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.

Information sharing in Onesocialweb using a multiple profile manager to better informed medical decision making processes

The study shows an alternative solution to existing efforts at solving the problem of how to centrally manage and synchronise users’ Multiple Profiles (MP) across multiple discrete social networks. Most social network users hold more than one social network account and utilise them in different ways depending on the digital context (Iannella, 2009a). They may, for example, enjoy friendly chat on Facebook1, professional discussion on LinkedIn2, and health information exchange on PatientsLikeMe3 In this thesis the researcher proposes a framework for the management of a user’s multiple online social network profiles. A demonstrator, called Multiple Profile Manager (MPM), will be showcased to illustrate how effective the framework will be. The MPM will achieve the required profile management and synchronisation using a free, open, decentralized social networking platform (OSW) that was proposed by the Vodafone Group in 2010. The proposed MPM will enable a user to create and manage an integrated profile (IP) and share/synchronise this profile with all their social networks. The necessary protocols to support the prototype are also proposed by the researcher. The MPM protocol specification defines an Extensible Messaging and Presence Protocol (XMPP) extension for sharing vCard and social network accounts information between the MPM Server, MPM Client, and social network sites (SNSs). . Therefore many web users need to manage disparate profiles across many distributed online sources. Maintaining these profiles is cumbersome, time-consuming, inefficient, and may lead to lost opportunity. The writer of this thesis adopted a research approach and a number of use cases for the implementation of the project. The use cases were created to capture the functional requirements of the MPM and to describe the interactions between users and the MPM. In the research a development process was followed in establishing the prototype and related protocols. The use cases were subsequently used to illustrate the prototype via the screenshots taken of the MPM client interfaces. The use cases also played a role in evaluating the outcomes of the research such as the framework, prototype, and the related protocols. An innovative application of this project is in the area of public health informatics. The researcher utilised the prototype to examine how the framework might benefit patients and physicians. The framework can greatly enhance health information management for patients and more importantly offer a more comprehensive personal health overview of patients to physicians. This will give a more complete picture of the patient’s background than is currently available and will prove helpful in providing the right treatment. The MPM prototype and related protocols have a high application value as they can be integrated into the real OSW platform and so serve users in the modern digital world. They also provide online users with a real platform for centrally storing their complete profile data, efficiently managing their personal information, and moreover, synchronising the overall complete profile with each of their discrete profiles stored in their different social network sites.

Social Media and Tacit Knowledge Sharing: Developing a Conceptual Model

With the advent of social web initiatives, some argued that these new emerging tools might be useful in tacit knowledge sharing through providing interactive and collaborative technologies. However, there is still a poverty of literature to understand how and what might be the contributions of social media in facilitating tacit knowledge sharing. Therefore, this paper is intended to theoretically investigate and map social media concepts and characteristics with tacit knowledge creation and sharing requirements. By conducting a systematic literature review, five major requirements found that need to be present in an environment that involves tacit knowledge sharing. These requirements have been analyzed against social media concepts and characteristics to see how they map together. The results showed that social media have abilities to comply some of the main requirements of tacit knowledge sharing. The relationships have been illustrated in a conceptual framework, suggesting further empirical studies to acknowledge findings of this study.

The role of organisational culture, trust and mechanisms in inter-project knowledge sharing

Knowledge has been recognised as a powerful yet intangible asset, which is difficult to manage. This is especially true in a project environment where there is the potential to repeat mistakes, rather than learn from previous experiences. The literature in the project management field has recognised the importance of knowledge sharing (KS) within and between projects. However, studies in that field focus primarily on KS mechanisms including lessons learned (LL) and post project reviews as the source of knowledge for future projects, and only some preliminary research has been carried out on the aspects of project management offices (PMOs) and organisational culture (OC) in KS. This study undertook to investigate KS behaviours in an inter-project context, with a particular emphasis on the role of trust, OC and a range of knowledge sharing mechanisms (KSM) in achieving successful inter-project knowledge sharing (I-PKS). An extensive literature search resulted in the development of an I-PKS Framework, which defined the scope of the research and shaped its initial design. The literature review indicated that existing research relating to the three factors of OC, trust and KSM remains inadequate in its ability to fully explain the role of these contextual factors. In particular, the literature review identified these areas of interest: (1) the conflicting answers to some of the major questions related to KSM, (2) the limited empirical research on the role of different trust dimensions, (3) limited empirical evidence of the role of OC in KS, and (4) the insufficient research on KS in an inter-project context. The resulting Framework comprised the three main factors including: OC, trust and KSM, demonstrating a more integrated view of KS in the inter-project context. Accordingly, the aim of this research was to examine the relationships between these three factors and KS by investigating behaviours related to KS from the project managers‘ (PMs‘) perspective. In order to achieve the aim, this research sought to answer the following research questions: 1. How does organisational culture influence inter-project knowledge sharing? 2. How does the existence of three forms of trust — (i) ability, (ii) benevolence and (iii) integrity — influence inter-project knowledge sharing? 3. How can different knowledge sharing mechanisms (relational, project management tools and process, and technology) improve inter-project knowledge sharing behaviours? 4. How do the relationships between these three factors of organisational culture, trust and knowledge sharing mechanisms improve inter-project knowledge sharing? a. What are the relationships between the factors? b. What is the best fit for given cases to ensure more effective inter-project knowledge sharing? Using multiple case studies, this research was designed to build propositions emerging from cross-case data analysis. The four cases were chosen on the basis of theoretical sampling. All cases were large project-based organisations (PBOs), with a strong matrix-type structure, as per the typology proposed by the Project Management Body of Knowledge (PMBoK) (2008). Data were collected from project management departments of the respective organisations. A range of analytical techniques were used to deal with the data including pattern matching logic and explanation building analysis, complemented by the use of NVivo for data coding and management. Propositions generated at the end of the analyses were further compared with the extant literature, and practical implications based on the data and literature were suggested in order to improve I-PKS. Findings from this research conclude that OC, trust, and KSM contribute to inter-project knowledge sharing, and suggest the existence of relationships between these factors. In view of that, this research identified the relationships between different trust dimensions, suggesting that integrity trust reinforces the relationship between ability trust and knowledge sharing. Furthermore, this research demonstrated that characteristics of culture and trust interact to reinforce preferences for mechanisms of knowledge sharing. This means that cultures that facilitate characteristics of Clan type are more likely to result in trusting relationships, hence are more likely to use organic sources of knowledge for both tacit and explicit knowledge exchange. In contrast, cultures that are empirically driven, based on control, efficiency, and measures (characteristics of Hierarchy and Market types) display tendency to develop trust primarily in ability of non-organic sources, and therefore use these sources to share mainly explicit knowledge. This thesis contributes to the project management literature by providing a more integrative view of I-PKS, bringing the factors of OC, trust and KSM into the picture. A further contribution is related to the use of collaborative tools as a substitute for static LL databases and as a facilitator for tacit KS between geographically dispersed projects. This research adds to the literature on OC by providing rich empirical evidence of the relationships between OC and the willingness to share knowledge, and by providing empirical evidence that OC has an effect on trust; in doing so this research extends the theoretical propositions outlined by previous research. This study also extends the research on trust by identifying the relationships between different trust dimensions, suggesting that integrity trust reinforces the relationship between ability trust and KS. Finally, this research provides some directions for future studies.

Communications materials on methods of development of revenue and cost estimates to non-technical audiences

This CDROM includes PDFs of presentations on the following topics: "TXDOT Revenue and Expenditure Trends;" "Examine Highway Fund Diversions, & Benchmark Texas Vehicle Registration Fees;" "Evaluation of the JACK Model;" "Future highway construction cost trends;" "Fuel Efficiency Trends and Revenue Impact"

Sharing environmental data : the role of an information policy framework and copyright licensing

Advances in information and communication technologies have brought about an information revolution, leading to fundamental changes in the way that information is collected or generated, shared and distributed. The importance of establishing systems in which research findings can be readily made available to and used by other researchers has long been recognized in international scientific collaborations. If the data access principles adopted by international scientific collaborations are to be effectively implemented they must be supported by the national policies and laws in place in the countries in which participating researchers are operating.

Content sharing on public screens: experiences through iterating social and spatial contexts

This paper describes the design and study of public urban screen applications aiming to facilitate urban dwellers to control content shown on public urban screens. Two types of content sharing are presented: aggregating existing social media content about particular locations for sharing, and sharing online videos with collocated people at a public urban screen. The paper describes an exploratory study, an observational study, as well as an interpretational study in regards to application usage and user experience. Sharing content on public urban screens can pique the curiosity of users towards collocated people and the application itself resulting in raised awareness of collocated people.

Researcher attitudes to data sharing : cultural change requires better motivations

While undertaking the ANDS RDA Gold Standard Record Exemplars project, research data sharing was discussed with many QUT researchers. Our experiences provided rich insight into researcher attitudes towards their data and the sharing of such data. Generally, we found traditional altruistic motivations for research data sharing did not inspire researchers, but an explanation of the more achievement-oriented benefits were more compelling.

Beyond demand management : the value of sharing electricity information

Technologies such as smart meters and electricity feedback are becoming an increasingly compelling focus for HCI researchers in light of rising power prices and peak demand. We argue, however, that a pre-occupation with the goal of demand management has limited the scope of design for these technologies. In this paper we present our work-in-progress investigating the potential value of socially sharing electricity information as a means of broadening the scope of design for these devices. This paper outlines some preliminary findings gathered from a design workshop and a series of qualitative interviews with householders in Brisbane, Australia, regarding their attitudes towards electricity feedback and sharing consumption information. Preliminary findings suggest that; (1) the social sharing of electricity feedback information has the potential to be of value in better informing consumption decisions, however; (2) the potential for sharing may be constrained by attitudes towards privacy, trust and the possibility of misinformation being shared. We conclude by outlining ideas for our future research on this topic and invite comments on these ideas.

The sound of music : sharing song selections between collocated strangers in public urban places

This paper presents Capital Music, a mobile application enabling real-time sharing of song choices with collocated urban dwellers. Due to the real-time, location-based peer-to-peer approach of the application, a user experience study was performed utilising the Wizard of Oz method. The study provides insight into how sharing non-privacy sensitive but personal data in an anonymous way can influence the user experience of people in public urban places. We discuss the findings in relation to how Capital Music influences the process of “cocooning” in public urban places, the practice of designing anonymous interactions between collocated strangers, and how the sharing of song choices can create a sense of commonality between anonymous users in the urban space. The outcomes of this study are relevant for future location-based social networking applications that aim to create interactions between collocated strangers.

Online multiple profile manager for eHealth information sharing

Online social networks connect millions of people around the globe. These electronic bonds make individuals comfortable with their behaviours. Such positive signs of sharing information is useful phenomena requires consideration to establish a socio-scientific effect. Recently, many web users have more than one social networking account. This means a user may hold multiple profiles which are stored in different Social Network Sites (SNNs). Maintaining these multiple online social network profiles is cumbersome and time-consuming [1]. In this paper we will propose a framework for the management of a user's multiple profiles. A demonstrator, called Multiple Profile Manager (MPM), will be showcased to illustrate how effective the framework will be.

Potentials of social media for tacit knowledge sharing amongst physicians : preliminary findings

Tacit knowledge sharing amongst physicians, such as the sharing of clinical experiences, skills, or know-how, or know-whom, is known to have a significant impact on the quality of medical diagnosis and decisions. This paper posits that social media can provide new opportunities for tacit knowledge sharing amongst physicians, and demonstrates this by presenting findings from a review of relevant literature and a survey conducted with physicians. Semi-structured interviews were conducted with ten physicians from around the world who were active users of social media. Initial thematic analysis revealed eight themes as potential contributions of social web tools to facilitate tacit knowledge flow amongst physicians. The emergent themes are defined, linked to the literature, and supported by instances of interview transcripts. Findings presented here are preliminary, and final results will be reported after accomplishing all phases of data collection and analysis.

Model development and dynamic load-sharing analysis of longitudinal-connected air suspensions

The objective of this research was to investigate the effect of suspension parameters on dynamic load-sharing of longitudinal-connected air suspensions of a tri-axle semi-trailer. A novel nonlinear model of a multi-axle semi-trailer with longitudinal-connected air suspension was formulated based on fluid mechanics and thermodynamics and was validated through test results. The effects of suspension parameters on dynamic load-sharing and road-friendliness of the semi-trailer were analyzed. Simulation results indicate that the road-friendliness metric DLC (Dynamic Load Coefficient), is generally in accordance with the load-sharing metric - DLSC (Dynamic Load Sharing Coefficient). When the static height or static pressure increases, the DLSC optimization ratio declines monotonically. The effect of employing larger air lines and connectors on the DLSC optimization ratio gives varying results as road roughness increases and as driving speed increases. The results also indicate that if the air line diameter is always assumed to be larger than the connector diameter, the influence of air line diameter on load-sharing is more significant than that of the connector.