The inherent international tax regime and its constraints on Australia's sovereignty

Neither an international tax, nor an international taxing body exists. Rather, there are domestic taxing rules adopted by jurisdictions which, coupled with double tax treaties, apply to cross-border transactions and international taxation issues. International bodies such as the OECD and UN, which provide guidance on tax issues, often steer and supplement these domestic adoptions but have no binding international taxing powers. These pragmatic realities, together with the specific use of the word ‘regime’ within the tax community, lead many to argue that an international tax regime does not exist. However, an international tax regime should be defined no differently to any other area of international law and when we step outside the confines of tax law to consider the definition of a ‘regime’ within international relations it is possible to demonstrate that such a regime is very real. The first part of this article, by defining an international tax regime in a broader and more traditional context, also outlining both the tax policy and principles which frame that regime, reveals its existence. Once it is accepted that an international tax regime exists, it is possible to consider its adoption by jurisdictions and subsequent constraints it places on them. Using the proposed changes to transfer pricing laws as the impetus for assessing Australia’s adoption of the international tax regime, the constraints on sovereignty are assessed through a taxonomy of the level adoption. This reveals the subsequent constraints which flow from the broad acceptance of an international tax regime through to the specific adoption of technical detail. By undertaking this analysis, the second part of this article demonstrates that Australia has inherently adopted an international tax regime, with a move towards explicit adoption and a clear embedding of its principles within the domestic tax legislation.

Improvising a future in the performing arts : a new strategy to help performance studies students successfully shift between academic culture, professional culture, industry and career?

If there is one thing performance studies graduates should be good at, it is improvising – play and improvisation are central to the contemporary and cultural performance practices we teach and the methods by which we teach them. Objective, offer, acceptance, advancing, reversing, character, status, manipulation, impression management, relationship management – whether we know them from Keith Johnson’s theatre theories or Erving Goffman’s theatre theories, the processes by which we play out a story, scenario or social situation to our own benefit are familiar. We understand that identity, action, interaction and its personal, aesthetic, professional or political outcomes are unpredictable, and that we need to adapt to changeable and uncertain circumstances to achieve our aims. Intriguingly, though, in a Higher Education environment that increasingly emphasises employability, skills in play, improvisation and self-performance are never cited as critical graduate attributes. Is the ability to play, improve and produce spontaneous new self-performances learned in the academy worth articulating into an ability to play, improvise and product spontaneous new self-performances after graduates leave the academy and move into the role of a performing arts professional in industry? A study of the career paths of our performance studies graduates over the past decade suggests that addressing the challenges they face in moving between academic culture, professional culture, industry and career in terms of improvisation and play principles may be very productive. In articles on performing arts careers, graduates are typically advised to find a market for their work, and develop career self-management, management and marketing skills, together with an ability to find, make and maintain relationships and opportunities for themselves. Transitioning to career is cast as a challenging process, requiring these skills, because performing arts careers do not offer the security, status and stability of other careers. Our data confirms this. In our study, though, we found that strategies commonly used to build the resilience, self-reliance and persistence graduates require – talking about portfolio careers, parallel careers, and portable, transferable or translatable skills, for example – can engender panic as easily as they engender confidence. In this paper, I consider what happens when we re-articulate some of the skills scholars and industry stakeholders argue are critical in allowing graduates to shift successfully from academy to industry in terms of skills like improvisation, play and self-performance that are already familiar, meaningful and much-practiced amongst performance studies graduates.

Compass points : the locations, landscapes and coordinates of identities in contemporary performance making : proceedings of the Australasian Association for Theatre, Drama & Performance Studies (ADSA) Conference 2012

Compass Points: The Locations, Landscapes and Coordinates of Identities' the Australasian Association for Theatre, Drama and Performance Studies (ADSA) Conference 2012 was held at Queensland University of Technology, July 3-6 2012. The Conference was sponsored by the Australasian Association for Theatre, Drama and Performance Studies (ADSA), Queensland University of Technology (QUT), Ian Potter Foundation, Arts Queensland, La Boite Theatre Company and Queensland Theatre Company. The papers selected for this collection represent a small sample of the scope, depth and diversity of scholarship presented at the conference - they cover a range of genres, cultures and contexts in contemporary performance making from autobiography, to playwrighting, to public space performance and beyond. The papers collected have been peer-reviewed to Australia’s Department of Education, Science and Training (DEST) standards - each has been subject to two blind reviews, followed by acceptance, rejection or revision, and editing of accepted papers - by colleagues from Australasia and overseas. The review process for the conference publication was separate from the review process for acceptance of abstracts for the actual conference presentations. The conference convenors, Bree Hadley and Caroline Heim, edited the collection, and would like to thank all those who gave their time to advise on the peer review process and act as reviewers - Tom Burvill, Christine Comans, Sean Edgecomb, Angela Campbell, Natalie Lazaroo, Jo Loth, Meg Mumford, Ulrike Garde, Laura Ginters, Andre Bastian, Sam Trubridge, Delyse Ryan, Georgia Seffrin, Gillian Arrighi, Rand Hazou, Rob Pensalfini, Sue Fenty-Studham, Mark Radvan, Rob Conkie, Kris Plummer, Lisa Warrington, Kate Flaherty, Bryoni Tresize, Janys Hayes, Lisa Warrington, Teresa Izzard, Kim Durban, Veronica Kelly, Adrian Keirnander, James Davenport, Julie Robson and others. We, and the authors, appreciate the rigour and care with which peers have approached the scholarship presented here. This collection was published in final form on July 3rd 2012, the first day of the ADSA Conference 2012.

Prediction of transcriptional regulatory interactions in bacteria : a comparative genomics approach

Exponential growth of genomic data in the last two decades has made manual analyses impractical for all but trial studies. As genomic analyses have become more sophisticated, and move toward comparisons across large datasets, computational approaches have become essential. One of the most important biological questions is to understand the mechanisms underlying gene regulation. Genetic regulation is commonly investigated and modelled through the use of transcriptional regulatory network (TRN) structures. These model the regulatory interactions between two key components: transcription factors (TFs) and the target genes (TGs) they regulate. Transcriptional regulatory networks have proven to be invaluable scientific tools in Bioinformatics. When used in conjunction with comparative genomics, they have provided substantial insights into the evolution of regulatory interactions. Current approaches to regulatory network inference, however, omit two additional key entities: promoters and transcription factor binding sites (TFBSs). In this study, we attempted to explore the relationships among these regulatory components in bacteria. Our primary goal was to identify relationships that can assist in reducing the high false positive rates associated with transcription factor binding site predictions and thereupon enhance the reliability of the inferred transcription regulatory networks. In our preliminary exploration of relationships between the key regulatory components in Escherichia coli transcription, we discovered a number of potentially useful features. The combination of location score and sequence dissimilarity scores increased de novo binding site prediction accuracy by 13.6%. Another important observation made was with regards to the relationship between transcription factors grouped by their regulatory role and corresponding promoter strength. Our study of E.coli ��70 promoters, found support at the 0.1 significance level for our hypothesis | that weak promoters are preferentially associated with activator binding sites to enhance gene expression, whilst strong promoters have more repressor binding sites to repress or inhibit gene transcription. Although the observations were specific to �70, they nevertheless strongly encourage additional investigations when more experimentally confirmed data are available. In our preliminary exploration of relationships between the key regulatory components in E.coli transcription, we discovered a number of potentially useful features { some of which proved successful in reducing the number of false positives when applied to re-evaluate binding site predictions. Of chief interest was the relationship observed between promoter strength and TFs with respect to their regulatory role. Based on the common assumption, where promoter homology positively correlates with transcription rate, we hypothesised that weak promoters would have more transcription factors that enhance gene expression, whilst strong promoters would have more repressor binding sites. The t-tests assessed for E.coli �70 promoters returned a p-value of 0.072, which at 0.1 significance level suggested support for our (alternative) hypothesis; albeit this trend may only be present for promoters where corresponding TFBSs are either all repressors or all activators. Nevertheless, such suggestive results strongly encourage additional investigations when more experimentally confirmed data will become available. Much of the remainder of the thesis concerns a machine learning study of binding site prediction, using the SVM and kernel methods, principally the spectrum kernel. Spectrum kernels have been successfully applied in previous studies of protein classification [91, 92], as well as the related problem of promoter predictions [59], and we have here successfully applied the technique to refining TFBS predictions. The advantages provided by the SVM classifier were best seen in `moderately'-conserved transcription factor binding sites as represented by our E.coli CRP case study. Inclusion of additional position feature attributes further increased accuracy by 9.1% but more notable was the considerable decrease in false positive rate from 0.8 to 0.5 while retaining 0.9 sensitivity. Improved prediction of transcription factor binding sites is in turn extremely valuable in improving inference of regulatory relationships, a problem notoriously prone to false positive predictions. Here, the number of false regulatory interactions inferred using the conventional two-component model was substantially reduced when we integrated de novo transcription factor binding site predictions as an additional criterion for acceptance in a case study of inference in the Fur regulon. This initial work was extended to a comparative study of the iron regulatory system across 20 Yersinia strains. This work revealed interesting, strain-specific difierences, especially between pathogenic and non-pathogenic strains. Such difierences were made clear through interactive visualisations using the TRNDifi software developed as part of this work, and would have remained undetected using conventional methods. This approach led to the nomination of the Yfe iron-uptake system as a candidate for further wet-lab experimentation due to its potential active functionality in non-pathogens and its known participation in full virulence of the bubonic plague strain. Building on this work, we introduced novel structures we have labelled as `regulatory trees', inspired by the phylogenetic tree concept. Instead of using gene or protein sequence similarity, the regulatory trees were constructed based on the number of similar regulatory interactions. While the common phylogentic trees convey information regarding changes in gene repertoire, which we might regard being analogous to `hardware', the regulatory tree informs us of the changes in regulatory circuitry, in some respects analogous to `software'. In this context, we explored the `pan-regulatory network' for the Fur system, the entire set of regulatory interactions found for the Fur transcription factor across a group of genomes. In the pan-regulatory network, emphasis is placed on how the regulatory network for each target genome is inferred from multiple sources instead of a single source, as is the common approach. The benefit of using multiple reference networks, is a more comprehensive survey of the relationships, and increased confidence in the regulatory interactions predicted. In the present study, we distinguish between relationships found across the full set of genomes as the `core-regulatory-set', and interactions found only in a subset of genomes explored as the `sub-regulatory-set'. We found nine Fur target gene clusters present across the four genomes studied, this core set potentially identifying basic regulatory processes essential for survival. Species level difierences are seen at the sub-regulatory-set level; for example the known virulence factors, YbtA and PchR were found in Y.pestis and P.aerguinosa respectively, but were not present in both E.coli and B.subtilis. Such factors and the iron-uptake systems they regulate, are ideal candidates for wet-lab investigation to determine whether or not they are pathogenic specific. In this study, we employed a broad range of approaches to address our goals and assessed these methods using the Fur regulon as our initial case study. We identified a set of promising feature attributes; demonstrated their success in increasing transcription factor binding site prediction specificity while retaining sensitivity, and showed the importance of binding site predictions in enhancing the reliability of regulatory interaction inferences. Most importantly, these outcomes led to the introduction of a range of visualisations and techniques, which are applicable across the entire bacterial spectrum and can be utilised in studies beyond the understanding of transcriptional regulatory networks.

The challenges in developing a strategic approach to managing diversity

Diversity management is recognised as a major challenge for organizations throughout the world. There is broad acceptance that when it comes to all aspects of workforce management major differences exist among individuals in terms of age, gender, national origin, physical capability, sexuality, religion and others. This chapter discusses the concept, meaning and application of managing that difference or ‘diversity’ through programs known as diversity management. It identifies and discusses the different contextual and theoretical approaches that frame diversity programs found in organizations today. A number of programs within different country contexts are examined. The discussion examines the challenges of diversity management its programs and its outcomes with a view to understanding the lessons learned and recommending future directions.

A new classification and database for stratospheric dust particles

With the increasing number of stratospheric particles available for study (via the U2 and/or WB57F collections), it is essential that a simple, yet rational, classification scheme be developed for general use. Such a scheme should be applicable to all particles collected from the stratosphere, rather than limited to only extraterrestial or chemical sub-groups. Criteria for the efficacy of such a scheme would include: (a) objectivity , (b) ease of use, (c) acceptance within the broader scientific community and (d) how well the classification provides intrinsic categories which are consistent with our knowledge of particle types present in the stratosphere.

Positive experiences for participants in suicide bereavement groups : a grounded theory model of elements that contribute to the process of adjusting to the loss

Grounded Theory was used to examine the experiences of 13 participants who had attended psycho-educational support groups for those bereaved by suicide. Results demonstrated core and central categories which fit well with group therapeutic factors developed by Yalom (1995) and emphasised the importance of universality, imparting information and instilling hope, catharsis and self-disclosure, and broader meaning making processes surrounding acceptance or adjustment. Participants were commonly engaged in a lengthy process of oscillating between loss oriented and restoration focused reappraisals. The functional experience of the group comprised feeling normal within the group, providing a sense of permission to feel and to express emotions and thoughts and to bestow meaning. Structural variables of information and guidance and different perspectives on the suicide and bereavement were gained from other participants, the facilitators, group content and process. Personal changes, including in relationships and in their sense of self, assisted participants to develop an altered and more positive personal narrative.

Immigrants and the utilization of hospital emergency departments

BACKGROUND: Immigrants with language barriers are at high risk of having poor access to health care services. However, several studies have indicated that immigrants tend to use emergency departments (EDs) as their primary source of care at the expense of primary care. This may place an additional burden on already overcrowded EDs and lead to a low level of patient satisfaction with ED care. The study was to review if immigrants utilize ED care differently from host populations and to assess immigrants’ satisfaction with ED care. DATA SOURCES: Studies about immigrants' utilization of EDs in Australia and worldwide were reviewed. RESULTS: There are confl icting results in the literature about the pattern of ED care use among immigrants. Some studies have shown higher utilization by immigrants compared to host populations and others have shown lower utilization. Overall, immigrants use ED care heavily, make inappropriate visits to EDs, have a longer length of stay in EDs, and are less satisfi ed with ED care as compared to host populations. CONCLUSIONS: Immigrants might use ED care differently from host populations due to language and cultural barriers. There is sparse Australian literature regarding immigrants' access to health care including ED care. To ensure equity, further research is needed to inform policy when planning health care provision to immigrants. KEY WORDS: Emergency department; Health service; Immigrants; Language; Utilization

Policy, citizenship and governance : the case of disability and employment policy in Australia

Current discussions regarding the relationship between welfare governance systems and employment promotion in disability policy appeal to a rejuvenated neo-liberal and paternalistic understanding of welfare governance. At the core of this rationality is the argument that people with disabilities not only have rights, but also duties, in relation to the State. In the Australia welfare system, policy tools are deployed to produce a form of self-discipline, whereby the State emphasises personal responsibility via assessment tools, ‘mutual obligation’ policy, and motivational strategies. Drawing on a two-year semi-longitudinal study with 80 people with a disability accessing welfare benefits, we examine how welfare governance subject recipients to strategies to produce productive citizens who are able to contribute to the national goal of maintaining competitiveness in the global economy. Participants’ interviews reveal the intended and unintended effects of this activation policy, including some acceptance of the logic of welfare-to-work and counter-hegemonic resistance to de-valued social identities.

The factor structure of the COPE Questionnaire in a sample of clinically depressed and anxious adults

The Coping Orientation to Problems Experienced is a multidimensional scale designed to assess how people respond to stress. The COPE has been validated in a variety of populations displaying variations in factor structure. However, in terms of mental health populations, it has only been validated in alcohol-dependent samples. This paper investigated the factor structure of the COPE in a sample of adults diagnosed with depression and anxiety. Two hundred and seventy-one patients attending cognitive behaviour therapy for anxiety and depression completed the COPE. Confirmatory factor analysis found a poor fit for both lower order and higher order factors based upon the Lyne and Roger (2000) study. Exploratory factor analyses identified six primary subscales (Active Planning, Social Support, Denial, Acceptance, Disengagement, Restraint) which explained approximately 60% of the variance in coping. These 6 subscales may assist researchers and clinicians to validly measure coping in anxious and depressed adults.

Toddlers’ food preferences : the impact of novel food exposure, maternal preferences and food neophobia

Food preferences have been identified as a key determinant of children’s food acceptance and consumption. The aim of this study was to identify factors that influence children’s liking for fruits, vegetables and non-core foods. Participants were Australian mothers (median age at delivery=31 years, 18-46 years) and their two-year-old children (M=25 months, SD=1 month; 52% female) allocated to the control group (N=230) of the NOURISH RCT. The effects of repeated exposure to new foods, maternal food preferences and child food neophobia on toddlers’ liking of vegetables, fruits and non-core foods and the proportion never tried were examined via hierarchical regression models; adjusting for key maternal (age, BMI, education) and child covariates (birth weight Z-score, gender), duration of breastfeeding and age of introduction to solids. Maternal preferences corresponded with child preferences. Food neophobia among toddlers was associated with liking fewer vegetables and fruits, and trying fewer vegetables. Number of repeated exposures to new food was not significantly associated with food liking at this age. Results highlight the need to: (i) encourage parents to offer a wide range of foods, regardless of their own food preferences, and (ii) provide parents with guidance on managing food neophobia.

Elaborated intrusion theory : a cognitive-emotional theory of food craving

A clear understanding of the cognitive-emotional processes underpinning desires to overconsume foods and adopt sedentary lifestyles can inform the development of more effective interventions to promote healthy eating and physical activity. The Elaborated Intrusion Theory of Desires offers a framework that can help in this endeavor through its emphases on the roles of intrusive thoughts and elaboration of multisensory imagery. There is now substantial evidence that tasks that compete for limited working memory resources with food-related imagery can reduce desires to eat that food, and that positive imagery can promote functional behavior. Meditation mindfulness can also short-circuit elaboration of dysfunctional cognition. Functional Decision Making is an approach that applies laboratory-based research on desire, to provide a motivational intervention to establish and entrench behavior changes, so healthy eating and physical activity become everyday habits.

Extending the explanatory utility of the EPPM beyond fear-based persuasion

In the 20 years since its inception, the EPPM has attracted much empirical support. Currently, and unsurprisingly given that is a model of fear-based persuasion, the EPPM’s explanatory utility has been based only upon fear-based messages. However, an argument is put forth herein, which draws upon existing evidence, that the EPPM may be an efficacious framework for explaining the persuasive process and outcomes of emotion-based messages more broadly when such messages are addressing serious health topics. For the current study, four different types of emotional appeals were purposefully devised and included a fear, an annoyance/agitation, a pride, and a humour-based message. All messages addressed the serious health issue of road safety, and in particular the risky behaviour of speeding. Participants (N = 551) were exposed to only one of the four messages and subsequently provided responses within a survey. A series of 2 (threat: low, high) x 2 (efficacy: low, high) analysis of variance was conducted for each of the appeals based on the EPPM’s message outcomes of acceptance and rejection. Support was found for the EPPM with a number of main effects of threat and efficacy emerging, reflecting that, irrespective of emotional appeal type, high levels of threat and efficacy enhanced message outcomes via maximising acceptance and minimising rejection. Theoretically, the findings provide support for the explanatory utility of the EPPM for emotion-based health messages more broadly. In an applied sense, the findings highlight the value of adopting the EPPM as a framework when devising and evaluating emotion-based health messages for serious health topics.

Mediating identity narratives : a case study in queer digital storytelling as everyday activism

Digital Stories are short autobiographical documentaries, often illustrated with personal photographs and narrated in the first person, and typically produced in group workshops. As a media form they offer ‘ordinary people’ the opportunity to represent themselves to audiences of their choosing; and this amplification of hitherto unheard voices has significant repercussions for their social participation. Many of the storytellers involved in the ‘Rainbow Family Tree’ case study that is the subject of this paper can be characterised as ‘everyday’ activists for their common desire to use their personal stories to increase social acceptance of marginalised identity categories. However, in conflict with their willingness to share their personal stories, many fear the risks and ramifications of distributing them in public spaces (especially online) to audiences both intimate and unknown. Additionally, while technologies for production and distribution of rich media products have become more accessible and user-friendly, many obstacles remain. For many people there are difficulties with technological access and aptitude, personal agency, cultural capital, and social isolation, not to mention availability of the time and energy requisite to Digital Storytelling. Additionally, workshop context, facilitation and distribution processes all influence the content of stories. This paper explores the many factors that make ‘authentic’ self-representation far from straight forward. I use qualitative data drawn from interviews, Digital Story texts and ethnographic observation of GLBTQIS participants in a Digital Storytelling initiative that combined face-to-face and online modes of participation. I consider mediating influences in practice and theory and draw on strategies put forth in cultural anthropology and narrative therapy to propose some practical tools for nuanced and sensitive facilitation of Digital Storytelling workshops and webspaces. Finally, I consider the implications of these facilitation strategies for voice, identity and social participation.

The use of CCTV to police public spaces : a case of big brother or big friend?

This paper considers the role of CCTV (closed circuit television) in the surveillance, policing and control of public space in urban and rural locations, specifically in relation to the use of public space by young people. The use of CCTV technology in public spaces is now an established and largely uncontested feature of everyday life in a number of countries and the assertion that they are essentially there for the protection of law abiding and consuming citizens has broadly gone unchallenged. With little or no debate in the U.K. to critique the claims made by the burgeoning security industry that CCTV protects people in the form of a ‘Big Friend’, the state at both central and local levels has endorsed the installation of CCTV apparatus across the nation. Some areas assert in their promotional material that the centre of the shopping and leisure zone is fully surveilled by cameras in order to reassure visitors that their personal safety is a matter of civic concern, with even small towns and villages expending monies on sophisticated and expensive to maintain camera systems. It is within a context of monitoring, recording and control procedures that young people’s use of public space is constructed as a threat to social order, in need of surveillance and exclusion which forms a major and contemporary feature in shaping thinking about urban and rural working class young people in the U.K. As Loader (1996) notes, young people’s claims on public space rarely gain legitimacy if ‘colliding’ with those of local residents, and Davis (1990) describes the increasing ‘militarization and destruction of public space’, while Jacobs (1965) asserts that full participation in the ‘daily life of urban streets’ is essential to the development of young people and beneficial for all who live in an area. This paper challenges the uncritical acceptance of widespread use of CCTV and identifies its oppressive and malevolent potential in forming a ‘surveillance gaze’ over young people (adapting Foucault’s ‘clinical gaze’c. 1973) which can jeopardise mental health and well being in coping with the ‘metropolis’, after Simmel, (1964).