macrocytosis occurs in chronic hemodialysis (CHD) patients; however, its significance is unknown. The purpose of this study was to establish the prevalence and distribution of macrocytosis, to identify its clinical associations and to determine if macrocytosis is associated with mortality in stable, chronic hemodialysis patients.</p> <p>Methods</p> <p>We conducted a single-centre prospective cohort study of 150 stable, adult CHD patients followed for nine months. Macrocytosis was defined as a mean corpuscular volume (MCV) > 97 fl. We analyzed MCV as a continuous variable, in tertiles and using a cutoff point of 102 fl.</p> <p>Results</p> <p>The mean MCV was 99.1 ± 6.4 fl, (range 66-120 fl). MCV was normally distributed. 92 (61%) of patients had an MCV > 97 fl and 45 (30%) > 102 fl. Patients were not B12 or folate deficient in those with available data and three patients with an MCV > 102 fl had hypothyroidism. In a logistic regression analysis, an MCV > 102 fl was associated with a higher Charlson-Age Comorbidity Index (CACI) and higher ratios of darbepoetin alfa to hemoglobin (Hb), [(weekly darbepoetin alfa dose in micrograms per kg body weight / Hb in g/L)*1000]. There were 23 deaths at nine months in this study. Unadjusted MCV > 102 fl was associated with mortality (HR 3.24, 95% CI 1.42-7.39, P = 0.005). Adjusting for the CACI, an MCV > 102 fl was still associated with mortality (HR 2.47, 95% CI 1.07-5.71, P = 0.035).</p> <p>Conclusions</p> <p>Macrocytosis may be associated with mortality in stable, chronic hemodialysis patients. Future studies will need to be conducted to confirm this finding.</p

unilateral lumbar interbody fusion (ULIF)

 Abstract: Results and clinical outcome of a prospective multicenter clinical study involving 100 patients undergoing a lumbar interbody fusion procedure using an unilateral approach to the spine to introduce a new surgical technique as a viable and less invasive alternative to standard posterior (PLIF) or transforaminal (TLIF) lumbar interbody fusion techniques: For certain indications clinical data show that unilateral lumbar interbody fusion (ULIF) offers the surgeon a considerable time advantage compared to standard lumbar interbody fusion techniques

Value Creation Process in the Retail Grocery Chain

Introduction: The retail market in the 21st century will be determined on how quickly and efficiently the retailer can respond to shifts in consumer demands. Due to the physical environment of the store (store value) and the interaction with the consumer (shopping trip value), the local retail store has the advantage of generating this tangible and intangible information. It is then of importance that this information will be transferred towards the retailer, who has the opportunity to use this information and generate it into outputs that can be used as negoitables; this value creation process is an unique success indicator for creating a value network within retail supply chain. Purpose: The aim of this research is to present an understanding on the value creation process in the grocery retail chain. Methodology: Having an inductive nature, this thesis tried to bring a new understanding on value creation in grocery retail business, by using hermeneutics as a methodology approach. For empirical study, the qualitative approach was used. Data was collected through open-ended interviews with representatives in grocery retail chains. Conclusion: The main players in the value network were determined in a grocery retail chain as retailer, local retail store and other stores in the chain; and the suppliers. An intensive value exchange between the retail store and the retailer was found and following that, it was concluded that the retailer converts the value input from the local retail store into tangible and intangible value outputs towards suppliers. Combining the conclusions, the research defines that a value network is existing, but on a very low level. But more to the point, the study shows the importance of value creation by the retail chain, and that creating the possibility to share information about products, in-store experience, consumer knowledge, and consumer requirements is one of the biggest advantage the grocery retail chain has to develop this value network further.