This diploma thesis deals with the issue of taxation of dividends from the point of view of legal entities. Taking into account the breadth of the topic, the work is focused on the taxation of dividends, which are due to a legal entity having its registered office or place of management in the territory of the Czech Republic. It specifies the legal provisions on the issue, both international, EU and national. The findings are applied to a complex model example that sets out the accounting view of the issue beyond the process of dividend taxation.

This diploma thesis is concerned with the taxation of dividends in the Czech Republic. It contains description of the applicable law in Czech Republic, the applicable law and especially directives of the European Union concerned with dividends. In the practical section are explained the various methods of taxation and differences in payment of dividends internally, to the European Union and to the third countries. Based on the findings there is described the procedure how to tax the dividends properly.

This diploma thesis deals with desigantion of usual price of ten residential units in Jemnice and Moravské Budějovice. Valuation is done with direct comparison and with comparative methody by valid price regulation. Constituent part of this thesis is analysis effect of location on the usual price of selected locality.

Two-sided matching markets are a cornerstone of modern economics. They model a wide range of applications such as ride-sharing, online dating, job positioning, school admissions, and many more. In many of those markets, monetary exchange does not play a role. For instance, the New York City public high school system is free of charge. Thus, the decision on how eighth-graders are assigned to public high schools must be made using concepts of fairness rather than price. There has been therefore a huge amount of literature, mostly in the economics community, defining various concepts of fairness in different settings and showing the existence of matchings that satisfy these fairness conditions. Those concepts have enjoyed wide-spread success, inside and outside academia. However, finding such matchings is as important as showing their existence. Moreover, it is crucial to have fast (i.e., polynomial-time) algorithms as the size of the markets grows. In many cases, modern algorithmic tools must be employed to tackle the intractability issues arising from the big data era. The aim of my research is to provide mathematically rigorous and provably fast algorithms to find solutions that extend and improve over a well-studied concept of fairness in two-sided markets known as stability. This concept was initially employed by the National Resident Matching Program in assigning medical doctors to hospitals, and is now widely used, for instance, by cities in the US for assigning students to public high schools and by certain refugee agencies to relocate asylum seekers. In the classical model, a stable matching can be found efficiently using the renowned deferred acceptance algorithm by Gale and Shapley. However, stability by itself does not take care of important concerns that arose recently, some of which were featured in national newspapers. Some examples are: how can we make sure students get admitted to the best school they deserve, and how can we enforce diversity in a cohort of students? By building on known and new tools from Mathematical Programming, Combinatorial Optimization, and Order Theory, my goal is to provide fast algorithms to answer questions like those above, and test them on real-world data. In Chapter 1, I introduce the stable matching problem and related concepts, as well as its applications in different markets. In Chapter 2, we investigate two extensions introduced in the framework of school choice that aim at finding an assignment that is more favorable to students -- legal assignments and the Efficiency Adjusted Deferred Acceptance Mechanism (EADAM) -- through the lens of classical theory of stable matchings. We prove that the set of legal assignments is exactly the set of stable assignments in another instance. Our result implies that essentially all optimization problems over the set of legal assignments can be solved within the same time bound needed for solving it over the set of stable assignments. We also give an algorithm that obtains the assignment output of EADAM. Our algorithm has the same running time as that of the deferred acceptance algorithm, hence largely improving in both theory and practice over known algorithms. In Chapter 3, we introduce a property of distributive lattices, which we term as affine representability, and show its role in efficiently solving linear optimization problems over the elements of a distributive lattice, as well as describing the convex hull of the characteristic vectors of the lattice elements. We apply this concept to the stable matching model with path-independent quota-filling choice functions, thus giving efficient algorithms and a compact polyhedral description for this model. Such choice functions can be used to model many complex real-world decision rules that are not captured by the classical model, such as those with diversity concerns. To the best of our knowledge, this model generalizes all those for which similar results were known, and our paper is the first that proposes efficient algorithms for stable matchings with choice functions, beyond classical extensions of the Deferred Acceptance algorithm. In Chapter 4, we study the discovery program (DISC), which is an affirmative action policy used by the New York City Department of Education (NYC DOE) for specialized high schools; and explore two other affirmative action policies that can be used to minimally modify and improve the discovery program: the minority reserve (MR) and the joint-seat allocation (JSA) mechanism. Although the discovery program is beneficial in increasing the number of admissions for disadvantaged students, our empirical analysis of the student-school matches from the 12 recent academic years (2005-06 to 2016-17) shows that about 950 in-group blocking pairs were created each year amongst disadvantaged group of students, impacting about 650 disadvantaged students every year. Moreover, we find that this program usually benefits lower-performing disadvantaged students more than top-performing disadvantaged students (in terms of the ranking of their assigned schools), thus unintentionally creating an incentive to under-perform. On the contrary, we show, theoretically by employing choice functions, that (i) both MR and JSA result in no in-group blocking pairs, and (ii) JSA is weakly group strategy-proof, ensures that at least one disadvantaged is not worse off, and when reservation quotas are carefully chosen then no disadvantaged student is worse-off. We show that each of these properties is not satisfied by DISC. In the general setting, we show that there is no clear winner in terms of the matchings provided by DISC, JSA, and MR, from the perspective of disadvantaged students. We however characterize a condition for markets, that we term high competitiveness, where JSA dominates MR for disadvantaged students. This condition is verified, in particular, in certain markets when there is a higher demand for seats than supply, and the performances of disadvantaged students are significantly lower than that of advantaged students. Data from NYC DOE satisfy the high competitiveness condition, and for this dataset our empirical results corroborate our theoretical predictions, showing the superiority of JSA. We believe that the discovery program, and more generally affirmative action mechanisms, can be changed for the better by implementing the JSA mechanism, leading to incentives for the top-performing disadvantaged students while providing many benefits of the affirmative action program.

Verstärkte Anstrengungen zur Förderung der T-Zell-basierten Immunität haben eine zwingende Notwendigkeit für unser Verständnis der menschlichen T-Zell-Funktion und –Erhaltung geschaffen. Das Paradigma, dass Gedächtnis-T-Lymphozyten kontinuierlich durch den Körper zirkulieren wurde vor kurzem durch die Entdeckung der Gedächtnis-T-Zellen, die in einer Vielzahl von Geweben, einschließlich des Knochenmarks angesiedelt sind, herausgefordert. Allerdings bleibt der Unterschied zwischen Funktionsweise von zirkulierenden und gewebeansässigen Gedächtnis-T-Zellen nur unzulänglich verstanden. Die Knochenmark ist die Heimat für eine große Anzahl Gedächtnis-T-Zellen. CD4+ Gedächtnis-T-Zellen aus dem Knochenmark beinhalten ein breites Spektrum an Antigenspezifitäten. Interessanterweise wurden CD4+ Gedächtnis-T-Zellen spezifisch für systemische Kindheitsantigene im Knochenmark von älteren Menschen gefunden, auch wenn sie nicht mehr in der Blutzirkulation nachgewiesen werden konnten. Gedächtnis-T-Zellen aus dem Knochenmark sind sesshaft und ruhend und Langzeitgedächtnis gegen systemische Antigene erhalten. Sowohl der Überlebensmechanismus von Gedächtnis-T-Zellen, als auch die Kapazität von gewebsansässigen Gedächtnis-T-Zellen nach einer systemischen Herausforderung mobilisiert zu werden, sind bisher nur unzureichend geklärt. Ich habe gezeigt, dass Gedächtnis-T-Zellen aus dem peripheren Blut und Knochenmark unterschiedliche Überlebensfähigkeiten haben. Weiterhin habe ich die Rolle von Überleben Faktoren in ihrer Erhaltung identifiziert. Zudem habe ich bestimmt, dass Gedächtnis-T-Zellen aus dem Blut und Knochenmark unterschiedliche Zellpopulationen sind, mit unterschiedliche TCRβ Repertoires. Schließlich konnte ich zeigen, dass sesshafte Gedächtnis-T-Zellen, die spezifisch für systemische Antigene sind, schnell in die Blutzirkulation mobilisiert werden. Zusammenfassend bieten diese Studien ein umfassenderes Verständnis der Funktion und des Erhalts des immunologischen Gedächtnisses. / Intensified efforts to promote protective T cell-based immunity in vaccines and immunotherapies have created a compelling need to expand our understanding of human T cell function and maintenance. The paradigm that memory T lymphocytes are continuously circulating through the body in search of their cognate antigen has been recently challenged by the discovery of memory T cells residing in a variety of tissues, including the bone marrow (BM). However, the division of labor and lifestyle of circulating versus tissue resident memory T cells remains poorly understood. The human BM is home to a great number of memory T cells. BM memory CD4+ T cells contain a wide array of antigen specificities. Interestingly, memory CD4+ T cells specific for systemic childhood antigens have been found in the BM of elderly humans, even when they were no longer detectable in peripheral blood (PB) circulation. BM memory T cells are resident, resting and maintain long-term memory to systemic antigens. The survival mechanisms of circulating and BM resident memory T cells; as well as the capacities of tissue resident memory T cells to be mobilized into blood circulation after systemic antigen re-challenge to confer us with immune protection remains to be elucidated. I have shown that PB and BM memory T cells have different survival capacities, as well as identified the role of survival factors in their maintenance. Moreover, using sequencing analysis of the TCRβ repertoire, I have determined that PB and BM memory T cells are separated cell populations. Finally, by tracking the dynamics of antigen-specific memory CD4+ T cells after systemic MMR re-vaccination I could show that TRM CD4+ T cells specific for systemic antigens can be rapidly mobilized into blood circulation and contribute to the immune response. These studies provide a more comprehensive understanding of the function and maintenance of immunological memory in humans.

The Effect of a Quality Improvement Initiative on Reducing Hospital Transfers of Nursing Home Residents by Denise Eileen Jarboe MSN, Walden University, 2010 BS, University of Maryland, 1981 Project Study Submitted in Partial Fulfillment of the Requirements for the Degree of Doctor of Nursing Practice Walden University February 2015 Nursing homes (NH) in the 21st century provide skilled healthcare services for resident populations who are older, frailer, and often suffering from multiple incurable chronic medical conditions. Nurses practicing in this setting must be keen observers and effective communicators with the ability to recognize and report subtle changes in health status that may lead to an avoidable or unnecessary hospital transfer. The purpose of this DNP project was to evaluate the impact of a quality assurance performance improvement (QAPI) initiative implementing the INTERACTTM (interventions to reduce acute care transfers) SBAR (situation, background, assessment/appearance, recommendation) communication tool in a skilled NH setting. The Synergy Model, which posits that optimal patient outcomes are possible when nurse competency is matched or synergized with patient care needs, provided the conceptual framework for this project. To evaluate the effect of the program, resident hospital transfer events groups before and after SBAR utilization (n = 295) were analyzed using a dependent t test to determine if significant differences existed in the groups in overall number of transfers, clinical condition categories, and those leading to an inpatient hospitalization. Although analysis of the data did not demonstrate significant decreases in resident transfer events, the results did provide valuable baseline information for future studies. This project contributed to social change by evaluating communication among care providers in a skilled NH setting, establishing baseline information and identifying the need for future projects. This information is vital for determining which resident transfers to the hospital are avoidable and for developing future programs addressing this practice issue.

South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa are subject to double taxation. This thesis evaluates whether South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa receive full relief from double taxation in South Africa. The thesis provides a qualitative examination of the fundamental legal designs used for the allocation of the right to mine oil and gas and the fiscal regimes applied to the taxation of oil and gas mining at the source. The thesis explores the basis for taxation of foreign oil and gas income in South Africa and the remedies for double taxation in terms of the domestic tax legislation. Assuming that a tax treaty exists between South Africa and the host government, qualification for double taxation relief and classification of income in terms of a double taxation agreement (DTA) are evaluated. It is anticipated that a South African resident Oil and Gas company will choose the most favourable method and form of double tax relief when filing its corporate tax return in South Africa based on the commercial impact thereof. To aid in this decision, the thesis contrasts the quantum of the double tax relief under the domestic tax legislation with that available under the DTA. Using an adaptation of the IMF's FARI methodology, a quantitative analysis of the economic impact for a South African resident Oil and Gas company mining in Egypt, Equatorial Guinea, Ghana and, Nigeria is examined. The thesis concludes that there are circumstances where South African resident Oil and Gas companies are unable to achieve full double tax relief under the domestic tax legislation and make recommendations (where applicable) for amendments to the domestic tax legislation to achieve a form of full double tax relief as close as possible to the single tax principle.

No description available.

No description available.

No description available.