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This paper addresses a principle in international taxation that has long been a subject of controversy in many countries regarding the countering of abusive maneuverings in tax matters and had engendered debates amongst academic scholars concerning its predictibility. This anti-abuse principle, doctrine or clause in international tax matters had over the years received many names according to variant applied in each country. It is mentioned sometimes or refer to in many jurisdictions as: the principle of economic reality, the doctrine of economic substance, theory of valid economic motives, the principle of substance over form, abuse of the law, theory of the new realism etc. However, inspite of its variation in countries, it is internationally known as the ‘’General Anti-Avoidance Rule’’ (or GAAR), generally covering abusive arrangements, and it is distinguished from the SAAR (‘’Specific Anti-Avoidance Rule’’), insofar as these latter rule apply to specific status in dealing with specific tax issues. The long time perspective regarding the principle that is expounded in this discussion paper contain some of the most relevant and important contexts in international tax law. It is interesting that this paper seeks to catapult vis-à-vis the GAARs along side the rule of law regarding its conformity.

<p>A fundamental problem in political philosophy is how the freedom and equality of persons can be reconciled with the authority of social morality or law. The Kantian solution is to hold that the exercise of authority can be legitimate if and only if it is freely endorsed by the subjects of its exercise; thereby allowing persons to act as both subject and legislator. However, the fact of reasonable pluralism makes this approach problematic. A recent attempt to solve this conflict between authority and the free and equal idea, while also accounting for the fact of reasonable pluralism, is the theory of public reason liberalism developed by Gerald Gaus. The aim of this thesis is to give a critical evaluation of how successful Gaus is in solving this fundamental problem, while also situating public reason liberalism within the larger debate. The first chapter gives an overview of Gaus's theory and introduces some preliminary worries about the possibility of successfully converging on a workable set of socio-moral rules under public reason liberalism. Chapter two goes further, developing an internal critique of Gaussean public reason liberalism, and showing how this critique could play out using real-world examples. Chapter three explores alternative approaches to realizing the free and equal ideal in an attempt to situate Gaus's theory within the larger debate; finally concluding that Gaussean public reason liberalism is deeply problematic, both on a theoretical and a practical level, yet still offers important insights into the relationship between social-morality and the freedom and equality of persons.</p> / Master of Philosophy (MA)

While many debates about sexual morality seem to be dominated by conservative, right wing Protestants, there are differing worldviews within Protestantism as there are in the larger American culture. In Protestantism, disparate beliefs about sexual morality have caused division between groups. Concurrently, these differing perspectives have bled into the larger discourse about sexual morality in the United States. Each group has spokespeople who attempt to validate what individuals should believe about issues like the family, sexuality, and how Protestants, and Americans in general, should think and act regarding these issues. Prior research provided a limited analysis about the views and conversations of these spokespeople and their arguments to validate their positions on sexual morality issues. To better understand how Protestants attempt to validate their beliefs, I focus on what liberals and conservatives say about sexual morality issues. In particular, what do those in influential positions (i.e., authors and pastors) tell others? To answer this question, I conduct a content analysis of 30 Protestant sex advice manuals and 20 in-depth pastoral interviews. The results indicate not only the differences and similarities of beliefs, but also that many spokespeople use various forms of validation besides, or in addition to, biblical texts. The influential are influenced greatly by their own personal biases and views of gender, maybe even more than their particular religious beliefs. Future research should explore whether there is a definitive correlation between spokespersons' messages and listeners' adherence. / Sociology

What do we owe to our loved ones? What is the status of these requirements? How do we reconcile them with other requirements? Are we allowed to buy our child an expensive car when that money could save countless strangers overseas? What exactly does morality demand of us? / My thesis defends an account of partiality justified in terms of relationships. I develop the view that relationships are inextricably linked to wellbeing, and I defend the idea that morality must be concerned with our wellbeing. I try to make sense of this account of partiality with the idea that morality carries a requirement of impartiality. If wellbeing is an important part of morally right actions, and if acting in accordance with reasons of partiality (qua relationships) sometimes promotes wellbeing better than impartiality, then some reasons of partiality lead to morally right actions. Minimally, I argue that for why a strictly impartial (or, on the other extreme, a strictly partial) theory does not work. Both reasons (of partiality and impartiality) must be taken into account and carefully calibrated. More ambitiously, I argue for why partiality deserves its own place at the table in normative ethical theorizing. This is not to say that partiality always leads to right action, rather the suggestion is that there are some forms of partiality (found within relationships) which morality requires. / Thesis / Candidate in Philosophy / Some forms of partiality seem clearly wrong, like racial bias or nepotism; in such cases, it is better to consider our reasons to be impartial, which seem to lead to more fairness or equality. Still, there seem to be other forms of partiality which are clearly right, like the love and care a parent has for their child; in these cases, considering our reasons to be impartial seem like (to quote Bernard Williams), “one thought too many.” This thesis tries fit reasons of partiality and reasons of impartiality together, and argues for a view of (moral) partiality grounded in relationships.

Deliberate firesetting is a dangerous behavior that is associated with considerable costs annually. It has been estimated that young people under the age of 18 are responsible for a large proportion of all firesetting incidents. Moreover, firesetting has been linked to serious antisocial and aggressive behaviors and behavioral difficulties among juveniles and has been found to predict later delinquency, which makes this an important area to study. Some previous studies have found support for the importance of factors akin to self-control, e.g., impulsivity, for juvenile firesetting. This study applied an aspect of situational action theory (SAT), where self-control is viewed as part of crime propensity, but of lesser importance than morality, to the study of juvenile firesetting for the first time. Analyzing self-report data from two waves of the longitudinal Malmö Individual and Neighbourhood Development Study (MINDS), this study examines a key proposition of situational action theory, namely that morality is more important than self-control and that self-control is relevant in the explanation of crime (firesetting) only for individuals with lower levels of morality. The results indicate support for this proposition.

The United States has many problems currently, the most persistent of which is the issue of race, and the problem of Mass Incarceration. This thesis addresses what Mass Incarceration is, as well as developing a theoretical understanding of how to overcome Mass Incarceration through the music of Kendrick Lamar and The Black Lives Matter Movement. This thesis presents the questions: What is the era of Mass Incarceration? How does Kendrick Lamar's music inform the problems of Mass Incarceration? How does The Back Lives Matter Movement use this information to create a solidarity movement against the oppression of African Americans? What does this mean going forward? Creating a synthesis of Mass Incarceration, the music of Kendrick Lamar, and The Black Lives Matter Movement, that overlaps and propels an intersection of culture and activism that inform one another. This all leads to the main takeaway of the thesis, that attempts to provide an interpretive understanding that pop culture, social media, and activism have created a different civil sphere, a Black public sphere that informs and educates through different avenues. All in all this thesis shows that music, social movements, and policy are all interconnected, and the music of Kendrick Lamar and the activism of The Black Lives Matter Movement provide a catalyst for change in the era of Mass Incarceration. / Master of Arts / The United States has many problems currently, the most persistent of which is the issue of race, and the problem of Mass Incarceration. This thesis addresses what Mass Incarceration is, as well as developing a theoretical understanding of how to overcome Mass Incarceration through the music of Kendrick Lamar and The Black Lives Matter Movement. This thesis presents the questions: What is the era of Mass Incarceration? How does Kendrick Lamar’s music inform the problems of Mass Incarceration? How does The Back Lives Matter Movement use this information to create a solidarity movement against the oppression of African Americans? What does this mean going forward? Creating a synthesis of Mass Incarceration, the music of Kendrick Lamar, and The Black Lives Matter Movement, that overlaps and propels an intersection of culture and activism that inform one another. This all leads to the main takeaway of the thesis, that attempts to provide an interpretive understanding that pop culture, social media, and activism have created a different civil sphere, a Black public sphere that informs and educates through different avenues. All in all this thesis shows that music, social movements, and policy are all interconnected, and the music of Kendrick Lamar and the activism of The Black Lives Matter Movement provide a catalyst for change in the era of Mass Incarceration.

Thesis (Ph.D.)--Boston University / PLEASE NOTE: Boston University Libraries did not receive an Authorization To Manage form for this thesis or dissertation. It is therefore not openly accessible, though it may be available by request. If you are the author or principal advisor of this work and would like to request open access for it, please contact us at open-help@bu.edu. Thank you. / This dissertation is an exposition and critique of Paul Tillich's and Erik H. Erikson's conceptualizations of the origin and nature of morality and ethics. After each author's theory of the origin and nature of morality and ethics is summarized, the similarities and differences which exist between their views are presented. Next their positions are evaluated according to the norm of coherence as defined by E.S. Brightman. Finally, a brief comparative criticism of their positions is made according to the same norm. The major similarity between Tillich's and Erikson's positions is their description of the origin of morality. Both men locate it in man's essential nature. On the basis of their descriptions of man's nature, both develop self-fulfillment theories of morality and ethics. However, they envision self-fulfillment within a communal rather than an individualistic context. The individual and society are described as a polar unity by both scholars. [TRUNCATED] / 2999-01-01

[pt] Este trabalho tem como foco as relações entre polícia-cidadão em uma comunidade em processo de pacificação. À luz de uma abordagem etnometodológica, buscou-se investigar como o conhecimento organizado em torno da categoria policial orientou a descrição que os moradores fazem daqueles que são membros do que se denomina Polícia Pacificadora. Com base nos conceitos de categoria de pertença e categorização de pertença, verificamos que o processo de categorização do policial que atua em uma Unidade de Polícia Pacificadora- UPP se realizou a partir do que é provido pelo conhecimento de senso comum como atividades atreladas à categoria de policial. É com base na descrição do que seria direito e dever do policial que os moradores constroem o significado de bom e mau policial. Os resultados mostram também que a categorização dos policiais é feita através de um processo de contraste com outras subcategorias militares e até com a categoria traficante. Através desse processo, percebe-se que, para os moradores, o novo modelo de polícia se afasta das expectativas de uma polícia focada no cidadão e no bem da comunidade, o que leva, em alguns casos, a uma inversão da categoria de mocinho e bandido. / [en] This research focuses on the relationship between police-citizen in a community in peace process. In light of the ethnomethodological approach, we sought to investigate how organized knowledge around the police category guided the description that residents produce in relation to those who are members of what is called Pacification Police. Based on the concepts of membership category and membership categorization, we find that the police categorization process that operates in a Pacifying Police Unit (UPP) was held from what is provided by the common sense knowledge as activities tied to the police category. It is based on the description of rights and duties of the police that the residents build the meaning of a good and a bad police officer. The results also show that the categorization of the police is made by a contrastive process with other military sub-categories and even with the trafficker category. Through this process, it is clear that, for the residents, the new police model departs from the expectations of a police focused on the citizen and on the well-being of the community, which leads, in some cases, a reversal of the good guy category and trafficker category.

[pt] O objetivo da dissertação é relacionar estética e moralidade a partir do ajuizamento estético do sublime, em Kant. Levando-se em conta que na Analítica do Sublime da Crítica da faculdade do juízo, Kant inúmeras vezes se refere ao sentimento ou ajuizamento do sublime como tendo uma relação com a moralidade a partir do sentimento moral ou o sentimento de respeito, sem, contudo, explicitar de que modo se daria essa relação, a hipótese que norteia a presente dissertação consiste na afirmação de uma ligação significativa entre sentimento estético e moralidade, argumentando que o ajuizamento do sublime atende a uma necessidade no inteiro sistema da filosofia kantiana, a saber, o estabelecimento da primazia do prático, sem que, contudo, seja ao preço da perda da autonomia do ajuizamento estético. / [en] The scope of this dissertation is to relate aesthetics and morality based on the aes-thetic judgment of the sublime in Kant. Taking into consideration that in the Analytic of the Sublime from the Critique of the Power of Judgment, Kant repeatedly refers to the sentiment or judgment of the sublime as being related to morality based on the moral sen-timent or feeling of respect, without however explaining how this relationship might work in practice, the hypothesis that underpins this dissertation consists of the affirmation of a significant link between aesthetic sentiment and morality, arguing that the judgment of the sublime fulfills a need in the entire structure of Kantian philosophy, namely establishing the primacy of the practical, however without involving the loss of autonomy of aesthetic judgment.