The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

How professional development impacts on experienced teachers' perceptions of their ICT practices

Teachers are at the forefront of Information Communication Technology (ICT) use in schools. Teachers face many challenges and competing priorities such as literacy, numeracy and changing curriculum frameworks and are expected to adopt new ICT practices to improve students¿ outcomes. Effective professional development (PD) methods must be identified and implemented. This research examined two core issues: (1) experienced teachers' perceptions of their ICT practices and (2) how PD courses have affected these practices. This case study and its findings has important implications for the implementation of effective PD in schools.

Peer mentoring for radiotherapy planning skills development: A pilot study

Introduction: This study aimed to determine the potential role and guidelines for implementation of skill-based peer mentoring for radiotherapy planning education. Methods: After four weekly mentoring sessions, both Year 3 mentors (n=9) and Year 2 mentees (n=9) were invited to complete a short online questionnaire relating to the impact of the initiative. The tool contained a mixture of Likert-style questions concerning student enjoyment and perceived usefulness of the initiative as well as more qualitative open questions that gathered perceptions of the peer mentoring process, implementation methods and potential future scope. Results: Several key discussion themes related to benefits to each stakeholder group, challenges arising, improvements and potential future directions. There were high levels of enjoyment and perceived value of the mentoring from both sides with 100% of the 18 respondents enjoying the experience. The informal format encouraged further learning, while mentors reported acquisition of valuable skills and gains in knowledge. Conclusions: Peer mentoring has a valuable and enjoyable role to play in radiotherapy planning training and helps consolidate theoretical understanding for experienced students. An informal approach allows for students to adopt the most appropriate mentoring model for their needs while providing them with a free space to engender additional discussion.

Adopting healthcare big data in Sri Lankan healthcare sector

The concept of big data has already outperformed traditional data management efforts in almost all industries. Other instances it has succeeded in obtaining promising results that provide value from large-scale integration and analysis of heterogeneous data sources for example Genomic and proteomic information. Big data analytics have become increasingly important in describing the data sets and analytical techniques in software applications that are so large and complex due to its significant advantages including better business decisions, cost reduction and delivery of new product and services [1]. In a similar context, the health community has experienced not only more complex and large data content, but also information systems that contain a large number of data sources with interrelated and interconnected data attributes. That have resulted in challenging, and highly dynamic environments leading to creation of big data with its enumerate complexities, for instant sharing of information with the expected security requirements of stakeholders. When comparing big data analysis with other sectors, the health sector is still in its early stages. Key challenges include accommodating the volume, velocity and variety of healthcare data with the current deluge of exponential growth. Given the complexity of big data, it is understood that while data storage and accessibility are technically manageable, the implementation of Information Accountability measures to healthcare big data might be a practical solution in support of information security, privacy and traceability measures. Transparency is one important measure that can demonstrate integrity which is a vital factor in the healthcare service. Clarity about performance expectations is considered to be another Information Accountability measure which is necessary to avoid data ambiguity and controversy about interpretation and finally, liability [2]. According to current studies [3] Electronic Health Records (EHR) are key information resources for big data analysis and is also composed of varied co-created values [3]. Common healthcare information originates from and is used by different actors and groups that facilitate understanding of the relationship for other data sources. Consequently, healthcare services often serve as an integrated service bundle. Although a critical requirement in healthcare services and analytics, it is difficult to find a comprehensive set of guidelines to adopt EHR to fulfil the big data analysis requirements. Therefore as a remedy, this research work focus on a systematic approach containing comprehensive guidelines with the accurate data that must be provided to apply and evaluate big data analysis until the necessary decision making requirements are fulfilled to improve quality of healthcare services. Hence, we believe that this approach would subsequently improve quality of life.

Email negotiations form a binding land contract without a 'signature'

Email is rapidly replacing other forms of communication as the preferred means of communication between contracting parties. The recent decision of Stellard Pty Ltd v North Queensland Fuel Pty Ltd [2015] QSC 119 reinforces the judicial acceptance of email as an effective means of creating a binding agreement and the willingness to adopt a liberal concept of ‘signing’ in an electronic environment.

The technological readiness of construction contractors

The Australian construction industry is often criticized for its comparatively low productivity. The most significant future productivity gains are predicted to arise from improvement in the firm’s project management. Information Communication Technologies (ICTs) are thought to offer such improvement. ICT adoption is particularly poor among Small and Medium Enterprises (SMEs). Existing studies provide only a general overview of adoption and diffusion of ICTs in SMEs, with no previous research measuring their readiness to adopt ICT. This paper outlines a theoretical approach to address this gap, exploring how to improve ICT adoption in Australian construction SMEs. A review of literature is undertaken to address the research question ‘What is the best conceptual approach to understanding ICT adoption in SMEs?’ The results emphasize the efficacy of a novel Technology Readiness and Acceptance Model (TRAM) to assess SMEs’ ICT implementation readiness. The proposed model consists of four major constructs to measure readiness comprising: - (1) optimism, - (2) innovativeness, - (3) discomfort and - (4) insecurity; two major constructs to measure technological acceptance comprising: - (1) perceived ease of use and - (2) perceived usefulness; and two extension variables comprising: - (1) self-efficacy and - (2) facilitating conditions. A limitation is that the performance of the conceptual model is yet to be tested empirically. Such research is planned in the coming year by the authors.

A generalized estimating equations approach for analysis of the impact of new technology on a trawl fishery

The article describes a generalized estimating equations approach that was used to investigate the impact of technology on vessel performance in a trawl fishery during 1988-96, while accounting for spatial and temporal correlations in the catch-effort data. Robust estimation of parameters in the presence of several levels of clustering depended more on the choice of cluster definition than on the choice of correlation structure within the cluster. Models with smaller cluster sizes produced stable results, while models with larger cluster sizes, that may have had complex within-cluster correlation structures and that had within-cluster covariates, produced estimates sensitive to the correlation structure. The preferred model arising from this dataset assumed that catches from a vessel were correlated in the same years and the same areas, but independent in different years and areas. The model that assumed catches from a vessel were correlated in all years and areas, equivalent to a random effects term for vessel, produced spurious results. This was an unexpected finding that highlighted the need to adopt a systematic strategy for modelling. The article proposes a modelling strategy of selecting the best cluster definition first, and the working correlation structure (within clusters) second. The article discusses the selection and interpretation of the model in the light of background knowledge of the data and utility of the model, and the potential for this modelling approach to apply in similar statistical situations.

Prevalence and developmental course of 'secret language'.

The prevalence and developmental course of supposed ‘secret language’ was examined in a cohort of twins and closely spaced singletons pairs, with systematic assessments at 20 months and again at 36 months. Two forms of apparent ‘secret language’ were examined: (1) shared understanding—speech directed generally but unintelligible to the parent, although apparently clearly understood within the child pair, and (2) private language directed exclusively to the other twin/sibling—not intelligible to the parent, but apparently clearly understood and used only within the child pair. Both occurred in singleton pairs, but the rate was much higher in twins. In most cases it seemed to be a developmental phenomenon occurring in the second year of life with the emergence of immature speech, and decreasing considerably over the next 16 months. A small group of children, primarily male twins, was reported to use a private language at 36 months. This group had poorer cognitive and language functioning, and was characterized by highly dependent relationships. Some aspects of the twins’ home environment were less stimulating and less responsive, most probably reflecting the abilities and relationships of the children. A follow-up of these children when they were ~6 years of age showed that language outcome was poor for the subgroup (n = 4) who did not develop normal language alongside the use of a private language.

The role of comfort in child restraint use practices

Suboptimal restraint use, particularly the incorrect use of restraints, is a significant and widespread problem among child vehicle occupants, and increases the risk of injury. Previous research has identified comfort as a potential factor influencing suboptimal restraint use. Both the real comfort experienced by the child and the parent’s perception of the child’s comfort are reported to influence the optimal use of restraints. Problems with real comfort may lead the child to misuse the restraint in their attempt to achieve better comfort whilst parent-perceived discomfort has been reported as a driver for premature graduation and inappropriate restraint choice. However, this work has largely been qualitative. There has been no research that objectively studies either the association between real and parent-perceived comfort, or any association between comfort and suboptimal restraint use. One barrier to such studies is the absence of validated tools for quantifying real comfort in children. We aimed to develop methods to examine both real and parent-perceived comfort and examine their effects on suboptimal restraint use. We conducted online parent surveys (n=470) to explore what drives parental perceptions of their child’s comfort in restraint systems (study 1) and used data from field observation studies (n=497) to examine parent-perceived comfort and its relationship with observed restraint use (study 2). We developed methods to measure comfort in children in a laboratory setting (n=14) using video analysis to estimate a Discomfort Avoidance Behaviour (DAB) score, pressure mapping and adapted survey tools to differentiate between comfortable and induced discomfort conditions (study 3). The DAB rate was then used to compare an integrated booster with an add-on booster (study 4) Preliminary analysis of our recent online survey of Australian parents (study 1) indicates that 23% of parents report comfort as a consideration when making a decision to change restraints. Logistic regression modelling of data collected during the field observation study (study 2) revealed that parent-perceived discomfort was not significantly associated with premature graduation. Contrary to expectation, children of parents who reported that their child was comfortable were almost twice as likely to have been incorrectly restrained (p<0.01, 95% CI 1.24 - 2.77).In the laboratory study (study 3) we found our adapted survey tools did not provide a reliable measurement of real comfort among children. However our DAB score was able to differentiate between comfortable and induced discomfort conditions and correlated well with pressure mapping. Preliminary results from the laboratory comparison study (study 4) indicate a positive correlation between DAB rate and use errors. In experiments conducted to date, we have seen a significantly higher DAB rate in the integrated booster compared to the add-on booster (p < 0.01). However, this needs to be confirmed in a naturalistic setting and in further experiments that take length of time under observation into account. Our results suggest that while some parents report concern about their child’s comfort, parent-reported comfort levels were not associated with restraint choice. If comfort is important for optimal restraint use, it is likely to be the real comfort of the child rather than that reported by the parent. The method we have developed for studying real comfort can be used in naturalistic studies involving child occupants to further understand this relationship. This work will be of interest to vehicle and child restraint manufacturers interested in improving restraint design for young occupants as well as researchers and other stakeholders interested in reducing the incidence of restraint misuse among children.

Combining propensity and influence models for product adoption prediction

This paper studies the problem of selecting users in an online social network for targeted advertising so as to maximize the adoption of a given product. In previous work, two families of models have been considered to address this problem: direct targeting and network-based targeting. The former approach targets users with the highest propensity to adopt the product, while the latter approach targets users with the highest influence potential – that is users whose adoption is most likely to be followed by subsequent adoptions by peers. This paper proposes a hybrid approach that combines a notion of propensity and a notion of influence into a single utility function. We show that targeting a fixed number of high-utility users results in more adoptions than targeting either highly influential users or users with high propensity.

International contact lens prescribing in 2014

Since the late 1990s, the International Contact Lens Prescribing Survey Consortium has prospectively gathered information about 285,000 contact lens fits from more than 50 countries. This article presents our 14th annual summary of current trends published in Contact Lens Spectrum. With only minor differences in the distribution of our surveys among markets, we have continued to adopt the same approach throughout the past 18 years. Through national coordinators, we approach contact lens prescribers in each country and ask them to record information about the first 10 patients whom they fit with contact lenses after receipt of our survey form. The information collected is generic, and respondents are weighted to reflect the volume of contact lens fits undertaken by each. For this 2014 report, we present information about 25,179 contact lens fits from 32 countries...

Employee green behavior: A theoretical framework, multilevel review, and future research agenda

We propose a conceptual model based on person–environment interaction, job performance, and motivational theories to structure a multilevel review of the employee green behavior (EGB) literature and agenda for future research. We differentiate between required EGB prescribed by the organization and voluntary EGB performed at the employees’ discretion. The review investigates institutional-, organizational-, leader-, team-, and employee-level antecedents and outcomes of EGB and factors that mediate and moderate these relationships. We offer suggestions to facilitate the development of the field, and call for future research to adopt a multilevel perspective and to investigate the outcomes of EGB.

A Lidl bit of grocery competition could cause a Coles rethink

Australian shoppers have inadvertently invited global discount grocers to our shores by demonstrating their readiness to adopt private labels. In 2001, German discounter Aldi opened its first store in Sydney. The impact this business format would have on the Australian grocery sector was underestimated.

Contemplating Knudsen's Baseline: Where small is not so beautiful

Does the Internet's World Wide Web (the web) represent an opportunity or threat to the small firms of the world? In line with recent calls for entrepreneurship research to adopt a more evolutionary approach, this article considers the context, process, and possible outcomes of small place-based firms operating in a web-impacted environment. Despite initial optimism that the web would provide a level-playing field for firms of all sizes, little evidence exist to support such a notion. When the learning abilities deemed necessary to exploit the web are considered, it would seem that only the most entrepreneurial of small firms would likely adapt to web-impacted environments. It is concluded that the present rate of web-based change represents a unique and valuable research opportunity for entrepreneurship researchers.

Cloud computing services for the small and medium enterprises: Key considerations for sourcing sustainable business value

The concept of cloud computing services (CCS) is appealing to small and medium enterprises (SMEs). However, while there is a significant push by various authorities on SMEs to adopt the CCS, knowledge of the key considerations to adopt the CCS is very limited. We use the technology-organization-environment (TOE) framework to suggest that a strategic and incremental intent, understanding the organizational structure and culture, understanding the external factors, and consideration of the human resource capacity can contribute to sustainable business value from CCS. Using survey data, we find evidence of a positive association between these considerations and the CCS-related business objectives. We also find evidence of positive association between the CCS-related business objectives and CCS-related financial objectives. The results suggest that the proposed considerations can ensure sustainable business value from the CCS. This study provides guidance to SMEs on a path to adopting the CCS with the intention of a long-term commitment and achieving sustainable business value from these services.