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.

Third International Conference on plant-based vaccines and antibodies

This relatively new biennial meeting - the first was in Prague in 2005 - was chaired by Julian Ma (Guy's Hospital, London, UK), with Mario Pezzotti (University of Verona, Italy) as local organizer, and attracted approximately 180 delegates from 25 countries. The theme was 'Plant Expression Systems for Recombinant Pharmacologics': there were 46 talks gathered into two plenaries, 12 themed sessions and 72 posters. Topics covered included publicly funded and commercial developments, innovation, regulation and commercialization, competition with conventional technology, manufacture and new products. © 2009 Expert Reviews Ltd.

International differences in management of physical activity data: Can they explain some of the difference in prevalence estimates?

Background: National physical activity data suggest that there is a considerable difference in physical activity levels of US and Australian adults. Although different surveys (Active Australia and BRFSS) are used, the questions are similar. Different protocols, however, are used to estimate “activity” from the data collected. The primary aim of this study was to assess whether the 2 approaches to the management of PA data could explain some of the difference in prevalence estimates derived from the two national surveys. Methods: Secondary data analysis of the most recent AA survey (N = 2987). Results: 15% of the sample was defined as “active” using Australian criteria but as “inactive” using the BRFSS protocol, even though weekly energy expenditure was commensurate with meeting current guidelines. Younger respondents (age < 45 y) were more likely to be “misclassified” using the BRFSS criteria. Conclusions: The prevalence of activity in Australia and the US appears to be more similar than we had previously thought.

Relationships and sexual health promotion project for QUT international students

International students may experience a variety of sexual health problems which include unplanned pregnancies, abortions and sexually transmitted diseases. These are often because of limited knowledge of sexual health matters and lack of sexual health education and/or access to health services in their home country. A study was undertaken to identify the concerns of international students and how to provide culturally appropriate promotion of sexual health for international students at Queensland University of Technology (QUT). The project included consultations with stakeholders, interviews with key informants, an online survey and focus group discussions with international students. The project found that sexual health is a concern for international students, particularly in developing relationships and when becoming sexually active in Australia, and there is a perceived lack of access to health services and insufficient knowledge on sexual health matters. Preferred methods of dissemination of sexual health information included use of student mentors, web-based online resources, brochures and confidential on-line advice.

International students using online information resources to learn : complex experience and learning needs

This paper reports the findings of a qualitative study which investigated 25 international students’ use of online information resources for study purposes at two Australian universities. Using an expanded critical incident approach, the study viewed international students through an information literacy lens, as information-using learners. The findings are presented in two complementary parts: as a word picture that describes their whole experience of using online information resources to learn; and as a tabulated set of critical findings that summarises their associated information literacy learning needs. The word picture shows international students’ resource use as a complex interplay of eight inter-related elements: students; information-learning environment; interactions (with online resources); strengths-challenges; learning-help; affective responses; reflective responses; cultural-linguistic dimensions. In using online resources, the international students experience an array of strengths and challenges, and an apparent information literacy imbalance between their more developed information skills and less developed critical information use. The critical findings about information literacy needs provide a framework for developing an inclusive informed learning approach that responds to international students’ complex information using experiences and needs. While the study is situated in Australia, the findings are of potential interest to educators, information professionals and researchers worldwide who seek to support learning in culturally diverse higher education contexts.

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.

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The preferences of private equity investors in selecting target acquisitions : an international investigation

This study investigates the characteristics and attributes that private equity investors prefer when selecting target acquisitions. These characteristics are examined against a matched sample of firms subject to corporate acquisitions via tender/merger offer during 2000-2009, across seven countries: Australia, Canada, the United Kingdom, the USA, France, Germany and Sweden. We show that firm-specific characteristics are more influential in target selection than external or institutional variables. In particular, private equity targets exhibit lower stock volatility and long-term growth prospects, are larger, and have greater abnormal operating income relative to tender/merger offer target firms. Further, private equity bidders exhibit 'home bias', implying that familiarity motivates target selection. Institutional factors remain largely insignificant across all tests.

Fish out of water : refugee and international students in mainstream Australian schools

In this paper, the authors combine Pierre Bourdieu’s concept of hysteresis (the ‘fish out of water’ experience) with the discourse historical approach to critical discourse analysis (CDA) as a theoretical and analytical framework through which they examine specific moments in the schooling experiences of one refugee student and one international student, both enrolled in post-compulsory education in Australian mainstream secondary schools. We examine specific moments – as narrated by these students during interviews – in which these students can be described as ‘fish out of water’. As such, this paper takes up the concerns of researchers who call for an examination of the lived geographies and the everyday lives of individual students in mainstream schools. We find that our students’ habitus, conditioned by their previous schooling experiences in their home countries, did not match their new Australian schools, resulting in frustration with, and alienation from, their mainstream schools. However, we also note that schools, too, need to adapt and adjust their habitus to the new multicultural world, in which there are international and refugee students among their usual cohort of mainstream students.

Personalization in tag ontology learning for recommendation making

Due to the explosive growth of the Web, the domain of Web personalization has gained great momentum both in the research and commercial areas. One of the most popular web personalization systems is recommender systems. In recommender systems choosing user information that can be used to profile users is very crucial for user profiling. In Web 2.0, one facility that can help users organize Web resources of their interest is user tagging systems. Exploring user tagging behavior provides a promising way for understanding users’ information needs since tags are given directly by users. However, free and relatively uncontrolled vocabulary makes the user self-defined tags lack of standardization and semantic ambiguity. Also, the relationships among tags need to be explored since there are rich relationships among tags which could provide valuable information for us to better understand users. In this paper, we propose a novel approach for learning tag ontology based on the widely used lexical database WordNet for capturing the semantics and the structural relationships of tags. We present personalization strategies to disambiguate the semantics of tags by combining the opinion of WordNet lexicographers and users’ tagging behavior together. To personalize further, clustering of users is performed to generate a more accurate ontology for a particular group of users. In order to evaluate the usefulness of the tag ontology, we use the tag ontology in a pilot tag recommendation experiment for improving the recommendation performance by exploiting the semantic information in the tag ontology. The initial result shows that the personalized information has improved the accuracy of the tag recommendation.

Content analysis of international research in geographical and environmental education : eighteen years of academic publishing

This paper examines the history of the IRGEE Journal in terms of its sustainable future. The development of geographical and environmental education is evaluated, as reflected from the articles published in the Journal “International Research in Geographical and Environmental Education” (IRGEE). A content analysis of all papers and forum sections which have appeared in the journal since Volume 1 Number 1 was published in 1992 has been conducted, examining the content of as many as 526 articles. The method was a content analysis, and revealed themes which have experienced an increasing or declining interest over the 18 years of publication of IRGEE (1992-2009), while other themes have remained current during this period. The main findings of this analysis are: a) the total number of articles has increased more than threefold, b) articles related to geographical education (sensu stricto) outweighed those related to environmental education, c) the themes “syllabi, textbooks, curricula” and “values, attitudes” attract the attention of researchers with increasing strength and d) emerging subjects, such as GIS and sustainability have appeared dynamically in the last years.

Statistical and scientometric analysis of international research in geographical and environmental education

Certain statistic and scientometric features of articles published in the journal “International Research in Geographical and Environmental Education” are examined in this paper, for the period 1992-2009, by applying nonparametric statistics and Shannon’s entropy (diversity) formula. The main findings of this analysis are: a) after 2004 the research priorities of researchers in geographical and environmental education seem to have changed, b) “teacher education” has been the most recurrent theme throughout these 18 years, followed by “values & attitudes” and “inquiry & problem solving” c) the themes “GIS” and “Sustainability” were the most “stable” throughout the 18 years, meaning that they maintained their ranks as publication priorities more than other themes, d) citations of IRGEE increase annually, e) the average thematic diversity of articles published during the period 1992-2009 is 82.7% of the maximum thematic diversity (very high), meaning that the Journal has the capacity to attract a wide readership for the 10 themes it has successfully covered throughout the 18 years of its publication.