This thesis examines the impact of environmental regulations on trade competitiveness for South Asian countries. The study further investigates whether South Asian countries have become a pollutive haven of industrial exports to OECD countries during 1984-2004. The thesis also analyses whether tariff walls created by the governments to offsets stringent environmental regulations negatively affect pollutive industrial trade flows. This study has identified gaps in the literature after critically reviewing both competing trade theories and empirical literature surrounding the subject. Firstly, most of the empirical literature on the subject has focused on developed countries while ignoring less developed regions like South Asia. Second, several studies concluded trade competitiveness impact of environmental policy following a single estimation method when results are sensitive to the choice of the method used. Hence, for robust results, cross-methods analysis was imperative. Thirdly, the empirical literature on the subject focused on most pollutive industries and ignored the research on somewhat pollutive and least pollutive sectors as well as comparative analysis between those industries. This study has contributed to the literature by filling these gaps. Following the neo-classical theory, the central hypothesis of this thesis is that environmental regulations negatively affect different categories of pollutive industrial export competitiveness. By using the highest dis-aggregated ISIC level trade data and incorporating other socio-economic variables, this study has deployed comparative advantage trade models by Balassa (1965), competitiveness indicator by XU (1999), and bilateral RCA model by Grether and de Melo (2004). The study used the gravity model to control for un-observed effects over time on trade flows while capturing environmental regulations impact on pollutive industrial trade competitiveness. Accordingly, to avert endogeneity/data sensitivity issues and to ascertain robust estimates, the present research has among others computed Random Effect and Newey-West standard error models. The statistical modeling results show that while India gained trade competitiveness in most pollutive industrial trade, Pakistan and Bangladesh lost their trade competitiveness in the same category. The research finds evidence of most pollutive industries of South Asian countries increasing their bilateral RCAs and exports with OECD countries and reset of the world. A comparative analysis between most pollutive to less pollutive industries showed a lack of support for any systematic specialization patterns of trade for South Asia during 1984-2004. Nonetheless, this study findings based on gravity modeling clearly depicted a statistically significant negative impact of environmental regulations on total exports, most pollutive exports, and less pollutive industrial exports for South Asia and OECD countries. This study rejected the pollution haven hypothesis between South Asian pollutive industrial exports with OECD. It further concluded that tariff barriers created by countries to offsets environmental regulation costs would prove counterproductive to competitiveness. At the policy level, instead of lobbing for protectionism to balance out environmental regulatory costs, the governments in both developed and developing countries need to focus on forming better environmental policies fostering both competitiveness and environmental quality. Also, trade-offs between environmental regulations and competitiveness are challenging situations for South Asia and OECD countries. Therefore, sustainable production and trade policies combined with innovative and cost-effective environmental policies are needed to accomplish environmental gains and competitiveness.

依現行所得稅法規定，只要受控外國公司盈餘未匯回，即可享有「租稅遞延」的效果，由於近十年臺灣利用受控外國公司，對大陸間接投資金額占全部對外投資總額比重超過五成以上，又因上市公司投資金額較大且具有代表性，因此本論文以國內上市公司利用受控外國公司，間接投資大陸子公司為研究對象，探討國內上市公司是否有透過「受控外國公司」不分配盈餘，藉由稅法「漏洞」以產生遞延課稅之效果，及我國若是建立受控外國公司課稅制度，對我國上市公司投資大陸子公司其損益稅負之影響。 　　本文研究結果，發現國內上市公司利用受控外國公司投資大陸子公司，普遍存在有盈餘卻不分配且不匯回之現象，我國有建立受控外國公司課稅制度之正當性及必要性；且我國如建立受控外國公司課稅制度，以產業別而言電子產業受影響最大，以研發強度而言，研發強度在5%~7%及9%以上之企業有較大之影響。又雖然實施受控外國公司課稅制度後，對於中等規模(資本額50億至100億)之有效稅率增加幅度最大，但受影響而應繳納稅負之金額仍以大型規模之企業為最高。 　　因此我國建立受控外國公司課稅制度，能拉近不同特性企業間適用有效稅率的差距，對舉債投資得扣除利息費用，境外投資收益卻能遞延課稅，以及在台灣享有研發投資抵減利益，卻有高額境外所得保留在海外未匯回台灣課稅之公司，有一定衡平作用，則我國建立受控外國公司課稅制度，實已非僅財政收入之考量而已，相對而言，改善租稅公平才是具有更大的意涵，因此有其正當性及必要性。文末提出幾點建議，期能作為政府研擬受控外國公司課稅制度之參考。 關鍵詞：受控外國公司、租稅庇護所、多國籍企業 / According to the current provisions of the Income Tax Act, Taiwanese companies will benefit from the "tax deferral" by not unremitting overseas earnings of their controlled foreign corporations (CFCs). Since the last decade in Taiwan, many companies have been increasing investments in Mainland China via their controlled foreign corporations, the investment in Mainland China have accounted for over half the Taiwanese total foreign investments. Therefore, this study focuses on the Taiwanese listed companies which invest indirectly in Mainland China. Furthermore, the controlled foreign corporations have become a tax loophole; this study examines whether those listed companies leverage the tax loophole to gain the tax benefit through the "tax deferral of Chinese subsidiary earnings." Besides, this study estimates the potential impacts on the profit and tax costs of the mainland subsidiaries of Taiwanese listed companies, if the controlled foreign corporation (CFC) tax system will be established in the future. 　　The results of this study show that the majority of Taiwanese listed companies do not fully distribute and remit the Chinese subsidiary earnings back to Taiwan. Hence, it is necessary for Taiwan to establish the controlled foreign company tax system to close the tax loophole. As to the impacts on industries, the electronics industries will be most affected by the CFC tax system, if established. In addition, companies whose R&D intensity range from 5% to 7% and over 9% will also be significantly influenced. Although the effective tax rates of medium-sized companies will have the highest increase in effective tax rates, but large companies will have the highest increase in the amount of CFC tax. 　　Therefore, the establishment of CFC tax system will contribute to narrowing down the gaps in effective tax rates between different firm characteristics of companies. Moreover, the new tax system can help prevent companies from shirking their fair shares of tax payments. The establishment of CFC tax system is not just for fiscal revenues, but also for the improvement of tax fairness—the latter being more important. Finally, this study concludes with suggestions that may be the useful references for the government to design CFC tax system in the future. Key words：Controlled Foreign Corporation, Tax Haven, Multinational Enterprise

The aim of this thesis is to explore the firm-specific determinants of the demand for tax haven operations by Czech firms. Our objective is to better understand the firms' incentives for tax haven use, and furthermore whether there exists cross-haven heterogeneity in those incentives. The thesis examines the firms' tax haven investment behaviour by analysing firm-level data for 15,530 Czech firms for year 2013. To the extent of our knowledge, this has been the first research of its kind devoted to Czech firms. The evidence suggests that larger, more profitable firms with larger international presence are most likely to use tax havens. The analysis also indicates that higher firm indebtedness is associated with greater likelihood of establishing tax haven operations. This would suggest Czech firms engage in profit shifting through the use of debt financing. Furthermore, service firms were found to be more likely to use tax havens than manufacturing firms. This contrasts with previous research where R&D intensity was a leading indicator of tax haven use. Additionally, we found significant cross-haven heterogeneity in the determinants, particularly in the sector-specific characteristics. In our sample, service firms favoured Cyprus and the Netherlands, while manufacturing firms preferred Luxembourg...

Values matter in both legal decision (lawmaking and lawapplying) and discourse (lawshaping and lawinfluencing). Yet, their purported subjectivity means that gaining or improving knowledge about values (whether they be epistemic, legal, moral, ethical, economic, political, cultural, social, or religious) in the context of analytic legal thought and understanding is often said to be at odds with its goal of objectivity. This phenomenon is amplified at the international level where the infusion of seemingly subjective political values by sovereigns, and the decisionmakers to whom they delegate, can, and does, interfere with an idealized and objective rule of law. The discourse on value subjectivity, and its relation to the purpose and function of the law, is particularly apparent in evolving international legal orders such as investment treaty arbitration. The primary aim of this work is to provide a new method for gaining empirical knowledge about value subjectivity that can help close a weak link in all nonpositivist (value-laden) legal theory: a weakness that has manifest itself as skepticism about the possibility of measuring value objectively enough to permit its incorporation as a necessary component of analytic jurisprudence. This work proposes a theory of configurative fairness for addressing the problem related to the development or evolution of legal regimes, and how legal regimes perceived as subjectively unfair can be remedied. Such a theory accepts the premise that perceptions of fairness matter in directing the way that legal orders develop, and that perceptions of fairness relate to the manner in which values are distributed and maximized in particular legal orders. It is posited that legal orders perceived as fair by their participants are more likely to be endorsed or accepted as legally binding (and are therefore more likely to comply with the processes and outcomes that such laws mandate). The purpose of a theory of configurative fairness is an attempt to provide a methodological bridge for improving knowledge about value in the context of legal inquiry through the employment of a technique called Q methodology: an epistemological and empirical means for the measurement and mapping of human subjectivity. It is a method that was developed in the early twentieth century by physicist-psychologist William Stephenson: the last research student of the inventor of factor analysis, Charles Spearman. What Stephenson did was to create a way for systematically measuring subjective perspectives, and although not previously used in jurisprudential thought, Q methodology will facilitate a means for the description and evaluation of shared subjectivities. In the context of law generally, and in investment treaty arbitration specifically, these are the subjectivities that manifest themselves as the conflicting perspectives about value that are omnipresent in both communicative lawshaping discourse and authoritative and controlling lawmaking and lawapplying decision. Knowledge about these shared value subjectivities among participants in investment treaty arbitration will allow the legal analyst to delineate and clarify points of overlapping consensus about the desired distribution of value as they relate to the regime-building issues of evolving legal orders. The focus for a theory of configurative fairness pertains to the identification of the various value positions that participants hold about a particular legal order and to configure those values, through its rules and principles, in a manner that is acceptable (and perceived as fair) by all of its participants. If such a value consensus can be identified, then particular rules in the legal order can be configured by decisionmakers in a way so as to satisfy participants’ shared value understandings. To engage such a theory, a means for identifying shared value subjectivities must be delineated. This work conducts a Q method study on the issues under debate relating to regime-building questions in investment treaty arbitration. The Q method study asked participants knowledgeable about investment treaty arbitration to rank-order a set of statements about the way that the values embraced by this legal order ought to be configured. The results of the study demonstrate that there is significant overlap about how participants in investment treaty arbitration perceive the desired distribution of values across the regime. The Q method study identified six distinct perspectives that represent shared subjectivities about value in the context of the development of investment treaty arbitration. The Q method study was also able to identify where there is an overlapping consensus about value distribution across the distinct perspectives. It is these areas of overlapping consensus that are most likely to reflect shared value understandings, and it is proposed that it is upon these shared value understandings that the future development of investment treaty arbitration ought to aim.

本文的主要目的係探究各國以污染密集度定義的出口貿易比較利益型態，在因素秉賦與環境政策隨著時間改變的前後十四年間是否有變動；環境因素稟賦是否可以解釋一國為何發展該種污染性質的出口產業型態；高污染性產業外移是否因為環境稟賦不同所造成。由於廣義環境因素稟賦的相關資料在收集與數量化上常遇到困難，所以過去有關環境因素稟賦對一國出口貿易產業型態影響的實證文獻非常少。針對上述所面對的的困難，本文嘗試以國際貿易理論中有關比較利益的模型，在加入環境因素稟賦等相關變數後，對一國以污染密集度定義的出口產業型態之發展有無影響？而環境因素稟賦隨著時間的演進，對該國以污染密集度定義的出口產業比較利益型態之影響程度為何？以檢定一國之出口產業比較利益型態的發展趨勢與環境因素稟賦之間的互動關係。茲將本文的研究步驟與結論分述如下： 　　（一）研究步驟 　　　　1.為了求得世界主要出口國家整體製造業以污染密集度定義產業性質之出口比較利益型態，乃運用Ralassa所提出的「A 'Stage Approach' to Comparative Advantage」的分析模型做為基本架構，將該分析模型內之第一階段迴歸估計式內以資本密集度定義的解釋變數，改為以污染密集度定義的解釋變數，以檢定上述各國的出口產業比較利益型態。另為分析各國出口產業比較利益的發展趨勢，乃以1976年、1987年、1990年等三個年度、十四年間的資料，分別求得各國該年度的出口產業比較利益型態為何種污染密集程度的產業。並將各主要出口國家按已開發國家、亞洲新興國家、中南美洲國家等三大分類，重新歸類其貿易型態與發展趨勢。 　　　　2.在上述模型架構下的第二階段迴歸估計式中，以第一階段所得的參數值為被解釋變數（即各國以污染密集度定義的產業型態參數估計值），再以各國廣義的環境因素稟賦為解釋變數（除了原有的物質資本、人力資本外，分別加入環保政策變數、自然資源因素稟賦、自然環境因素稟賦與廣義的環境因素稟賦等做為其他項的生產因素稟賦），檢定環保政策變數與該三類的因素稟賦對各國所發展的比較利益產業型態的關聯性。另外配合1976年、1987年、1990年等三年度的資料，觀察環境因素稟賦隨著時間的變遷，是否對該國的出口產業比較利益型態有不同程度的影響。 　　　　3.在有關產業外移的問題中，以經濟部投審會核准的國人赴海外投資之資料，以分區分業分年的統計結果分析台灣的高污染性質製造業是否有外移的趨勢。 　　（二）研究結論 　　　　1.各國的出口比較利益型態，除了中南美洲與少數國家外，OECD國家及亞洲各國整體製造業的出口比較利益型態，在最近十四年間的變化，並無明顯的改變。 　　　　2.環保法規政策變數對各國出口比較利益型態之影響並無實證統計上的顯著性，無法判定其對高污染密集度產業之出口比較利益會有何種影響。 　　　　3.在觀察未加入環保政策變數的第二階段迴歸分析中，首先該階段迴歸式內的解釋變數分成三類。在第一類自然資源因素稟賦中，只有石油礦產具有正相關與統計上顯著性的特性。而其他各種礦產，除了煤礦產具有負相關與統計上顯著性的特徵外，雖然不具有統計上的顯著性，但其迴歸係數仍為正相關。故基本上，該國如富有污染密集較高的礦產類生產因素，則對輸出該礦產所製造的產業，具有相對的比較利益。而第二類的自然環境因素稟賦，除了空氣污染程度的虛擬變數具有與本文假設的負相關特性及統計上的顯著性外，其他的自然因素稟賦包括降雨量、森林面積比例等並非是良好的解釋變數。第三類的廣義環境因素稟賦，除了教有程度一項在三個檢定年度不具有統計上的顯著性，且正負相關會隨著時間而改變外，其他各迴歸係數或有統計上不顯著的缺點，但其趨向與本文假設的相關方向呈現一致。原則土是可以解釋該國為何發展某種污染密集程度的產業，尤其是在都市化程度、每人國內生產毛額兩項。另從三個檢定年度的迴歸係數觀之，其間的變化雖然不大，但是某些環境因素稟賦對一國出口貿易比較利益型態的影響，卻與日俱增（例如：每人國內生產毛額、都市化程度、空氣污染程度）。 　　　　4.根據外國文獻所整理收集的資料顯示，產業外移受到許多因素影響，而環境因素稟賦所造成約比較利益型態差異或環境政策之鬆緊不同祇是其原因之一。本文以經濟部投審會的資料所做的分析顯示，在1988年後，國人投資於泰國、印尼、馬來西亞、菲律賓等四國的高污染密集產業有明顯增加的趨勢。而在1991年方有統計資料的大陸地區投資，也同時顯示投資於該產業的金額與比例有遞增的趨勢。故純由數據顯示，從短期的觀點而言，高污染密集的產業確實有外移的現象，但是否表示因為近年來環保法規採高標準的緣故，仍值得更長期的觀察。

Intravenous line placement is one of the most common procedures performed on children presenting to the Emergency Department. Anxiety about needles is widespread, and many children experience high levels of fear and/or pain with their IV line placements. Hypnosis is a behavioral intervention that shows significant promise for alleviating procedure-related pain and anxiety in children. Twenty-five developmentally normal, English-speaking children between the ages of five and fifteen who required IV line placement in the Pediatric Emergency Department at Yale-New Haven Childrens Hospital were randomized to receive either the standard of care or standard of care plus a brief hypnotic intervention. The groups were similar with regard to baseline demographic and socioeconomic status, previous experience with medical care, and presence or absence of chronic medical conditions. Childrens pre-procedural anxiety ratings on a 10cm visual analog scale (VAS) and expected procedural pain ratings by 10-point oucher and 10cm VAS were not significantly different between the groups. Children randomized to the hypnosis group reported less anxiety during the procedure (mean 5.0 vs 3.1, median 7.2 vs 2.2, p = 0.28) than children randomized to the standard of care group. Cases also had a decrease in anxiety from expected to actual of 1.6 on a 10cm scale, while those randomized to the control group had an increase from expected to actual anxiety of 1.1 (p=0.01). A smaller trend towards decreased pain in the hypnosis group was also present. As measured by VAS, cases had lower mean pain scores (3.4 vs 4.3) than controls. In a comparison of anticipated and actual pain scores between groups, the hypnosis group had a mean decrease of 0.8 on a 10cm VAS , while the control group had a mean increase of 0.5 (p=0.14). Recruitment of subjects is ongoing, but preliminary results suggest that hypnosis is effective for alleviating needle-related anxiety in children undergoing IV line placement and may be helpful for alleviating the pain of IV line placement as well.

Thesis (M. Arch.)--University of Tennessee, Knoxville, 2009. / Title from title page screen (viewed on Mar. 11, 2010). Thesis advisor: William Rudd. Vita. Bailey appendix II.pdf (18364 KB) link located at bottom of [Article summary page]. Includes bibliographical references.

The pressure on tax haven countries to engage in tax information exchange shows first effects on capital markets. Empirical research suggests that investors do react to information exchange and partially withdraw from previous secrecy jurisdictions that open up to information exchange. While some of the economic literature emphasizes possible positive effects of tax havens, the present paper argues that proponents of positive effects may have started from questionable premises, in particular when it comes to the effects that tax havens have for emerging markets like China and India. (authors' abstract) / Series: WU International Taxation Research Paper Series

Submitted by Luciana Chalela (luciana.chalela@gmail.com) on 2013-08-28T20:02:38Z No. of bitstreams: 1 Tese_Luciana_Chalela.pdf: 1144874 bytes, checksum: 44035bb007d5e61c9867903ace28fdbc (MD5) / Approved for entry into archive by Suzinei Teles Garcia Garcia (suzinei.garcia@fgv.br) on 2013-08-28T20:07:46Z (GMT) No. of bitstreams: 1 Tese_Luciana_Chalela.pdf: 1144874 bytes, checksum: 44035bb007d5e61c9867903ace28fdbc (MD5) / Made available in DSpace on 2013-08-29T13:10:57Z (GMT). No. of bitstreams: 1 Tese_Luciana_Chalela.pdf: 1144874 bytes, checksum: 44035bb007d5e61c9867903ace28fdbc (MD5) Previous issue date: 2013-07-29 / International agreements arising from the need to deal with the global warming promoted by countries decided to embrace a climate change policy bring on the debate of the impacts on firms in a global competitive market. Facing, therefore, different environmental standards accordingly to firm’s physical location. Once European Union is taking the lead in adopting stringent environmental regulation, this study aims to assess the impact of environmental regulations on firms in Europe. A novel database was constructed providing firm-level air pollution emission information in the European Union. Using difference-in-difference model, the effect of the intervention of EU environmental policy change suggests a negative response in fixed assets among EU firms due to the 2006 EU policy. The evidence to the hypothesis that firms in European Union have been decreasing its firms fixed assets, as a proxy of production capacity, with the change in environmental regulation, provides general support for the PHH, however, it doesn’t remain in robustness checks. The contribution of this work is bringing a revisited view of the actual effect of environmental regulation based on Kyoto Protocol directives on European firms.

The Master's thesis is focused on tax optimalization through tax havens. The Master's thesis is divided into six parts. The first part generally outlines the problems of international tax optimalization. The next one defines concepts related to tax havens, use of tax havens and the fight against tax evasion. The third chapter concentrates on direct foreign investments, which are connected with holding companies. Information from this chapter is used in the following chapters. The practical part consists of two and shows the costs for establishment of a model subsidiary and the tax costs of the company for the first year of its running in chosen tax havens. These costs together with other information about chosen tax havens are analysed. Subsequently, a suitable location for the company in one of these destinations is suggested.