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.

Dien Bien Phu: development and conservation in a Vietnamese cultural landscape

It has been possible to nominate places for their cultural landscape values to the World Heritage List since December 1992. The Operational Guidelines (2005) define cultural landscapes as cultural properties that ‘represent the “combined works of nature and man” designated in Article 1 of the Convention’. They are illustrative of the evolution of human society and settlement over time, under the influence of the physical constraints and/or opportunities presented by their natural environment and of successive social, economic and cultural forces, both internal and external’ (Para 47). Refining this further, the World Heritage system recognises three categories of cultural landscapes:

1. Clearly defined landscapes designed and intentionally created by man;

2. Organically evolved landscapes of two subtypes:
·  Relict or fossil landscapes in which an evolutionary process has come to an end but where its distinguishing features are still visible;
·  Continuing landscapes which retain an active social role in contemporary society associated with a traditional way of life and in which the evolutionary process is still in progress and where it exhibits significant material evidence of its evolution over time;

3. Associative cultural landscapes where the outstanding universal value relates to the powerful religious, artistic, or cultural associations of the natural elements rather than the evidence of material culture.

Simulation of dynamic recrystallization using random grid cellular automata

Computer simulation is a powerful tool to predict microstructure and its evolution in dynamic and post-dynamic recrystallization. CAFE proposed as an appropriate approach by combining finite element (FE) method and cellular automata (CA) for recrystallization simulation. In the current study, a random grid cellular automaton (CA), as micro-scale model, based on finite element (FE), as macro-scale method, has been used to study initial and evolving microstructural features; including nuclei densities, dislocation densities, grain size and grain boundary movement during dynamic recrystallization in a C-Mn steel. An optimized relation has been established between mechanical variables and evolving microstructure features during recrystallization and grain growth. In this model, the microstructure is defined as cells located within grains and grain boundaries while dislocations are randomly dispersed throughout microstructure. Changes of dislocation density during deformation are described considering hardening, recovery and recrystallization. Recrystallization is assumed to initiate near grain boundaries and nucleation rate was considered constant (site-saturated condition). The model produced a mathematical formulation which captured the initial and evolving microstructural entities and linked their effects to measurable macroscopic variables (e.g. stress).

Towering over all : the Italianate villa in the colonial landscape

The Picturesque aesthetic emerged in the later 18th century, uniting the Sublime and the Beautiful and had its roots in the paintings of Claude Lorrain. In Britain, and in Australia, it came to link art, literature and landscape with architecture. The Picturesque aesthetic informed much of colonial culture which was achieved, in part, through the production and dissemination of architectural pattern books catering for the aspirations of the rising middle classes. This was against a background of political change including democratic reform. The Italianate villa, codified and promoted in such pattern books, was a particularly successful synthesis of style, form and function. The first Italianate villa in England, Cronkhill (1803) by John Nash contains all the ingredients which were essential to the model and had a deeper meaning. Deepdene (from 1807) by Thomas Hope gave the model further impetus. The works of Charles Barry and others in a second generation confirmed the model's acceptability. In Britain, its public status peaked with Osborne House (from 1845), Queen Victoria's Italianate villa on the Isle of Wight, Robert Kerr used a vignette of Osborne House on the title page of his sophisticated and influential pattern book, The Gentleman's House (1864,1871). It was one of many books, including those of J.C, Loudon and AJ. Downing, current in colonial Victoria. The latter authors and horticulturists were themselves villa dwellers with libraries and orchards, two criteria for the true villa lifestyle. Situation and a sense of retreat were the two further criteria for the villa lifestyle. As the new colony of Victoria blossomed between 1851 and 1891, the Italianate villa, its garden setting and its landscape siting captured the tenor of the times. Melbourne, the capital was a rich manufacturing metropolis with a productive hinterland and international markets. The people enjoyed a prosperity and lifestyle which they wished to display. Those who had a position in society were keen to demonstrate and protect it. Those with aspirations attempted to provide the evidence necessary for such acceptance, The model matured and became ubiquitous. Its evolution can be traced through a series of increasingly complicated rural and suburban examples, a process which modernist historians have dismissed as a decadent decline. These villas, in fact, demonstrate an increasingly sophisticated retreat by merchants from ‘the Town’ and by graziers from ‘the Country’. In both town and country, the towers of villas mark territory newly acquired. The same claim was often made in humbler situations. Government House, Melbourne (from 1871), a splendid Italianate villa and arguably finer than Osborne House, was set in a cultivated landscape and towered above all It incorporated the four criteria and, in addition, claimed its domain, focused authority and established the colony's social status. It symbolised ancient notions of democracy and idealism but with a modem appreciation for the informal and domestic. Government House in Melbourne is the epitome of the Italianate villa in the colonial landscape and is the climax of the Picturesque aesthetic in Victoria.

澳大利亚的民主和公民权

With the granting of the franchise to white men and women in 1902, Australia became one of the first mass electoral democracies. When the early federal governments passed innovative social and economic legislation, Australia also laid claim to being, or at least becoming, a social democracy. Nonetheless, these achievements built upon an earlier record of political, social, and economic reform in the Australian colonies. This paper offers a brief history of the evolution of Australian democracy that takes account of the interactions between institutional change and political struggles for citizenship rights. The process of democratisation has not been uniform, either in its evolution or scope, and the outcomes for citizens have been uneven. Where liberal and social democratic principles generally predominate, these remain in constant tension with more authoritarian tendencies, which then become a focus for resistance from individual citizens, organised labour, and social movements. Democratisation in Australia, as in many countries, is a process that inevitably involves conflict, not only over the character of its political and legal institutions, but also over who is to be included or excluded as citizens, and the rights and responsibilities of citizenship.

Finite element simulations of the cyclic elastoplastic behaviour of copper thin films

A large-scale computational and statistical strategy is presented to investigate the development of plastic strain heterogeneities and plasticity induced roughness at the free surface in multicrystalline films subjected to cyclic loading conditions, based on continuum crystal plasticity theory. The distribution of plastic strain in the grains and its evolution during cyclic straining are computed using the finite element method in films with different ratios of in-plane grain size and thickness, and as a function of grain orientation (grains with a {1 1 1} or a {0 0 1} plane parallel to the free surface and random orientations). Computations are made for 10 different realizations of aggregates containing 50 grains and one large aggregate with 225 grains. It is shown that overall cyclic hardening is accompanied by a significant increase in strain dispersion. The case of free-standing films is also addressed for comparison. The overall surface roughness is shown to saturate within 10 to 15 cycles. Plasticity induced roughness is due to the higher deformation of {0 0 1} and random grains and due to the sinking or rising at some grain boundaries.

Book review: Studying mobile media: cultural technologies, mobile communication, and the iPhone, by Hjorth, Larissa, Burgess, Jean and Richardson, Ingrid (eds), Routledge, New York, 2012

A review of a series of articles exploring the role of online networked mobile devices, such as the iPhone, in changing communication, with multidisciplinary relevance. The articles examine the smartphone as a cultural object, a platform for specific uses as a multi-purpose input device and its evolution from a personal communication device to a multimedia tool with implications for politics and social change.

Sexual size dimorphism and body condition in the Australasian Gannet

Sexual size dimorphism is widespread throughout seabird taxa and several drivers leading to its evolution have been hypothesised. While the Australasian Gannet (Morus serrator) has previously been considered nominally monomorphic, recent studies have documented sexual segregation in diet and foraging areas, traits often associated with size dimorphism. The present study investigated the sex differences in body mass and structural size of this species at two colonies (Pope's Eye, PE; Point Danger, PD) in northern Bass Strait, south-eastern Australia. Females were found to be 3.1% and 7.3% heavier (2.74 ± 0.03, n = 92; 2.67 ± 0.03 kg, n = 43) than males (2.66 ± 0.03, n = 92; 2.48 ± 0.03 kg, n = 43) at PE and PD, respectively. Females were also larger in wing ulna length (0.8% both colonies) but smaller in bill depth (PE: 2.2%; PD: 1.7%) than males. Despite this dimorphism, a discriminant function provided only mild accuracy in determining sex. A similar degree of dimorphism was also found within breeding pairs, however assortative mating was not apparent at either colony (R2 < 0.04). Using hydrogen isotope dilution, a body condition index was developed from morphometrics to estimate total body fat (TBF) stores, where TBF(%) = 24.43+1.94*(body mass/wing ulna length) - 0.58*tarsus length (r2 = 0.84, n = 15). This index was used to estimate body composition in all sampled individuals. There was no significant difference in TBF(%) between the sexes for any stage of breeding or in any year of the study at either colony suggesting that, despite a greater body mass, females were not in a better condition than males. While the driving mechanism for sexual dimorphism in this species is currently unknown, studies of other Sulids indicate segregation in foraging behaviour, habitat and diet may be a contributing factor.

Constitutive modelling of high strength titanium alloy Ti-6Al-4 V for sheet forming applications at room temperature

To enable the design and optimisation of forming processes at room temperature the material behaviour of Ti-6Al-4 V needs to be accurately represented in numerical analysis and this requires an advanced material model. In particular, an accurate representation of the shape and size of the yield locus as well as its evolution during forming is important. In this study a rigorous set of experiments on the quasi-static deformation behaviour of a Ti-6Al-4 V alloy sheet sample at room temperature was conducted for various loading conditions and a constitutive material model developed. To quantify the anisotropy and asymmetry properties, tensile and compression tests were carried out for different specimen orientations. To examine the Bauschinger effect and the transient hardening behaviour in - plane tensile - compression and compression - tensile tests were performed. Balanced biaxial and plane strain tension tests were conducted to construct and validate the yield surface of the Ti-6Al-4 V alloy sheet sample at room temperature. A recently proposed anisotropic elastic-plastic constitutive material model, so-called HAH, was employed to describe the behaviour, in particular for load reversals. The HAH yield surface is composed of a stable component, which includes plastic anisotropy and is distorted by a fluctuating component. The key of the formulation is the use of a suitable yield function that reproduces the experimental observations well for the stable component. Meanwhile, the rapid evolution of the material structure must be captured at the macro - scale level by the fluctuating component embedded in the HAH model. Compared to conventional hardening equations, the proposed model leads to higher accuracy in predicting the Bauschinger effect and the transient hardening behaviour for the Ti-6Al-4 V sheet sample tested at room temperature.

Contact pressure evolution and its relation to wear in sheet metal forming

For a given sheet metal forming process, an accurate determination of the contact pressure distribution is an essential step towards the estimation of tool life. This investigation utilizes finite element (FE) analysis to model and explain the evolution and distribution of contact pressure over the die radius, throughout the duration of a channel forming process. It was found that a typical two-peak steady-state contact pressure response exists for the majority of the process. However, this was preceded by an initial transient response, characterized by extremely large and localized contact pressures, which were more than double the magnitude of the steady-state peak pressure. The validity of the predicted contact pressure behavior was assessed via detailed numerical analysis and by examining the wear response of an experimental stamping operation. The experimental results revealed that the high contact pressure zones of the transient response corresponded to a severe galling wear mechanism. Therefore, the transient response may be of primary significance to the tool wear response; thus questioning the applicability of traditional bending-under-tension wear tests for sheet metal stamping processes. Finally, a parametric study was conducted, examining the influence of the major process parameters on the steady-state and peak transient contact pressures, using the developed FE model. It was found that the bend ratio and the blank material ultimate tensile strength had the most influence on the peak contact pressures. The main process-related parameters, friction coefficient and blank holder force, were found to have only a minor influence.

Hierarchical dirichlet process for tracking complex topical structure evolution and its application to autism research literature

In this paper we describe a novel framework for the discovery of the topical content of a data corpus, and the tracking of its complex structural changes across the temporal dimension. In contrast to previous work our model does not impose a prior on the rate at which documents are added to the corpus nor does it adopt the Markovian assumption which overly restricts the type of changes that the model can capture. Our key technical contribution is a framework based on (i) discretization of time into epochs, (ii) epoch-wise topic discovery using a hierarchical Dirichlet process-based model, and (iii) a temporal similarity graph which allows for the modelling of complex topic changes: emergence and disappearance, evolution, splitting and merging. The power of the proposed framework is demonstrated on the medical literature corpus concerned with the autism spectrum disorder (ASD) - an increasingly important research subject of significant social and healthcare importance. In addition to the collected ASD literature corpus which we made freely available, our contributions also include two free online tools we built as aids to ASD researchers. These can be used for semantically meaningful navigation and searching, as well as knowledge discovery from this large and rapidly growing corpus of literature.

The Sustainability and Evolution of Quality Improvement Programmes-an Australian Case Study

This paper presents a case study on the implementation of quality management programmes and initiatives in one manufacturing company in Australia, which has lasted for more than two decades. Using data collected through in-depth interviews, the case study describes how the company progressed from an earlier initiative based on quality control to the present initiatives that emphasize customer focus, product development, and innovation. Several important insights are drawn from the case study, including the importance of aligning the quality programmes or initiatives with a clear strategic focus. In addition, the commitment and leadership of senior management of the company has been demonstrated, particularly in the provision of resources and facilities to support the TQM programme, and also shown is how the company has been successful in maintaining its long-term commitment to quality management, which has led to an accumulation of various knowledge and competencies, which function as a valuable resource to sustain its business performance.

Program management: the next step in the evolution of project management?

The term ‘program management’, while referred to occasionally in journals, organisation publications and by training consultants, is not a widely acknowledged notion. While literature on project management is plentiful and the concept is well entrenched in both a practical and academic
sense, program management is a term that is used differently by various sectors. Its meaning is less defined and more broadly applied than that of project management. For example, although Program Managers are sometimes recruited under that title, the definition still remains somewhat
obscure. Seen mostly in the health and education public sectors, program management is commonly thought of as separate to project management but, as this paper will suggest, program management is more likely an extension of project management and a complementary tool to achieving
organisational outcomes. This paper attempts to clarify the distinctions between the management approaches by looking at existing literature and comparing it to common practice in a government instrumentality. It will become apparent that further research is needed regarding this significant
step in the evolution of management practices.

Phylogenetic relationships of the globally distributed freshwater prawn genus Macrobrachium (Crustacea: Decapoda: Palaemonidae): biogeography, taxonomy, and the convergent evolution of abbreviated larval development

There has hitherto been little research into evolutionary and taxonomic relationships amongst species of the freshwater prawn genus Macrobrachium Bate across its global distribution. Previous work by the authors demonstrated that the endemic Australian species did not evolve from a single ancestral lineage. To examine whether other regional Macrobrachium faunas also reflect this pattern of multiple origins, the phylogeny of 30 Macrobrachium species from Asia, Central/South America and Australia was inferred from mitochondrial 16S rRNA sequences. Phylogenetic relationships demonstrate that, despite some evidence for regional diversification, Australia, Asia and South America clearly contain Macrobrachium species that do not share a common ancestry, suggesting that large-scale dispersal has been a major feature of the evolutionary history of the genus. The evolution of abbreviated larval development (ALD), associated with the transition from an estuarine into a purely freshwater lifecycle, was also mapped onto the phylogeny and was shown to be a relatively homoplasious trait and not taxonomically informative. Other taxonomic issues, as well as the evolutionary origins of Macrobrachium, are also discussed.