O presente trabalho consiste num estudo analítico sobre a prescrição tributária com a finalidade de, didaticamente, buscar identificar um subsistema jurídico próprio, dotado de normas e valores próprios, que permita o estudo destacado do tema dentro do sistema do direito positivo, a partir de uma análise lógico-sintática da expressão prescrição tal qual referido na alínea b do inciso III do art. 146 da Constituição Federal de 1988 (CF/88)2, que outorga competência ao legislador complementar para fixar normas gerais sobre a prescrição tributária, para construir uma significação possível para tal expressão, identificando sua acepção de base3, não se admitindo que se diga que o seu conteúdo seja vazio, a fim de que se possa identificar o regime jurídico aplicável à prescrição tributária, com a completa compreensão dos limites da competência do legislador complementar e ordinário nesse âmbito, de modo que se possa perceber a existência de uma tríplice4 perspectiva pragmática do uso dessa expressão no discurso do direito positivo, no qual por vezes é tomado como norma prescricional, ou como fato prescricional (hipotético), ou ainda como relação jurídica prescricional, o que já foi anteriormente investigado por outros autores, mas não sob o rótulo aqui sugerido, apesar de pouco explorada, daí porque merecendo melhor atenção, compreensão e aplicação na solução de casos da pragmática jurídica, para, ao final, identificar os eventuais acertos e/ou vacilos da jurisprudência do Superior Tribunal de Justiça (STJ) e do Supremo Tribunal Federal (STF) no julgamento dos casos e problemas aqui apresentados. / The present paper consists of an analytical study on tax statute of limitations with the aim of identifying, didactically, a special legal subsystem, endowed with its own normative values and rules, allowing the aforementioned study within the system of positive law, from a logical syntactic analysis of the phrase Statute of Limitations pursuant to as mentioned in Article 146, III, b, of the 1988 Brazilian Federal Constitution5, which grants to the supplementary law competence concerning establishing general rules with regard to the tax limitation, to constitute a possible meaning to such a phrase, identifying its basic acceptation6, not considering to say that its content is hollow, in order to identify the legal regime applicable to tax limitation, with the comprehensive understanding of the supplementary and ordinary laws competence limits herein, in order to realize the existence of a triple7 pragmatic perspective of using such phrase in the utterance of the positive law, in which is sometimes taken as statute of limitations, or statute of limitations fact (hypothetical), or even as Legal Relationship of Limitations, which has previously been investigated by other authors, but not under the approach suggested hereto, though little investigated, hence why deserves better attention, understanding and application in solving cases of Legal pragmatism, to, in the end, identify any adjustments and/or wanderings of the jurisprudence of the Superior Court of Justice (STJ) and the Federal Supreme Court (STF) in judging cases and claims presented herein.

The "work first" philosophy of the Personal Responsibility and Work Opportunity Reconciliation Act sent millions of people into the labor force, many for the first time. The result was a dramatic increase in the number of workers whose earnings failed to pull them and their families out of poverty. Assistance in the form of childcare, transportation, medical coverage, and the Earned Income Tax Credit is beginning to receive attention as support mechanisms for people who do not earn adequate wages and receive little benefits from their employers. This study examines the effectiveness of Georgia's approach to providing work support programs to its working poor citizens. No single entity is responsible for making work supports accessible. Thus, services often go underutilized because those who might qualify are not aware of their potential eligibility. Further, there is no state level strategy for ensuring that wage advancement is considered by agencies providing work support services. Using client administrative wage data from the Georgia Department of Labor and qualitative interviews from program staff, the state's structure for assisting the working poor is examined.

The concept of the work-first principle (arbetslinjen) might be considered old, but still serves as the main principle as well as an instrument in the Swedish labour market and social policy today. The original idea was that work and willingness to work was to be rewarded, especially due to a common opposition against the passive receipt of grants. The general definition of work, today, is that it is something desirable that should be achieved and that unemployed primarily will be offered training or work rather than grants and subsidies. When the Moderate party re-launched themselves as Sweden's "workers' party of today", in the beginning of the 2000's, the concept was brought back into the spotlight. In the elections of 2006 and 2010, the labour market was widely debated and become a controversial issue, with the concept of the work-first principle playing a major role. The purpose of this thesis is to analyse and problematize how the concept was presented and explained in the nationwide newspapers Aftonbladet and Svenska Dagbladet during the 2010 elections, this in order to increase the understanding of the concept’s contemporary definition and policy implications. This was done by analysing news articles, including articles from the debate and cultural sections, as well as editorials in afore mentioned newspapers, through a discourse analytical approach using the conceptual and analytical tools from both the discourse theory and the critical discourse analysis. The result of this thesis shows that the discourse is not primarily a matter of the work-first principle’s existence or nonexistence but rather how it should be defined and what to include. Other main result was that the common definition of the work-first principle and its content, during the election of 2010 (1 January - 19 September), was closely connected to the policy of the, ruling Alliance Government.

This dissertation contains three independent essays relating energy economics. The first essay investigates price asymmetry of diesel in South Korea by using the error correction model. Analyzing weekly market prices in the pass-through of crude oil, this model shows asymmetric price response does not exist at the upstream market but at the downstream market. Since time-variant residuals are found by the specified models for both weekly and daily retail prices at the downstream level, these models are implemented by a Generalized Autoregressive Conditional Heteroskedasticity (GARCH) process. The estimated results reveal that retail prices increase fast in the rise of crude oil prices but decrease slowly in the fall of those. Surprisingly, retail prices rarely respond to changes of crude oil prices for the first five days. Based on collusive behaviors of retailers, this price asymmetry in Korea diesel market is explained. The second essay aims to evaluate the new incentive system for biodiesel in South Korea, which keeps the blend mandate but abolishes tax credits for government revenues. To estimate changed welfare from the new policy, a multivariate stochastic simulation method is applied into time-series data for the last five years. From the simulation results, the new biodiesel policy will lead government revenues to increases with the abolishment of tax credit. However, increased prices of blended diesel will cause to decrease demands of both biodiesel and blended diesel, so consumer and producer surplus in the transport fuel market will decrease. In the third essay, the Regression - Seasonal Autoregressive Integrated Moving Average (REGSARIMA) model is employed to predict the impact of air temperature on daily peak load demand in Houston. Compared with ARIMA and Seasonal Model, a REGARIMA model provides the more accurate prediction for daily peak load demand for the short term. The estimated results reveal air temperature in the Houston areas causes an increase in electricity consumption for cooling but to save that for heating. Since the daily peak electricity consumption is significantly affected by hot air temperature, this study makes a conclusion that it is necessary to establish policies to reduce urban heat island phenomena in Houston.

我國所得稅法自民國八十七年一月一日開始實施兩稅合一制度。這原本是政府一項消除重複課稅的美意，但是仍受到多方批評。其爭議點就在於「未分配盈餘加徵百分之十營利事業所得稅」這項配套措施的實施。許多專家學者認為，對企業的未分配盈餘課稅，不利於企業內部資金的累積，進而影響其創新活動的投入與產出。而財政部卻持有不同的看法。 基於上述爭議，本研究以迴歸模式探討「未分盈餘加徵百分之十營利事業所得稅」制度的實施，對企業創新活動的影響。經實證結果發現： 1.對企業未分配盈餘加徵10%營利事業所得稅，確實會影響企業資本形成，降低其創新活動。因此，為求稅制良善，促進國家經濟發展，政府對於稅制之設計應謹慎為之。 2.以高科技產業和傳統產業比較，高科技產業由於兩稅合一未分配盈餘加徵10%營利事業所得稅制度的實施，其創新活動較制度實施前縮減，且縮減程度明顯大於傳統產業。此結果顯示，高科技產業顯然可謂新稅制下的最大受害者。因此，對高科技產業之未分配盈餘加以課稅，無疑是形成其創新活動的絆腳石、增加其營運上的風險。政府對此情況，應予正視。 3.以融資受限公司和融資未受限公司比較，兩稅合一之未分配盈餘加徵10%營利事業所得稅制度對融資受限公司之影響不大。經分析樣本特性，發現融資受限公司的獲利能力較差，因此租稅課徵對於其所造成的影響較低。因此可推論，獲利能力差之融資受限公司的創新活動受到非租稅因素的影響比租稅因素來得大。 關鍵字：未分配盈餘加徵百分之十營利事業所得稅，兩稅合一，創新活動 / In response to the public concern, Taiwan has adopted the imputation tax credit system since January 1st, 1998. Although the new tax reform can eliminate double taxation, the implementation of additional 10% surtax on undistributed surplus earnings has engendered lots of comments. Based on the disputations resulted from the new tax system, we conduct an empirical research analyzing the impacts of the implementation of additional 10% surtax on undistributed surplus earnings on the enterprises’ innovation. The empirical results in this research can be summarized as follows: 1. Imposing 10% surtax on corporate undistributed surplus earnings has adverse effect on capital accumulation, in turn leading to reduction in incentive of enterprises to conduct innovative activities. 2. Compared to the traditional industry, adverse effect of this new system is more profound for firms in the high-tech industry. The results indicate that high-tech industry is the major victim under the new tax reform. Therefore, imposing additional 10% surtax on high-tech industry will be an obstacle to enterprises’ growth and increase its operating risks. 3. Compared to unconstrained firms, we find out that the new tax system have less effects on constrained firms. Owing to considering the poor profitability, we can infer that non-tax factors have greater influence on the innovation of constrained firms relative to tax factors. Key words: additional 10% surtax on undistributed surplus earnings, the imputation tax credit system, innovation

The article analyzes if in the assumption that in a payment voucher referred to a Value Added Tax (VAT) exemption, such tax is consigned by mistake, in application of VAT adjustment regulations, the operation referred in that voucher must be consider taxable.In that regard, the article makes a description of the VAT and its elements, concluding that adjustment regulations correspond to the measurable element, but to define if the operation is taxable, is necessary to analyze the regulations about taxable operations (article1 of VAT Law). / En el presente artículo, se analiza si en el supuesto que en un comprobante de pago emitido por una operación no gravada con IGV se consigne por error dicho impuesto, en aplicación de las normas sobre ajustes de la Ley del IGV, debe considerarse gravada tal operación.Al respecto, se hace una descripción del IVA, modalidad de Impuesto al Consumo que adopta el IGV, y los Aspectos de la Hipótesis de Incidencia del IGV, señalando que las normas sobre ajustes corresponden al Aspecto Mensurable, concluyéndose que la norma que identifica qué operaciones están gravadas (Aspecto Material) es el artículo 1º, motivo por el cual las normas sobre ajustes se deben interpretar partiendo de la revisión de dicho artículo y, por ello, se concluye que las operaciones no gravadas no generan IGV, aun cuando se haya consignado por error en el comprobante de pago.

The aim of this work is to identify development income tax burden as a result of changes in laws and amount of income for the selected type of household, divided by income groups within five years. The work is divided into two parts ? thoretical and practical. The theoretical part discribes the basic concpets regarding the division of family, the subsistence minimum and the average wages. Also includes information about the natural person income tax. The practical part includes a description of the selected type of household (family without children in the four income situations) and own calculations of tax liability this family within five years.

Thesis aims to map the developement of wages taxation in the period of 2003-2013 and to evaluate the impact of the tax on personal income from employment and function benefits to the taxpayers wit different levels of income in a variety of situations, particularly in the case of maintenance of one or more children. The aim was to identify how the changes in the Law on Income Tax had affected different income groups, which of them had been affected the most and how.

L'innovation est aujourd'hui l'une des variables essentielles de la croissance économique et de l'emploi. Toutefois, son financement est complexe. Ce qui justifie l'intervention des pouvoirs publics. Ainsi en France, la puissance publique dispose de deux outils principaux pour inciter les entreprises à augmenter leurs dépenses de R&D, les aides directes et apparentées et les incitations fiscales. Toutefois, c'est une mesure d'aide fiscale, le crédit d'impôt recherche (CIR), qui constitue le dispositif majeur de soutien à l'innovation en France. Puissant instrument d'encouragement à la R&D depuis 1983, il est devenu depuis sa dernière grande réforme, en 2008, le dispositif incitatif le plus prisé des entreprises et la deuxième dépense de l'État. Une sortie de l'anonymat suivie d'une entrée dans la polémique car en raison de son poids de plus en plus prégnant dans l'économie française, le CIR soulève plusieurs interrogations. La plus partagée concerne naturellement la réalité de son efficacité, opposant partisans et détracteurs de la mesure. Mais celle-ci appelle pourtant d'autres questions et d'autres observations. Car s'il semble partagé que ce crédit présente de nombreux avantages pour ses bénéficiaires, la sécurité fiscale de ceux-là apparaît néanmoins fragile. Puis, le choix même de la dépense fiscale comme mesure de soutien interpelle, tant s'agissant de son opportunité réelle dans l'ordre interne que de son articulation avec la réglementation européenne des aides d'État. Ce qui pourrait justifier une adaptation du mécanisme à partir des modalités d'un autre dispositif opérant dans un autre secteur et ne souffrant pas à ce jour des mêmes carences que le CIR. / Today, innovation is one of the essential variables of the growth of the economy and employment. However, its financing is complex. This justifies the intervention of public authorities. In France, the public powers therefore have two main tools for encouraging companies to increase their R&D expenses, direct aids (and similar) and tax incentives. However, the main mechanism in support of innovation in France is a fiscal aid measure, namely the research tax credit. A powerful instrument for encouraging R&D since 1983, it has become, since its last major reform in 2008, the preferred incentive measure of companies and, at the same time, the State's second leading expenditure. A departure from anonymity followed by a step into controversy, since due to its increasing weight within the French economy, the research tax credit is prompting many questions. The most widely-shared question naturally relates to the reality of its efficiency, with supporters and detractors in equal measure. But this mechanism also elicits other questions and other observations. Since while it seems to be agreed that this credit offers many advantages for its beneficiaries, the fiscal security of the latter nevertheless appears to be fragile. Moreover, the very choice of a fiscal expenditure as a support measure is of concern, both with regard to its actual advisability within the internal order and in terms of its linkage with the European regulations relative to State aid. This could justify an adaptation of the mechanism on the basis of the provisions of another system used in another sector, but that does not currently have the same deficiencies as the research tax credit.

This diploma thesis deals with the tax reliefs, focusing on direct taxes in the Czech Republic. First, I have chosen those tax reliefs that have a social element. The thesis deals with their evolution and their comparison with other countries. Furthermore, the thesis examines the tax reliefs in more detail in terms of their objectives, utilization, and efficiency conditions. This is achieved with using various tax load indicators and effective taxation, comparing costs and additionally also the views of experts. Generally, however, this issue lacks a comprehensive study and analysis, and thus also the particular data. Tax reliefs along with social benefits constitute a redistribution system. Their costs and impacts are different. At the beginning of the writing of this thesis, I thought that the tax system should primarily be transparent, simple, focusing on its primary fiscal function and should therefore be free of social politics. I have, however, changed my opinion, because it has turned out that the social tax elements have their positive specifics that are difficult and expensive to transport to the system of direct benefits.