scholarly journals Taxation of Instagram Influencers

2021 ◽  
Vol 30 (2) ◽  
pp. 339
Author(s):  
Michal Radvan
Keyword(s):  
Developed Countries ◽  
Tax Law ◽  
Scientific Article ◽  
Structural Components ◽  
Labour Law ◽  
Tax Base ◽  
Tax Rate ◽  
Different Types ◽  
The Relationship ◽  
Specific Tax

<p>This scientific article discusses issues related to the taxation of Instagram influencers. Its main objective is to define how the influencers’ incomes should be taxed. To achieve this primary purpose, the partial objective is defined to give the list of (legal) cooperation contracts between the marketers and influencers. The hypothesis that there is no need to adopt new specific tax law norms to tax influencers’ incomes properly, at least in developed countries, was confirmed. All jurisdictions are taxing influencers’ incomes. It is always necessary to focus on the content of the relationship generating influencer’s income, as the principle of priority of content over form must be used. The tax liability is influenced only by the tax base. The tax rate and other structural components of the tax remain the same for different types of incomes. Generally, it is always better for the influencer to have a trading license (to be a businessman) than tax his/her incomes as incomes from copyright. Incomes from dependent activities based on labour law contract or occasional incomes are not probable for a typical influencer, and still, the taxation in this way is not really favourable. The novelty of the presented research lies in the fact that no scientific articles deal with the covered issues published so far. The author believes that the article has a cognitive value for both science and practice.</p>

scholarly journals The importance of knowledge for wellbeing of society in the contemporary world

2017 ◽  
Vol 28 (4) ◽  
pp. 1136-1159
Author(s):  
Dusan Markovic ◽  
Mrdjan Mladjan
Keyword(s):  
Developed Countries ◽  
Contemporary World ◽  
Types Of Knowledge ◽  
National Competitiveness ◽  
Long Run ◽  
New Knowledge ◽  
Physical Resources ◽  
Potential Problems ◽  
Different Types ◽  
The Relationship

Following the recent wave of globalization, the possession of different types of knowledge became even more important for economic development than the possession of physical resources. The ability of a society to adopt existing and create new knowledge thus gained fundamental importance for its wellbeing. In this paper, we identify important aspects of the relationship between education, creation of knowledge, economic growth, as well as both material and immate?rial wellbeing of a society. We describe potential problems that prevent societies from maximizing the benefit from the effort its members invest in acquiring knowledge. The problems of failure of the national markets for education as well as the global migrations which lead to drain of knowledge towards economically highly developed countries are especially analyzed. In the long run, they lead to a decline in both national competitiveness and different aspects of the immate?rial wellbeing. As the basis for solving these problems we propose a combination of economic theory and the concept of solidarity between more and less devel?oped countries, individuals and societies of their origin, respecting the free will of individuals.

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

The Dominant Voices in Double Taxation Agreements: A Critical Analysis of the “Dividend” Article in the Agreement between Uganda and the Netherlands

2009 ◽  
Vol 11 (4) ◽  
pp. 387-407 ◽  
Author(s):  
Jalia Kangave
Keyword(s):  
Developing Countries ◽  
Third World ◽  
Investment Decisions ◽  
Developed Countries ◽  
Tax Rates ◽  
Double Taxation ◽  
Tax Base ◽  
Tax Rate ◽  
Practical Reality ◽  
Rich Countries

AbstractIn a bid to attract foreign investment, Third World countries are increasingly concluding Double Taxation Treaties with capital-rich countries, based on either the UN model treaty convention or the OECD model. Using the example of the dividend Article in the Uganda-Netherlands treaty, the discussion in this article illustrates the increased use of tax treaties to shift income from developing to developed countries. By essentially reducing the tax rate on dividend income to nil, that treaty significantly erodes Uganda's tax base. Such agreements raise concern, especially when one takes into account the fact that investment decisions are often driven by factors external to tax, meaning that reduced tax rates do not guarantee increased investments. Worse still, because developing countries are net capital importers, the benefits accruing from such treaties are often one-sided. The paper calls for a rethinking and redrafting of the UN model convention to ensure that the taxing rights of Third World countries are strengthened. In addition, since the practical reality is that developed countries often base their agreements (even with developing countries) on the OECD model, there is a need to amend the latter model to take this reality into account.

THEORY OF LAW AND PHILOSOPHY OF LAW AS THEORETICAL DISCOURSES: SPECIFICS AND RELATIONSHIP

2020 ◽  
pp. 9-17
Author(s):  
Вадим Леонидович Афанасьевский
Keyword(s):  
Scientific Knowledge ◽  
Scientific Theory ◽  
Theoretical Concept ◽  
Philosophy Of Law ◽  
The West ◽  
Scientific Creativity ◽  
Key Characteristics ◽  
Different Types ◽  
Theory Of Law ◽  
The Relationship

В статье анализируется проблема взаимоотношений философии права и научной теории права. Рассматриваемая проблема стала особенно актуальной в российском образовательном пространстве в связи с введением после длительного перерыва в государственный образовательный стандарт магистратуры по юриспруденции учебной дисциплины «Философия права». Автор статьи в качестве базисного принимает тезис, согласно которому философия права, являясь сферой философской мысли, и теория права как область научного социогуманитарного знания представляют собой разные типы теоретического дискурса. Исходя из этого, в статье выстраивается теоретическая концепция, согласно которой задачей философии права как философского типа мышления является конструирование или экспликация онтологических, эпистемологических, аксиологических, феноменологических оснований для формирования и функционирования научных теоретико-правовых и историко-правовых построений. Для реализации поставленной в статье задачи подробно рассматриваются ключевые характеристики как теории философского типа, так и идеалов, норм и характеристик научного знания. Выявленное различие экстраполируется на взаимоотношение теории права как продукта научного творчества и философии права как конструкции, задающей базовые мировоззренческие смыслы. В качестве примера выработанных философией права и государства оснований научных теорий прогресса, государства, морали и права, автор приводит взгляды мыслителей западноевропейской философской классики: Т. Гоббса, Ж.-Ж. Руссо, И. Канта, Г.В.Ф. Гегеля. Именно их философские концепции предопределили образы теоретико- и историко-правовых учений XVIII, XIX, XX и даже начала XXI в. Таким образом, отношение философии права и теории права выстраивается по «вертикали»: от онтологического основания к возведению теоретико-правовых и историко-правовых научных построений. The article analyzes the problem of the relationship between the philosophy of law and the scientific theory of law. The problem under consideration has become especially urgent in the Russian educational space in connection with the introduction of the Philosophy of Law discipline master's degree in law after a long break. The author of the article takes as the basis the thesis that the philosophy of law, being the sphere of philosophical thought, and the theory of law as a field of scientific socio-humanitarian knowledge are different types of theoretical discourse. Based on this, the article builds a theoretical concept according to which the task of the philosophy of law as a philosophical type of thinking is the construction or explication of ontological, epistemological, axiological, phenomenological grounds for the formation and functioning of concrete scientific theoretical and legal and historical and legal constructions. To implement the task posed in the article, the key characteristics of both a theory of a philosophical type and ideals, norms and characteristics of scientific knowledge are examined in detail. The revealed difference is extrapolated to the relationship between the theory of law as a product of scientific creativity and the philosophy of law as a construction that sets basic philosophical meanings. As an example of the foundations of the scientific theories of progress, state, morality and law developed by the philosophy of law and the state, the author gives the views and thinkers of the West European philosophical classics T. Hobbes, J.-J. Russo, I. Kant, G.V.F. Hegel. It was their philosophical concepts that predetermined the images of theoretical and historical-legal doctrines of the XVIII, XIX, XX and even the beginning of the XXI centuries. Thus, the attitude of the philosophy of law and the theory of law is built along the «vertical»: from the ontological foundation to the construction of theoretical and historical and historical legal scientific constructions.

Characteristics of Different Types of Childhood Violence and the Risk of Revictimization

2019 ◽  
Vol 25 (14) ◽  
pp. 1696-1716 ◽  
Author(s):  
Ida Frugaard Stroem ◽  
Helene Flood Aakvaag ◽  
Tore Wentzel-Larsen
Keyword(s):  
Childhood Abuse ◽  
Telephone Survey ◽  
Regression Analyses ◽  
Multiple Forms ◽  
Different Types ◽  
Children And Young Adults ◽  
Childhood Violence ◽  
Forms Of Violence ◽  
The Relationship

This study investigates the relationship between the characteristics of different types of childhood violence and adult victimization using two waves of data from a community telephone survey (T1) and a follow-up survey, including 505 cases and 506 controls, aged 17-35 years (T2). The logistic regression analyses showed that exposure to childhood abuse, regardless of type, was associated with adult victimization. Exposure to multiple types of abuse, victimization both in childhood and in young adulthood, and recency of abuse increased these odds. Our findings emphasize the importance of assessing multiple forms of violence when studying revictimization. Practitioners working with children and young adults should be attentive to the number of victimization types experienced and recent victimization to prevent further abuse.

scholarly journals Endolysosomal Cation Channels and MITF in Melanocytes and Melanoma

Biomolecules ◽  
2021 ◽  
Vol 11 (7) ◽  
pp. 1021
Author(s):  
Carla Abrahamian ◽  
Christian Grimm
Keyword(s):  
Breast Cancer ◽  
Gene Expression ◽  
Transcription Factor ◽  
Convincing Evidence ◽  
Signaling Cascades ◽  
Cation Channels ◽  
Pore Channel ◽  
Different Types ◽  
Canonical Wnt ◽  
The Relationship

Microphthalmia-associated transcription factor (MITF) is the principal transcription factor regulating pivotal processes in melanoma cell development, growth, survival, proliferation, differentiation and invasion. In recent years, convincing evidence has been provided attesting key roles of endolysosomal cation channels, specifically TPCs and TRPMLs, in cancer, including breast cancer, glioblastoma, bladder cancer, hepatocellular carcinoma and melanoma. In this review, we provide a gene expression profile of these channels in different types of cancers and decipher their roles, in particular the roles of two-pore channel 2 (TPC2) and TRPML1 in melanocytes and melanoma. We specifically discuss the signaling cascades regulating MITF and the relationship between endolysosomal cation channels, MAPK, canonical Wnt/GSK3 pathways and MITF.

scholarly journals Time series analysis of the relationship between diarrhea in children and Rota 2 vaccine in the Fanteakwa District of the eastern region of Ghana

2021 ◽  
Vol 21 (1) ◽  
Author(s):  
James Atampiiga Avoka ◽  
Elvis J. Dun-Dery ◽  
Issah Seidu ◽  
Armel N. E. Abou ◽  
Paul Twene ◽  
...  
Keyword(s):  
Pearson Correlation ◽  
Developed Countries ◽  
Seasonal Effects ◽  
Eastern Region ◽  
Least Developed Countries ◽  
R Software ◽  
Significant Difference ◽  
Severe Gastroenteritis ◽  
Access To Medical Care ◽  
The Relationship

Abstract Background Rotavirus is considered the main causal factor of severe gastroenteritis among infants and children globally. The association with severe rotavirus infection is mostly worse among the least developed countries, mainly due to inadequate access to medical care and poverty. This study was conducted to determine the seasonal effects in respect of diarrhea cases in children, the association between diarrhea cases and Rota2 vaccine in the Fanteakwa District of the Eastern Region of Ghana. Methods The study compares monthly diarrhea cases against children vaccinated with Rota2 extracted from DHIMS2 spanning May 2012 to December 2017 in Fanteakwa District. A univariate association between diarrhea cases and children vaccinated with Rota 2 was conducted using the R-software version 3.4.4 with the use of forecast, tseries and TSAPred. Pearson Correlation coefficient was also computed between monthly diarrhea cases and Rota 2 as well as lagged values of Rota 2 and Diarrhea cases. Results The study shows that February recorded the highest average number of diarrhea cases (172) over the period 2012 to 2017 with a standard deviation of 59. However, a one-way analysis of variance shows a significant difference amongst the monthly averages with an F-statistic of 0.042 and P-value of 0.064. It is observed that the correlations between each of the Rota2 doses and the lagged cases are positive, showing higher Rota2 doses a month ago ((Xt − 1),0.346 to0.735), two months ago ((Xt − 2),0.383 to 0.746), three months ago ((Xt − 3), 0.330 to 0.737) and four months ago ((Xt − 4), 0.236 to 0.723) are associated with lower diarrhea cases. The results also show that an increase in the previous two month’s Rota2 figures by 100 is associated with a significant decrease in the currently expected diarrhea cases by approximately 36. Conclusion Seasonal variations exist in the occurrence of diarrhea in children, with January recording the highest number of diarrhea cases (172). There is a relationship between episodes of diarrhea in children and Rota2 (p-value = 0.064); thus, the more children are vaccinated with Rota2, the less diarrhea cases are recorded. Diarrhea cases in Fanteakwa district are generally low, except 2013 and 2016 where the cases are higher than the rest of the other years.

scholarly journals More than a method: trusting relationships, productive tensions, and two-way learning as mechanisms of authentic co-production

2021 ◽  
Vol 7 (1) ◽  
Author(s):  
Sarah E. Knowles ◽  
Dawn Allen ◽  
Ailsa Donnelly ◽  
Jackie Flynn ◽  
Kay Gallacher ◽  
...  
Keyword(s):  
Patient Involvement ◽  
Ways Of Knowing ◽  
Knowledge Mobilisation ◽  
Academic Knowledge ◽  
Willingness To Change ◽  
Different Types ◽  
Hybrid Knowledge ◽  
Key Issues ◽  
Field Notes ◽  
The Relationship

Abstract Background Knowledge mobilisation requires the effective elicitation and blending of different types of knowledge or ways of knowing, to produce hybrid knowledge outputs that are valuable to both knowledge producers (researchers) and knowledge users (health care stakeholders). Patients and service users are a neglected user group, and there is a need for transparent reporting and critical review of methods used to co-produce knowledge with patients. This study aimed to explore the potential of participatory codesign methods as a mechanism of supporting knowledge sharing, and to evaluate this from the perspective of both researchers and patients. Methods A knowledge mobilisation research project using participatory codesign workshops to explore patient involvement in using health data to improve services. To evaluate involvement in the project, multiple qualitative data sources were collected throughout, including a survey informed by the Generic Learning Outcomes framework, an evaluation focus group, and field notes. Analysis was a collective dialogic reflection on project processes and impacts, including comparing and contrasting the key issues from the researcher and contributor perspectives. Results Authentic involvement was seen as the result of “space to talk” and “space to change”. "Space to talk" refers to creating space for shared dialogue, including space for tension and disagreement, and recognising contributor and researcher expertise as equally valuable to the discussion. ‘Space to change’ refers to space to adapt in response to contributor feedback. These were partly facilitated by the use of codesign methods which emphasise visual and iterative working, but contributors emphasised that relational openness was more crucial, and that this needed to apply to the study overall (specifically, how contributors were reimbursed as a demonstration of how their input was valued) to build trust, not just to processes within the workshops. Conclusions Specific methods used within involvement are only one component of effective involvement practice. The relationship between researcher and contributors, and particularly researcher willingness to change their approach in response to feedback, were considered most important by contributors. Productive tension was emphasised as a key mechanism in leading to genuinely hybrid outputs that combined contributor insight and experience with academic knowledge and understanding.

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