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 semiautomatic method to identify vertebral end plate lesions (Schmorl's nodes)

Background Context There are differences in definitions of end plate lesions (EPLs), often referred to as Schmorl’s nodes, that may, to some extent, account for the large range of reported prevalence (3.8 to 76%). Purpose To develop a technique to measure the size, prevalence and location of EPLs in a consistent manner. Study Design/Setting This study proposed a method using a detection algorithm which was applied to five adolescent females (average age 15.1 years, range 13.0 to 19.2 years) with idiopathic scoliosis (average major Cobb angle 60°, range 55 to 67°). Methods Existing low-dose, computed tomography scans were segmented semi-automatically to extract 3D morphology of each vertebral endplate. Any remaining attachments to the posterior elements of adjacent vertebrae or endplates were then manually sectioned. An automatic algorithm was used to determine the presence and position of EPLs. Results EPLs were identified in 15 of the 170 (8.8%) endplates analysed with an average depth of 3.1mm. 11/15 of the EPLs were seen in the lumbar spine. The algorithm was found to be most sensitive to changes in the minimum EPL gradient at the edges of the EPL. Conclusions This study describes an imaging analysis technique for consistent measurement of the prevalence, location and size of EPLs. The technique can be used to analyse large populations without observer errors in EPL definitions.

Identifying vertebral end plate lesions (schmorl's nodes) using a semi-automatic method

INTRODUCTION There is a large range in the reported prevalence of end plate lesions (EPLs), sometimes referred to as Schmorl's nodes in the general population (3.8-76%). One possible reason for this large range is the differences in definitions used by authors. Previous research has suggested that EPLs may potentially be a primary disturbance of growth plates that leads to the onset of scoliosis. The aim of this study was to develop a technique to measure the size, prevalence and location of EPLs on Computed Tomography (CT) images of scoliosis patients in a consistent manner. METHODS A detection algorithm was developed and applied to measure EPLs for five adolescent females with idiopathic scoliosis (average age 15.1 years, average major Cobb 60°). In this algorithm, the EPL definition was based on the lesion depth, the distance from the edge of the vertebral body and the gradient of the lesion edge. Existing low-dose, CT scans of the patients' spines were segmented semi-automatically to extract 3D vertebral endplate morphology. Manual sectioning of any attachments between posterior elements of adjacent vertebrae and, if necessary, endplates was carried out before the automatic algorithm was used to determine the presence and position of EPLs. RESULTS EPLs were identified in 15 of the 170 (8.8%) endplates analysed with an average depth of 3.1mm. 73% of the EPLs were seen in the lumbar spines (11/15). A sensitivity study demonstrated that the algorithm was most sensitive to changes in the minimum gradient required at the lesion edge. CONCLUSION An imaging analysis technique for consistent measurement of the prevalence, location and size of EPLs on CT images has been developed. Although the technique was tested on scoliosis patients, it can be used to analyse other populations without observer errors in EPL definitions.

Serum levels of soluble receptor for advanced glycation end products and of S100 proteins are associated with inflammatory, autoantibody, and classical risk markers of joint and vascular damage in rheumatoid arthritis

Introduction: The receptor for advanced glycation end products (RAGE) is a member of the immunoglobulin superfamily of cell surface receptor molecules. High concentrations of three of its putative proinflammatory ligands, S100A8/A9 complex (calprotectin), S100A8, and S100A12, are found in rheumatoid arthritis (RA) serum and synovial fluid. In contrast, soluble RAGE (sRAGE) may prevent proinflammatory effects by acting as a decoy. This study evaluated the serum levels of S100A9, S100A8, S100A12 and sRAGE in RA patients, to determine their relationship to inflammation and joint and vascular damage. Methods: Serum sRAGE, S100A9, S100A8 and S100A12 levels from 138 patients with established RA and 44 healthy controls were measured by ELISA and compared by unpaired t test. In RA patients, associations with disease activity and severity variables were analyzed by simple and multiple linear regressions. Results: Serum S100A9, S100A8 and S100A12 levels were correlated in RA patients. S100A9 levels were associated with body mass index (BMI), and with serum levels of S100A8 and S100A12. S100A8 levels were associated with serum levels of S100A9, presence of anti-citrullinated peptide antibodies (ACPA), and rheumatoid factor (RF). S100A12 levels were associated with presence of ACPA, history of diabetes, and serum S100A9 levels. sRAGE levels were negatively associated with serum levels of C-reactive protein (CRP) and high-density lipoprotein (HDL), history of vasculitis, and the presence of the RAGE 82Ser polymorphism. Conclusions: sRAGE and S100 proteins were associated not just with RA inflammation and autoantibody production, but also with classical vascular risk factors for end-organ damage. Consistent with its role as a RAGE decoy molecule, sRAGE had the opposite effects to S100 proteins in that S100 proteins were associated with autoantibodies and vascular risk, whereas sRAGE was associated with protection against joint and vascular damage. These data suggest that RAGE activity influences co-development of joint and vascular disease in rheumatoid arthritis patients.

Genetic studies in osteoporosis: The end of the beginning

Osteoporosis and disorders of bone fragility are highly heritable, but despite much effort the identities of few of the genes involved has been established. Recent developments in genetics such as genome-wide association studies are revolutionizing research in this field, and it is likely that further contributions will be made through application of next-generation sequencing technologies, analysis of copy number variation polymorphisms, and high-throughput mouse mutagenesis programs. This article outlines what we know about osteoporosis genetics to date and the probable future directions of research in this field.

Synthesis and luminescent properties of star-burst D-Pi-A compounds based on 1,3,5-triazine core and carbazole end-capped phenylene ethynylene arms

Two new star-burst compounds based on 1,3,5-triazine core and carbazole end-capped phenylene ethynylene arms (1a and 1b) were synthesized and characterized. Their photophysical properties were investigated systematically via spectroscopic and theoretical methods. Both compounds exhibit strong 1π–π⁎ transitions in the UV region and intense 1π–π⁎/intramolecular charge transfer (1ICT) absorption bands in the UV–vis region. Introducing the carbazole end-capped phenylene ethynylene arm on the 1,3,5-triazine core causes a slight bathochromic shift and enhanced molar extinction coefficient of the 1π–π⁎/1ICT transition band. Both compounds are emissive in solution at room temperature and 77 K, which exhibit pronounced positive solvatochromic effect. The emitting state could be ascribed to 1ICT state in more polar solvent, and 1π–π⁎ state in low-polarity solvent. The high emission quantum yields (Φem=0.90~1.0) of 1a and 1b (in hexane and toluene) make them potential candidates as efficient light-emitting materials. The spectroscopic studies and theoretical calculations indicate that the photophysical properties of these compounds can be tuned by the carbazole end-capped phenylene ethynylene arm, which would also be useful for rational design of photofunctional materials.

Micro inverter with a front-end current-fed converter

The reliability of micro inverters is an important factor as it would be necessary to reduce cost and maintenance of the small and medium scale distributed PV power conversion systems. Electrolytic capacitors and active power decouple circuits can be avoided in micro inverters with the use of medium voltage DC-link. Such a DC-link based micro inverter is proposed with a front-end dual inductor current-fed push-pull converter. The primary side power switches of the front-end converter have reduced switching losses due to multi-resonant operation. In addition, the voltage and current stresses on the diodes of the secondary diode voltage doubler rectifier are reduced due to the presence of a series resonant circuit in the front-end converter. The operation of the proposed micro inverter is explained using an in-depth analysis of the switching characteristics of the power semiconductor devices. The theoretical analysis of the proposed micro inverter is validated using simulation result.

From users to citizens: Some thoughts on designing for polity and civics

This paper presents an essay aimed at prompting broad discussion crucial in keeping the interaction design discourse fresh, critical, and in motion. We trace the changing role of people who have advanced from consumers to producers, from stationary office workers to mobile urban nomads, from passive members of the plebs to active instigators of change. Yet, interaction designers often still refer to them only as ‘users.’ We follow some of the historic developments from the information superhighway to the smart city in order to provide the backdrop in front of which we critically analyse three core areas. First, the issue of echo chambers and filter bubbles in social media results in a political polarisation that jeopardises the formation of a functioning public sphere. Second, pretty lights and colourful façades in media architecture are increasingly making way for situated installations and interventions fostering community engagement. And third, civic activism is often reduced to forms of slacktivism. We synthesise our discussion to propose ‘citizen-ability’ as an alternative goal for interaction designers to aspire to in order to create new polities and civics for a better quality of life.

Will algorithmic playlist curation be the end of music stardom?

It is 2015 and there are no indications that the relentless digital transformation of the music economy is about to slow down. Rather, the music economy continues to rapidly reinvent itself and industry powers, positions and practices that were redefined only a few years ago are being questioned once again. This paper examines the most recent changes of the music economy as it moves from a product-based towards an access-based logic. The paper starts out by recognising the essential role of technology in the evolution of the music economy. It then moves on to a discussion about the rise of so-called access-based music business models and points out some of the controversies and debates that are associated with these models and online services. With this as a background the paper explores how access-based music services and the algorithmically curated playlists developed by these services transform the relationship between artists, music and fans and challenges the music industrial power relationships and established industry practices once again.

Body composition and components of energy expenditure in children with end-stage liver disease

Background: Better understanding of body composition and energy metabolism in pediatric liver disease may provide a scientific basis for improved medical therapy aimed at achieving optimal nutrition, slowing progression to end-stage liver disease (ESLD), and improving the outcome of liver transplantation. Methods: Twenty-one children less than 2 years of age with ESLD awaiting liver transplantation and 15 healthy, aged-matched controls had body compartment analysis using a four compartment model (body cell mass, fat mass, extracellular water, and extracellular solids). Subjects also had measurements of resting energy expenditure (REE) and respiratory quotient (RQ) by indirect calorimetry. Nine patients and 15 control subjects also had measurements of total energy expenditure (TEE) using doubly labelled water. Results: Mean weights and heights were similar in the two groups. Compared with control subjects, children with ESLD had higher relative mean body cell mass (33 ± 2% vs 29 ± 1% of body weight, P < 0.05), but had similar fat mass, extracellular water, and extracellular solid compartments (18% vs 20%, 41% vs 38%, and 7% vs 13% of body weight respectively). Compared with control subjects, children with ESLD had 27% higher mean REE/body weight (0.285 ± 0.013 vs 0.218. ± 0.013 mJ/kg/24h, P < 0.001), 16% higher REE/unit cell mass (P < 0.05); and lower mean RQ (P < 0.05). Mean TEE of patients was 4.70 ± 0.49 mJ/24h vs 3.19 ± 0.76 in controls, (P < 0.01). Conclusions: In children, ESLD is a hypermetabolic state adversely affecting the relationship between metabolic and non-metabolic body compartments. There is increased metabolic activity within the body cell mass with excess lipid oxidation during fasting and at rest. These findings have implications for the design of appropriate nutritional therapy.

Value of total body potassium in assessing the nutritional status of children with end-stage liver disease

Malnutrition is a common problem in children with end-stage liver disease (ESLD), and accurate assessment of nutritional status is essential in managing these children. In a retrospective study, we compared nutritional assessment by anthropometry with that by body composition. We analyzed all consecutive measurements of total body potassium (TBK, n = 186) of children less than 3 years old with ESLD awaiting transplantation found in our database. The TBK values obtained by whole body counting of 40K were compared with reference TRK values of healthy children. The prevalence of malnutrition, as assessed by weight (weight Z score < -2) was 28%, which was significantly lower (chi-square test, p < 0.0001) than the prevalence of malnutrition (76%) assessed by TBK (< 90% of expected TRK for age). These results demonstrated that body weight underestimated the nutritional deficit and stressed the importance of measuring body composition as part of assessing nutritional status of children with ESLD.

Growth hormone resistance and somatomedins in children with end-stage liver disease awaiting transplantation

Background: The success of orthotopic liver transplantation as treatment for end-stage liver disease has prompted investigation of strategies to maintain or improve nutrition and growth in children awaiting transplantation, because malnutrition is an adverse prognostic factor. The purpose of this study was to evaluate the effect of recombinant human growth hormone therapy on body composition and indices of liver function in patients awaiting transplant. Methods: The study was designed as a placebo- controlled, double-blind, crossover trial. Patients received 0.2 U/kg growth hormone, subcutaneously, or placebo daily for 28 days during two treatment periods, separated by a 2-week washout period. Ten patients (mean age, 3.06 ± 1.15 years; range, 0.51-11.65 years, five men), with extrahepatic biliary atresia (n = 8) or two with Alagille's syndrome (n = 2), with end-stage liver disease, completed the trial while awaiting orthotopic liver transplantation. Height, weight, total body potassium, total body fat, resting energy expenditure, respiratory quotient, hematologic and multiple biochemical profile, number of albumin infusions, insulin-like growth factor-1 and 1, growth hormone binding protein (GHBP), and insulin-like growth factor binding protein-1 (IGFBP-1) and insulin-like growth factor binding protein (IGFBP-3) were measured at the beginning and end of each treatment period. Results: Growth hormone treatment was associated with a significant decline in serum bilirubin (-34.6 ± 16.5 μmol/l vs. 18.2 ± 11.59 μmol/l; p < 0.02) but there was no significant effect on any anthropometric or body composition measurements, or on any biochemical or hematologic parameters. Conclusions: These children with end-stage liver disease displayed growth hormone resistance, particularly in relation to the somatomedin axis. Exogenous growth hormone administration may be of limited value in these patients

Corporate governance and law reform in Japan: From the lost decade to the end of history?

Japan is in the midst of massive law reform. Mired in ongoing recession since the early 1990s, Japan has been implementing a new regulatory blueprint to kickstart a sluggish economy through structural change. A key element to this reform process is a rethink of corporate governance and its stakeholder relations. With a patchwork of legislative initiatives in areas as diverse as corporate law, finance, labour relations, consumer protection, public administration and civil justice, this new model is beginning to take shape. But to what extent does this model represent a break from the past? Some commentators are breathlessly predicting the "Americanisation" of Japanese law. They see the triumph of Western-style capitalism - the "End of History", to borrow the words of Francis Fukuyama - with its emphasis on market-based, arms-length transactions. Others are more cautious, advancing the view that there new reforms are merely "creative twists" on what is a uniquely (although slowly evolving) strand of Japanese capitalism. This paper takes issue with both interpretations. It argues that the new reforms merely follow Japan's long tradition of 'adopting and adapting' foreign models to suit domestic purposes. They are neither the wholesale importation of "Anglo-Saxon" regulatory principles nor a thin veneer over a 'uniquely unique' form of Confucian cultural capitalism. Rather, they represent a specific and largely political solution (conservative reformism) to a current economic problem (recession). The larger themes of this paper are 'change' and 'continuity'. 'Change' suggests evolution to something identifiable; 'continuity' suggests adhering to an existing state of affairs. Although notionally opposites, 'change' and 'continuity' have something in common - they both suggest some form of predictability and coherence in regulatory reform. Our paper, by contrast, submits that Japanese corporate governance reform or, indeed, law reform more generally in Japan, is context-specific, multi-layered (with different dimensions not necessarily pulling all in the same direction for example, in relations with key outside suppliers), and therefore more random or 'chaotic'.

What hinders help seeking behaviours?

The STIMulate program provides support for learning across maths, science and IT to QUT coursework students. The program has good traction with the diverse QUT student community, with a focus on helping students in threshold skills and concepts across discipline areas. Students who attend learning support programs generally speak highly of these services. However, staff commonly report that many of the students most in need fail to access support. At the end of 2014, we sought feedback from non-users of STIMulate to investigate why they didn’t use the program. Of the 223 respondents, 34% of students had not used STIMulate services. These students were asked why they had not used STIMulate, and what would encourage them to attend STIMulate services. Based on student responses, issues that would encourage students to attend STIMulate can be classified into 6 key areas: marketing, timing, mode, belonging, need and space. These issues are then addressed through actionable recommendations to better enable future students to utilise the STIMulate program.