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318 result(s) for "CFCS"
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An analysis of controlled foreign company (CFC) rules of Mauritius; a comparative study with the UK and US
Purpose Numerous policies are established in Mauritius to attract foreign direct investment, but at the same time, severe concerns were raised concerning the erosion of Mauritian tax base, which is witnessed by the decrease in the percentage of tax revenue to gross domestic product in recent years. To avoid these issues, in 2019, the Mauritian legislator has domesticated the Organisation for Economic Co-operation and Development (OECD) BEPS 2013 Action 3 on controlled foreign company (CFC) in its income tax legislation. As such, the purpose of this study is to critically assess the implications of CFC rules of Mauritius to reduce tax avoidance in the light of international tax competition. Design/methodology/approach To achieve the research objective, this study will adopt a black letter approach by analysing the rules and regulations of various jurisdiction as well as international standards on CFCs and other tax avoidance legal provisions. A comparative analysis will be conducted between Mauritian laws on CFCs and the corresponding legislation of the UK and the USA, which are selected to assess the developed world’s position on strict CFC rules. Findings A hasty implementation of CFC rules leads to various complexities like interpretation issues and diminishing the competitiveness of the country to multinationals. In this respect, there is the risk of a trade-off between tax collected and foreign direct investment in the country. Consequently, the research recommends that Mauritius reforms its CFC legislation by extending the scope of tax exemptions for intra-group financing income, for the first year of CFC’s operation with the possibility of offsetting foreign taxes and for the Mauritius Revenue Authority to establish detailed guidelines on the determination of CFC income and its attribution for tax purposes in Mauritius. Originality/value Existing literature has to a great extent focused on the role of CFC rules as a tax avoidance measure and on the divergence or convergence between domestic CFC legislation against the OECD recommendations (Dourado, 2015; Xu, 2018; Beebeejaun et al., 2023). However, limited literature is available on the evaluation of the purpose of CFC rules enacted by a developing country being Mauritius in the context of the global competitive market, to which this research aims at filling the gap.
Advancing multifunctional carbon fibre composites: the role of nanomaterials in boosting electrochemical performance for energy storage
Carbon fibre composites (CFCs) hold significant promise for energy storage and harvesting applications owing to their exceptional strength-to-weight ratio and structural versatility, but their electrochemical performance is constrained by inherent limitations such as low surface area and restricted ion transport pathways. This review examines how strategic integration of nanomaterials—including graphene, carbon nanotubes and MXenes—can overcome these challenges by enhancing surface reactivity, improving electrical conductivity and facilitating efficient ion diffusion, thereby enabling high-performance multifunctional composites. We discuss key advances in nanomaterial-incorporated CFCs for structural batteries and supercapacitors, where tailored interfaces and hierarchical architectures contribute to superior energy and power densities, as well as their emerging role in integrated energy harvesting systems that combine energy storage with triboelectric, piezoelectric or thermoelectric conversion capabilities. The analysis further addresses critical manufacturing challenges related to nanomaterial dispersion, interfacial bonding and scalable processing, while evaluating solutions such as advanced deposition techniques and hybrid material designs. By systematically reviewing both fundamental mechanisms and practical considerations, this work provides insights into the development of next-generation smart composites that simultaneously achieve mechanical robustness and advanced electrochemical functionality for applications ranging from wearable electronics to electric vehicles and aerospace systems.
Cell-free circulating epimarks in cancer monitoring
Cancer numbers increasing, cases heterogeneity and the drug resistance emergence have pushed scientists to search for innovative solutions for patients and epimutations can be one. Methylated DNA, modified nucleosomes and noncoding RNAs are found in all cells, including tumor cells. They are intracellular actors but also have intercellular communication roles, being released in extracellular environment and in different body fluids. Here, we reviewed current literature on the use of these blood circulating epimarks in cancer monitoring. What stands out is that epimarkers must be considered as ‘real time’ images of the tumor, and can be isolated without invasive methods. In the future, the real challenge lies in the development of specific, sensitive, fast and clinically applicable detection and analysis methods of epimarkers.
Quantification of Phase-Amplitude Coupling in Neuronal Oscillations: Comparison of Phase-Locking Value, Mean Vector Length, Modulation Index, and Generalized-Linear-Modeling-Cross-Frequency-Coupling
Phase-amplitude coupling is a promising construct to study cognitive processes in electroencephalography (EEG) and magnetencephalography (MEG). Due to the novelty of the concept, various measures are used in the literature to calculate phase-amplitude coupling. Here, performance of the three most widely used phase-amplitude coupling measures - phase-locking value (PLV), mean vector length (MVL), and modulation index (MI) - and of the generalized linear modeling cross-frequency coupling (GLM-CFC) method is thoroughly compared with the help of simulated data. We combine advantages of previous reviews and use a realistic data simulation, examine moderators and provide inferential statistics for the comparison of all four indices of phase-amplitude coupling. Our analyses show that all four indices successfully differentiate coupling strength and coupling width when monophasic coupling is present. While the MVL was most sensitive to modulations in coupling strengths and width, only the MI and GLM-CFC can detect biphasic coupling. Coupling values of all four indices were influenced by moderators including data length, signal-to-noise-ratio, and sampling rate when approaching Nyquist frequencies. The MI was most robust against confounding influences of these moderators. Based on our analyses, we recommend the MI for noisy and short data epochs with unknown forms of coupling. For high quality and long data epochs with monophasic coupling and a high signal-to-noise ratio, the use of the MVL is recommended. Ideally, both indices are reported simultaneously for one data set.
Fuzzy ELECTRE and TOPSIS method to analyze the risk factors of tuberculosis
Tuberculosis (TB) is an infectious disease that mainly affects the lungs and it is caused by Mycobacterium tuberculosis bacteria. WHO reported that nearly 1.4 million people died of TB in 2019 and TB is one of the top 10 causes of death in the world. Over 95% of cases and deaths are occurring in developing countries and a lot of factors such as diabetes, immune problem, malnutrition, alcohol, active smoking, crowded places, HIV infection, air pollution, kidney diseases, cancer and tuberculosis treatment workers are linked to TB. So, it is our utmost interest is to analyze the risk factors of TB. Therefore, this present study intended to combine the salient features of ELECTRE and TOPSIS methods under a fuzzy environment to analyze the risk factors of TB. Moreover, the comparative analysis is demonstrated to find the most influencing risk factors of TB. Finally, the sensitivity analysis is also performed using the entropy method to verify the results.
A Modeling Study of Business English Students’ Intercultural Competitiveness and Strategies in the Belt and Road Initiative
Intercultural competitiveness is an important guarantee for Business English majors to show their advantages and grasp the opportunities of the times in the Belt and Road Initiative. This paper evaluates the cross-cultural competitiveness of business English majors by constructing the CFCS-TOPSIS model and proposes strategies to improve the cross-cultural competitiveness of business English majors in the Belt and Road Initiative based on the evaluation results. The evaluation system of cross-cultural competitiveness of business English students is constructed, while the CFCS algorithm is used to denazify the fuzzy-valued indexes, and the obtained indexes are used as input factors to calculate the TOPSIS model. The research is conducted on students who major in business English at a university and the current level of their intercultural competitiveness is measured and analyzed using statistical analysis methods. The results indicate that business English majors in this university have a good level of intercultural competitiveness, but their intercultural skills and values still require improvement. Cross-sectional comparison of the cross-cultural competitiveness of business English majors in 15 colleges and universities focusing on the construction of the Belt and Road, the values of U2, U5, U12, and U15 colleges and universities are 0.493, 0.536, 0.748, and 0.645, respectively. The indexes of understanding the international business environment (X1), cross-cultural communication theory (X2), and openness (X7) have the most significant influence on the cross-cultural competitiveness of business English majors. The most significant effect is caused by intercultural competitiveness.
Cardio-facio-cutaneous syndrome and gastrointestinal defects: report on a newborn with 19p13.3 deletion including the MAP 2 K2 gene
Background Cardio-facio-cutaneous syndrome (CFCS) belongs to RASopathies, a group of conditions caused by mutations in genes encoding proteins of the rat sarcoma/mitogen-activated protein kinase (RAS/MAPK) pathway. It is a rare syndrome, with about 300 patients reported. Main clinical manifestations include facial dysmorphisms, growth failure, heart defects, developmental delay, and ectodermal abnormalities. Mutations (mainly missense) of four genes ( BRAF , MAP 2 K1 , MAP 2 K2 , and KRAS ) have been associated to CFCS. However, whole gene deletions/duplications and chromosomal microdeletions have been also reported. Specifically, 19p13.3 deletion including MAP 2 K2 gene are responsible for cardio-facio-cutaneous microdeletion syndrome, whose affected subjects show more severe phenotype than CFCS general population. Case presentation Hereby, we report on a female newborn with prenatal diagnosis of omphalocele, leading to further genetic investigations through amniocentesis. Among these, array comparative genomic hybridization (a-CGH) identified a 19p13.3 microdeletion, spanning 1.27 Mb and including MAP 2 K2 gene. Clinical features at birth (coarse face with dysmorphic features, sparse and friable hair, cutaneous vascular malformations and hyperkeratotic lesions, interventricular septal defect, and omphalocele) were compatible with CFCS diagnosis, and further postnatal genetic investigations were not considered necessary. Soon after discharge, at around 1 month of life, she was readmitted to our Neonatal Intensive Care Unit due to repeated episodes of vomiting, subtending a hypertrophic pyloric stenosis (HPS) which was promptly identified and treated. Conclusions Our report supports the 19p13.3 microdeletion as a contiguous gene syndrome, in which the involvement of the genes contiguous to MAP 2 K2 may modify the patients’ phenotype. It highlights how CFCS affected subjects, including those with 19p13.3 deletions, may have associated gastrointestinal defects (e.g., omphalocele and HPS), providing further data on 19p13.3 microdeletion syndrome, and a better characterization of its genomic and phenotypic features. The complex clinical picture of such patients may be worsened by additional, and even precocious, life-threatening conditions like HPS. Clinicians must consider, anticipate and/or promptly treat possible medical and surgical complications, with the aim of reducing adverse outcomes. Extensive diagnostic work-up, and early, continuous, and multidisciplinary follow-up, as well as integrated care, are necessary for the longitudinal clinical evolution of any single patient.
FREQ‐NESS Reveals the Dynamic Reconfiguration of Frequency‐Resolved Brain Networks During Auditory Stimulation
The brain is a dynamic system whose network organization is often studied by focusing on specific frequency bands or anatomical regions, leading to fragmented insights, or by employing complex and elaborate methods that hinder straightforward interpretations. To address this issue, a new analytical pipeline named FREQuency‐resolved Network Estimation via Source Separation (FREQ‐NESS) is introduced. This pipeline is designed to estimate the activation and spatial configuration of simultaneous brain networks across frequencies by analyzing the frequency‐resolved multivariate covariance between whole‐brain voxel time series. In this study, FREQ‐NESS is applied to source‐reconstructed magnetoencephalography (MEG) data during resting state and isochronous auditory stimulation. Our results reveal simultaneous, frequency‐specific brain networks during resting state, such as the default mode, alpha‐band, and motor‐beta networks. During auditory stimulation, FREQ‐NESS detects: 1) emergence of networks attuned to the stimulation frequency, 2) spatial reorganization of existing networks, such as alpha‐band networks shifting from occipital to sensorimotor areas, 3) stability of networks unaffected by auditory stimuli. Furthermore, auditory stimulation significantly enhances cross‐frequency coupling, with the phase of auditory networks attuned to the stimulation modulating gamma band amplitude in medial temporal lobe networks. In conclusion, FREQ‐NESS effectively maps the brain's spatiotemporal dynamics, providing a comprehensive view of brain function by revealing a landscape of simultaneous, frequency‐resolved networks and their interaction. A new analytical pipeline, FREQuency‐resolved Network Estimation via Source Separation (FREQ‐NESS), reveals how the brain at rest is organized in frequency‐specific networks and dynamically rearranges during auditory stimulation. By analyzing source‐reconstructed magnetoencephalography (MEG) data, FREQ‐NESS uncovers the networks' prominence, spatial restructuring, and interaction via cross‐frequency coupling. This approach offers a comprehensive view of brain functioning, advancing the understanding of network dynamics.
Study the Impact of Carbon Fiber Chopped (CFC) on Pure Gypsum properties with variable water content
The purpose ofˑthis study is to evaluate the density and compressive strength characteristics of pure gypsum in order to ascertain the extent to which the use of Carbon-Fiber-Chopped (CFC) has an impact on these parameters. When dealing with gypsum in its purest form, four distinct combinations were used. As a result of the fact that the proportion of water to pure gypsum in the combinations is either 0.55 or 0.65, the combinations are separated into two different groups. Using the volume fraction ( Vfˑ) of 0.0 % and 0.4 % of CFC (pure gypsum with and without fibers), each group set is split into two unique groups. These groups are based on the volume fraction. Three samples, each measuring 5 centimeters by 5 centimeters by 5 centimeters, were employed for each admixture. Increasing and enhancing compressive strength for two distinct water / pure gypsum ratios (Wˑ/ˑPG) has been shown to be attainable by the use of CFC in pure gypsum mixtures. This was demonstrated on two separate occasions. Compressive strength grows at a pace that is directly proportional to the W/PG ratio, which is directly tied to the rate at which CFC is applied. When compared to the ratio, this rate is precisely proportional to it. It is also essential to keep in mind that an increase in the W/PG ratio results in a decrease in both the density and the compressive strength of the material. Regarding this particular matter, it is important to take it into mind. On the other hand, the be- havior of pure gypsum (with CFC) results in a decrease in the drop rate of decline in both density and compressive strength concurrently. This is as a result of the reaction between the two properties.
Multi-proxy (CFCs, Cl, δ18O and δD) assessment of the origin, residence time and recharge of groundwater in the Bilate River Basin (BRB) of Southern Main Ethiopian Rift (SMER)
The volcanic aquifer of Bilate River Basin (BRB) situated on the southwestern side of the Main Ethiopian Rift (MER) serves as the sole reservoir of water supply for urban and rural people found in the basin. This study investigates residence time and groundwater recharge process in the Bilate River Basin. For the first time, this research work delivers information on the resident time and groundwater recharge on the basis of multi-tracer approach (CFCs, Cl, δ 18 O and δD). The δ 18 O and δD values of groundwater are drawn along or close to local Addis Ababa Meteoric Water Line (AAMWL), indicating that groundwater recharge is of meteoric origin. CFC data show that the oldest component of groundwater was recharged before 1950, while the younger component recharged in different time as of 1950. The assigned apparent age for groundwater range from 24 to more than 50 years. Binary mixing model is used to estimate the age and fraction of the younger component. Mixing model suggest that groundwater consists young groundwater that mainly recharged the aquifer between the mid-1980s and mid-1990s. The proportion of young water in the groundwater shows decreasing trend from highland towards the rift indicating the main recharge area is the highland part. The chloride mass balance employed to Bilate River Basin calculated yearly average groundwater recharge to be 217 mm/y which accounted for 20% of the mean annual areal rainfall. The estimated recharge decrease from highland to the rift floor highlighting the importance of preferential flow recharge mechanism. The analysis of apparent age, young proportion and recharge rate, can aid in understanding complex groundwater flow system and residence time of groundwater in the complex hydrogeological setting of rift volcanic aquifer.