International transfer pricing : the Australian approach and lessons for Canada

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.

Tracking the magmatic evolution of island arc volcanism : insights from a high-precision Pb isotope record of Montserrat, Lesser Antilles

The volcanic succession on Montserrat provides an opportunity to examine the magmatic evolution of island arc volcanism over a ∼2.5 Ma period, extending from the andesites of the Silver Hills center, to the currently active Soufrière Hills volcano (February 2010). Here we present high-precision double-spike Pb isotope data, combined with trace element and Sr-Nd isotope data throughout this period of Montserrat's volcanic evolution. We demonstrate that each volcanic center; South Soufrière Hills, Soufrière Hills, Centre Hills and Silver Hills, can be clearly discriminated using trace element and isotopic parameters. Variations in these parameters suggest there have been systematic and episodic changes in the subduction input. The SSH center, in particular, has a greater slab fluid signature, as indicated by low Ce/Pb, but less sediment addition than the other volcanic centers, which have higher Th/Ce. Pb isotope data from Montserrat fall along two trends, the Silver Hills, Centre Hills and Soufrière Hills lie on a general trend of the Lesser Antilles volcanics, whereas SSH volcanics define a separate trend. The Soufrière Hills and SSH volcanic centers were erupted at approximately the same time, but retain distinctive isotopic signatures, suggesting that the SSH magmas have a different source to the other volcanic centers. We hypothesize that this rapid magmatic source change is controlled by the regional transtensional regime, which allowed the SSH magma to be extracted from a shallower source. The Pb isotopes indicate an interplay between subduction derived components and a MORB-like mantle wedge influenced by a Galapagos plume-like source.

Climates of Hate: Media and State Inspired Victimisation of Muslims in Canada and Australia since 9/11

This article represents a preliminary comparative exploration of anti-Muslim racism and violence in Australia and Canada, especially since September 11. We contextualise the anti-Muslim vilification and victimisation within parallel – yet still distinct – political climates that bestow permission to hate. That is, negative media portrayals, together with discriminatory rhetoric, policy and practices at the level of the state create an enabling environment that signals the legitimacy of public hostility toward the Muslim communities. We conclude by pointing toward the need for more extensive empirical exploration of the phenomenon in both countries.

Tephrochronology of marine sediments around the Island of Montserrat, Lesser Antilles volcanic arc

The recent history of the Soufrière Hills Volcano, Montserrat, Lesser Antilles volcanic arc, is reconstructed using data obtained from recently drilled submarine cores.Tephra layers in these cores preserve a record of the volcanic history of Montserrat back to ~250 ka on the basis of micropaleontology and stable isotope stratigraphy. Stratigraphic relationships identified in the cores collected in 2002 and 2005 document the fate of both pyroclastic flows entering the ocean to the east of Montserrat and carbonate-rich turbidites sourced from the carbonate platformssurrounding the islands of the Lesser Antilles. Using oxygen isotope stratigraphy, micropalaeontological analysis and Carbon-14 dating, it can be shown that three significant volcanic events, including the on-going eruption, have occurred over the last 12 ka. Preceding this was a time of volcanic quiescence, with three carbonate-rich turbidite events being documented in many of the cores. Our data suggest that these events occurred during Marine Isotope Stage 2, following the Last Glacial Maximum (LGM) and onset of post-glacial sea level rise.

The gender wage gap : a comparison of Australia and Canada

Using data from the 1989 Canadian Labour Market Activity Survey and, for Australia, the 1989-90 Income Distribution Survey, the authors investigate the reasons for the significantly lower gender wage gap in Australia than in Canada. Key similarities and differences between these two countries, the authors argue, make them a good basis for a "natural experiment" to investigate the effects of different labor market institutions. In particular, Australia has a stronger union movement and a greater degree of centralization in wage determination than Canada, and most of its workers are covered by legally binding minimum working conditions. The authors conclude that several differences between the countries in labor market structure-notably, a lower rate of return to education, a lower rate of return to labor market experience, and a lower level of wage inequality in Australia than in Canada- are largely responsible for the smaller gender wage gap in Australia.

4000 years of phenotypic change in an island bird: heterogeneity of selection over three microevolutionary timescales.

Pronounced phenotypic shifts in island populations are typically attributed to natural selection, but reconstructing heterogeneity in long-term selective regimes remains a challenge. We examined a scenario of divergence proposed for species colonizing a new environment, involving directional selection with a rapid shift to a new optimum and subsequent stabilization. We provide some of the first empirical evidence for this model of evolution using morphological data from three timescales in an island bird, Zosterops lateralis chlorocephalus. In less than four millennia since separation from its mainland counterpart, a substantial increase in body size has occurred and was probably achieved in fewer than 500 generations after colonization. Over four recent decades, morphological traits have fluctuated in size but showed no significant directional trends, suggesting maintenance of a relatively stable phenotype. Finally, estimates of contemporary selection gradients indicated generally weak directional selection. These results provide a rare description of heterogeneity in long-term natural regimes, and caution that observations of current selection may be of limited value in inferring mechanisms of past adaptation due to a lack of constancy even over short time-frames.

Large body size in an island-dwelling bird : a microevolutionary analysis

Island races of passerine birds display repeated evolution towards larger body size compared with their continental ancestors. The Capricorn silvereye (Zosterops lateralis chlorocephalus) has become up to six phenotypic standard deviations bigger in several morphological measures since colonization of an island approximately 4000 years ago. We estimated the genetic variance-covariance (G) matrix using full-sib and 'animal model' analyses, and selection gradients, for six morphological traits under field conditions in three consecutive cohorts of nestlings. Significant levels of genetic variance were found for all traits. Significant directional selection was detected for wing and tail lengths in one year and quadratic selection on culmen depth in another year. Although selection gradients on many traits were negative, the predicted evolutionary response to selection of these traits for all cohorts was uniformly positive. These results indicate that the G matrix and predicted evolutionary responses are consistent with those of a population evolving in the manner observed in the island passerine trend, that is, towards larger body size.

Role of kilometer-scale weak circular heterogeneities on upper crustal deformation patterns: Evidence from scaled analogue modeling and the Sudbury Basin, Canada

The Sudbury Basin is a non-cylindrical fold basin occupying the central portion of the Sudbury Impact Structure. The impact structure lends itself excellently to explore the structural evolution of continental crust containing a circular region of long-term weakness. In a series of scaled analogue experiments various model crustal configurations were shortened horizontally at a constant rate. In mechanically weakened crust, model basins formed that mimic several first-order structural characteristics of the Sudbury Basin: (1) asymmetric, non-cylindrical folding of the Basin, (2) structures indicating concentric shortening around lateral basin termini and (3) the presence of a zone of strain concentration near the hinge zones of model basins. Geometrically and kinematically this zone corresponds to the South Range Shear Zone of the Sudbury Basin. According to our experiments, this shear zone is a direct mechanical consequence of basin formation, rather than the result of thrusting following folding. Overall, the models highlight the structurally anomalous character of the Sudbury Basin within the Paleoproterozoic Eastern Penokean Orogen. In particular, our models suggest that the Basin formed by pure shear thickening of crust, whereas transpressive deformation prevailed elsewhere in the orogen. The model basin is deformed by thickening and non-cylindrical synformal buckling, while conjugate transpressive shear zones propagated away from its lateral tips. This is consistent with pure shear deformation of a weak circular inclusion in a strong matrix. The models suggest that the Sudbury Basin formed as a consequence of long-term weakening of the upper crust by meteorite impact.

An Indigenous perspective on the standardisation of restorative justice in New Zealand and Canada

The dramatic increase in restorative justice activity in western jurisdictions since the early 1990s has driven state officials, supported by some theorists and practitioners, to standardise the design and delivery of restorative justice programmes. The purpose of this paper is to provide a critical indigenous examination of various rationale proffered in support of the standardisation process that is occurring in the neo-colonial jurisdictions of Canada and New Zealand. The paper ends with a call for Maori justice practitioners to develop their own standard for enhancing the delivery of restorative justice initiatives to Maori offenders, victims, families and communities.