Global profit split: An evolutionary approach to international income allocation

International taxation is concerned mainly with the equitable allocation of cross-border income between countries in which income-earning activities take place. Such allocation has traditionally been governed by the arm’s-length principle, which has been interpreted as requiring a comparable transactional pricing approach. This approach assumes that each member of a multinational enterprise (MNE) group is a separate entity and that the transactions between related parties can be separated and compared with arm’s-length transactions. It has, however, proved difficult to apply comparable transactional pricing to internationally integrated businesses, especially those involving intangibles and services, and formulary apportionment has been suggested as an alternative. Essentially, formulary apportionment treats the MNE group as a single economic entity. The group’s profit is allocated to members according to a formula that reflects the particular member’s contribution to the production of that profit. A rich academic literature exists which either defends or attacks this alternative approach. The OECD and national governments have rejected formulary apportionment mainly on the ground that it violates the arm’s-length principle. This article proposes a global profit split (GPS) method for allocating international income. The GPS would allocate the global profit of an integrated business to each country in accordance with the economic contributions made by components of the business located in that country. The allocation would be based on a formula that would reflect the economic factors that contribute to profit making. While the GPS draws on elements of the traditional formulary apportionment and profit split methods, it also differs from them. The author discusses in detail the key issues involved in designing the GPS. She also presents and evaluates the main policy and pragmatic justifications for the adoption of this innovative approach. The author argues that the GPS is not only theoretically and practically superior to traditional income allocation methods, but also consistent with the arm’s-length principle. On the basis of historical developments, interpretation of article 9 of the OECD model tax convention, and international tax policy considerations, the author establishes that the GPS is not a radical departure from the arm’s-length principle, but rather a natural development in its evolution. She concludes that the law of evolution ison the side of reform because the GPS would provide for a fair and effective allocation of income derived from globally integrated business activities.

Evolutionary structure learning algorithm for Bayesian network and penalized mutual information metric

This paper formulates the problem of learning Bayesian network structures from data as determining the structure that best approximates the probability distribution indicated by the data. A new metric, Penalized Mutual Information metric, is proposed, and a evolutionary algorithm is designed to search for the best structure among alternatives. The experimental results show that this approach is reliable and promising.

Evolutionary multiobjective optimization in engineering management: an empirical study on bridge deck rehabilitation

There exist multiple objectives in engineering management such as minimum cost and maximum service capacity. Although solution methods of multiobjective optimization problems have undergone continual development over the past several decades, the methods available to date are not particularly robust, and none of them performs well on the broad classes. Because genetic algorithms work with a population of points, they can capture a number of solutions simultaneously, and easily incorporate the concept of Pareto optimal set in their optimization process. In this paper, a genetic algorithm is modified to deal with the rehabilitation planning of bridge decks at a network level by minimizing the rehabilitation cost and deterioration degree simultaneously.

Evolutionary multiobjective optimization in engineering management: an empirical application in infrastructure systems

Generally multiple objectives exist in transportation infrastructure management, such as minimum cost and maximum service capacity. Although solution methoak of multiobjective optimization problems have undergone continual development over the part several decades, the methods available to date are not particularly robust, and none of them perform well on the broad classes. Because genetic algorithms work with apopulation ofpoints, they can capture a number of solutions simultaneously, and easily incorporate the concept of a Pareto optimal set in their optimization process. In this paper, a genetic algorithm is modified to deal with an empirical application for the rehabilitation planning of bridge decks, at a network level, by minimizing the rehabilitation cost and deterioration degree simultaneously.

Isogramma Meek and Worthen, 1870 (Dictyonellida, Brachiopoda) from the upper Palaeozoic of East Asia: implications for biogeography and evolutionary trends

Isogramma manchoukuoensis from the Upper Carboniferous of northeast China is redefined based on re-examination of the type specimens. Isogramma specimens from the Middle Permian of northeastern Japan are reassigned to I. aff. paotechowensis. A new family, Schizopleuroniidae, is proposed to include Schizopleuronia, but excludes Megapleuronia, which belongs to the Megapleuroniidae Liao, 1983. The family Isogrammidae is considered to be a transitional group in the eichwaldid-isogrammid-schizopleuronid evolutionary lineage within the Dictyonellida. A review of the global distribution of Isogramma species reveals that the genus has a total of 56 species ranging from the Mississippian (Early Carboniferous) to the Lopingian (Late Permian). Isogramma diversified rapidly after its origination in the middle Viséan and its species diversity remained high throughout the Mississippian. The genus possibly suffered a severe mid-Carboniferous boundary mass extinction, with no Early Carboniferous species surviving this event. Bashkirian Isogramma species show low diversity, followed by a global recovery in the Moscovian. During the latest Carboniferous Isogramma became highly diversified again. At the Carboniferous–Permian (C/P) transition Isogramma underwent another dramatic diversity drop, followed by several stepwise declines in diversity during the Early–Middle Permian. The Wuchiapingian I. sinosa is the last Isogramma species.

Ukraine was the possible centre of origin for Isogramma. From Ukraine Isogramma spread over the Moscow Basin of Russia, Central Europe (Germany, Austria), South Europe (Spain) and West Europe (England, Ireland and Scotland), and migrated to the North American midcontinent and South China during the late Viséan (Early Carboniferous). In Europe, Isogramma migrated to Spain and eastern Europe (Serbia) in the Moscovian, from there it then dispersed into Central Asia (Uzbekistan and Kazakhstan) in the Kasimovian-Gzhelian. In the Palaeo-Tethys Isogramma migrated from South China to northeast and northwest China in the Moscovian, spread over the North China Block during the C/P transition, moved to Russian Siberia, Japan and the Qiangtang terrane of the Palaeo-Tethys during the Early–Late Permian. In North America Isogramma spread over the midcontinent during the Late Carboniferous and Early–Middle Permian and migrated to South America (Bolivia) in latest Carboniferous. Biogeographically, Isogramma was confined principally to the palaeo-tropical and warm to temperate zones throughout the Late Palaeozoic, with the possible exception of the Artinskian, as a questionable species of the genus also occurs in the Transbaikal region of southeast Russia.

Sexual segregation in western grey kangaroos: testing alternative evolutionary hypotheses

In sexually dimorphic ungulates, sexual segregation is hypothesized to have evolved because of sex-specific differences in body size and/or reproductive strategies. We tested these alternative hypotheses in kangaroos, which are ecological analogues of ungulates. Kangaroos exhibit a wide range of body sizes, particularly among mature males, and so the effects of body size and sex can be distinguished. We tested predictions derived from these hypotheses by comparing the distribution of three sex–sex size classes of western grey kangaroos Macropus fuliginosus, in different habitats, and the composition of groups of kangaroos, across seasons. In accordance with the predation risk-reproductive strategy hypothesis, during the non-breeding season, females, which were more susceptible to predation than larger males, and were accompanied by vulnerable young-at-foot, were over-represented in secure habitats. Large males, which were essentially immune to predation, occurred more often than expected in nutrient-rich habitat, and small males, which faced competing demands of predator avoidance and feeding, were intermediate between females and large males in their distribution across habitats. During the breeding season, females continued to be over-represented in secure habitats when their newly emerged pouch young were most vulnerable to predation. All males occupied these same habitats to maximize their chances of securing mates. Consistent with the social hypotheses, groups composed of individuals of the same sex, irrespective of body size, were over-represented in the population during the non-breeding season, while during the breeding season all males sought females so that mixed-sex groups predominated. These results indicate that body size and reproductive strategies are both important, yet independent, factors influencing segregation in western grey kangaroos.

An evolutionary computing approach to minimize dynamic hedging error

The objective of our present paper is to derive a computationally efficient genetic pattern learning algorithm to evolutionarily derive the optimal rebalancing weights (i.e. dynamic hedge ratios) to engineer a structured financial product out of a multiasset, best-of option. The stochastic target function is formulated as an expected squared cost of hedging (tracking) error which is assumed to be partly dependent on the governing Markovian process underlying the individual asset returns and partly on
randomness i.e. pure white noise. A simple haploid genetic algorithm is advanced as an alternative numerical scheme, which is deemed to be
computationally more efficient than numerically deriving an explicit solution to the formulated optimization model. An extension to our proposed scheme is suggested by means of adapting the Genetic Algorithm parameters based on fuzzy logic controllers.

Evolutionary approach to revising modernization theory : an introduction to the credible polity

The future global distribution of the political regimes of countries, just like that of their economic incomes, displays a surprising tendency for polarization into only two clubs of convergence at the extrema. This, in itself, is a persuasive reason to analyze afresh the logical validity of an endogenous theory for political and economic development inherent in modernization theory. I suggest how adopting a simple evolutionary game theoretic view on the subject allows an explanation for these parallel clubs of convergence in political regimes and economic income within the framework of existing research in democratization theory. I also suggest how instrumental action can be methodically introduced into such a setup using learning strategies adopted by political actors. These strategies, based on the first principles of political competition, are motivated by introducing the theoretical concept of a Credible Polity.

Avian color vision and coloration : multidisciplinary evolutionary biology

A fundamental issue in biology is explaining the diversity of coloration found in nature. Birds provide some of the best-studied examples of the evolution and causes of color variation and some of the most arresting color displays in the natural world. They possess perhaps the most richly endowed visual system of any vertebrate, including UV-A sensitivity and tetrachromatic color vision over the 300-700-nm waveband. Birds provide model systems for the multidisciplinary study of animal coloration and color vision. Recent advances in understanding avian coloration and color vision are due to recognition that birds see colors in a different way than humans do and to the ready availability of small spectrometers. We summarize the state of the current field, recent trends, and likely future directions.

Evolutionary relationships among bluetongue and related orbiviruses

Polymerase chain reaction (PCR) sequencing of specific viral gene segments was used to investigate the phylogenetic relationships among the orbiviruses. Sequence comparisons of the bluetongue virus (BTV) RNA3 from different regions of the world (North America, South Africa, India, Indonesian, Malaysia, Australia and the Caribbean region) showed that geographic separation had resulted in significant divergence, consistent with the evolution of distinct viral populations. There were at least 3 topotypes (Gould, 1987); the Australasian, African - American and another topotype represented by BTV 15 isolated in Australia in 1986. The topotypes of BTV had RNA3 nucleotide sequences that differed by approximately 20 per cent. Analysis of BTV-specific gene segments from animal and insect specimens showed that bluetongue viruses had entered northern Australia from South East Asia, possibly by wind-borne vectors. Nucleotide sequence comparisons were used to show the close genetic relationship between BTV 2 (Ona-A strain) from Florida and BTV 12 from Jamaica, and to investigate the reassortment of BTV genome segments in nature. The mutation rates of the BTV RNA2 and RNA3 segments were estimated to be of the order of 10(-4) nucleotide changes/site/year, similar in magnitude to that reported for other RNA viruses.

Adventures of punctuated equilibria : a struggle for authority in the evolutionary sciences

The theory of ‘punctuated equilibria’ was formulated by two paleontologists, Niles Eldredge and Stephen Gould, in 1972 and has been the focus of considerable controversy within the evolutionary sciences ever since. The primary intentions of this thesis are to relate the history of punctuated equilibria and to examine how it has affected evolutionary science. Several modes of analysis have been used to illuminate the history: The sociological perspectives of Pierre Bourdieu and Bruno Latour (who see scientific debate as a ‘struggle for authority’); Rhetorical analysis of some of the key documents; Communication with practising scientists via questionnaires and correspondence; Citation Analysis. Chapter 1 gives a short summary of the history and introduces the methods and socio-philosophical perspectives used to illuminate the history. Chapters 3 and 4 examine the rhetorical process by which Eldredge and Gould constructed the ‘punctuationist revolution’. Chapters 2, 3, 5 and 6 relate the history of punctuated equilibria.