The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Reply to Camens : how recently did modern monotremes diversify?

Camens (1) responds to our analysis of morphological data (2) in which platypuses (Ornithorhynchidae) and echidnas (Tachyglossidae) were inferred to be each other's closest relatives, to the exclusion of Early Cretaceous forms, Teinolophos and Steropodon. Our phylogeny is consistent with the late appearance of undisputed fossil echidnas and platypuses. Molecular dating provided important independent corroboration, revealing that platypuses and echidnas diverged only 19–48 Ma, implying that Teinolophos and Steropodon (105–121 Ma) must lie outside the platypus–echidna dichotomy...

Strolling through the (post)modern city: Modes of being a flaneur in picture books

The city and the urban condition, popular subjects of art, literature, and film, have been commonly represented as fragmented, isolating, violent, with silent crowds moving through the hustle and bustle of a noisy, polluted cityspace. Included in this diverse artistic field is children’s literature—an area of creative and critical inquiry that continues to play a central role in illuminating and shaping perceptions of the city, of city lifestyles, and of the people who traverse the urban landscape. Fiction’s textual representations of cities, its sites and sights, lifestyles and characters have drawn on traditions of realist, satirical, and fantastic writing to produce the protean urban story—utopian, dystopian, visionary, satirical—with the goal of offering an account or critique of the contemporary city and the urban condition. In writing about cities and urban life, children’s literature variously locates the child in relation to the social (urban) space. This dialogic relation between subject and social space has been at the heart of writings about/of the flâneur: a figure who experiences modes of being in the city as it transforms under the influences of modernism and postmodernism. Within this context of a changing urban ontology brought about by (post)modern styles and practices, this article examines five contemporary picture books: The Cows Are Going to Paris by David Kirby and Allen Woodman; Ooh-la-la (Max in love) by Maira Kalman; Mr Chicken Goes to Paris and Old Tom’s Holiday by Leigh Hobbs; and The Empty City by David Megarrity. I investigate the possibility of these texts reviving the act of flânerie, but in a way that enables different modes of being a flâneur, a neo-flâneur. I suggest that the neo-flâneur retains some of the characteristics of the original flâneur, but incorporates others that take account of the changes wrought by postmodernity and globalization, particularly tourism and consumption. The dual issue at the heart of the discussion is that tourism and consumption as agents of cultural globalization offer a different way of thinking about the phenomenon of flânerie. While the flâneur can be regarded as the precursor to the tourist, the discussion considers how different modes of flânerie, such as the tourist-flâneur, are an inevitable outcome of commodification of the activities that accompany strolling through the (post)modern urban space.

Sustainable, smart, safe : a 3'S' approach towards a modern transportation system

Sustainability, smartness and safety are three sole components of a modern transportation system. The objective of this study is to introduce a modern transportation system in the light of a 3‘S’ approach: sustainable, smart and safe. In particular this paper studies the transportation system of Singapore to address how this system is progressing in this three-pronged approach towards a modern transportation system. While sustainability targets environmental justice and social equity without compromising economical efficiency, smartness incorporates qualities like automated sensing, processing and decision making, and action-taking into the transportation system. Since a system cannot be viable without being safe, the safety of the modern transportation system aims minimizing crash risks of all users including motorists, motorcyclists, pedestrians, and bicyclists. Various policy implications and technology applications inside the transportation system of Singapore are discussed to illustrate a modern transportation system within the framework of the 3‘S’ model.

Composing maternal identities : the living realities of mothers with young adult-children in twenty-first century Australia

There is an abundance of books available on the topic of motherhood and mothering; the majority of these books focus on the vulnerability of babies and young children and the motherwork such vulnerability demands. In particular they focus on what it is right to do in the interests of the child, and particularly his or her growth and development. Such a focus is consistent in Western culture with modern moral frameworks where understandings of goodness have been assimilated to dimensions of human action rather than dimensions of human being, selfhood, or specific forms of life. As Charles Taylor has observed, much modern moral philosophy has focused =on what it is right to do rather than the nature of the good life‘ (1989, 13). The master narratives of motherhood and the prevailing social discourses of intensive1 and sacrificial2 mothering exemplify this view as such narratives and discourses depict =what mothers are expected to do [and] how mothers are supposed to be‘ (Nelson 2001, 140). From such infant/child-focused accounts a canonical maternal identity can be discerned; arguably, it is a restricted one. The majority of these books fail to address questions related to what it means be a mother in particular situated, existing, living realities. For instance, ask a mother with young children what being a mother means to her and she may speak of the challenges she faces balancing paid employment and her role as a mother, or the impact of the demands being made on her time and energy. However, ask a mother with young adult-children3 what being a mother means to her and she may speak in similar tones, but she may also speak in differing tones. For example, a "mature" mother may speak of the "empty nest", the "crowded house" and/or "its revolving front door". She may speak of issues related to the vulnerability of the long term marriage, elder care, or grandparenting, or even disillusionment and disenchantment. The purpose of this research is to explore the identity challenges and prospects of some mothers with young adult-children aged between 18 and 30 years of age in twenty-first century Australia. In interpreting the identity challenges and prospects this particular cohort of mothers encounter in their ordinary, everyday living, a diverse and particular range of maternal experiences.my own included5.have been traced, along with the social and ethical meanings ascribed in them. With an understanding and appreciation of voice as the medium which connects one's inner and outer worlds, this research illuminates the plurality of voices and the multiple layers of meaning in each of these mother's particular living and existing realities. Specifically, this research addresses the narrowly constructed, canonical maternal identity through a critical exploration and reflection on stories, shared in a research context, of the living realities of a group of self-identified "mature", middle-class, Australian mothers with children aged between 18 and 30 years of age6. By appraising the broader familial, historical, social, cultural, institutional, and, importantly, moral contexts in which these mothers are situated, 'thick descriptions' (Geertz 1973, 27)7 of maternal identities, and the challenges and prospects these mothers are negotiating, are provided. In terms of its ethical orientation, the frameworks which support and frame this research reject, repudiate and contest (Nelson 2001) the reduction of ethical concerns to individual or intellectual problems or dilemmas to be solved through the application of a theory derived from reasoned thinking. In dismissing deductive and =theoretical-juridical‘8 approaches, the individualistic orientation entrenched in contemporary Western moral thinking, expressed in the notion of '"what ought I to do" when faced with a problem, issue or dilemma of practical urgency' (Isaacs & Massey 1994, 1), is simultaneously rejected, repudiated and contested (Nelson 2001). In countering such understandings, this research reorients us to the illumination and articulation of who it is good to be, for each of these mothers, in allegiance with those goods which guide and inspire her orientations towards living a good life—a life which embraces and enhances the flourishing of herself and her significant others. With an understanding and appreciation that 'mind is never free of precommitment[—t]here is no innocent eye, nor is there one that penetrates aboriginal reality' (Bruner 1987, 32), this thesis is written with the voices of other interlocutors9. These interlocutors include the voices of my research participants whom I refer to as "research interlocutors", my textual "friends" — those scholars whose work resonates strongly with my orientations—as well as the myriad other voices that speak to mothers, for mothers and about mothers, such as those found in popular and mainstream press and culture. Sometimes these voices resonate; other times dissonance may be heard. In situating this research within these complementary frameworks, this research invites readers to join with me in considering, appreciating and appraising the narrow construction of maternal identity. I seek for this engagement, like the engagements with my research interlocutors, to be 'a meeting of voices, an authentic dialogue that is inclusive of the voices of all concerned participants' (Isaacs 2001, 6). I hope that the voices in this thesis resonate with yours (although, at times, you may feel some dissonance) and that together we can draw closer to the accounting, re-counting and re-stor(y)ing of maternal identities; like concentric circles of witness, the dialogue, ...will thus be expanded rippling into corners where one might both imagine, and least expect. Possibilities, then, are vast; the future exciting (Smith 2007, 397). This research is also shaped and guided by maternal scholarship, a relatively new field of inquiry known as 'motherhood studies' (O'Reilly 2011, xvii) which has its origins within the broader terrain of feminist scholarship. As a work of maternal scholarship, this thesis draws upon and continues the tradition of examining motherhood as it is experienced 'in a social context, as embedded in a political institution: in feminist terms' (Rich 1995, ix). It values mothers, their experiences, their stories, their lives. As such, this research is oriented towards 'matricentric feminism', a particular form of feminist inquiry, politics and theory which is consistent with and receptive to feminist frameworks of care and equal rights (O‘Reilly 2011, 25). A number of complementary conceptual frameworks have been engaged in this research with the thesis presented in three parts: the pre-figurative, configurative and re-configurative. As my particular living experiences provided the initial motivation for this research, an account of the challenges I experienced as a mother with young adult-children are outlined as a Prelude to this thesis. Attention then turns to Part One – Pre-figuring Maternal Identities in which the contextual, conceptual and methodological foundations underpinning this research are explored and outlined. In Chapter One, the prevailing cultural narratives and social discourses supporting and shaping the construction of the canonical maternal identity are outlined. Next, in setting the scholarly context, the critiques — arising from feminist and maternal scholarship — of motherhood as a patriarchal institution, mothering as experience, and mothering as work, are explored. As this research engaged with participants who are embedded in particular middle-class, heterosexual, familial and cultural structures, an exploration of family life cycle theory and main stream media accounts are also incorporated. The terrain in which "mature" mothering within an Australian context is experienced is also outlined, including the notions of "empty nests" and "crowded houses", grandparenting, elder care and women's midlife transition. Chapter Two gives an account of the conceptual ontological, ethical, identity and narrative frameworks underpinning this research. In setting the context for rich interpretations, the characteristics of being human10 are outlined before attention turns to our embodiment and embeddedness in our shared human condition11. From this point, attention then turns to understanding the moral form of human living12. In appreciating the vulnerability inherent in our shared human condition, the ways in which we may experience trouble in our lives is noted. The framing of identity constitution13 as complex, multi-faceted, relationally negotiated and composed is then outlined, followed by an understanding of why narrative is a valuable interpretive tool for interpreting and understanding human experiences. This chapter concludes with an appreciation of the ethical significance of storytelling. The research methodology is then outlined in Chapter Three. The rationale underpinning the adoption of the narrative interviewing technique of in-depth interviewing is explored. In exploring these methodological frameworks, the recruitment and interview processes involved in gathering and interpreting the recorded transcripts of ten Australian mothers with young adult-children are outlined. The method of analysis known as the Listening Guide14 best complements the multi-layered, pluri-vocal nature of narrative accounting. The final section of Chapter Three outlines The Guide, with one mother's recorded transcript used to illustrate this method's step-by-step process. Having gathered an understanding and appreciation of the pluri-vocal, multi-layered nature of narrative and identity constitution, the tone of this thesis changes in Part Two . Configuring Maternal Identities. This section consists of Chapters Four and Five and seeks to find meaning in, and make sense of, the differences and commonalities across these particular accounts. Chapter Four explores the living realities of four Australian mothers with young adult-children: Poppy, Honey, Lily and Heather. In presenting a thick description of these mothers' situated realities, the frameworks.the familial, social, cultural, historical and institutional backgrounds.which have supported and shaped each mother's experiences are illuminated. Simultaneously revealed through these particular accounts are the plurality of goods focusing and moving each mother to the moral form of life, a life of meaning and purpose. The harms challenging some mothers' moral motivations are also revealed in this chapter. Specifically illustrated in Chapter Four are the unique and qualitative differences of particular maternal identity configurations. Chapter Five reveals the commonalities amongst all of the research interlocutors' accounts. This chapter contests the individualistic orientation of many contemporary accounts of motherhood which are aimed at defining or contesting what a "good" mother ought to do. By turning away from such individualistic orientations, the chapter does not seek to define 'the content of obligation' (Taylor 1989, 3) but rather seeks to illuminate and articulate a richer, deeper understanding and appreciation of maternal be-ing and be-coming - that is, who it is good to be, for each of these mothers - in allegiance with those goods that focus and inspire her moral motivations. Part Three - Re-Configuring Maternal Identities, which is comprised of Chapter Six, draws this thesis to a close. In this final chapter, the preconceptions, conditions and aspirations for this mother-centred account of the living realities of a small, local cohort of mothers are reiterated. The insights gathered from the rich, descriptive accounts are illuminated and articulated, and the chapter closes with some suggestions for future research. In a Postlude, I reflect on how this research has been a transformative learning experience in my own life.an experience in which I have been able to not only deeply understand and appreciate the challenges and disorientation I was experiencing but also to identify and reorient my stance in relation to the good. In a practical sense, by offering thick descriptions of the living realities of this cohort of "mature" mothers, this research challenges the canonical maternal identity and questions its relevance for, and effect on, "mature" mothers' identity constitution. By bringing to light the complex existing realities of these particular mothers, this research critiques the canonical maternal identity by illustrating that each mother's life and her identity constitutions are complex, relationally negotiated and composed and that motherhood is an enduring way of being. Through these illustrations, this research engages with and extends understandings of difference feminism. This research, however, not only rejects, repudiates and contests (Nelson 2001) the narrowly defined canonical maternal identity. By illuminating and articulating the goods which shape and inspire these "mature" mothers' motherwork, this research offers a matricentric account which is consistent with and respectful of the particular, situated realities—the broader familial, social, institutional, but most importantly, moral values and frameworks—in which each mother‘s life is embedded and her motherwork oriented. By understanding and appreciating the complex and multiple webs of relationships in which each mother exists, this matricentric re-stor(y)ing of maternal experiences not only understands and appreciates the unique nature of each mother‘s existing realities, it is oriented to the continuing enhancing of the shared pursuit of the good which underpins particular maternal practices and particular maternal ways of being.

Malay Kingship in Kedah : Religion, Trade, and Society

The book probes and examines traditional sources of royal power and control, as well as indigenous socio-political systems in the Malay world. It is focused on the north-western Malaysian Sultanate of Kedah which is acknowledged as the oldest unbroken independent kingship line in the ‘Malay and Islamic world’ with 1,000 years of history. Little scholarly attention has been paid to its pre-modern history, society, religion, system of government and unique geographic situation, potentially controlling both land and sea lines of communication into the remainder of Southeast Asia. It will thus provide the first comprehensive treatment in English, or other languages, on Kedah’s pre-modern and nineteenth century historiography and can provide a foundation for comparative studies of the various Malay states which is presently lacking. The proposed book also sheds much needed light on a range of important topics in Malay history including: Kedah and the northern Melaka Straits history, colonial expansion and rivalry, Southeast Asian history and politics, interregional migration and the influence of the sea peoples or orang laut, traditional Malay socio-political and economic life, Islamic influences and the course of Thai-Malay relations. The book attempts to offer a new understanding, not only of Kedah, but of the political and cultural development of the entire Malay world and of its relationships with the broader forces in both its continental and maritime settings. It argues that Kedah does not seem to follow, and in fact, often seems to contradict what has been commonly been accepted as the “typical model” of the traditional Malay state. Thus it concludes that the ruling dynasty has historically exploited a wide range of unique environmental conditions, local traditions, global spiritual trends and economic forces to preserve and strengthen its political position. The scope and theme of book The Kedah Sultanate is the oldest unbroken independent kingship lines in the “Malay world” with 1,000 years of history, and arguably one of the oldest in the Islamic world. In this study I examine key geopolitical and spiritual attributes of Malay kingship that have traditionally cemented the ruler, the peoples, and the environment. Brief description of the primary audience for the book: There is little written in English or Malay on Kedah’s pre twentieth century history. The available sources only look at certain aspects of Kedah’s history, are outdated or are confined to a specific period often outside the scope of the book. It is therefore anticipated that the readership and market for the book includes: • Scholars of Southeast Asian history, Islam, kingship, trade. • Academics & Historians (including: Asian, Thai history, Islamic, Maritime, Persian, South Asian, Southeast Asian and Colonial) • Libraries • Students, particularly those in Malaysia (especially the states of Kedah, Perlis and Penang), Thailand and Singapore. • Universities • Scholars and students in Political Science & International Relations

Making sense of mass education

Making Sense of Mass Education provides a comprehensive analysis of the field of mass education. The book presents new assessment of traditional issues associated with education – class, race, gender, discrimination and equity –to dispel myths and assumptions about the classroom. It examines the complex relationship between the media, popular culture and schooling, and places the expectations surrounding the modern teacher within ethical, legal and historical contexts. The book blurs some of the disciplinary boundaries within the field of education, drawing upon sociology, cultural studies, history, philosophy, ethics and jurisprudence to provide stronger analyses. The book reframes the sociology of education as a complex mosaic of cultural practices, forces and innovations. Engaging and contemporary, it is an invaluable resource for teacher education students, and anyone interested in a better understanding of mass education.

"Are there any right or wrong answers in teaching philosophy": ethics, epistemology, and philosophy in the classroom

This article assesses undergraduate teaching students’ assertion that there are no right and wrong answers in teaching philosophy. When asked questions about their experiences of philosophy in the classroom for primary children, their unanimous declaration that teaching philosophy has ‘no right and wrong answers’ is critically examined across the three sub-disciplinary areas to which they were generally referring, namely, pedagogy, ethics, and epistemology. From a pedagogical point of view, it is argued that some teaching approaches may indeed be more effective than others, and some pupils’ opinions less defensible, but pedagogically, in terms of managing the power relations in the classroom, it is counter-productive to continually insist on notions of truth and falsity at every point. From an ethical point of view, it is contended that anti-realist approaches to meta-ethics may represent a viable intellectual position, but from the point of view of normative ethics, notions of right and wrong still retain significant currency. From an epistemological point of view, it is argued using Karl Poppers’ work that while it may be difficult to determine what constitutes a right answer, determining a wrong one is far more straightforward. In conclusion, it is clear that prospective teachers engaging in philosophy in the classroom, and also future teachers in general, require a far more nuanced philosophical understanding of the notions of right and wrong and truth and falsity. In view of this situation, it we wish to promote the effective teaching of philosophical thinking to children, or produce educators who can understand the conceptual limits of the claims they make and their very real and often serious practical and social consequences, it is recommended that philosophy be reinstated to a fundamental, foundational place within the pre-service teaching curriculum.