FDI Implications of Recent European Court of Justice Decision on Corporation Tax Matters

Corporation tax rates significantly influence the location of foreign direct investment (FDI) as well as company decisions on corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. While direct taxation remains within the competence of individual EU member states, the European Court of Justice (ECJ) has faced an increasing number of corporation-tax-related cases over recent years and its judgements have significantly redrawn the European tax landscape. The present paper reviews and synthesises these ECJ decisions and analyses their implications for the FDI decisions of Multinational Corporations.

Voyages Between France and Ireland: Culture, Tourism and Sport

The voyage – the quest, the odyssey, the expedition – is one of the driving forces of civilisation. From ancient times to the present day, human beings have travelled through necessity (wars, persecutions, economic and political pressures), by vocation (religious and humanitarian) and for pleasure (tourism, culture and sport). A voyage intensifies our perception of self, leading us to define and redefine our identity in the liminal space where we are confronted with the Other. This often leads to a change of perspective in our attitudes to culture, identity and politics. The sea is an important feature of the geography of both Ireland and France, so it is perhaps unsurprising that voyages occupy such an important place in the history of both countries. This volume explores aspects of French and Irish society, past and present, through the prism of the voyage. The contributors focus on a wide range of topics, including cultural tourism, literature, gastronomy and sport, in order to trace the ebb and flow of the exchanges between these two countries and their continued influence on one anotherhttps://arrow.tudublin.ie/afisbo/1003/thumbnail.jp

Geophysical studies of basin structure along the eastern front of the Sierra Nevada, California

A seismic and gravity survey along the eastern front of the Sierra Nevada, California, between southern Owens Valley and the Garlock fault, outlines a series of basins with maximum depths ranging from 5,000 to 9,000 ft. These basins follow the front of the Sierra Nevada in a continuous chain with one interruption of about 10 miles near Little Lake. The gravity anomalies indicate that the basins are bounded by a series of high-angle faults rather than a single large fault. The seismic velocities in the basin deposits appear to correlate with the stratigraphy of the section exposed in the El Paso Mountains. A comparison of Bouguer anomalies with seismic depths indicates a density contrast of 0.35 g/cc in basins less than 3,000 ft deep, and an average but widely varying density contrast of 0.25 g/cc in basins 4,000 to 8,000 ft deep. A digital-computer program for automatic computation of basin depths from gravity anomalies was evaluated and found to be useful in this type of analysis. Changes in the depth to the Mohorovicic discontinuity cannot produce regional gradients as large as the regional gradients observed in the area of the survey. Either structure on an intermediate crustal boundary or lateral changes in crustal densities, or a combination of these, is required to explain the gravity data

Further model study of the radiation of elastic waves from a dipole source

Earthquake-generated compressional and shear waves have been used extensively in recent years for studying the mechanism at the focus? In general the procedure is to compare the radiation pattern of these waves with the theoretical pattern derived from simple sources such as singlets, dipoles, quadrupoles, etc. The importance of these investigations to our understanding of tectonic processes makes it desirable to examine the methods with a view toward placing them on a firm theoretical and experimental foundation. One approach is to use the methods of ultrasonic-model seismology to determine whether or not the radiation pattern postulated for certain sources is actually observed. The effects of various perturbations such as finite fault length and elastic heterogeneity near the focus can be conveniently examined

Two-dimensional seismic models with continuously variable velocity depth and density functions

A method for fabricating 2-dimensional ultrasonic seismic models with variable velocity and density is described. The method is justified theoretically. It is tested by comparing the experimental and theoretical dispersion of Rayleigh waves in a model of a 2-layered earth crust

Using Student-Generated UV-Induced \u3cem\u3eEscherichia coli\u3c/em\u3e Mutants in a Directed Inquiry Undergraduate Genetics Laboratory

We report a thematic sequence of directed inquiry-based labs taking students from bacterial mutagenesis and phenotypic identification of their own self-created mutant, through identification of mutated genes by biochemical testing, to verification of mutant alleles by complementation, and finally to mutant allele characterization by DNA sequence analysis. The lab utilizes UV mutagenesis with wild-type Escherichia coli and a UV-sensitive isogenic derivative optimized for undergraduate use. The labs take advantage of the simplicity of E. coli in a realistic genetic investigation using safe UV irradiation methods for creation and characterization of novel mutants. Assessment data collected over three offerings of the course suggest that the labs, which combine original investigation in a scientifically realistic intellectual environment with learned techniques and concepts, were instrumental in improving students’ learning in a number of areas. These include the development of critical thinking skills and understanding of concepts and methods. Student responses also suggest the labs were helpful in improving students’understanding of the scientific process as a rational series of experimental investigations and awareness of the interdisciplinary nature of scientific inquiry

How Popular Culture Travels, Sylvie Mikowski, Yann Philippe (eds.)

In the Introduction to their thought-provoking and thoroughly enjoyable volume How Popular Culture Travels, Mikowski and Philippe invite us on an archaeological dig through the multiple strata of complex cultural exchanges to uncover the bedrock of connections that form the essence of intercultural transfer – and, dare I say it, they have unearthed some gems… The starting point for the dig clearly illustrates the difficulty and the importance of reaching this bedrock: the origin of the song D..

Using Experimentally Calibrated Regularized Stokeslets to Assess Bacterial Flagellar Motility Near a Surface

The presence of a nearby boundary is likely to be important in the life cycle and evolution of motile flagellate bacteria. This has led many authors to employ numerical simulations to model near-surface bacterial motion and compute hydrodynamic boundary effects. A common choice has been the method of images for regularized Stokeslets (MIRS); however, the method requires discretization sizes and regularization parameters that are not specified by any theory. To determine appropriate regularization parameters for given discretization choices in MIRS, we conducted dynamically similar macroscopic experiments and fit the simulations to the data. In the experiments, we measured the torque on cylinders and helices of different wavelengths as they rotated in a viscous fluid at various distances to a boundary. We found that differences between experiments and optimized simulations were less than 5% when using surface discretizations for cylinders and centerline discretizations for helices. Having determined optimal regularization parameters, we used MIRS to simulate an idealized free-swimming bacterium constructed of a cylindrical cell body and a helical flagellum moving near a boundary. We assessed the swimming performance of many bacterial morphologies by computing swimming speed, motor rotation rate, Purcell’s propulsive efficiency, energy cost per swimming distance, and a new metabolic energy cost defined to be the energy cost per body mass per swimming distance. All five measures predicted that the optimal flagellar wavelength is eight times the helical radius independently of body size and surface proximity. Although the measures disagreed on the optimal body size, they all predicted that body size is an important factor in the energy cost of bacterial motility near and far from a surface

Pyruvate Formate Lyase and Acetate Kinase are Essential for Anaerobic Growth of \u3cem\u3eEscherichia coli\u3c/em\u3e on Xylose

During anaerobic growth of bacteria, organic intermediates of metabolism, such as pyruvate or its derivatives, serve as electron acceptors to maintain the overall redox balance. Under these conditions, the ATP needed for cell growth is derived from substrate-level phosphorylation. In Escherichia coli, conversion of glucose to pyruvate yields 2 net ATPs, while metabolism of a pentose, such as xylose, to pyruvate only yields 0.67 net ATP per xylose due to the need for one (each) ATP for xylose transport and xylulose phosphorylation. During fermentative growth, E. coli produces equimolar amounts of acetate and ethanol from two pyruvates, and these reactions generate one additional ATP from two pyruvates (one hexose equivalent) while still maintaining the overall redox balance. Conversion of xylose to acetate and ethanol increases the net ATP yield from 0.67 to 1.5 per xylose. An E. coli pfl mutant lacking pyruvate formate lyase cannot convert pyruvate to acetyl coenzyme A, the required precursor for acetate and ethanol production, and could not produce this additional ATP. E. coli pfl mutants failed to grow under anaerobic conditions in xylose minimal medium without any negative effect on their survival or aerobic growth. An ackA mutant, lacking the ability to generate ATP from acetyl phosphate, also failed to grow in xylose minimal medium under anaerobic conditions, confirming the need for the ATP produced by acetate kinase for anaerobic growth on xylose. Since arabinose transport by AraE, the low-affinity, high-capacity, arabinose/H+ symport, conserves the ATP expended in pentose transport by the ABC transporter, both pfl and ackA mutants grew anaerobically with arabinose. AraE-based xylose transport, achieved after constitutively expressing araE, also supported the growth of the pfl mutant in xylose minimal medium. These results suggest that a net ATP yield of 0.67 per pentose is only enough to provide for maintenance energy but not enough to support growth of E. coli in minimal medium. Thus, pyruvate formate lyase and acetate kinase are essential for anaerobic growth of E. coli on xylose due to energetic constraints

Spatial Structure of the Mormon Cricket Gut Microbiome and Its Predicted Contribution to Nutrition and Immune Function

The gut microbiome of insects plays an important role in their ecology and evolution, participating in nutrient acquisition, immunity, and behavior. Microbial community structure within the gut is heavily influenced by differences among gut regions in morphology and physiology, which determine the niches available for microbes to colonize. We present a high-resolution analysis of the structure of the gut microbiome in the Mormon cricket Anabrus simplex, an insect known for its periodic outbreaks in the western United States and nutrition-dependent mating system. The Mormon cricket microbiome was dominated by eleven taxa from the Lactobacillaceae, Enterobacteriaceae, and Streptococcaeae. While most of these were represented in all gut regions, there were marked differences in their relative abundance, with lactic-acid bacteria (Lactobacillaceae) more common in the foregut and midgut and enteric (Enterobacteriaceae) bacteria more common in the hindgut. Differences in community structure were driven by variation in the relative prevalence of three groups: a Lactobacillus in the foregut, Pediococcus lactic-acid bacteria in the midgut, and Pantoea agglomerans, an enteric bacterium, in the hindgut. These taxa have been shown to have beneficial effects on their hosts in insects and other animals by improving nutrition, increasing resistance to pathogens, and modulating social behavior. Using PICRUSt to predict gene content from our 16S rRNA sequences, we found enzymes that participate in carbohydrate metabolism and pathogen defense in other orthopterans. These were predominately represented in the hindgut and midgut, the most important sites for nutrition and pathogen defense. Phylogenetic analysis of 16S rRNA sequences from cultured isolates indicated low levels of divergence from sequences derived from plants and other insects, suggesting that these bacteria are likely to be exchanged between Mormon crickets and the environment. Our study shows strong spatial variation in microbiome community structure, which influences predicted gene content and thus the potential of the microbiome to influence host function