36 resultados para Banks, George Washington.

em Queensland University of Technology - ePrints Archive


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Over the past several decades, policy has become increasingly global. In economics, for example, policy has followed the so-called Washington Consensus of privatization, liberalization, and deregulation. In education, global policy has included the proliferation of strategies including standardized testing, paraprofessional teachers, user fees, and privatization. There are many problems with these neoliberal policies. Foremost among them, is the havoc they wreak on the lives of so many children and adults. Poverty, inequality, and myriad associated problems have reached new heights in this neoliberal era. Moreover, these policies have been adopted uncritically and alternative policies have been ignored, which leads to our focus here.

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The International Network of Indigenous Health Knowledge and Development (INIHKD) Conference was held from Monday 24 May to Friday 28 May 2010 at Kiana Lodge, Port Madison Indian Reservation, Suquamish Nation, Washington State, United States of America. The overall theme for the 4th Biennial Conference was ‘Knowing Our Roots: Indigenous Medicines, Health Knowledges and Best Practices’. This article details the experience of participants who were at the INIHKD Conference. It concludes with an encouragement to people to attend the 5th INIHKD Conference in Australia in 2012.

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In this paper we study both the level of Value-at-Risk (VaR) disclosure and the accuracy of the disclosed VaR figures for a sample of US and international commercial banks. To measure the level of VaR disclosures, we develop a VaR Disclosure Index that captures many different facets of market risk disclosure. Using panel data over the period 1996–2005, we find an overall upward trend in the quantity of information released to the public. We also find that Historical Simulation is by far the most popular VaR method. We assess the accuracy of VaR figures by studying the number of VaR exceedances and whether actual daily VaRs contain information about the volatility of subsequent trading revenues. Unlike the level of VaR disclosure, the quality of VaR disclosure shows no sign of improvement over time. We find that VaR computed using Historical Simulation contains very little information about future volatility.

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In the late 1880s a pre-fabricated Japanese house was shipped from Kobe, Japan, to Brisbane, Australia, and erected in the up-market suburb of New Farm by Japanese tradesmen. This paper is developed from a broader project researching the life of G W Paul, the man who had the house built and subsequently lived in it for the remainder of his life. Paul’s motivation in importing the house represented a unique, but unfulfilled effort to develop a future, hybrid culture for Queensland. This effort took the form of a commercial venture to construct Japanese houses as desirable and climatically suitable dwellings. Against the backdrop of this ambition, this paper presents new research to elucidate and extend previous knowledge, assesses the reception of the house by its nineteenth century Brisbane audience, and considers possible reasons for the limited response which signalled the cancellation of the commercial venture.

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On 20 September 2001, the former US President, George W. Bush, declared what is now widely, and arguably infamously, known as a ‘war on terror’. In response to the fatal 9/11 attacks in New York and Washington, DC, President Bush identified the US military response as having far-reaching and long-lasting consequences. It was, he argued, ‘our war on terror’ that began ‘with al Qaeda, but … it will not end until every terrorist group of global reach has been found, stopped and defeated’ (CNN 2001). This was to be a war that would, in the words of former British Prime Minister, Tony Blair, seek to eliminate a threat that was ‘aimed at the whole democratic world’ (Blair 2001). Blair claimed that this threat is of such magnitude that unprecedented measures would need to be taken to uphold freedom and security. Blair would later admit that it was a war that ‘divided the country’ and was based on evidence ‘about Saddam having actual biological and chemical weapons, as opposed to the capability to develop them, has turned out to be wrong’ (Blair 2004). The failures of intelligence ushered in new political rhetoric in the form of ‘trust me’ because ‘instinct is no science’ (Blair 2004). The war on terror has been one of the most significant international events in the past three decades, alongside the collapse of the former Soviet Union, the end of apartheid in South Africa, the unification of Europe and the marketization of the People's Republic of China. Yet, unlike the other events, it will not be remembered for advancing democracy or sovereignty, but for the conviction politics of particular politicians who chose to dispense with international law and custom in pursuit of personal instincts that proved fatal. Since the invasions of Afghanistan in October 2001 and …

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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. 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. The conclusion that the unitary taxation model may be theoretically superior to the current arm's-length model that applies to multinational banks, despite significant implementation, compliance, and enforcement issues, is based on the unitary taxation model providing greater alignment with the unique features of these banks. The formulary apportionment model looks to the economic substance of the multinational entity and, in this sense, adopts a substance-over- form approach. Formulary apportionment further recognizes the impossibility of using arm's-length pricing for economically interdependent multinational entities. A final advantage to formulary apportionment, which is also a consequence of this model achieving greater inter-nation equity, is the elimination of double taxation.

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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.

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As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

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The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as 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.