Taxation determinations as de facto regulation : private equity exits in Australia

The Australian Taxation Office (AT)) attempted to challenge both the private equity fund reliance on double tax agreements and the assertion that profits were capital in nature in its dispute with private equity group TPG. Failure to resolve the dispute resulted in the ATO issuing two taxation determinations: TD 2010/20 which states that the general anti-avoidance provisions can apply to arrangements designed to alter the intended effect of Australia's international tax agreements net; and TD 2010/21 which states that the profits on the sale of shares in a company group acquired in a leveraged buyout is assessable income. The purpose of this article is to determine the effectiveness of the administrative rulings regime as a regulatory strategy. This article, by using the TPG-Myer scenario and subsequent tax determinations as a case study, collects qualitative data which is then analysed (and triangulated) using tonal and thematic analysis. Contemporaneous commentary of private equity stakeholders, tax professionals, and media observations are analysed and evaluated within a framework of responsive regulation and utilising the current ATO compliance model. Contrary to the stated purpose of the ATO rulings regime to alleviate complexities in Australian taxation law and provide certainty to taxpayers, and despite the de facto law status afforded these rulings, this study found that the majority of private equity stakeholders and their advisors perceived that greater uncertainty was created by the two determinations. Thus, this study found that in the context of private equity fund investors, a responsive regulation measure in the form of taxation determinations was not effective.

Disparate companions : tissue engineering meets cancer research

Recreating an environment that supports and promotes fundamental homeostatic mechanisms is a significant challenge in tissue engineering. Optimizing cell survival, proliferation, differentiation, apoptosis and angiogenesis, and providing suitable stromal support and signalling cues are keys to successfully generating clinically useful tissues. Interestingly, those components are often subverted in the cancer setting, where aberrant angiogenesis, cellular proliferation, cell signalling and resistance to apoptosis drive malignant growth. In contrast to tissue engineering, identifying and inhibiting those pathways is a major challenge in cancer research. The recent discovery of adult tissue-specific stem cells has had a major impact on both tissue engineering and cancer research. The unique properties of these cells and their role in tissue and organ repair and regeneration hold great potential for engineering tissue-specific constructs. The emerging body of evidence implicating stem cells and progenitor cells as the source of oncogenic transformation prompts caution when using these cells for tissue-engineering purposes. While tissue engineering and cancer research may be considered as opposed fields of research with regard to their proclaimed goals, the compelling overlap in fundamental pathways underlying these processes suggests that cross-disciplinary research will benefit both fields. In this review article, tissue engineering and cancer research are brought together and explored with regard to discoveries that may be of mutual benefit.

Pressure state response-based method for evaluating social benefits from smart grid development

In this paper, the inherent mechanism of social 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 regarded as pressures. The improvements of the performance and efficiency of power system operation, such as the enhanced capability of accommodating renewable energy generation, are regarded as states. The effects of smart grid development on society are regarded as responses. Then, a novel method for evaluating social benefits from smart grid development is presented. Finally, the social benefits from smart grid development in a province in northwest China are carried out by using the developed evaluation system, and reasonable evaluation results are attained.

University of Glasgow at ImageCLEFPhoto 2009 : optimising similarity and diversity in image retrieval

In this paper we describe the approaches adopted to generate the runs submitted to ImageCLEFPhoto 2009 with an aim to promote document diversity in the rankings. Four of our runs are text based approaches that employ textual statistics extracted from the captions of images, i.e. MMR [1] as a state of the art method for result diversification, two approaches that combine relevance information and clustering techniques, and an instantiation of Quantum Probability Ranking Principle. The fifth run exploits visual features of the provided images to re-rank the initial results by means of Factor Analysis. The results reveal that our methods based on only text captions consistently improve the performance of the respective baselines, while the approach that combines visual features with textual statistics shows lower levels of improvements.

Public transport travel time variability definitions and monitoring

Public Transport Travel Time Variability (PTTV) is essential for understanding the deteriorations in the reliability of travel time, optimizing transit schedules and route choices. This paper establishes the key definitions of PTTV in which firstly include all buses, and secondly include only a single service from a bus route. The paper then analyzes the day-to-day distribution of public transport travel time by using Transit Signal Priority data. A comprehensive approach, using both parametric bootstrapping Kolmogorov-Smirnov test and Bayesian Information Creation technique is developed, recommends Lognormal distribution as the best descriptor of bus travel time on urban corridors. The probability density function of Lognormal distribution is finally used for calculating probability indicators of PTTV. The findings of this study are useful for both traffic managers and statisticians for planning and analyzing the transit systems.

iNOS expression and osteocyte apoptosis in idiopathic, non- traumatic osteonecrosis

Background and purpose Non-traumatic osteonecrosis is a progressive disease with multiple etiologies. It affects younger individuals more and more, often leading to total hip arthroplasty. We investigated whether there is a correlation between inducible nitric oxide synthase (iNOS) expression and osteocyte apoptosis in non-traumatic osteonecrosis. Patients and methods We collected and studied 20 human idiopathic, non-traumatic osteonecrosis femoral heads. Subchondral bone samples in the non-sclerotic region (n = 30), collected from osteoarthritis patients, were used as controls. Spontaneously hypertensive rats were used as a model for osteonecrosis in the study. We used scanning electron microscopy, TUNEL assay, and immunohistochemical staining to study osteocyte changes and apoptosis. Results The morphology of osteocytes in the areas close to the necrotic region changed and the number of apoptotic osteocytes increased in comparison with the same region in control groups. The expression of iNOS and cytochrome C in osteocytes increased while Bax expression was not detectable in osteonecrosis samples. Using spontaneously hypertensive rats, we found a positive correlation between iNOS expression and osteocyte apoptosis in the osteonecrotic region. iNOS inhibitor (aminoguanidine) added to the drinking water for 5 weeks reduced the production of iNOS and osteonecrosis compared to a control group without aminoguanidine. Interpretation Our findings show that increased iNOS expression can lead to osteocyte apopotosis in idiopathic, non-traumatic osteonecrosis and that an iNOS inhibitor may prevent the progression of the disease.

A promise and a possibility : the limitations of the traditional criminal justice system as an explanation for the emergence of restorative justice

The claim that restorative justice emerged in response to the failings of the traditional criminal justice system is frequently made and rarely challenged in the restorative justice literature. It is stated unproblematically, as though it is an unassailable fact rather than a powerful truth claim, thereby positioning restorative justice as a natural, progressive and superior model of justice in comparison with the traditional criminal justice system. This truth claim therefore bestows restorative justice with a legitimacy that is difficult to challenge or refute. Drawing on a Foucaultian genealogy of restorative justice, this article seeks to destabilise the truth claim that restorative justice emerged in response to the failings of the criminal justice system. While the shortcomings of the traditional criminal justice system may provide a backdrop to the emergence of restorative justice, this article argues that such a possibility makes restorative justice a possibility rather than an inevitability.

Robust and reversible numerical set watermarking

Numeric sets can be used to store and distribute important information such as currency exchange rates and stock forecasts. It is useful to watermark such data for proving ownership in case of illegal distribution by someone. This paper analyzes the numerical set watermarking model presented by Sion et. al in “On watermarking numeric sets”, identifies it’s weaknesses, and proposes a novel scheme that overcomes these problems. One of the weaknesses of Sion’s watermarking scheme is the requirement to have a normally-distributed set, which is not true for many numeric sets such as forecast figures. Experiments indicate that the scheme is also susceptible to subset addition and secondary watermarking attacks. The watermarking model we propose can be used for numeric sets with arbitrary distribution. Theoretical analysis and experimental results show that the scheme is strongly resilient against sorting, subset selection, subset addition, distortion, and secondary watermarking attacks.

Pedestrian dynamics in real and simulated world

The paper examines the knowledge of pedestrian movements, both in real scenarios, and from more recent years, in the virtual 4 simulation realm. Aiming to verify whether it is possible to learn from the study of virtual environments how people will behave in real 5 environments, it is vital to understand what is already known about behavior in real environments. Besides the walking interaction among 6 pedestrians, the interaction between pedestrians and the built environment in which they are walking also have greatest relevance. Force-based 7 models were compared with the other three major microscopic models of pedestrian simulation to demonstrate a more realistic and capable 8 heuristic approach is needed for the study of the dynamics of pedestrians.

Single nucleotide polymorphisms and mRNA expression of VEGF-A in papillary thyroid carcinoma: Potential markers for aggressive phenotypes

BACKGROUND AND OBJECTIVES Polymorphisms of the VEGF gene are known to affect the biological behaviour of cancers but have seldom been studied in thyroid cancer. The aim of the current study is to evaluate the prevalence and relevance of VEGF-A polymorphisms and mRNA expression in papillary thyroid carcinoma (PTC). MATERIALS AND METHODS Genomic DNA and total RNA were isolated from paraffin-embedded tissue from 91 PTC (51 conventional PTC and 40 follicular variant) and 78 control thyroid tissues. Three DNA polymorphisms (+936C > T, +405C > G and -141A > C) in the 3' and 5' untranslated region (3'-UTR, 5'-UTR) of VEGF-A were studied using PCR and RFLP. Also, the mRNA expression of VEGF-A in these tissues was studied by real-time PCR. RESULTS Distribution of polymorphisms in the 5'-UTR (VEGF-VEGF -141A > C and +405C > G) and 3'-UTR (VEGF +936C > T) were all significantly different in PTC and benign thyroid tissue (p = 0.0001, 0.001 and 0.028 respectively). The VEGF -141 C allele was more common in PTC with lymph node metastases (p = 0.026). VEGF + 405 Galleles andVEGF +936 CC genotype were more common in PTC of advanced pathological staging (p = 0.018 and 0.017 respectively). Also, increased expression of VEGF-A mRNA was noted in PTC compared to control (p = 0.009). Within the group of patients with conventional PTC, those with lymph nodal metastases had a higher level of VEGF-A mRNA expression than other patients (p = 0.0003). CONCLUSION These findings suggest that VEGF polymorphisms and mRNA expression may predict the aggressiveness behaviour of thyroid cancer.

The role of radiotherapy patients in provision of student interpersonal skills feedback

Background At Queensland University of Technology, student radiation therapists receive regular feedback from clinical staff relating to clinical interpersonal skills. Although this is of great value, there is anecdotal evidence that students communicate differently with patients when under observation. Purpose The aim of this pilot was to counter this perceived observer effect by allowing patients to provide students with additional feedback. Materials and methods Radiotherapy patients from two departments were provided with anonymous feedback forms relating to aspects of student interpersonal skills. Clinical assessors, mentors and students were also provided with feedback forms, including questions about the role of patient feedback. Patient perceptions of student performance were correlated with staff feedback and assessment scores. Results Results indicated that the feedback was valued by both students and patients. Students reported that the additional dimension focused them on communication, set goals for development and increased motivation. These changes derived from both feedback and study participation, suggesting that the questionnaires could be a useful teaching tool. Patients scored more generously than mentors, although there was agreement in relative grading. Conclusions The anonymous questionnaire is a convenient and valuable method of gathering patient feedback on students. Future iterations will determine the optimum timing for this method of feedback.

Charge transport and density of trap states in balanced high mobility ambipolar organic thin-film transistors

We report on charge transport and density of trap states (trap DOS) in ambipolar diketopyrrolopyrrole-benzothiadiazole copolymer thin-film transistors. This semiconductor possesses high electron and hole field-effect mobilities of up to 0.6 cm 2/V-s. Temperature and gate-bias dependent field-effect mobility measurements are employed to extract the activation energies and trap DOS to understand its unique high mobility balanced ambipolar charge transport properties. The symmetry between the electron and hole transport characteristics, parameters and activation energies is remarkable. We believe that our work is the first charge transport study of an ambipolar organic/polymer based field-effect transistor with room temperature mobility higher than 0.1 cm 2/V-s in both electrons and holes.

A Bit-Stream based space vector modulator

Bit-Stream based control, which uses one bit wide signals to control power electronics applications, is a new approach for controller design in power electronic systems. Bit-Stream signals are inherently high frequency in nature, and as such some form of down sampling or modulating is essential to avoid excessive switching losses. This paper presents a novel three-phase space vector modulator, which is based on the Bit-Stream technique and suitable for standard three-phase inverter systems. The proposed modulator simultaneously converts a two phase reference to the three-phase domain and reduces switching frequencies to reasonable levels. The modulator consumes relatively few logic elements and does not require sector detectors, carrier oscillators or trigonometric functions. The performance of the modulator was evaluated using ModelSim. Results indicate that, subject to limits on the modulation index, the proposed modulator delivers a spread-spectrum output with total harmonic distortion comparable to standard space vector pulse width modulation techniques.

Improving the shear capacities of lipped channel beams with web openings using plate stiffeners

Cold-formed steel lipped channel beams (LCB) are used extensively in residential, industrial and commercial buildings as load bearing structural elements. Their shear capacities are considerably reduced when web openings are included for the purpose of locating building services. Past research has shown that the shear capacities of LCBs were reduced by up to 70% due to the inclusion of these web openings. Hence there is a need to improve the shear capacities of LCBs with web openings. A cost effective way of eliminating the detrimental effects of large web openings is to attach suitable stiffeners around the web openings and restore the original shear strength and stiffness of LCBs. Hence detailed experimental studies were undertaken to investigate the behaviour and strength of LCBs with stiffened web openings subject to shear, and combined bending and shear actions. Both plate and stud stiffeners with varying sizes and thicknesses were attached to the web elements of LCBs using different screw-fastening arrangements. Simply supported test specimens of LCBs with aspect ratios of 1.0 and 1.5 were loaded at mid-span until failure. Numerical studies were also undertaken to investigate the strength of LCBs with stiffened web openings. Finite element models of LCBs with stiffened web openings under shear, combined bending and shear actions were developed to simulate the behaviour of tested LCBs. The developed models were then validated by comparing their results with experimental results and used in further studies. Both experimental and finite element analysis results showed that the stiffening arrangements recommended by past research and available design guidelines are not adequate to restore the original shear strengths of LCBs. Therefore new stiffener arrangements were proposed based on screw fastened plate stiffeners. This paper presents the details of this research study and the results.