The taxation of multinational banks : alternative apportionment through a unitary taxation regime aligning with economic reality

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.

Controlled growth of carbon nanotubes for electronic and photovoltaic applications

Carbon nanotubes (CNTs), experimentally observed for the first time twenty years ago, have triggered an unprecedented research effort, on the account of their astonishing structural, mechanical and electronic properties. Unfortunately, the current inability in predicting the CNTs’ properties and the difficulty in controlling their position on a substrate are often limiting factors for the application of this material in actual devices. This research aims at the creation of specific methodologies for controlled synthesis of CNTs, leading to effectively employ them in various fields of electronics, e.g. photovoltaics. Focused Ion Beam (FIB) patterning of Si surfaces is here proposed as a means for ordering the assembly of vertical-aligned CNTs. With this technique, substrates with specific nano-structured morphologies have been prepared, enabling a high degree of control over CNTs’ position and size. On these nano-structured substrates, the growth of CNTs has been realized by chemical vapor deposition (CVD), i.e. thermal decomposition of hydrocarbon gases over a heated catalyst. The most common materials used as catalysts in CVD are transition metals like Fe and Ni; however, their presence in the CNT products often results in shortcomings for electronic applications, especially for those based on silicon, being the metallic impurities incompatible with very-large-scale integration (VLSI) technology. In the present work the role of Ge dots as an alternative catalysts for CNTs synthesis on Si substrates has been thoroughly assessed, finding a close connection between the catalytic activity of such material and the CVD conditions, which can affect both size and morphology of the dots. Successful CNT growths from Ge dots have been obtained by CVD at temperatures ranging from 750 to 1000°C, with mixtures of acetylene and hydrogen in an argon carrier gas. The morphology of the Si surface is observed to play a crucial role for the outcome of the CNT synthesis: natural (i.e. chemical etching) and artificial (i.e. FIB patterning, nanoindentation) means of altering this morphology in a controlled way have been then explored to optimize the CNTs yield. All the knowledge acquired in this study has been finally applied to synthesize CNTs on transparent conductive electrodes (indium-tin oxide, ITO, coated glasses), for the creation of a new class of anodes for organic photovoltaics. An accurate procedure has been established which guarantees a controlled inclusion of CNTs on ITO films, preserving their optical and electrical properties. By using this set of conditions, a CNTenhanced electrode has been built, contributing to improve the power conversion efficiency of polymeric solar cells.

Reducing Actuator Switchings for Motion Control of Autonomous Underwater Vehicles

A priority when designing control strategies for autonomous underwater vehicles is to emphasize their cost of implementation on a real vehicle. Indeed, due to the vehicles' design and the actuation modes usually under consideration for underwater plateforms the number of actuator switchings must be kept to a small value to insure feasibility and precision. This is the main objective of the algorithm presented in this paper. The theory is illustrated on two examples, one is a fully actuated underwater vehicle capable of motion in six-degrees-of freedom and one is minimally actuated with control motions in the vertical plane only.

A tutorial on visual servo control

This article provides a tutorial introduction to visual servo control of robotic manipulators. Since the topic spans many disciplines our goal is limited to providing a basic conceptual framework. We begin by reviewing the prerequisite topics from robotics and computer vision, including a brief review of coordinate transformations, velocity representation, and a description of the geometric aspects of the image formation process. We then present a taxonomy of visual servo control systems. The two major classes of systems, position-based and image-based systems, are then discussed in detail. Since any visual servo system must be capable of tracking image features in a sequence of images, we also include an overview of feature-based and correlation-based methods for tracking. We conclude the tutorial with a number of observations on the current directions of the research field of visual servo control.

Alternative primary sources for studying Australian television history : an annotated list of online private collections

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)...

An estimation of crash risks using a log-linear model and the induced exposure technique

Prevention and safety promotion programmes. Traditionally, in-depth investigations of crash risks are conducted using exposure controlled study or case-control methodology. However, these studies need either observational data for control cases or exogenous exposure data like vehicle-kilometres travel, entry flow or product of conflicting flow for a particular traffic location, or a traffic site. These data are not readily available and often require extensive data collection effort on a system-wide basis. Aim: The objective of this research is to propose an alternative methodology to investigate crash risks of a road user group in different circumstances using readily available traffic police crash data. Methods: This study employs a combination of a log-linear model and the quasi-induced exposure technique to estimate crash risks of a road user group. While the log-linear model reveals the significant interactions and thus the prevalence of crashes of a road user group under various sets of traffic, environmental and roadway factors, the quasi-induced exposure technique estimates relative exposure of that road user in the same set of explanatory variables. Therefore, the combination of these two techniques provides relative measures of crash risks under various influences of roadway, environmental and traffic conditions. The proposed methodology has been illustrated using Brisbane motorcycle crash data of five years. Results: Interpretations of results on different combination of interactive factors show that the poor conspicuity of motorcycles is a predominant cause of motorcycle crashes. Inability of other drivers to correctly judge the speed and distance of an oncoming motorcyclist is also evident in right-of-way violation motorcycle crashes at intersections. Discussion and Conclusions: The combination of a log-linear model and the induced exposure technique is a promising methodology and can be applied to better estimate crash risks of other road users. This study also highlights the importance of considering interaction effects to better understand hazardous situations. A further study on the comparison between the proposed methodology and case-control method would be useful.

A mill design concept for reducing bagasse moisture

This paper describes the development and testing of a novel mill design to reduce the moisture content of bagasse. It takes advantage of gravity to separate juice from bagasse by pushing bagasse upwards while juice drains downwards under gravity. The potential of the design to reduce bagasse moisture content has not been adequately established. The prototype mill had limited power available that prevented typical delivery nip compactions from being achieved. Tests conducted did show a reduction in bagasse moisture but that moisture reduction is less than expected under ideal conditions. Work on the mill design has ceased, at least for the foreseeable future. The design does have potential to reduce bagasse moisture content but presents some engineering challenges to establish a reliable, low maintenance design alternative.

Rapid prototyping framework for visual control of autonomous micro aerial vehicles

Rapid prototyping environments can speed up the research of visual control algorithms. We have designed and implemented a software framework for fast prototyping of visual control algorithms for Micro Aerial Vehicles (MAV). We have applied a combination of a proxy-based network communication architecture and a custom Application Programming Interface. This allows multiple experimental configurations, like drone swarms or distributed processing of a drone's video stream. Currently, the framework supports a low-cost MAV: the Parrot AR.Drone. Real tests have been performed on this platform and the results show comparatively low figures of the extra communication delay introduced by the framework, while adding new functionalities and flexibility to the selected drone. This implementation is open-source and can be downloaded from www.vision4uav.com/?q=VC4MAV-FW

See-and-avoid quadcopter using fuzzy control optimized by cross-entropy

In this work we present an optimized fuzzy visual servoing system for obstacle avoidance using an unmanned aerial vehicle. The cross-entropy theory is used to optimise the gains of our controllers. The optimization process was made using the ROS-Gazebo 3D simulation with purposeful extensions developed for our experiments. Visual servoing is achieved through an image processing front-end that uses the Camshift algorithm to detect and track objects in the scene. Experimental flight trials using a small quadrotor were performed to validate the parameters estimated from simulation. The integration of cross- entropy methods is a straightforward way to estimate optimal gains achieving excellent results when tested in real flights.

UAS See-and-Avoid using two different approaches of Fuzzy Control

This work presents two UAS See and Avoid approaches using Fuzzy Control. We compare the performance of each controller when a Cross-Entropy method is applied to optimase the parameters for one of the controllers. Each controller receive information from an image processing front-end that detect and track targets in the environment. Visual information is then used under a visual servoing approach to perform autonomous avoidance. Experimental flight trials using a small quadrotor were performed to validate and compare the behaviour of both controllers

Evaluation of the control of carbon emissions of construction facilities in Hong Kong

This paper investigates the policies and instruments adopted in Hong Kong to control the carbon emissions of construction facilities, including the whole building life cycle: production of material stage, construction stage, operation stage and demolition stage. This commences with a literature review comparing activities world-wide to those in Hong Kong to identify the main issues at stake, followed by a report on a series of local interviews to evaluate the present situation in Hong Kong, as well as future opportunities for local carbon mitigation. The interviewees included practitioners from engineering contracting firms, consulting firms, clients and energy provider, together with two university experts and a counsellor. A small case study is also provided of a building project in Hong Kong to illustrate some of the innovative design aspects being incorporated into buildings in Hong Kong as a result of the current emphasis on sustainability. The paper concludes with a summary of main findings and proposals for improvement in policy related to carbon mitigation and building sustainability in Hong Kong.

Socioeconomic inequalities in weight status among mid-aged adults : the contribution of perceptions of weight status and weight-control behaviours

Background Socioeconomically-disadvantaged adults in developed countries experience a higher prevalence of a number of chronic diseases, such as cardiovascular disease, type 2 diabetes, osteoarthritis and some forms of cancer. Overweight and obesity are major risk factors for these diseases. Lower socioeconomic groups have a greater prevalence of overweight and obesity and this may contribute to their higher morbidity and mortality. International studies suggest that socioeconomic groups may differ in their self-perceptions of weight status and their engagement in weightcontrol behaviours (WCBs). Research has shown that lower socioeconomic adults are more likely to underestimate their weight status, and are less likely to engage in WCBs. This may contribute (in part) to the marked inequalities in weight status observed at the population level. There are few, and somewhat limited, Australian studies that have examined the types of weight-control strategies people adopt, the barriers to their weight control, the determinants of their perceived weight status and WCBs. Furthermore, there are no known Australian studies that have examined socioeconomic differences in these factors to better understand the reasons for socioeconomic inequalities in weight status. Hence, the overall aim of this Thesis is to examine why socioeconomically-disadvantaged group experience a greater prevalence of overweight and obesity than their more-advantaged counterparts. Methods This Thesis used data from two sources. Men and women aged 45 to 60 years were examined from both data source. First, the longitudinal Australian Diabetes, Obesity and Lifestyle (AusDiab) Study were used to advance our knowledge and understanding of socioeconomic differences in weight change, perceived weight status and WCBs. A total of 2753 participants with measured weights at both baseline (1999-2000) and follow-up (2004-2005) were included in the analyses. Percent weight change over the five-year interval was calculated and perceived weight status, WCBs and highest attained education were collected at baseline. Second, the Candidate conducted a postal questionnaire from 1013 Brisbane residents (69.8 % response rate) to investigate the relationship between socioeconomic position, determinants of perceived weight status, WCBs, and barriers and reasons to weight control. A test-retest reliability study was conducted to determine the reliability of the new measures used in the questionnaire. Most new measures had substantial to almost perfect reliability when considering either kappa coefficient or crude agreement. Results The findings from the AusDiab Study (accepted for publication in the Australian and New Zealand Journal of Public Health) showed that low-educated men and women were more likely to be obese at baseline compared to their higheducated respondents (O.R. = 1.97, 95 % C.I. = 1.30-2.98 and O.R. = 1.52, 95 % C.I. = 1.03-2.25, respectively). Over the five year follow-up period (1999-2000 to 2004- 05) there were no socioeconomic differences in weight change among men, however socioeconomically-disadvantaged women had greater weight gains. Participants perceiving themselves as overweight gained less weight than those who saw themselves as underweight or normal weight. There was no relationship between engaging in WCBs and five-year weight change. The postal questionnaire data showed that socioeconomically-disadvantaged groups were less likely to engage in WCBs. If they did engage in weight control, they were less likely to adopt exercise strategies, including moderate and vigorous physical activities but were more likely to decrease their sitting time to control their weight. Socioeconomically-disadvantaged adults reported more barriers to weight control; such as perceiving weight loss as expensive, requiring a lot of cooking skills, not being a high priority and eating differently from other people in the household. These results have been accepted for publication in Public Health Nutrition. The third manuscript (under review in Social Science and Medicine) examined socioeconomic differences in determinants of perceived weight status and reasons for weight control. The results showed that lower socioeconomic adults were more likely to specify the following reasons for weight control: they considered themselves to be too heavy, for occupational requirements, on recommendation from their doctor, family members or friends. Conversely, high-income adults were more likely to report weight control to improve their physical condition or to look more attractive compared with those on lower-incomes. There were few socioeconomic differences in the determinants of perceived weight status. Conclusions Education inequalities in overweight/obesity among men and women may be due to mis-perceptions of weight status; overweight or obese individuals in loweducated groups may not perceive their weight as problematic and therefore may not pay attention to their energy-balance behaviours. Socioeconomic groups differ in WCBs, and their reasons and perceived barriers to weight control. Health promotion programs should encourage weight control among lower socioeconomic groups. More specifically, they should encourage the engagement of physical activity or exercise and dietary strategies among disadvantaged groups. Furthermore, such programs should address potential barriers for weight control that disadvantaged groups may encounter. For example, disadvantaged groups perceive that weight control is expensive, requires cooking skills, not a high priority and eating differently from other people in the household. Lastly, health promotion programs and policies aimed at reducing overweight and obesity should be tailored to the different reasons and motivations to weight control experienced by different socioeconomic groups. Weight-control interventions targeted at higher socioeconomic groups should use improving physical condition and attractiveness as motivational goals; while, utilising social support may be more effective for encouraging weight control among lower socioeconomic groups.

Control and application of minimally-actuated underwater vehicles

Establishing a persistent presence in the ocean with an Autonomous Underwater Vehicle capable of observing temporal variability of large-scale ocean processes requires a unique sensor platform. In this paper, we examine the utility of Lagrangian profiling floats for such extended deployments. We propose a strategy that utilizes ocean model predictions to facilitate a basic level of autonomy to achieve general control of this minimally-actuated underwater vehicle. We extend experimentally validated techniques for utilising ocean current models to control under-actuated autonomous underwater vehicles by presenting this investigation into the application of these methods on profiling floats. With the appropriate vertical actuation, and utilising spatiotemporal variations in water speed and direction, we show that broad controllability results can be met. First, we apply an A* planner to a local controllability map generated from predictions of ocean currents. This computes a path between start and goal waypoints that has the highest likelihood of successful execution over a given duration. The computed depth plan is generated with a model predictive controller, and selects the depths for the vehicle so that ambient currents guide it toward the goal. Mission constraints are included to simulate and motivate a practical data collection mission. Results are presented in simulation for a mission off the coast of Los Angeles, CA USA, that show surprising results in the ability of a drifting vehicle to maintain a prescribed course and reach a desired location.

Empirical evaluation of alternative approaches in identifying crash hot spots

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.