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.

A 4D automatic simulation tool for construction resource planning: A case study

Purpose Traditional construction planning relies upon the critical path method (CPM) and bar charts. Both of these methods suffer from visualization and timing issues that could be addressed by 4D technology specifically geared to meet the needs of the construction industry. This paper proposed a new construction planning approach based on simulation by using a game engine. Design/methodology/approach A 4D automatic simulation tool was developed and a case study was carried out. The proposed tool was used to simulate and optimize the plans for the installation of a temporary platform for piling in a civil construction project in Hong Kong. The tool simulated the result of the construction process with three variables: 1) equipment, 2) site layout and 3) schedule. Through this, the construction team was able to repeatedly simulate a range of options. Findings The results indicate that the proposed approach can provide a user-friendly 4D simulation platform for the construction industry. The simulation can also identify the solution being sought by the construction team. The paper also identifies directions for further development of the 4D technology as an aid in construction planning and decision-making. Research limitations/implications The tests on the tool are limited to a single case study and further research is needed to test the use of game engines for construction planning in different construction projects to verify its effectiveness. Future research could also explore the use of alternative game engines and compare their performance and results. Originality/value The authors proposed the use of game engine to simulate the construction process based on resources, working space and construction schedule. The developed tool can be used by end-users without simulation experience.

An Electron-Accepting Chromophore Based on Fluorene and Naphthalenediimide Building Blocks for Solution-Processable Bulk Heterojunction Devices

We have designed, synthesized and utilized a new non-fullerene electron acceptor, 9,9′-(9,9-dioctyl-9H-fluorene-2,7-diyl)bis(2,7-dioctyl-4-(octylamino)benzo[lmn][3,8]phenanthroline-1,3,6,8(2H,7H)-tetraone) (B2), for use in solution-processable bulk-heterojunction devices. B2 is based on a central fluorene moiety, which was capped at both ends with an electron-accepting naphthalenediimide functionality. B2 exhibited excellent solubility (>30 mg mL−1 in chloroform), high thermal and photochemical stability, and appropriate energy levels for use with the classical polymer donor regioregular poly(3-hexylthiophene). A power conversion efficiency of 1.16 % was achieved for primitive bulk-heterojunction devices with a high fill factor of approximately 54 %.

Conjoint use of Dibenzosilole and Indan-1,3-dione Functionalities to Prepare an Efficient Non-Fullerene Acceptor for Solution-Processable Bulk-Heterojunction Solar Cells

A solution-processable, non-fullerene electron acceptor, 2,2′-(((5,5-dioctyl-5 H-dibenzo[b,d]silole-3,7-diyl)bis(thiophene-5,2-diyl))bis(methanylylidene))bis(1 H-indene-1,3(2 H)-dione) (called N5) comprised of dibenzosilole and 1,3-indanedione building blocks was designed, synthesized, and fully characterized. N5 is highly soluble in various organic solvents, has high thermal stability, and has energy levels matching those of archetypal donor poly(3-hexylthiophene). Solution-processable, bulk-heterojunction solar cells afforded promising power conversion efficiency of 2.76 % when N5 was used as a non-fullerene electron acceptor along with the conventional donor polymer poly(3-hexylthiophene). As per our knowledge, the material reported herein is the first example in the literature where synchronous use of such building blocks is demonstrated in the design an efficient, non-fullerene acceptor.

Scalable and flexible large display arrays: A novel approach to the architectural enhancement of a prototype large display array

Large Display Arrays (LDAs) use Light Emitting Diodes (LEDs) in order to inform a viewing audience. A matrix of individually driven LEDs allows the area represented to display text, images and video. LDAs have undergone rapid development over the past 10 years in both the modular and semi-flexible formats. This thesis critically analyses the communication architecture and processor functionality of current LDAs and presents an alternative method, that is, Scalable Flexible Large Display Arrays (SFLDAs). SFLDAs are more adaptable to a variety of applications because of enhancements in scalability and flexibility. Scalability is the ability to configure SFLDAs from 0.8m2 to 200m2. Flexibility is increased functionality within the processors to handle changes in configuration and the use of a communication architecture that standardises two-way communication throughout the SFLDA. While common video platforms such as Digital Video Interface (DVI), Serial Digital Interface (SDI), and High Definition Multimedia Interface (HDMI) are considered as solutions for the communication architecture of SFLDAs, so too is modulation, fibre optic, capacitive coupling and Ethernet. From an analysis of these architectures, Ethernet was identified as the best solution. The use of Ethernet as the communication architecture in SFLDAs means that both hardware and software modules are capable of interfacing to the SFLDAs. The Video to Ethernet Processor Unit (VEPU), Scoreboard, Image and Control Software (SICS) and Ethernet to LED Processor Unit (ELPU) have been developed to form the key components in designing and implementing the first SFLDA. Data throughput rate and spectrophotometer tests were used to measure the effectiveness of Ethernet within the SFLDA constructs. The result of testing and analysis of these architectures showed that Ethernet satisfactorily met the requirements of SFLDAs.

Positive development and assessment

Purpose – There has been a tendency in sustainability science to be passive. The purpose of this paper is to introduce an alternative positive framework for a more active and direct approach to sustainable design and assessment that de-couples environmental impacts and economic growth. Design/methodology/approach – This paper deconstructs some systemic gaps that are critical to sustainability in built environment management processes and tools, and reframes negative “sustainable” decision making and assessment frameworks into their positive counterparts. In particular, it addresses the omission of ecology, design and ethics in development assessment. Findings – Development can be designed to provide ecological gains and surplus “eco-services,” but assessment tools and processes favor business-as-usual. Despite the tenacity of the dominant paradigm (DP) in sustainable development institutionalized by the Brundtland Report over 25 years ago, these omissions are easily corrected. Research limitations/implications – The limitation is that the author was unable to find exceptions to the omissions cited here in the extensive literature on urban planning and building assessment tools. However, exceptions prove the rule. The implication is that it is not too late for eco-positive retrofitting of cities to increase natural and social capital. The solutions are just as applicable in places like China and India as the USA, as they pay for themselves. Originality/value – Positive development (PD) is a fundamental paradigm shift that reverses the negative models, methods and metrics of the DP of sustainable development. This paper provides an example of how existing “negative” concepts and practices can be converted into positive ones through a PD prism. Through a new form of bio-physical design, development can be a sustainability solution.

Vaccination of koalas (Phascolarctos cinereus) with a recombinant chlamydial major outer membrane protein adjuvanted with poly I:C, a host defense peptide and polyphosphazine, elicits strong and long lasting cellular and humoral immune responses

Chlamydial infections are wide spread in koalas across their range and a solution to this debilitating disease has been sought for over a decade. Antibiotics are the currently accepted therapeutic measure, but are not an effective treatment due to the asymptomatic nature of some infections and a low efficacy rate. Thus, a vaccine would be an ideal way to address this infectious disease threat in the wild. Previous vaccine trials have used a three-dose regimen; however this is very difficult to apply in the field as it would require multiple capture events, which are stressful and invasive processes for the koala. In addition, it requires skilled koala handlers and a significant monetary investment. To overcome these challenges, in this study we utilized a polyphosphazine based poly I:C and a host defense peptide adjuvant combined with recombinant chlamydial major outer membrane protein (rMOMP) antigen to induce long lasting (54 weeks) cellular and humoral immunity in female koalas with a novel single immunizing dose. Immunized koalas produced a strong IgG response in plasma, as well as at mucosal sites. Moreover, they showed high levels of C. pecorum specific neutralizing antibodies in the plasma as well as vaginal and conjunctival secretions. Lastly, Chlamydia-specific lymphocyte proliferation responses were produced against both whole chlamydial elementary bodies and rMOMP protein, over the 12-month period. The results of this study suggest that a single dose rMOMP vaccine incorporating a poly I:C, host defense peptide and polyphosphazine adjuvant is able to stimulate both arms of the immune system in koalas, thereby providing an alternative to antibiotic treatment and/or a three-dose vaccine regime.

An alternative approach to describing agility in sports through establishment of a relationship between velocity and radius of curvature

Agility is an essential part of many athletic activities. Currently, agility drill duration is the sole criterion used for evaluation of agility performance. The relationship between drill duration and factors such as acceleration, deceleration and change of direction, however, has not been fully explored. This paper provides a mathematical description of the relationship between velocity and radius of curvatures in an agility drill through implementation of a power law (PL). Two groups of skilled and unskilled participants performed a cyclic forward/backward shuttle agility test. Kinematic data was recorded using motion capture system at a sampling rate of 200 Hz. The logarithmic relationship between tangential velocity and radius of curvature of participant trajectories in both groups was established using the PL. The slope of the regression line was found to be 0.26 and 0.36, for the skilled and unskilled groups, respectively. The magnitudes of regression line slope for both groups were approximately 0.3 which is close to the expected 1/3 value. Results are an indication of how the PL could be implemented in an agility drill thus opening the way for establishment of a more representative measure of agility performance instead of drill duration.

Countering disablism: An alternative universal income support system based on egalitarianism

The long-term vision of economic security and social participation for people with a disability held by disability activists and policy-makers has not been realised on a global scale. This is despite the implementation of various poverty alleviation initiatives by international and national governments. Indeed within advanced Western liberal democracies, the inequalities and poverty gaps have widened rather than closed. This article is based on findings from a historical-comparative policy and discourse analysis of disability income support system in Australia and the Basic Income model. The findings suggest that a model such as Basic Income, grounded in principles of social citizenship, goes some way to maintaining an adequate level of subsistence for people with a disability. The article concludes by presenting some challenges and a commitment to transforming income support policy.

A controlled trial comparing the efficacy of rice-based and hypotonic glucose oral rehydration solutions in infants and young children with gastroenteritis

A prospective randomized trial was conducted to compare the efficacy of a rice-based oral rehydration solution (ORS) with glucose ORS in infants and children under 5 years of age with acute diarrhoea and mild to moderate dehydration (<10%). One hundred children presenting to a large metropolitan teaching hospital were eligible for entry to the study and were randomized to receive rice ORS or glucose ORS. Outcome measures were stool output (SO), duration of illness (DD) and recovery time to introduction of other fluids (RTF) and diet (RTD). Significant differences were found for all outcome measures in favour of the rice ORS group. Mean SO was lower (160 vs 213 mt; P<0.02), mean DD was reduced (17.3 vs 24.3 h; P = 0.03) and median RTF was decreased (12.7 vs 18.1 h; P< 0.001) in the rice ORS group compared with the glucose ORS group. The median rime to introduction of diet and mean length of hospital stay showed similar significant reductions. Our study has shown rice ORS to be an acceptable alternative to glucose ORS in young children and have shown that it is significantly more effective in reducing the course of diarrhoeal illness and the time taken to return to normal drinking and eating habits.

Director independence or decision bias? An investigation of alternative sources of agency costs in board decision making

Research into boards traditionally focuses on independent monitoring of management, with studies focused on the effect of board independence on firm performance. This thesis aims to broaden the research tradition by consolidating prior research and investigating how agents may circumvent independent monitoring. Meta-analysis of previous board independence-firm performance studies indicated no systematic relationship between board independence and firm performance. Next, a series of experiments demonstrated that the presentation of recommendations to directors may bias decision making irrespective of other information presented and the independence of the decision maker. Together, results suggest that independence may be less important than the agent's motivation to misdirect the monitoring process.

A 3-hour quantitative comparison of glucose-based versus rice-based oral rehydration solution intake by children with diarrhoea in Port Moresby General Hospital

Measurements were made of the intake of a WHO/UNICEF glucose-based and a rice cereal-based oral rehydration solution (ORS) by children with diarrhoea. Twenty children who presented to the Children's Outpatient Department at Port Moresby General Hospital with acute diarrhoea and mild dehydration were randomly assigned to an ORS and measurements were taken over the following 3 hours. For data analysis, the patients were paired by weight. Testing the means of the paired samples by t test showed that there was no significant difference between the amount of rice ORS and the amount of glucose ORS taken over 3 hours. The discovery of oral rehydration solution (ORS) for the treatment of diarrheal disease has been heralded as the most important medical discovery of the century. Cereal-based ORS is able to decrease stool output and the duration of diarrheal illness more than the standard glucose-based ORS, through the increased absorption provided by oligosaccharides without the imposition of a greater osmotic penalty. Moreover, the peptides in cereals enhance amino acid and water absorption, while providing nutritional benefits. UNICEF's glucose-based ORS is becoming more widely used in Papua New Guinea (PNG). 20 children aged 6-37 months (mean age, 15 months) who presented to the Children's Outpatient Department at Port Moresby General Hospital during September-October 1993 with acute diarrhea and mild dehydration were randomly assigned to receive either a rice-based ORS or standard glucose ORS, and measurements were taken over the following 3 hours. The patients were paired by weight for analysis. No statistically significant difference was found between the amount of rice ORS and the amount of glucose ORS taken over 3 hours.

Acceptability of a rice-based oral rehydration solution in Port Moresby General Hospital's Children's Outpatient Department

The guardians of children brought to the Port Moresby General Hospital's Children's Outpatient Department with a chief complaint of diarrhoeal disease were questioned regarding their preference of glucose-based vs rice-based oral rehydration solution (ORS) in order to determine the acceptability of a rice-based ORS. Of the 93 guardians interviewed, greater than 60% preferred the glucose-based solution in its mixability, appearance and taste, and 65% initially reported that their children preferred the taste of the glucose solution. However, after a 30-minute trial, only 58% of children still preferred the glucose solution. In a country where diarrhoeal disease is a leading cause of child death and guardians are the primary health care providers, the acceptability of an ORS is critical to the morbidity and mortality of Papua New Guinea's children. Killing an estimated 2.9 million children annually, diarrheal disease is the second leading cause of child mortality worldwide. Diarrheal disease is also the second leading cause of child mortality in Papua New Guinea (PNG), killing an average 193 inpatient children per year over the period 1984-90. However, despite the high level of diarrhea-related mortality and the proven efficacy of oral rehydration therapy (ORT) in managing diarrhea-related dehydration, standardized ORT has been underutilized in PNG. The current glucose-based oral rehydration solution (ORS) does not reduce the frequency or volume of a child's diarrhea, the most immediate concern of caregivers during episodes of illness. Cereal-based ORS, made from cereals which are commonly available as food staples in most countries, better address the short-term concerns of caregivers while offering a superior nutritional profile. A sample of guardians of children brought to the Port Moresby General Hospital's Children's Outpatient Department complaining of child diarrhea were asked about their preferences on glucose-based versus rice-based ORS in order to determine the acceptability of a rice-based ORS. More than 60% of the 93 guardians interviewed preferred the glucose-based solution for its mixability, appearance, and taste. 65% initially reported that their children preferred the taste of the glucose solution. However, after a 30-minute trial, only 58% of children still preferred the glucose solution.