Typescript. / Thesis (Ph. D.)--University of Hawaii, 1966. / Bibliography: leaves 76-80. / v, 80 l mounted illus., tables

Thesis (M.S.)--Humboldt State University, 2007. / Includes bibliographical references (leaves 27-31). Also available via Humboldt Digital Scholar.

As opposed to earlier beliefs, the brain is altering itself throughout an individual’s life. The process of functional or structural alterations is referred to as plasticity, and can be induced by several factors such as experience or physical exercise. In this thesis, the research area of experience-dependent plasticity, with focus on exercise-induced plasticity is examined critically. Evidence from a vast array of studies are reviewed and compared in order to find whether physical exercise can induce neural plasticity in the human brain, how it may be beneficial, and what some of the plausible mediators of exercise-induced plasticity are. The findings demonstrated in this thesis suggest that although there are knowledge gaps and limitations in the literature, physical exercise can indeed result in exhibited plasticity as well as being beneficial for the human brain in several ways.

Abiotic stresses such as salt stress are the major limiting factors for agricultural productivity, and cause global food insecurity. It is well known that plant associated beneficial microorganisms can stimulate plant growth and enhance resistance to abiotic stresses. In this context, bacterial endophytes are a group of bacteria that colonize the host plant and play a fundamental role in plant growth enhancement under stress condition. Recently, our group reported that the beneficial bacteria Enterobacter sp.SA187 induces plant growth in Arabidopsis under salt stress conditions by manipulation of the plant ethylene signaling pathway. We therefore compared inoculation of plants by SA187 with virulent and non-virulent strains Pst DC3000. Although both strains inhibit plant growth at ambient conditions, Pst DC3000 hrcC-, but not Pst DC3000, induced salt stress tolerance, suggesting that Pst DC3000 hrcC- also contains plant growth promoting activity under stress conditions. Our results indicate that Pst DC3000 hrcC- shares features with beneficial bacteria by inducing salt tolerance through reduction of the shoot and root Na+/K+ ratio. To further elucidate the underlying mechanisms of this interaction with Arabidopsis, RNAseq, hormone and biochemical analyses were performed. Genetic studies also show that Pst DC3000 hrcC- induced salt stress tolerance involving several phytohormone pathways, including auxin, ethylene and salicylic acid. Transcriptome and genetic analyses indicate that glucosinolates play an important role in this beneficial interaction. We found that indolic and alkyl glucosinolates act as negative factors on Pst DC3000 hrcC-, alkyl glucosinolates are positive and indolic glucosinolates negative regulators in SA187 interaction with Arabidopsis. These results reveal that besides a repertoire of effectors, Pst DC3000 hrcC- also produces factors that can be beneficial for plant growth under certain stress conditions, as observed with Enterobacter sp. SA187.

The Hemiptera order has 23,000 species that are distributed among many families. Two of these are the Pentatomidae and Reduviidae families. The aim of this study was to identify the different species of insects from the Reduviidae and Pentatomidae families as well as each species’ abundance in three ecological niches (forest, forest edge, and farm land). The study was conducted in six communities of Los Yungas, La Paz (Carmen Pampa, San Pablo, San Juan de la Miel, Altuspata, Choro Alto, and Choro). In each community, three Malaise traps were installed in the three ecological niches (forest, forest edge, and farm land). The six communities were evaluated for a period of one year. The work was divided among four groups due to the fact that two families were being studied in two different municipalities. In the Coroico municipality (Carmen Pampa, San Pablo, and San Juan de la Miel), the study took place from May 2006 to May 2007. In the Coripata municipality (Altuspata, Choro Alto, and Choro), the study took place from May 2007 to May 2008. The first group identified 34 morphospecies of the Pentatomidae family with 137 individuals in the Carmen Pampa, San Pablo, and San Juan de la Miel communities. The second group identified 19 species of the Pentatomidae family with 54 individuals in the Altuspata, Choro Alto, and Choro communities. The third group found 31 species of the Reduviidae family along with 77 individuals. The fourth group identified 14 species of the Reduviidae family along with 60 individuals. Carmen Pampa and San Juan de la Miel are similar in terms of plant life and climate. San Pablo, however, is different due to its much drier climate. Morphospecies number three from the Pentatomidae family was the most abundant in the farm land niche in San Juan de la Miel. In all six communities, we found that morphospecies 16 was the most abundant in the forest niche. In addition, we found that there is little similarity between the species that inhabit both the forest and farm land areas. A recurrent pattern in the six communities was the presence of similar species in the forest and forest edge niches. This is due to the transitional character of the forest edge niche. Morphospecies 16 of the Reduviidae family was found most often in the forest and forest edge niches of the Altuspata and Choro Alto communities. It was absent in the Choro community. The area of study has insect species of the Pentatomidae and Reduviidae families that play important ecological roles - in some cases they can be pests and in others they can be predators of pests. There is a notable difference in the presence of insects from the Reduviidae and Pentatomidae families between municipalities. This difference is explained by the increased application of agrochemicals in the municipality of Coripata.

No description available.

Begreppet beneficial owner finns i artiklarna 10, 11 och 12 i OECD:s modellavtal och är viktigt då det krävs att en part utgör beneficial owner för att denne ska ha rätt till den skattelättnad som erbjuds i de relevanta artiklarna. Då begreppet är oklart har OECD gett ut förslag på nya kommentarer till det i avsikt att klargöra dess innebörd. Uppsatsens syfte är att utreda innebörden av beneficial owner i artiklarna 10, 11 och 12 i OECD:s modellavtal från ett tolknings och tillämpnings perspektiv. Av utredningen framkom att begreppet enbart bör tolkas enligt modellavtalet och att det ska tillämpas i situationer, i vilket en mottagare av en inkomst har en skyldighet relaterad till att vidarebefordra inkomsten till en annan part och därför agerar som en mellanhandel. Om en part har en sådan skyldighet kan denne inte utgöra beneficial owner. I nuläget är dock termen relaterad oklar och författaren anser att den bör klargöras av OECD snarast. Vid utredningen om en part utgör beneficial owner bör först ett legalt tillvägagångsätt användas för att undersöka om det finns en skyldighet relaterad till att vidarebefordra inkomsten i partens legala dokument. Om detta inte hittas bör därefter både ett legalt och faktabaserat tillvägagångsätt användas, vid utredningen av fakta och omständigheter för att se om det finns substans som visar på att parten i praktiken är bunden (som om att parten hade en kontraktuell eller legal skyldighet) att vidarebefordra inkomsten.   Författarens slutsats blev att en part för att utgöra beneficial owner måste vara den som har rätten att använda den mottagna inkomsten efter vilja och även vara den som faktiskt åtnjuter de ekonomiska fördelarna av denna. Vidare måste parten också behandlas som ägaren till inkomsten i skattehänseende i hemviststaten, då en skattelättnad inte bör ges om det inte föreligger en risk för dubbelbeskattning. / The term beneficial owner is contained in articles 10, 11 and 12 in the OECD Model Tax Convention and is of importance since it is required that a party is the beneficial owner in order to be entitled to the tax relief offered in the relevant articles. Since the term is unclear, OECD has published proposals for new comments to clarify its meaning. The purpose of this study is to investigate the meaning of the term beneficial owner in articles 10, 11 and 12 in the OECD Model Tax Convention from an interpretation and application perspective. The investigation revealed that the term should only be interpreted in accordance with the OECD Model Tax Convention and that it aims at a recipient who has an obligation related to forwarding an income to another party and who is therefore acting as an intermediary. If a party has such an obligation, then he cannot be the beneficial owner. At present the term related is unclear and the author thinks that it should be clarified by the OECD as soon as possible. When investigating whether a party is the beneficial owner a legal approach should be used first to examine whether there is an obligation related to forwarding the income in the party's legal documents. If this is not found, then both a legal and factual approach should be used when examining the facts and circumstances in order to see if there is substance to show that the party is in practice bound (as if that party had a contractual or legal obligation) to forward the income. The author's conclusion is that a part to be the beneficial owner must be the one who has the right to use the received income as they wish and also be the one who actually enjoys the economic benefits of it. Furthermore, the party must also be treated as the owner of the income for tax purposes in the State of residence, since tax relief should not be given unless there is a risk of double taxation.

Thesis (MComm) -- Stellenbosch University, 2011. / ENGLISH ABSTRACT: The study’s focus is to provide an analysis of the development of the definition of royalties in the context of Model Tax Conventions (‘MTC’). The secondary focus of the study is to analyse the evolution of the concept of beneficial ownership as a limitation to the application of the treaty benefits contained in royalty provisions of the MTC’s. In terms of the focus of the study, it is concluded that the most significant developments with regards to the definition of royalties, since originating in the League of Nations Model Convention’s first Draft Model in 1928, occurred during the final Committee meetings held in Mexico and London (producing the Mexico and London Draft Models respectively) and in terms of the Organisation for European Economic Cooperation (‘OEEC’), which set out the founding principles of the definition. It is also concluded that the later MTC’s did not significantly change the Treaty royalty definition but added clarification as to the meaning of the term by way of the Commentaries to the MTC. The secondary focus of the study concludes that the term has not really changed since it was first used in an international context. The most recent case law on the matter confirmed that the attributes of the concept is that of ownership and that the matter is one which needs to be decided from a legalistic perspective and should not be based on the economic interpretation of the term ‘beneficial ownership’, which could effectively turn the concept into a broad anti-avoidance provision. / AFRIKAANSE OPSOMMING: geen opsomming

Diplomová práce: Beneficiární vlastník v daňovém právu Abstrakt v anglickém jazyce BENEFICIAL OWNER IN TAX LAW In many instances, the concept of beneficial owner can be found in tax law, enabling the taxpayers to lower the taxation of their income. Despite the fact that the term beneficial owner is not very commonly used in the Czech law, interpretation of this term is important part of the international tax law. Therefore, the purpose of my Theses is to review relevant laws (including Czech tax law, international tax law, European law, and relevant Czech and international court's decisions) to determine common characteristics of the term beneficial owner as it is used in the above mentioned fields of law. In the European law, the term beneficial owner can be found in two European directives - "Interest and royalty payments directive" and "Income savings directive". Although there are differences between the interpretation on the term beneficial owner in these European directives (based mostly on the fact that one directive is applicable to natural persons whereas the other one to legal entities), we can say that the purpose and aim of the regulation is the same. The OECD and its fiscal committee are concern with the interpretation and appropriate application of the term beneficial owner in the...

O conceito de beneficiário efetivo nos acordos internacionais contra a bitributação, apesar de não expressamente definido, é um requisito específico para que pessoas possam usufruir das disposições relativas aos dividendos, juros e royalties do mesmo. O presente trabalho tem o objetivo de analisar os critérios para a determinação do significado desse termo nos acordos celebrados com base na Convenção Modelo da OCDE, examinando também os limites e implicações de sua definição para os Estados Contratantes. A Introdução tem o objetivo de delimitar o escopo do objeto de estudo, bem como apresentar algumas prévias considerações didáticas sobre o direito tributário internacional, ramo no qual este estudo se insere. No Capítulo I, analisaremos a origem do termo beneficiário efetivo. O elemento central é a sua relação com os atributos do direito de propriedade no direito interno dos países de common law, onde este foi criado. Adicionalmente, realizaremos a comparação com o tratamento legal dessa expressão no direito interno dos países de civil law e, especificamente, no direito interno brasileiro. O Capítulo II compreende o exame das regras de interpretação dos acordos internacionais contra a bitributação e de que maneira a construção de sentido de termos não definidos em seu texto é realizada. Para este fim, serão analisados os diversos instrumentos que compõe o contexto desses acordos, assim como a relação entre os demais instrumentos que podem auxiliar neste processo de exegese, demonstrando também as condições para o reenvio interpretativo do termo por meio de lei interna dos Estados Contratantes. No Capítulo III, as diferentes formas e critérios para a interpretação do termo serão estudados. Será analisada a disciplina do tema na CM OCDE e Comentários, a sua relevância e alcance no combate ao treaty shopping e a jurisprudência internacional atual. Ao final, apresentaremos uma síntese conclusiva do nosso estudo. / The concept of beneficial owner in the double tax treaties, although not expressly defined, is a requirement for the treaty entitlement of persons receiving income from dividends, interest and royalties. This study aims at analyzing the criteria for the definition of its meaning within the double tax treaties that adopt the OECD Model Convention, also examining the limits and implications of this concept to Contracting States. The purpose of the Introduction is to define the scope of the object of study and, also, to present certain didactic considerations about international tax law, the area to which this work is related. In Chapter I, the origin of the term beneficial owner is analyzed. The main element therein is its relationship with the attributes of property law under the domestic laws of the common law countries, where it was created. Additionally, we will proceed the comparison with the legal treatment of this expression in the internal law of the civil law countries and, specifically, in the Brazilian law. Chapter II deals with the analysis of the interpretation rules of the double tax treaties and on which way they act on the construction of the meaning of terms not defined on its text. For this purpose, the several instruments that constitute the context of the tax treaties will be analyzed, as well as the relation of the other instruments that may help in the interpretation process, demonstrating the requirements for the interpretative remittance of the term through domestic law of the Contracting States. On Chapter III, the different forms and criteria for the interpretation of the term will be examined. Also, we will analyze the treatment of the subject on OECD MC and Commentaries, its relevance and scope in the fight against treaty shopping and the current international jurisprudence. At the end, we will present a conclusive synthesis of our study.