478 resultados para Alternative dispute resolution


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Children’s literature has conventionally and historically been concerned with identity and the often tortuous journey to becoming a subject who is generally older and wiser, a journey typically characterised by mishap, adventure, and detours. Narrative closure in children’s and young adult novels and films typically provides a point of self-realisation or self-actualisation, whereby the struggles of finding one’s “true” identity have been overcome. In this familiar coming-of-age narrative, there is often an underlying premise of an essential self that will emerge or be uncovered. This kind of narrative resolution provides readers with a reassurance that things will work for the best in the end, which is an enduring feature of children’s literature, and part of liberal-humanism’s project of harmonious individuality. However, uncertainty is a constant that has always characterised the ways lives are lived, regardless of best-laid plans. Children’s literature provides a field of narrative knowledge whereby readers gain impressions of childhood and adolescence, or more specifically, knowledge of ways of being at a time in life, which is marked by uncertainty. Despite the prevalence of children’s texts which continue to offer normative ways of being, in particular, normative forms of gender behaviour, there are texts which resist the pull for characters to be “like everyone else” by exploring alternative subjectivities. Fiction, however, cannot be regarded as a source of evidence about the material realities of life, as its strength lies in its affective and imaginative dimensions, which nevertheless can offer readers moments of reflection, recognition, or, in some cases, reality lessons. As a form of cultural production, contemporary children’s literature is highly responsive to social change and political debates, and is crucially implicated in shaping the values, attitudes and behaviours of children and young people.

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The taxation of multinational banks currently is governed by the general principles of international tax. However, it is arguable that there are characteristics exclusive to multinational banks that may warrant the consideration of a separate taxing regime. This article argues that because of the unique nature of multinational banks, the traditional international tax rules governing jurisdiction to tax and allocation of income do not produce a result which is optimal, as it does not reflect economic reality. That is, the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment. Formulary apportionment is considered as an alternative that reflects economic reality by recognising the unique nature of multinational banks and allocating the income to the location of the economic activity. The unique nature of multinational banking is recognised in the fact that formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Starting from this recognition, the purpose of this article is to demonstrate that formulary apportionment is a theoretically superior (or optimal) model for the taxation of multinational banks. An optimal regime, for the purposes of this article, is considered to be one that distributes the taxing rights in an equitable manner between the relevant jurisdictions, while, simultaneously allowing decisions of the international banks to be tax neutral. In this sense, neutrality is viewed as an economic concept and equity is regarded as a legal concept. A neutral tax system is one in which tax rules do not affect economic choices about commercial activities. Neutrality will ideally be across jurisdictions as well as across traditional and non-traditional industries. The primary focus of this article is jurisdictional neutrality. A system that distributes taxing rights in an equitable manner between the relevant jurisdictions ensures that each country receives its fair share of tax revenue. Given the increase in multinational banking, jurisdictions should be concerned that they are receiving their fair share. Inter-nation equity is concerned with re-determining the proper division of the tax base among countries. Richard and Peggy Musgrave argue that sharing of the tax base by countries of source should be seen as a matter of inter-nation equity requiring international cooperation. The rights of the jurisdiction of residency will also be at issue. To this extent, while it is agreed that inter-nation equity is an essential attribute to an international tax regime, there is no universal agreement as to how to achieve it. The current system attempts to achieve such equity through a combined residency and source regime, with the transfer pricing rules used to apportion income between the relevant jurisdictions. However, this article suggests, that as an alternative to the current regime, equity would be achieved through formulary apportionment. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. Yet these are two separate issues. As such, this article is divided into two core parts. The first part examines the theoretical soundness of the formulary apportionment model concluding that it is theoretically superior to the arm’s length pricing requirement of the traditional transfer pricing regime. The second part examines the practical implications of accepting formulary apportionment as an optimal model with a view to disclosing the issues that arise when a formulary apportionment regime is adopted. Prior to an analysis of the theoretical and practical application of formulary apportionment to multinational banks, the unique nature of these banks is considered. The article concludes that, while there are significant implementation, compliance, and enforcement issues to overcome, the unitary taxation model may be theoretically superior to the current arm’s length model which applies to multinational banks. This conclusion is based on the unitary taxation model providing greater alignment with the unique features of these banks.

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It is possible to write many different histories of Australian television, and these different histories draw on different primary sources. The ABC of Drama, for example, draws on the ABC Document Archives (Jacka 1991). Most of the information for Images and Industry: television drama production in Australia is taken from original interviews with television production staff (Moran 1985). Ending the Affair, as well as archival work, draws on ‘over ten years of watching … Australian television current affairs’ (Turner 2005, xiii). Moran’s Guide to Australian TV Series draws exhaustively on extant archives: the ABC Document Archives, material sourced through the ABC Drama department, the Australian Film Commission, the library of the Australian Film, Television and Radio School, and the Australian Film Institute (Moran 1993, xi)...

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The marsupial order Diprotodontia includes 10 extant families, which occupy all terrestrial habitats across Australia and New Guinea and have evolved remarkable dietary and locomotory diversity. Despite considerable attention, the interrelations of these families have for the most part remained elusive. In this study, we separately model mitochondrial RNA and protein-coding sequences in addition to nuclear protein-coding sequences to provide near-complete resolution of diprotodontian family-level phylogeny. We show that alternative topologies inferred in some previous studies are likely to be artifactual, resulting from branch-length and compositional biases. Subordinal groupings resolved herein include Vombatiformes (wombats and koala) and Phalangerida, which in turn comprises Petauroidea (petaurid gliders and striped, feathertail, ringtail and honey possums) and a clade whose plesiomorphic members possess blade-like premolars (phalangerid possums, kangaroos and their allies and most likely, pygmy possums). The topology resolved reveals ecological niche structuring among diprotodontians that has likely been maintained for more than 40 million years.

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While researchers strive to improve automatic face recognition performance, the relationship between image resolution and face recognition performance has not received much attention. This relationship is examined systematically and a framework is developed such that results from super-resolution techniques can be compared. Three super-resolution techniques are compared with the Eigenface and Elastic Bunch Graph Matching face recognition engines. Parameter ranges over which these techniques provide better recognition performance than interpolated images is determined.

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The time consuming and labour intensive task of identifying individuals in surveillance video is often challenged by poor resolution and the sheer volume of stored video. Faces or identifying marks such as tattoos are often too coarse for direct matching by machine or human vision. Object tracking and super-resolution can then be combined to facilitate the automated detection and enhancement of areas of interest. The object tracking process enables the automatic detection of people of interest, greatly reducing the amount of data for super-resolution. Smaller regions such as faces can also be tracked. A number of instances of such regions can then be utilized to obtain a super-resolved version for matching. Performance improvement from super-resolution is demonstrated using a face verification task. It is shown that there is a consistent improvement of approximately 7% in verification accuracy, using both Eigenface and Elastic Bunch Graph Matching approaches for automatic face verification, starting from faces with an eye to eye distance of 14 pixels. Visual improvement in image fidelity from super-resolved images over low-resolution and interpolated images is demonstrated on a small database. Current research and future directions in this area are also summarized.

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The structure of the 1:1 brucinium salt of cis-cyclohexane-1,2-dicarboxylic acid, 2,3-dimethoxy-10-oxostrychnidinium (1R,2S)-2-carboxycyclohexane-1-carboxylate dihydrate, has revealed the resolved (1R,2S) enantiomer of the acid. Crystals of the compound are orthorhombic, space group P212121, with unit cell dimensions a = 8.1955(3), b = 12.4034(3), c = 29.9073(9)Å, and Z = 4. The asymmetric unit comprises the brucinium cation, the hydrogen cis-cyclohexane-1,2-dicarboxylate cation, in which the carboxylate group is disordered over two sites (58, 42%), and two water molecules of solvation, one of which is occupies two 50% occupancy sites. The classic undulating brucinium cation substructures are present with the anion and the water molecules occupying the interstitial cavities and are hydrogen-bonded to them in a two-dimensional network structure.

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This study proposes a framework of a model-based hot spot identification method by applying full Bayes (FB) technique. In comparison with the state-of-the-art approach [i.e., empirical Bayes method (EB)], the advantage of the FB method is the capability to seamlessly integrate prior information and all available data into posterior distributions on which various ranking criteria could be based. With intersection crash data collected in Singapore, an empirical analysis was conducted to evaluate the following six approaches for hot spot identification: (a) naive ranking using raw crash data, (b) standard EB ranking, (c) FB ranking using a Poisson-gamma model, (d) FB ranking using a Poisson-lognormal model, (e) FB ranking using a hierarchical Poisson model, and (f) FB ranking using a hierarchical Poisson (AR-1) model. The results show that (a) when using the expected crash rate-related decision parameters, all model-based approaches perform significantly better in safety ranking than does the naive ranking method, and (b) the FB approach using hierarchical models significantly outperforms the standard EB approach in correctly identifying hazardous sites.

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This article examines the recently introduced Neighbourhood Disputes Resolution Act 2011 (Qld). The operation of the Act is considered as it impacts upon the responsibility of neighbours for dividing fences and trees as well as disclosure obligations associated with sale transactions. A particular focus of the article is the interrelationship of the disclosure obligations imposed by the Act with the operation of standard contractual warranties in Queensland.

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This study assessed the validity of a scale measuring psychologists' attitudes towards complementary and alternative therapies and compared the attitudes of psychologists with a previous sample of psychology students. The scale, derived from existing measures for medical professionals and previously tested on a sample of psychology students, was completed by practising psychologists (N = 122). The data were factor analysed, and three correlated subscales were identified, assessing the perceived importance of knowledge about available therapies, attitudes towards integration with psychological practice, and concerns about associated risks of use. This structure was similar, but not identical, to that found in a previous sample of psychology students; however, psychologists expressed more concern for risks associated with integration and were less likely to hold a positive attitude towards integration. This scale will be useful in gauging changes in psychologists' attitudes towards integrative practice over time.

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In this study the impact of message strategy on advertising performance will be in examined in a business-to-business (B2B) context. From a theoretical standpoint, the study will explore differences in message type between symbolic and literal approaches in B2B advertisements. While there has been much discussion on the effect of symbolism, (eg. metaphors, abstract images and figurative language), an empirically-tested scale that measures the degree of symbolism has not been developed. This research project focuses on development of a methodological scale to accurately test the difference in the direction of message appeals. Thus, insights in the role of message strategy in the B2B adoption process are anticipated with contributions in future consumer and business advertising research.