Trata-se de dissertação para obtenção do grau de Mestre perante a Faculdade de Direito da Universidade de São Paulo, versando sobre as regras de Subcapitalização no Direito Tributário Brasileiro. O tema central da dissertação pode ser resumido da seguinte maneira: o que são regras de subcapitalização e qual a real necessidade de estabelecimento destas no direito tributário brasileiro, tendo em vista o ordenamento jurídico precedente à publicação das referidas normas. Iniciaremos o trabalho com a contextualização histórica do tema e, na sequência, analisaremos a legislação relativa à subcapitalização no direito comparado, estudando os princípios norteadores, bem como as regras específicas existentes nas diversas localidades estudadas. Estudaremos ainda o sistema jurídico tributário precedente às regras de subcapitalização, bem como analisaremos caso julgado pelo Conselho de Contribuintes, conhecido como caso Colgate/Kolynos, considerado o principal julgado a respeito da matéria no Brasil e que, certamente, foi relevante para o estabelecimento das regras de subcapitalização no Brasil. Por fim, após descrição minuciosa da legislação estabelecida no Brasil, será realizada avaliação crítica, tendo em vista as imperfeições e lacunas verificadas na norma introdutora das regras de subcapitalização no Brasil, a saber, Medida Provisória nº 472/09, de 16 de dezembro de 2009, posteriormente convertida na Lei nº 12.249, de 14 de junho de 2010, bem como da regulamentação expedida pela Receita Federal do Brasil por meio da Instrução Normativa nº 1.154, de 12 de maio de 2011. / This is a dissertation to obtain the Master before the University of São Paulo Law School, about thin capitalization rules in Brazilian Tax Law. The central theme of the dissertation can be summarized this way: what are thin capitalization rules and what is the real need of establishing such rules in the Brazilian Tax Law, considering the previous existing law system. The starting point will be the historical contextualization of the theme and, in the sequel, we will analyze the thin capitalization rules in the foreign law, studying the guiding principles and the existing specific rules in the places studied. It will be studied the legal tax system precedent to thin capitalization rules, as well as it will be analyzed a case judged by Council Taxpayers, known as case Colgate/Kolynos, considered the principal case related to the subject in Brazil which, certainly, was relevant for establishing the thin capitalization rules in Brazil. Lastly, it will also be analyzed in details the rules established in Brazil, including a critical evaluation, in the view of imperfections and gaps verified in the rules which established thin capitalization rules in Brazil, namely, Provisory Measure nº 472, 2009 December 16th, converted into Law nº 12.249, 2010 June 14th, and regulation issued by Federal Tax Authorities, Normative Instruction nº 1.154, 2011 May 12

Abstract The role of relationship banking has been the subject of intensive discussion in recent years. A large body of the literature has examined the benefits and costs related to lender-borrower relationships in small business finance. Despite the numerous studies conducted in both market-based and bank-based economies, the specific sources of the determinants of the value of relationship lending are ambiguous. However, many research results imply that a close and long-term relationship with the bank is desirable for small businesses. In this study, we investigate the sources of value in Finnish lender-borrower relationships in small business finance. We conduct three separate empirical studies that cover the following aspects of relationship banking: determinants of the value of the bank-firm relationship, collateral requirements and borrower risk, and the comparison of the different characteristics of relationship banking in bank financing and non-bank financing. We use unique and detailed credit file data from two sources, bank data from one of the largest banks in Finland and non-bank data from a large financial institution owned by the Finnish state. Both datasets cover the period 1995 to 2001. Our main findings are the following. First, duration and scope are important characteristics in determining the sources of value in the bank-firm relationship. We find that a longer relationship tends to lower the cost of the credit, and that wider scope tends to decrease the collateral requirements significantly. Second, a long-lasting bank-firm relationship is beneficial, especially to high-risk firms. As the relationship matures, loan premiums for high-risk firms decrease at a higher rate than for low-risk firms. Third, low-risk borrowers put up more collateral than high-risk borrowers, which implies the existence of a signaling effect. According to the signaling theory, low-risk firms are willing to pledge more collateral than high-risk firms. Fourth, when comparing bank and non-bank credit files, we find that bank-firm characteristics are not fully transferable to the relationship between a non-bank and a firm.

This thesis examines the motives behind museum loan and exchange policies and how loans can act as a new avenue for protecting and preserving paintings. When borrowed artworks are transported from one museum to another, there are many variables that come into play and careful planning is necessary for the safety of the object. Specific case studies of several well-known and respected museums that engage in and encourage loans will explore the complex nature of lending policies, their effect on the condition of artworks and their significance and impact on the museum world. This thesis culminates in an analysis of the loan fitness and possibility for transport of Joachim Beich’s Untitled, a painting in the Scripps College collection.

[pt] Este estudo tem por objetivo analisar o uso de neologismos da área da informática por grupos sociais que caracterizamos como comunidades de prática, tomando como caso exemplar as formas verbais printar e bugar, derivadas do inglês print e bug. Defendendo a hipótese de que os empréstimos são fenômenos linguísticos naturais e inevitáveis, tratamos a questão dos estrangeirismos, primeiramente, sob o ponto de vista histórico, e, posteriormente, como fenômeno gramatical exemplificado por essas novas formas verbais. Finalmente, a questão é considerada do ponto de vista social, buscando-se mostrar a participação das comunidades de prática na consolidação e extensão de significado das importações lexicais. / [en] This study aims to examine the use of neologisms loaned from the area of information technology by social groups characterized as communities of practice, taking as an exemplary case the verb forms printar and bugar, derived from the English words print and bug. Defending the hypothesis that loans are natural and inevitable linguistic phenomena, we treat the appropriation of foreign words initially from the point of view of history, and later as a grammatical phenomenon, exemplified by such new verb forms. Finally, the issue is considered from the social point of view, trying to show the involvement of communities of practice in the consolidation and extension of lexical meaning of loans.

Thesis discusses a current topic of decision making on most effective strategy of utilization of real estates. The aim of this diploma thesis is to compare the economic advantage of model-based strategies for the utilization of real estates, to identify variants of acquisition, lease, alternatively their combinations, to evaluate these variants through income, expenditures and equity, to analyze and subsequently to find the most financially effective variant of housing. In the theoretical part, there is analyzed the conceptual apparatus, but also the relevant theoretical and legislative framework. Further, the methodology of the analysis is stated, where is chosen equity as the decisive criterion. Using this criterion, the best option of real estate utilization is detected from four variants of real estate utilization from the financial point of view, while the cash flow development is monitored in the practical part of the diploma thesis. At the end of the thesis the advantages, disadvantages and risks of strategies are formulated and recommendations are made.

Botswana has adopted policies in its construction industry aimed at developing its citizen contractors to a standard comparable to any other. Towards this end, it has instituted a number of interventions one of which is to provide these contractors with an advance loan to enable them mobilize on site. This facility greatly enhances their chances of success. This study is an evaluation of this scheme and provides a valuable feedback on the scheme's effectiveness, its shortcomings as well as offering some suggestions as to how its administration can be improved. This it does through a critical analysis of the performance of beneficiaries over a six-year period, identifies reasons for their failure and tries to address concerns of the key players in the application of the scheme. The major findings are that the scheme has not been as successful as expected. The biggest problem seems to be the diversion of loan funds from their intended purpose. Rigorous sustained training of contractors and monitoring of their progress in skills attainment is the recommended solution. The Government's intervention should also target other role players in the industry for support including emerging suppliers and plant leasing companies, to break down existing monopolistic structures. / Dissertation (MSc (Project Management))--University of Pretoria, 2004. / Construction Economics / unrestricted

The decision making between leasing and loan. Impact of taxation on deciding - income tax and value added tax. General characteristic of the leasing and the loan. The legislative and tax definition of leasing and bank loan. Main advantages and disadvantages of financing through leasing or loan. Discounted costs, net leasing advantage. A practical example of a decision on the financing of passenger car and machinery.

The aim of this thesis is to describe the course of corporate financing. The thesis is divided into two main parts - the theoretical part and practical part. The theoretical section describes the financial statements, financial analysis and the individual components of the loan proposal. In the practical part is given financial analysis based on data from the client's annual reports. Here is a loan proposal, drawn up on the basis of the conclusions of financial analysis, which provides appropriate funding attending various financial risks, which the client must undergo as an entrepreneur.

Graduate work uses decisions methods of management for decisions of individual options for financing the fleet. The result is a simple formula that can be used by small businesses to choice of financing a vehicle intended for business. Evaluation of options, using the real calculations are: financial leasing, operational leasing and loan.

The object of the Diploma thesis is the analysis of mortgage loan parameters on the Czech market, their subsequent comparison and evaluation of the most advantage variants of housing financing. The thesis also deals with the conditions of mortgage loans providing. The comprarison is made on the most significant providers of mortgage loans, who have controlled in the long term 90 % of the market. Within the Diploma thesis is compared five mortgage products offered by Hypoteční banka, a. s., Česká spořitelna, a. s., Komerční banka, a. s., Raiffeisenbank, a. s. a UniCredit Bank, a. s. For analysis was compiled form that includes parameters, basic interest rates and charges for mortgage loans. The parameters are obtained from external and internal bank materials and structured interviews with mortgage specialists. The evaluation of products is used to assess the flexibility, complexity and costs of particular product. I find Hypotéka České spořitelny to be the most comprehensive and flexible product. The lowest interest rates offer Komerční bank with Hypoteční úvěr Plus and UniCredit Bank with Hypoteční úvěr Individual, the highest interest rates has Hypoteční banka with Hypoteční úvěr do 100 %. Hypotéka Klasik offered by Raiffeisenbank is the charges most gentle, the most demanding on charges is Hypoteční úvěr do 100 % offered by Hypoteční banka. The most advantageous mortgage loan can't be unequivocally evaluated. It depends on whether the client prefers the lowest repayment or the most comprehensive and flexible product by which is possible, for example, pay the extraordinary instalment.