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.

Unitary Taxation of the Finance Sector

Multinational financial institutions (MNFIs) play a significant role in financing the activities of their clients in developing nations. Consistent with the ‘follow-the-customer’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. However, not only are MNFIs persistent users of tax havens, but also, more than other industries, have the opportunity to reduce tax through transfer pricing measures. This paper establishes a case for an industry-specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. In doing so, it considers the practicalities of implementing this by examining both definitional issues and possible formulas for MNFIs. This paper 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 the factors that should be included in an allocation formula, and the appropriate weighting. This paper concludes that unitary taxation with formulary apportionment is a viable industry-specific alternative for MNFIs.

Buckling behaviour and design of tapered steel lighting masts

Tapered tubular steel masts are commonly used to support floodlights in a range of applications. The design of these slender tapered masts requires a rational elastic flexural buckling analysis as the thickness also varies with height. Therefore a series of finite element analyses of tapered masts with varying geometry parameters was conducted to develop an elastic flexural buckling load formula. This paper briefly discusses the design methods, and then presents the details of the finite element analyses and the results. 1–Associate Professor of Civil Engineering, and Director, Physical Infrastructure Centre 2–Former BE (Civil) Student, QUT

Community participation in post-disaster reconstruction

When a community already torn by a prolonged war is subsequently subjected to being hit by a natural disaster, the combined impact of such disasters can be extremely devastating. Affected communities often face enormous challenges during the long-term reconstruction, mainly due to the lack of a viable community involvement process. In post-war settings, affected communities are often conceived as being disabled and are hardly ever consulted when reconstruction projects are instigated. This lack of community involvement often leads to poor project planning, decreased community support and an unsustainable completed project. The impact of war, coupled with the tensions created by the poor housing provisions, often hinder the affected residents from integrating permanently into their home communities. This paper identifies a number of fundamental factors that act as barriers to community participation in reconstruction projects. The paper is based on a statistical analysis of a questionnaire survey administered in 2012 in Afghanistan.

A new single-phase frequency adaptive Phase-Locked Loop (PLL) for harmonic measurement

The paper presents an improved Phase-Locked Loop (PLL) for measuring the fundamental frequency and selective harmonic content of a distorted signal. This information can be used by grid interfaced devices and harmonic compensators. The single-phase structure is based on the Synchronous Reference Frame (SRF) PLL. The proposed PLL needs only a limited number of harmonic stages by incorporating Moving Average Filters (MAF) for eliminating the undesired harmonic content at each stage. The frequency dependency of MAF in effective filtering of undesired harmonics is also dealt with by a proposed method for adaptation to frequency variations of input signal. The method is suitable for high sampling rates and a wide frequency measurement range. Furthermore, an extended model of this structure is proposed which includes the response to both the frequency and phase angle variations. The proposed algorithm is simulated and verified using Hardware-in-the-Loop (HIL) testing.

Storytelling and new media technologies: Investigating the potential of the ABC's Heywire for regional youth

This thesis investigates an instance of audience participation within the Australian public service media institution, the ABC. The case study for this research – the ABC’s ‘Heywire’ project – is a regional youth storytelling project, an online platform, and an example of the potentials as well as the limitations of personal narrative and digital technologies for incorporating the voices and self-representations of audiences. By investigating 'Heywire', this thesis illuminates the exciting opportunities and also some profound challenges that arise when public service media institutions invite their audiences to participate as content creators and storytellers.

Experimental studies on the performance of rail joints with modified wheel/railhead contact

Rail joints are provided with a gap to account for thermal movement and to maintain electrical insulation for the control of signals and/or broken rail detection circuits. The gap in the rail joint is regarded as a source of significant problems for the rail industry since it leads to a very short rail service life compared with other track components due to the various, and difficult to predict, failure modes – thus increasing the risk for train operations. Many attempts to improve the life of rail joints have led to a large number of patents around the world; notable attempts include strengthening through larger-sized joint bars, an increased number of bolts and the use of high yield materials. Unfortunately, no design to date has shown the ability to prolong the life of the rail joints to values close to those for continuously welded rail (CWR). This paper reports the results of a fundamental study that has revealed that the wheel contact at the free edge of the railhead is a major problem since it generates a singularity in the contact pressure and railhead stresses. A design was therefore developed using an optimisation framework that prevents wheel contact at the railhead edge. Finite element modelling of the design has shown that the contact pressure and railhead stress singularities are eliminated, thus increasing the potential to work as effectively as a CWR that does not have a geometric gap. An experimental validation of the finite element results is presented through an innovative non-contact measurement of strains. Some practical issues related to grinding rails to the optimal design are also discussed.

On robust face recognition via sparse coding: The good, the bad and the ugly

In the field of face recognition, sparse representation (SR) has received considerable attention during the past few years, with a focus on holistic descriptors in closed-set identification applications. The underlying assumption in such SR-based methods is that each class in the gallery has sufficient samples and the query lies on the subspace spanned by the gallery of the same class. Unfortunately, such an assumption is easily violated in the face verification scenario, where the task is to determine if two faces (where one or both have not been seen before) belong to the same person. In this study, the authors propose an alternative approach to SR-based face verification, where SR encoding is performed on local image patches rather than the entire face. The obtained sparse signals are pooled via averaging to form multiple region descriptors, which then form an overall face descriptor. Owing to the deliberate loss of spatial relations within each region (caused by averaging), the resulting descriptor is robust to misalignment and various image deformations. Within the proposed framework, they evaluate several SR encoding techniques: l1-minimisation, Sparse Autoencoder Neural Network (SANN) and an implicit probabilistic technique based on Gaussian mixture models. Thorough experiments on AR, FERET, exYaleB, BANCA and ChokePoint datasets show that the local SR approach obtains considerably better and more robust performance than several previous state-of-the-art holistic SR methods, on both the traditional closed-set identification task and the more applicable face verification task. The experiments also show that l1-minimisation-based encoding has a considerably higher computational cost when compared with SANN-based and probabilistic encoding, but leads to higher recognition rates.

ISPCAN child abuse screening tool children's version (ICAST-C): Instrument development and multi-national pilot testing

Objective To develop a child victimization survey among a diverse group of child protection experts and examine the performance of the instrument through a set of international pilot studies. Methods The initial draft of the instrument was developed after input from scientists and practitioners representing 40 countries. Volunteers from the larger group of scientists participating in the Delphi review of the ICAST P and R reviewed the ICAST C by email in 2 rounds resulting in a final instrument. The ICAST C was then translated and back translated into six languages and field tested in four countries using a convenience sample of 571 children 12–17 years of age selected from schools and classrooms to which the investigators had easy access. Results The final ICAST C Home has 38 items and the ICAST C Institution has 44 items. These items serve as screeners and positive endorsements are followed by queries for frequency and perpetrator. Half of respondents were boys (49%). Endorsement for various forms of victimization ranged from 0 to 51%. Many children report violence exposure (51%), physical victimization (55%), psychological victimization (66%), sexual victimization (18%), and neglect in their homes (37%) in the last year. High rates of physical victimization (57%), psychological victimization (59%), and sexual victimization (22%) were also reported in schools in the last year. Internal consistency was moderate to high (alpha between .685 and .855) and missing data low (less than 1.5% for all but one item). Conclusions In pilot testing, the ICAST C identifies high rates of child victimization in all domains. Rates of missing data are low, and internal consistency is moderate to high. Pilot testing demonstrated the feasibility of using child self-report as one strategy to assess child victimization. Practice implications The ICAST C is a multi-national, multi-lingual, consensus-based survey instrument. It is available in six languages for international research to estimate child victimization. Assessing the prevalence of child victimization is critical in understanding the scope of the problem, setting national and local priorities, and garnering support for program and policy development aimed at child protection.

The functional liminality of the not-dead-yet students, or, how public schooling became compulsory: A glancing history

This paper redefines the focus for narrating histories of education in the USA through a ‘glancing history’. It highlights the important role played by ‘not-dead-yet students’ who occupied a liminal place on the scale of life in late nineteenth- and early twentieth-century. Traditional histories of education have been more singularly focused on the advent and dynamics of public schooling, ignoring the functionality of such child subjects to public schooling’s existence. This paper argues that public schools as historical objects cannot be understood outside of a broader trinary system of prior institutions that were established for ‘delinquent’ and ‘special’ children. These prior institutions facilitated the formation of ‘the public’ in public schooling less in opposition to ‘the private’ and more in consonance with ‘the human’. The existence of prior institutions enabled the enforcement of compulsory attendance legislation. Compulsory attendance legislation, in place across all existing states by 1918, was concerned more with the conditions for exclusion and exemption than with compelling attendance. Thus, at the most immediate level, this paper historicizes some of the discursive and hence institutional events that linked an array of tutelary complexes by the early 1900s, and which enabled such legislation. This part of the argument extends the notion of institution to consider broader places of confinement and systematicity. It examines the prior practice of reservation and slavery systems, and the efficacy they lent to further institutionalized segregation in the USA. At a second level, the narrative reflects on how such a narration has become possible. It considers how histories of education can currently be rethought and rewritten around the notion of dis/ability, historicizing the formation of dis/ability as identity categories made noticeable in part (and circularly) through the crystallization of a segregated but linked common schooling system. The paper thus provides a counter-memory against dominant economic foundationalist and psychomedical accounts of schooling’s past. It documents both ‘external’ conditions of possibility for public schooling’s emergence and ‘internal’ effects that emerged through the experiences of confinement

State Library Queensland

Sheona Thomson writes about the transformation of a public institution in relation to a study on post-occupancy. "Brisbanites like me, with memories of long hours of study in the former buildings of the State Library of Queensland, can only marvel at the living institution we have in our city today. For most of the 80s, our bookish pursuits were hosted in the fustily intimate reading rooms of Centennial Hall, the late 1950s extension to the nineteenth-century building (formerly housing the state museum) by F. D. G. Stanley in William Street on the north bank of the Brisbane River. At the time, the wheels of an expansive cultural ambition were turning, and piece by piece on the south bank of the river the rambling Queensland Cultural Centre was realized. The fourth stage of the complex opened in 1988 as the new home for the State Library and for many years after, countless studious, transient folk whiled away time in the deep interiors of the straight-faced concrete and glass edifice by Robin Gibson and Partners..."

Pulse-echo ultrasound transit time spectroscopy: A comparison of experimental measurements and simulation prediction

Considering ultrasound propagation through complex composite media as an array of parallel sonic rays, a comparison of computer simulated prediction with experimental data has previously been reported for transmission mode (where one transducer serves as transmitter, the other as receiver) in a series of ten acrylic step-wedge samples, immersed in water, exhibiting varying degrees of transit time inhomogeneity. In this study, the same samples were used but in pulse-echo mode, where the same ultrasound transducer served as both transmitter and receiver, detecting both ‘primary’ (internal sample interface) and ‘secondary’ (external sample interface) echoes. A transit time spectrum (TTS) was derived, describing the proportion of sonic rays with a particular transit time. A computer simulation was performed to predict the transit time and amplitude of various echoes created, and compared with experimental data. Applying an amplitude-tolerance analysis, 91.7±3.7% of the simulated data was within ±1 standard deviation (STD) of the experimentally measured amplitude-time data. Correlation of predicted and experimental transit time spectra provided coefficients of determination (R2) ranging from 100.0% to 96.8% for the various samples tested. The results acquired from this study provide good evidence for the concept of parallel sonic rays. Further, deconvolution of experimental input and output signals has been shown to provide an effective method to identify echoes otherwise lost due to phase cancellation. Potential applications of pulse-echo ultrasound transit time spectroscopy (PE-UTTS) include improvement of ultrasound image fidelity by improving spatial resolution and reducing phase interference artefacts.

#auspol: The hashtag as community, event, and material object for engaging with Australian politics

Critical, loud, highly discursive and polarised; the #auspol hashtag represents a space, an event and a network for politically involved individuals to engage in and with Australian politics and speak to, at and about a variety of involved stakeholders. Contributors declare, debate and often berate each other’s opinions about current Australian politics. The hashtag itself is an important material object and engagement event involved within this performance of political participation. As a long-standing institution in the Twittersphere, and one studied by the authors and their colleagues since its early beginnings (Bruns and Burgess, 2011; Bruns and Stieglitz, 2012; 2013), the #auspol hashtag provides a potent case study through which to explore the discursive and affective dimensions of a hashtag public. This chapter that engages both empirically and theoretically with the use of this particular hashtag on Twitter to provide a qualitatively illustrated case in point for thinking about the long-term use of political hashtags as engagement events.

Evaluation of growth and changes in body composition following neonatal diagnosis of cystic fibrosis

Early deficits in nutritional status that might require specific treatment and early response to nutritional therapy were studied longitudinally in 25 infants with cystic fibrosis (CF) diagnosed by neonatal screening, using anthropometric and research body composition methodology, and evaluation of pancreatic function. At the time of confirmed diagnosis (mean 5.4 weeks), body mass, length, total body fat (TBF), and total body potassium (TBK) were all significantly reduced. Following diagnosis and commencement of therapy there was a normalization of weight, length, and TBK by 6-12 months of age, indicating catch-up growth. But in some individuals the response was incomplete, and as a group, mean total body fat remained significantly lower than normal at 1 year of age. Seven of 25 (28%) were pancreatic sufficient at diagnosis, and all but one had evidence of declining pancreatic function requiring the institution of pancreatic enzyme therapy during the next 1-9 months. The median age of commencement of enzyme therapy was 10 weeks (range 5 weeks to 11 months). These longitudinal assessments emphasize the dynamic changes occurring in absorptive function, body composition, and nutritional status following neonatal diagnosis of cystic fibrosis and may reflect previously described abnormalities of energy metabolism in this age group. Abnormal body composition is evident in most CF infants following diagnosis by neonatal screening but pancreatic damage may still be evolving. We suggest that early active nutritional therapy and surveillance for changes in pancreatic function are warranted in CF infants diagnosed by neonatal screening.

Lavage treatment of distal intestinal obstruction syndrome in children with cystic fibrosis

The efficacy, adverse reactions, and long-term effects of intestinal lavage treatment with a balanced electrolyte solution (Golytely) was evaluated in patients with cystic fibrosis and distal intestinal obstruction syndrome. Twenty-two patients with cystic fibrosis (mean age 21.8 years, range 14 to 34 years, 15 boys or men) who sough medical attention because of abdominal pain and a mass in the right iliac fossa received Golytely, 5.6 ± 1.9 L (mean ± 1 SD), either orally (n = 14) or via nasogastric tube (n = 8) during 5.6 ± 2.4 hours. No serious side effects occurred. Serum electrolyte values remained within normal limits. Body weight did not change significantly. Minor adverse reactions included bloating (n = 12), nausea (n = 8), vomiting (n = 1), and chills (n = 3). All but one patient reported impressive relief of symptoms and remained pain free for an average of 3 months (range 1 to 19 months). Symptoms of abdominal pain and radiologic signs of fecal impaction assessed before and after lavage both decreased significantly (P < .0001). During follow-up (mean 15.2 months, range 4 to 26 months), 11 patients required a total of 38 (range one to nine) additional doses of Golytely. Seven patients drank the solution at home (21 treatments); only two patients chose a nasogastric tube. In ten patients with symptoms of recurrent distal intestinal obstruction syndrome prior to institution of therapy, duration of hospitalization was significantly reduced by this treatment (5.1 ± 7.6 v 2.3 ± 6.3 hospital days per annum, P < .02). It is concluded that intestinal lavage is a well-accepted, safe, and effective therapy for distal intestinal obstruction syndrome in patients with cystic fibrosis.