1,720,982 research outputs found
La residenza delle società dotate di personalità giuridica ai fini delle imposte dirette in base al diritto tributario interno e alle convenzioni per evitare le doppie imposizioni sottoscritte dall'Italia
Full text linkThe paper analyzes the notion of residence provided for by Italian domestic law, doctrine and jurisprudence. It also analyses the issue of the interaction of the residence concept with that of “management and coordination” which is a typical feature of multinational group of enterprises. More precisely, an analysis has been conducted in order to ascertain if and in what measure the “management and coordination” feature may have an impact on the issue of residence as interpreted in Italy.
The analysis also concern the notion of residence in the context of the OECD Model to conclude that this notion mainly rests on the requirement of the liability to tax.
Particular emphasis has been given to the ascertainment of the true meaning of the concept of place of effective management reported in Art. 4(3). In this respect, an in-dept historical analysis has been conducted with respect to the relevant League of Nations’ and OEEC’s (subsequently become OECD) documents.
The (ab)use of double resident companies in triangular situation is deeply analyzed with respect to principles set out in the jurisprudence of some important States as well as on those ultimately expressed by the OECD in the 2008 Model Commentary and the OECD position has been criticised.
Moreover, with particular reference to Italy, an extensive analysis has been carried out with respect to the double tax treaties entered into by it that somehow deviate from the OECD Model Convention with respect to the residence of companies especially in cases of dual resident companies.
Finally, in relation to some features of the Italian income tax law, the access to double tax treaties has been verified with particular reference to entities which have opted for the tax consolidation (consolidato fiscale) or for the tax transparency (trasparenza fiscale) regimes
Conformational studies by dynamic NMR Spectroscopy. Part 96: Stereomutations of highly hindered naphthylphenyl atropisomers in solution and in the solids.
No full textWhen a benzene ring bears two 2-methyl-1-naphthyl moieties in the para, meta or ortho positions as in 1,4-bis(2-methyl-1-naphthyl)benzene, 1, 1,3-bis(2-methyl-1-naphthyl)benzene, 2 and 1,2-bis(2-methyl-1-naphthyl)benzene 3, two rotational isomers (atropisomers) are generated, with the two naphthyl substituents in a syn or anti relationship. In the case of the para and meta derivatives (1 and 2, respectively) these atropisomers could not be separated but were detected by NMR spectroscopy, that also allowed the determination of their syn-anti interconversion barriers in solution (19.5 and 20.4 kcal mol-1, respectively) and, in the case of 2, also in the solid state (26.7 kcal mol-1). In the more hindered ortho derivative 3, the syn (meso) and anti (racemic) atropisomers interconvert in solution with a barrier (31.2 kcal mol-1) sufficiently high to allow their physical separation. The racemic form could also be separated (by enantioselective HPLC) into the PP and MM enantiomers. Analysis of the corresponding CD spectra allowed the assignment of the absolute configuration. When three such naphthyl substituents are bonded to the phenyl in a meta relationship, two atropisomers in statistical proportions were observed: the anti (Cs symmetry) and the syn (C3v symmetry) display a 3:1 ratio at the equilibrium in solution. This ratio is different in the solid state, as is the interconversion barrier (22.1 and 32.1 kcal mol-1 in solution and in the solid, respectively
Conformational Studies by Dynamic NMR. 97.Structure, Conformation, Stereodynamics and Enantioseparation of Aryl Substituted Norbornanes.
Full text linkCAN 140:163414 AN 2003:996217 CAPLUS (COPYRIGHT (C) 2008 ACS ON SCIFINDER (R))
ABSTRACT
THE STRUCTURE OF A 1,7,7-TRIARYLNORBORNANE (I) HAS BEEN DETD. BY X-RAY DIFFRACTION AND WAS FOUND ESSENTIALLY EQUAL TO THAT PREDICTED BY MOL. MECHANICS CALCNS. RESTRICTED ROTATION OF THE ARYL GROUPS ALSO HAS BEEN OBSD. BY DYNAMIC NMR SPECTROSCOPY IN THIS COMPD. AND IN A NO. OF ANALOGOUSLY SUBSTITUTED NORBORNANES. THE ARYL-NORBORNANE BOND ROTATION BARRIERS WERE MEASURED BY LINE SHAPE ANAL. OF THE 13C NMR SPECTRA OBTAINED AT TEMPS. LOWER THAN -100 °C AND WERE FOUND TO COVER THE RANGE 6.0 TO 7.9 KCAL MOL-1. AN EXCEPTION WAS THE ROTATION INVOLVING THE O-ANISYL GROUP IN II, WHICH OCCURS NEAR AMBIENT TEMP. SINCE THE CORRESPONDING BARRIER IS MUCH HIGHER (14.4 KCAL MOL-1). IN ONE CASE (III) CONFIGURATIONAL ENANTIOMERS COULD BE SEPD. BY CHIRAL HPLC AND THE CORRESPONDING CD SPECTRA RECORDED
Amore, lutto, poesia: Adone e l’elegia pastorale
No full textStudio dell'irraggiamento 'architestuale' del mito di Adone esaminato nella sua fase più antica, attraverso l'analisi dei testi che concorrono ad alimentare la tradizione della successiva 'elegia pastorale' (in particolare l'Epitafio di Adone di Bione di Smirne e la sua prima riscrittura da parte dell'anonimo autore di [Mosco] 3)
Octa-1,7-diene-4,5-diamine Derivatives: Useful Intermediates for the Stereoselective Synthesis of Nitrogen Heterocycles and Ligands for Asymmetric Catalysis
No full textThe octa-1,7-diene-4,5-diamine skeleton is usually prepared by the addition of allylic organometallic reagents to glyoxal diimines. The relative and absolute configurations of the C4 and C5 stereocenters are dependent on the nature of the (chiral) nitrogen substituents. These compounds are useful intermediates for the construction of NHC carbene complexes and nitrogen heterocycles, such as 2,2′-bipyrrolidines, 2,5-diazabicyclo[2.2.1]heptanes, amino- and hydroxy-substituted 7-azanorbornane, and diamino-substituted cyclohexanols and cyclohexanediols
Oblio e memoria di Adone, o: dell’invincibile forza delle cose fragili
No full textPresentazione del volume "Fragilità di Adone" e considerazioni preliminari sui caratteri generali della tradizione adonia, in particolare in riferimento alla prospettiva interdisciplinare adottata nel volume
Going Beyond Counting First Authors in Author Co-citation Analysis
Full text linkThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Variations on the Author
Full text link“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
Full text linkWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
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