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.

Four by two theory of non-profit museum governance

As plainly illustrated by the collapse of Enron in the US and HIH in Australia, the world of organisational governance is complicated. In response to ongoing trustee tensions, legislative reforms have been adapted to encourage organisational performance. However, limited theoretical foundation exists regarding how trustee dynamics are forced to adjust within non-profit museums. The trustee’s world requires insights from different mindsets to be synthesised into a whole. The purpose of this article is to examine the research conducted on governance and apply it to the non-profit museum. The article contends that most research on governance has been conducted in the for-profit arena, with little robust empirical research having been conducted on non-profit governance. It identifies concerns with the thrust of articles published as they restrict new theory development. The article provides a four by two theory of non-profit museum governance, that is characterised by close interaction with the research published and application to the non-profit museum. It concludes by demonstrating the increased performance opportunity of a model to the non-profit museum seeking to be accountable in an increasingly complex and demanding environment.

Entrepreneurship, marketing and leadership in non-profit performing arts organisations

This paper argues that the entrepreneurial leader in non-profit PAOs has received too little attention in literature pertaining to these organisations. This criticism also applies to museums. The paper explores how leaders in non-profit performing arts organisations balance the interests of the various funding sources and market opportunities to service their revenue requirements. It reviews a tension in non-profit performing arts organisations: the relationship between limited funding and the subsequent need to act entrepreneurially and innovatively among the various funding sources. Using longitudinal analysis of annual reports, the paper uncovers interplay essential to entrepreneurship. Hence, strategies and tensions are highlighted that non-profit leaders have used. Comparisons are made with non-profit art museums which previous research has shown have the same funding tensions.

The profit-driven action sport industry working within the not-for-profit Australian sport system : the case of freestyle BMX Australia and the Australian sports commission

When not-for-profit organisations and for-profit organisations are forced to work together, conflict can arise. This paper explores the tensions that have resulted in the Australian sport setting when the Australian Sport Commission (ASC), with its emphasis predominantly directed at not for profit sport, sought to embrace the traditionally for profit sport of Freestyle BMX into the mainstream sport system. This case study traces the development and implementation of the ASC's Street Active program through Freestyle BMX. It was found that Freestyle BMX experienced mission drift and did not provide a product or service relevant to its consumers by adhering to the guidelines required by the ASC. Further, in the development of the program, the ASC did not expect the rivalry between suppliers in the free market action sport industry when it engaged three management groups to deliver the Street Active program. As a result the action sport industry is further fragmented into for-profit agencies, and farther removed from the Australia's federal governing agency, the ASC.

The application of non-profit marketing in the international higher education sector

This study considers the impact of the university service and learning environments (which we define as non educational factors) on student satisfaction among international postgraduate students from Asia studying in Australian universities. It is based on the expectations/perceptions paradigm and analyses the relationship between key variables and overall satisfaction of student groups in respect of their service and learning environments. The aim of this paper is to consider the importance of non-educational factors in international postgraduate university students, in particular, with regard to information and communication, infrastructure, and university recognition. The data used in this study is derived from a mail survey conducted among international postgraduate students from China, India, Indonesia and Thailand studying in five universities in Victoria. Structural Equation Modelling was used to understand the relationship between the constructs in this study. The results indicate that noneducation related factors are very important to international postgraduate students and they are predictors of overall satisfaction.

Virtual non-profit organisations : literary virtual communities in Russia

This paper is a study of one of the "unknown" segments of the Internet - non-profit ventures in the Russian language. Based on the understanding of the concept of virtual community we consider the family of free publishing literary websites. We discuss their experience to demonstrate their contribution not only to the national culture, but also to the creation of open and democratic society in the former communist world, and to new forms of literary life. Some of the innovative concepts, principles and practices, adopted on those sites may be of interest to the Internet developers and communities worldwide.

Fun or profit : primary students' perceptions of mathematics and science

As the number of students pursuing mathematics and science in higher education decline, it becomes imperative· that we look for the causes of the decline. As part of the Australian Improving Middle Years Mathematics and Science (IMYMS) project, students were asked to rate their perceptions of classroom practice in mathematics and science and their attitudes to these subjects. Results of this survey reveal little difference in perceptions of classroom practice, but significant differences in students' attitudes between mathematics and science. Differences were particularly evident for items relating to the usefulness of mathematics and science (mathematics was more useful) and enjoyment of the subjects (science is more fun). If teachers are aware of such perspectives, it may be possible to change students' attitudes.

Effective student engagement depends on students enjoying their studies in mathematics and science, being confident in their ability and recognising the relevance of these subjects to everyday life, now and in the future.
(Education Training Committee, 2006, p. xvii)

Science and technology are the widely acknowledged foundation of Australia's future development. Underpinning these are the key learning areas of mathematics and science. However, Australia is experiencing a decline in numbers of mathematics and science students in higher education. Moreover, studies over the last two decades have shown a general decline in Australian students' interest and enjoyment of science across the compulsory secondary school years, with a particularly sharp decline across the primary to secondary school transition (e.g. Adams, Doig, & Rosier 1991; Goodrum, Hackling, & Rennie, 200 I) and a decline in the numbers of students studying' advanced mathematical courses in upper secondary school (Thomas, 2000).

Improving teaching and learning in the middle years of schooling (Years 5 to 9) is receiving particular attention because of the coincidence of the disengagement of students with the significance of these years for the preparation of students for their future role in society. Thus the Improving Middle Years Mathematics and Science: The role of subject cultures in school and teacher change (IMYMS) project, which is the source of data for this paper, is investigating the role of mathematics and science' knowledge and subject cultures in mediating change processes in the middle years of schooling.

Mathematics and science are sometimes seen as "love-hate" subjects, rating highest for subjects disliked, but also rating relatively highly among preferred subjects (Hendley & Stables, 1996). Students, even primary aged students, can often shed light on what constitutes good practice (see, for example, 'van den Heuvel-Panhuizen, 2005). Students' attitudes towards mathematics and science and their perceptions of what they regard as positive aspects of classroom practice have been shown to decline from the primary years to junior secondary (Race, 2000). The decline in interest in science in the early years of secondary school is of particular concern, since it is in these years that attitudes to the pursuit of science subjects and careers are formed (Speering & Rennie, 1996). Students' negative attitude towards the relevance of science ,content for their lives was a strong theme in the report by Goodrum, Hackling, & Rennie (2001) on the status and quality of teaching and learning of science.

As part of the IMYMS project, the IMYMS Student Survey was administered to all students in 2004 and 2005. The survey included a 36 item section on students' perceptions of classroom practice and attitudes towards mathematics and science, and a 24 item section on students' learning preferences. Students completed separate, parallel surveys for mathematics and science.

This paper focuses on students' perceptions and attitudes. It explores the differences in 700 Year 5 and 6 students' perceptions of their learning environment and their attitudes to mathematics and science during 2005, the second (and final) year of schools , involvement in the IMYMS project.

Stakeholders and strategic planning in non-profit organisations : case studies in complexity and conflict

The experiences of two Australian non-profit member-benefit associations as they attempt to develop strategic plans are explored, with emphasis on the influence of the many stakeholders in this process. We conclude that
corporate strategic planning is a complex, conflict-ridden, and largely
unsuccessful process in non-profit member-benefit associations because of the number and commitment of stakeholders. Therefore we suggest that future research should focus on clarifying whether such corporate management techniques are actually appropriate for all non-profit organisations, and, if they are, how non-profit organisations can best manage the process, taking into account the values and needs of stakeholders.

Understanding the Components in Social Behavioural Change: Implications for Non-profit Organisations

In this paper we investigate the relationship between intrinsic motivation, extrinsic motivation and government influence with the over riding objective of developing more effective and efficient social behavioural change programs that have been instigated by public sector environmental management organisations. Based on the notion of intrinsic and extrinsic motivation, which has previously been shown to explain altitudes and behaviour associated with environmental issues, we extend the analysis in this paper to include the influence of government. A survey of a random sample of 566 landmanagers in South-eastern Australia was conducted and the data collected subsequently analysed using a structural equation modelling approach. The model that was developed identified the relationship between intrinsic motivation, extrinsic motivation and government influence.

Virtual non-profit organisations: literary virtual communities in Russia

This paper is a study of one of the “unknown” segments of the Internet - non-profit ventures in the Russian language.Based on the understanding of the concept of virtual community we consider the family of free publishing literary websites. We discuss their experience to demonstrate their contribution not only to the national culture, but also to the creation of open and democratic society in the former communist world, and to new forms of literary life. Some of the innovative concepts, principles and practices, adopted on those sites may be of interest to the Internet developers and
communities worldwide.