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.

Human papillomavirus prevalence, viral load and pre-cancerous lesions of the cervix in women initiating highly active antiretroviral therapy in South Africa : a cross-sectional study

Background Cervical cancer and infection with human immunodeficiency virus (HIV) are both important public health problems in South Africa (SA). The aim of this study was to determine the prevalence of cervical squamous intraepithelial lesions (SILs), high-risk human papillomavirus (HR-HPV), HPV viral load and HPV genotypes in HIV positive women initiating anti-retroviral (ARV) therapy. Methods A cross-sectional survey was conducted at an anti-retroviral (ARV) treatment clinic in Cape Town, SA in 2007. Cervical specimens were taken for cytological analysis and HPV testing. The Digene Hybrid Capture 2 (HC2) test was used to detect HR-HPV. Relative light units (RLU) were used as a measure of HPV viral load. HPV types were determined using the Roche Linear Array HPV Genotyping test. Crude associations with abnormal cytology were tested and multiple logistic regression was used to determine independent risk factors for abnormal cytology. Results The median age of the 109 participants was 31 years, the median CD4 count was 125/mm3, 66.3% had an abnormal Pap smear, the HR-HPV prevalence was 78.9% (Digene), the median HPV viral load was 181.1 RLU (HC2 positive samples only) and 78.4% had multiple genotypes. Among women with abnormal smears the most prevalent HR-HPV types were HPV types 16, 58 and 51, all with a prevalence of 28.5%. On univariate analysis HR-HPV, multiple HPV types and HPV viral load were significantly associated with the presence of low and high-grade SILs (LSIL/HSIL). The multivariate logistic regression showed that HPV viral load was associated with an increased odds of LSIL/HSIL, odds ratio of 10.7 (95% CI 2.0 – 57.7) for those that were HC2 positive and had a viral load of ≤ 181.1 RLU (the median HPV viral load), and 33.8 (95% CI 6.4 – 178.9) for those that were HC2 positive with a HPV viral load > 181.1 RLU. Conclusion Women initiating ARVs have a high prevalence of abnormal Pap smears and HR-HPV. Our results underscore the need for locally relevant, rigorous screening protocols for the increasing numbers of women accessing ARV therapy so that the benefits of ARVs are not partially offset by an excess risk in cervical cancer.

Cross layer optimization of VANET routing with multi-objective decision making

Vehicular Ad-hoc Networks (VANET) have different characteristics compared to other mobile ad-hoc networks. The dynamic nature of the vehicles which act as routers and clients are connected with unreliable radio links and Routing becomes a complex problem. First we propose CO-GPSR (Cooperative GPSR), an extension of the traditional GPSR (Greedy Perimeter Stateless Routing) which uses relay nodes which exploit radio path diversity in a vehicular network to increase routing performance. Next we formulate a Multi-objective decision making problem to select optimum packet relaying nodes to increase the routing performance further. We use cross layer information for the optimization process. We evaluate the routing performance more comprehensively using realistic vehicular traces and a Nakagami fading propagation model optimized for highway scenarios in VANETs. Our results show that when Multi-objective decision making is used for cross layer optimization of routing a 70% performance increment can be obtained for low vehicle densities on average, which is a two fold increase compared to the single criteria maximization approach.

International tax cooperation in the Post-GFC era

Over the last five years we have observed the fallout from the global financial crisis (GFC). International cooperation and jointly adopted policies have dominated many of the solutions to the problems which have arisen. Initially, many nations in response to the GFC, implemented a two pronged short term solution by undertaking fiscal intervention and delivering rescue packages aimed at first, bailing out financial institutions and second, preventing or minimising the impact of a recession. Both programs involved large amounts of domestic spending. It was difficult in early 2007 to foresee the reduction that nations were about the face in domestic revenue collected. Five years on, not only have the first line effects of the GFC reduced the revenue raised by governments around the world, but the consequential costs associated with the rescue packages have also depleted domestic revenue bases. The response by stakeholders has been to attempt to secure domestic revenue bases through fiscally sustainable measures. Domestic sovereignty allows the levying of taxes as a nation chooses. However, rather than raise domestic taxes, revenue may also be increased by stemming the flow of income and capital to low and no-tax jurisdictions. The intervening five-year period since the GFC allows a unique insight into the response by nations and international organisations to tax evasion, tax avoidance and aggressive tax competition through the cross border flows of capital and the resulting affect that the GFC has had on international tax cooperation. By investigating the change in the international tax landscape over the last five years, which reveals the work done by stakeholders in developing fiscally responsible responses to the problems that have arisen, it may be possible to predict the trajectory of the international tax landscape over the next five years.

The effect of ribbing on the energy flow between two rectangular plates coupled at right angle

This paper presents an analytical model to study the effect of stiffening ribs on vibration transmission between two rectangular plates coupled at right angle. Interesting wave attenuation patterns were observed by placing the stiffening rib either on the source or on the receiving plate. The result can be used to improve the understanding of vibration and for vibration control of more complex structures such as transformer tanks and machine covers.

The Multidimensional Loss Scale : validating a cross cultural instrument for measuring loss in Burmese refugees

The Multidimensional Loss Scale: Initial Development and Psychometric Evaluation The Multidimensional Loss Scale (MLS) represents the first instrument designed specifically to measure loss in refugee populations. Researchers developed initial items of the Multidimensional Loss Scale to assess Experience of Loss Events and Loss Distress in a culturally sensitive manner across multiple domains (social, material, intra-personal and cultural). A sample of 70 recently settled Burmese adult refugees completed a battery of questionnaires, including new scale items. Analyses explored the scale’s factor structure, internal consistency, convergent validity and divergent validity. Principal Axis Factoring supported a five-factor model: Loss of Symbolic Self, Loss of Interdependence, Loss of Home, Interpersonal Loss, and Loss of Intrapersonal Integrity. Chronbach’s Alphas indicated satisfactory internal consistency for Experience of Loss Events (.85) and Loss Distress (.92). Convergent and divergent validity of Loss Distress were supported by moderate correlations with interpersonal grief and trauma symptoms and weak correlations with depression and anxiety. The new scale was well received by people from refugee backgrounds and shows promise for application in future research and practice

Image based flow visualisation of experimental flow fields inside a gross pollutant trap

Typical flow fields in a stormwater gross pollutant trap (GPT) with blocked retaining screens were experimentally captured and visualised. Particle image velocimetry (PIV) software was used to capture the flow field data by tracking neutrally buoyant particles with a high speed camera. A technique was developed to apply the Image Based Flow Visualization (IBFV) algorithm to the experimental raw dataset generated by the PIV software. The dataset consisted of scattered 2D point velocity vectors and the IBFV visualisation facilitates flow feature characterisation within the GPT. The flow features played a pivotal role in understanding gross pollutant capture and retention within the GPT. It was found that the IBFV animations revealed otherwise unnoticed flow features and experimental artefacts. For example, a circular tracer marker in the IBFV program visually highlighted streamlines to investigate specific areas and identify the flow features within the GPT.

Cross-cultural language learning and web design complexity

Accepting the fact that culture and language are interrelated in second language learning (SLL), the web sites should be designed to integrate with the cultural aspects. Yet many SLL web sites fail to integrate with the cultural aspects and/or focus on language acquisition only. This study identified three issues: (1) anthropologists’ cultural models mostly adopted in cross-cultural web user interface have been superficially used; (2) web designers deal with culture as a fixed one which needs to be modeled into interface design elements, so (3) there is a need for a communication framework between educators and design practitioners, which can be utilized in web design processes. This paper discusses what anthropology can contribute to language learning, mediated through web design processes and suggests a cultural user experience framework for web-based SLL by presenting an exemplary matrix. To evaluate the effectiveness of the framework, the key stakeholders (learners, teachers, and designers) participated in a case scenario-based evaluation. The result shows a high possibility that the framework can enhance the effective communication and collaboration for the cultural integration.

Contribution to single-point closure Reynolds-stress modelling of inhomogeneous flow

This paper is concerned with recent advances in the development of near wall-normal-free Reynolds-stress models, whose single point closure formulation, based on the inhomogeneity direction concept, is completely independent of the distance from the wall, and of the normal to the wall direction. In the present approach the direction of the inhomogeneity unit vector is decoupled from the coefficient functions of the inhomogeneous terms. A study of the relative influence of the particular closures used for the rapid redistribution terms and for the turbulent diffusion is undertaken, through comparison with measurements, and with a baseline Reynolds-stress model (RSM) using geometric wall normals. It is shown that wall-normal-free rsms can be reformulated as a projection on a tensorial basis that includes the inhomogeneity direction unit vector, suggesting that the theory of the redistribution tensor closure should be revised by taking into account inhomogeneity effects in the tensorial integrity basis used for its representation.

Adaption and use of a compressible flow code for turbomachinery design

The present paper presents and discusses the use of dierent codes regarding the numerical simulation of a radial-in ow turbine. A radial-in ow turbine test case was selected from published literature [1] and commercial codes (Fluent and CFX) were used to perform the steady-state numerical simulations. An in-house compressible- ow simulation code, Eilmer3 [2] was also adapted in order to make it suitable to perform turbomachinery simulations and preliminary results are presented and discussed. The code itself as well as its adaptation, comprising the addition of terms for the rotating frame of reference, programmable boundary conditions for periodic boundaries and a mixing plane interface between the rotating and non-rotating blocks are also discussed. Several cases with dierent orders of complexity in terms of geometry were considered and the results were compared across the dierent codes. The agreement between these results and published data is also discussed.

Cross-dressing footballer tackles issues and scores with the crowd

MISOGYNY, no matter how it's defined, has become a political football. Fifteen minutes into the first quarter of David Williamson's Managing Carmen and Brent Lyall, a star AFL footballer, has already taken a high tackle from his hottie girlfriend, had a clanger with his manager and been caught wearing women's clothes by his acting coach. Not a good look for Brent's sponsors. By full time, Williamson's witty banter and colourful characters have hit their mark. No wonder he's already working on the screenplay.

The backfilled GEI : a cross-capture modality gait feature for frontal and side-view gait recognition

In this paper, we propose a novel direction for gait recognition research by proposing a new capture-modality independent, appearance-based feature which we call the Back-filled Gait Energy Image (BGEI). It can can be constructed from both frontal depth images, as well as the more commonly used side-view silhouettes, allowing the feature to be applied across these two differing capturing systems using the same enrolled database. To evaluate this new feature, a frontally captured depth-based gait dataset was created containing 37 unique subjects, a subset of which also contained sequences captured from the side. The results demonstrate that the BGEI can effectively be used to identify subjects through their gait across these two differing input devices, achieving rank-1 match rate of 100%, in our experiments. We also compare the BGEI against the GEI and GEV in their respective domains, using the CASIA dataset and our depth dataset, showing that it compares favourably against them. The experiments conducted were performed using a sparse representation based classifier with a locally discriminating input feature space, which show significant improvement in performance over other classifiers used in gait recognition literature, achieving state of the art results with the GEI on the CASIA dataset.

Eigenvoice modeling for cross likelihood ratio based speaker clustering : a Bayesian approach

This paper proposes the use of Bayesian approaches with the cross likelihood ratio (CLR) as a criterion for speaker clustering within a speaker diarization system, using eigenvoice modeling techniques. The CLR has previously been shown to be an effective decision criterion for speaker clustering using Gaussian mixture models. Recently, eigenvoice modeling has become an increasingly popular technique, due to its ability to adequately represent a speaker based on sparse training data, as well as to provide an improved capture of differences in speaker characteristics. The integration of eigenvoice modeling into the CLR framework to capitalize on the advantage of both techniques has also been shown to be beneficial for the speaker clustering task. Building on that success, this paper proposes the use of Bayesian methods to compute the conditional probabilities in computing the CLR, thus effectively combining the eigenvoice-CLR framework with the advantages of a Bayesian approach to the diarization problem. Results obtained on the 2002 Rich Transcription (RT-02) Evaluation dataset show an improved clustering performance, resulting in a 33.5% relative improvement in the overall Diarization Error Rate (DER) compared to the baseline system.