Arm’s length pricing and multinational banks : an old fashioned approach in a modern world

In “Arm’s Length Pricing and Multinational Banks: An Old Fashioned Approach in a Modern World”, Kerrie Sadiq, describes the high level of integration of multinational financial institutions and argues that treating each element within a given operation as a separate entity for transfer pricing purposes is not economically or legally realistic. She proposes instead formulary apportionment as a device for managing this complexity.

A Bayesian regression approach to assess uncertainty in pollutant wash-off modelling

Due to knowledge gaps in relation to urban stormwater quality processes, an in-depth understanding of model uncertainty can enhance decision making. Uncertainty in stormwater quality models can originate from a range of sources such as the complexity of urban rainfall-runoff-stormwater pollutant processes and the paucity of observed data. Unfortunately, studies relating to epistemic uncertainty, which arises from the simplification of reality are limited and often deemed mostly unquantifiable. This paper presents a statistical modelling framework for ascertaining epistemic uncertainty associated with pollutant wash-off under a regression modelling paradigm using Ordinary Least Squares Regression (OLSR) and Weighted Least Squares Regression (WLSR) methods with a Bayesian/Gibbs sampling statistical approach. The study results confirmed that WLSR assuming probability distributed data provides more realistic uncertainty estimates of the observed and predicted wash-off values compared to OLSR modelling. It was also noted that the Bayesian/Gibbs sampling approach is superior compared to the most commonly adopted classical statistical and deterministic approaches commonly used in water quality modelling. The study outcomes confirmed that the predication error associated with wash-off replication is relatively higher due to limited data availability. The uncertainty analysis also highlighted the variability of the wash-off modelling coefficient k as a function of complex physical processes, which is primarily influenced by surface characteristics and rainfall intensity.

A methodological approach to reporting corrected small field relative outputs

Purpose The goal of this work was to set out a methodology for measuring and reporting small field relative output and to assess the application of published correction factors across a population of linear accelerators. Methods and materials Measurements were made at 6 MV on five Varian iX accelerators using two PTW T60017 unshielded diodes. Relative output readings and profile measurements were made for nominal square field sizes of side 0.5 to 1.0 cm. The actual in-plane (A) and cross-plane (B) field widths were taken to be the FWHM at the 50% isodose level. An effective field size, defined as FSeff=A·B, was calculated and is presented as a field size metric. FSeffFSeff was used to linearly interpolate between published Monte Carlo (MC) calculated kQclin,Qmsrfclin,fmsr values to correct for the diode over-response in small fields. Results The relative output data reported as a function of the nominal field size were different across the accelerator population by up to nearly 10%. However, using the effective field size for reporting showed that the actual output ratios were consistent across the accelerator population to within the experimental uncertainty of ±1.0%. Correcting the measured relative output using kQclin,Qmsrfclin,fmsr at both the nominal and effective field sizes produce output factors that were not identical but differ by much less than the reported experimental and/or MC statistical uncertainties. Conclusions In general, the proposed methodology removes much of the ambiguity in reporting and interpreting small field dosimetric quantities and facilitates a clear dosimetric comparison across a population of linacs

Estimation of biodiesel properties from chemical composition – An artificial neural network (ANN) approach

Biodiesel, produced from renewable feedstock represents a more sustainable source of energy and will therefore play a significant role in providing the energy requirements for transportation in the near future. Chemically, all biodiesels are fatty acid methyl esters (FAME), produced from raw vegetable oil and animal fat. However, clear differences in chemical structure are apparent from one feedstock to the next in terms of chain length, degree of unsaturation, number of double bonds and double bond configuration-which all determine the fuel properties of biodiesel. In this study, prediction models were developed to estimate kinematic viscosity of biodiesel using an Artificial Neural Network (ANN) modelling technique. While developing the model, 27 parameters based on chemical composition commonly found in biodiesel were used as the input variables and kinematic viscosity of biodiesel was used as output variable. Necessary data to develop and simulate the network were collected from more than 120 published peer reviewed papers. The Neural Networks Toolbox of MatLab R2012a software was used to train, validate and simulate the ANN model on a personal computer. The network architecture and learning algorithm were optimised following a trial and error method to obtain the best prediction of the kinematic viscosity. The predictive performance of the model was determined by calculating the coefficient of determination (R2), root mean squared (RMS) and maximum average error percentage (MAEP) between predicted and experimental results. This study found high predictive accuracy of the ANN in predicting fuel properties of biodiesel and has demonstrated the ability of the ANN model to find a meaningful relationship between biodiesel chemical composition and fuel properties. Therefore the model developed in this study can be a useful tool to accurately predict biodiesel fuel properties instead of undertaking costly and time consuming experimental tests.

A product of their culture : Using a value systems approach to understand the work practices of journalists

Past approaches adopted by scholars in comparing international news have tended to concentrate on political and economic perspectives, while the role that culture plays in determining news has been somewhat neglected until recently. This article examines the role of culture in the development of journalistic practices and how a value systems approach can be applied to understanding journalism practices across cultures. Specifically, the article compares German and Anglo-American journalism practices with a view to locating differences between these traditions. The study demonstrates that using value systems as developed by Dutch anthropologist Geert Hofstede can be immensely useful in comparing the differences between the two traditions, as well as in understanding how journalists in these traditions report about the world.

Product ecosystems : an emerging methodological approach to study the implementation of disruptive innovations : the case of the CityCar

The car has arguably had more influence on our lifestyle and urban environment than any other consumer product; allowing unprecedented freedom for living, working and recreation where and when we choose. However, problems of pollution, congestion, road trauma, inefficient land use and social inequality are associated with car use. Despite 100 years of design and technology refinements, the aforementioned problems are significant and persistent: many argue that resolving these problems requires a fundamental redesign of the car. Redesigned vehicles have been proposed such as the MIT CityCar and others such as the Renault Twizy, commercialized. None however have successfully brought about significant change and the study of disruptive innovation offers an explanation for this. Disruptive innovation, by definition, disrupts a market. It also disrupts the product ecosystem. The existing product ecosystem has co-evolved to support the conventional car and is not optimized for the new design: which will require a redesigned ecosystem to support it. A literature review identifies a lack of methodology for identifying the components of product ecosystems and the changes required for disruptive innovation implementation. This paper proposes such a methodology based on Design Thinking, Actor Network Theory, Disruptive Innovation and the CityCar scenarios.

Introducing dynamics : a new approach to "new media" [Editorial]

The term ‘‘new media’’ has been in play for decades now, and one might be forgiven for wondering how much longer digital forms and platforms can really be called ‘‘new,’’ or even what the scholarship of new media contributes to knowledge. Is it possible to say new things about new media? We think so. This Companion not only demonstrates the variety, salience, and importance of new media studies but also proposes a distinctive approach to the topic : an approach we call ‘‘new media dynamics.’’ In this view, what’s interesting about ‘‘new media’’ is not novelty as such but dynamism. Capitalism, technology, social networks, and media all evolve and change, sometimes to our delight, sometimes our dismay. This incessant process of disruption, renewal, and eventual (if often partial) replacement is now one of humanity’s central experiences. This cutting-edge collection brings together a stellar array of the world’s top researchers, cultural entrepreneurs, and emerging scholars to give the dynamics of new media their first full-length, multidisciplinary, historical, and critical treatment. Across 34 chapters, an international line-up of the very best authors reflects on the historical, technical, cultural, and political changes that underlie the emergence of new media, as existing patterns and assumptions are challenged by the forces of ‘‘creative destruction’’ and innovation, both economic and cultural. At the same time they show that familiar themes and problems carry through from ‘‘old’’media – questions of identity, sexuality, politics, relationships, and meaning.

Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

A new approach for evaluating the benefits of smart grid development

In this paper, the inherent mechanism of benefits associated with smart grid development is examined based on the Pressure-State-Response (PSR) model from resource economics. The emerging types of technology brought up by smart grid development are taken as pressures. The improvements of the performance and efficiency of power system operation are taken as states. The effects of smart grid development on society are taken as responses. Then, a novel method for evaluating social benefits in energy saving and CO2 emission reduction from smart grid development is presented. Finally, the benefits in a province in northwest China is carried out by employing the developed evaluation system, and reasonable evaluation results are attained.

Reaction of Aromatic Peroxyl Radicals with Alkynes: A Mass Spectrometric and Computational Study Using the Distonic Radical Ion Approach

The reaction of the aromatic distonic peroxyl radical cations N-methyl pyridinium-4-peroxyl (PyrOO center dot+) and 4-(N,N,N-trimethyl ammonium)-phenyl peroxyl (AnOO center dot+), with symmetrical dialkyl alkynes 10?ac was studied in the gas phase by mass spectrometry. PyrOO center dot+ and AnOO center dot+ were produced through reaction of the respective distonic aryl radical cations Pyr center dot+ and An center dot+ with oxygen, O2. For the reaction of Pyr center dot+ with O2 an absolute rate coefficient of k1=7.1X10-12 cm3 molecule-1 s-1 and a collision efficiency of 1.2?% was determined at 298 K. The strongly electrophilic PyrOO center dot+ reacts with 3-hexyne and 4-octyne with absolute rate coefficients of khexyne=1.5X10-10 cm3 molecule-1 s-1 and koctyne=2.8X10-10 cm3 molecule-1 s-1, respectively, at 298 K. The reaction of both PyrOO center dot+ and AnOO center dot+ proceeds by radical addition to the alkyne, whereas propargylic hydrogen abstraction was observed as a very minor pathway only in the reactions involving PyrOO center dot+. A major reaction pathway of the vinyl radicals 11 formed upon PyrOO center dot+ addition to the alkynes involves gamma-fragmentation of the peroxy O?O bond and formation of PyrO center dot+. The PyrO center dot+ is rapidly trapped by intermolecular hydrogen abstraction, presumably from a propargylic methylene group in the alkyne. The reaction of the less electrophilic AnOO center dot+ with alkynes is considerably slower and resulted in formation of AnO center dot+ as the only charged product. These findings suggest that electrophilic aromatic peroxyl radicals act as oxygen atom donors, which can be used to generate alpha-oxo carbenes 13 (or isomeric species) from alkynes in a single step. Besides gamma-fragmentation, a number of competing unimolecular dissociative reactions also occur in vinyl radicals 11. The potential energy diagrams of these reactions were explored with density functional theory and ab initio methods, which enabled identification of the chemical structures of the most important products.

A multi-scaling approach to predict hydraulic damage of poromaterials

The purpose of this paper is to introduce the concept of hydraulic damage and its numerical integration. Unlike the common phenomenological continuum damage mechanics approaches, the procedure introduced in this paper relies on mature concepts of homogenization, linear fracture mechanics, and thermodynamics. The model is applied to the problem of fault reactivation within resource reservoirs. The results show that propagation of weaknesses is highly driven by the contrasts of properties in porous media. In particular, it is affected by the fracture toughness of host rocks. Hydraulic damage is diffused when it takes place within extended geological units and localized at interfaces and faults.

Towards an international approach for geography education

"Geography education is indispensable to the development of responsible and active citizens in the present and future world" is one of the main statements in the International Charter on Geographical Education. This charter was edited in 1992 by Haubrich, chair of the Commission on Geographical Education of the International Geographical Union (IGU). Twenty years later this statement is still true. Geography educators all over the world are looking for ways to talk with young people about their image of their world and to help them to develop their knowledge, skills and ideas about the complex world we live in. However, different ideas exist about what geography we should learn and teach and how. The Commission on Geographical Education of the International Geographical Union tries to help to improve the quality and position of geography education worldwide promoting the dissemination of good practices and research results in the field of geography education.

Redrawing the Map : An Interdisciplinary Geocritical Approach to Australian Cultural Narratives

In this chapter we seek to interrogate the methods and assumptions underpinning geocriticism by engaging with and reframing dominant ways of analysing mediated representations of Australian space in cultural narratives, specifically film, literature, and theatre. What, we ask, might geocriticism contribute to the analysis of Australian texts in which location figures prominently? We argue a geocritical approach may provide an interdisciplinary framework that offers a way of identifying tropes across geographic regions and across media representations. Drawing on scholarship spanning Australian cinematic, literary and theatrical narratives, this chapter surveys published work in the field and posits that a refined geocritical mapping and analysis of the cultural terrain foregrounds the significance of geography to culture and draws different traditions of spatial enquiry into dialogue without privileging any particular textual form. We conclude by scoping possibilities for future research emerging from recent technological developments in interactive online cartography.

Deleuze and music : a creative approach to the study of music

The work of Gilles Deleuze has influenced an increasing number of music scholars and practicing musicians, particularly those interested in experimental, electronic and popular music. This is despite the notoriously complex nature of his writings, and the specialised theoretical vocabulary that he employs. This thesis both demystifies some of the key terms and concepts of this vocabulary, before demonstrating how Deleuze’s ideas may be put to work in new and fruitful ways; this is achieved with specific reference to the relationships that music has with thought, time and machines. In Chapter 1, Deleuze’s understanding of the power of thought is examined, in particular his approach to communication, transcendence and immanence, and the “powers of thought.” Each of these concepts helps us to understand Deleuze’s work within broad problem of how to think about music immanently: that is, how to maintain that thought and music are both immanent aspects of life and experience. Chapter 2 examines time within a Deleuzian framework, linking his work on cinema with the concept of the “refrain”; both of these areas prove crucial to his understanding of music, as seen in Deleuze’s approach to the work of Varese, Messiaen, and Boulez. In addition, Deleuze’s understanding of time proves fruitful in examining various aspects of music production, as seen in contemporary electronic dance music. Finally, Chapter 3 looks at the concept of the machine, as developed by Deleuze and Guattari, with reference to the sorts of “machinic” connections that a Deleuzian approach encourages us to seek out in music. Once again, examples from contemporary electronic music are presented, in relation to the notions of becoming and subjectivity. Throughout these chapters, Deleuze’s broad understanding of philosophy as the “creation of concepts” is deployed. This means introducing new ideas and specific types of music that encourage creative and novel engagements with the study of music.