Improving compliance of income tax in developing countries: Bangladesh perspective

The thesis examines tax compliance issues in developing countries in the field of income tax with special emphasis on Bangladesh. The thesis explores the state and taxpayers relationship as a fiduciary one. The effectiveness of specific legal tools in Bangladesh are discussed critically. Policy suggestions are made to improve compliance

Response : A defensible and workable approach to the income tax treatment of financial instruments

It is a privilege to have the opportunity to respond to the comments on my monograph1 provided by Mark Gergen, Glenn May, and Gordon Longhouse. Their comments, which are inevitably coloured by their very different perspectives, reflect the considerable expertise that each one of them has in the area of the income taxation of financial instruments. Indeed, it is with some hesitation that I offer a response in defence of various portions of the analysis presented in my monograph in support of some pretty modest proposals in this extremely difficult area of income tax law. Although I spent considerable time exploring some necessary first principles and their implications for the design of a system for the income taxation of financial instruments, I made several concessions to certain practical constraints that led me to support, in some measure, the status quo reflected in certain of the existing literature, as well as the legislation in a select group of countries. On the assumption that many readers may be unfamiliar with the monograph, I propose to respond by outlining much of my analysis in the monograph and the proposals that are the logical outcome. Throughout the outline, I will highlight and respond to what I see as the important points of difference emphasized by Gergen, May, and Longhouse.

Income security of international students in Australia

Growth in the number of international students studying in English language countries has slowed in recent years and this development has generated extended debate amongst university managers and policy makers. In these discussions much attention has focussed on whether the slow down is to be explained by currency realignments, visa requirements, the quality of education, or the increasing competitiveness of the international education market. But what has attracted little attention is the fact that when parents and students choose in which country they will purchase a foreign education their choice is commonly influenced by the level of security that is perceived to characterise the range of options. What security means can take many forms and in this paper we focus on income security. Drawing on interview data from 9 Australian universities, we clarify the sources of international student income, the extent to which these students experience income security/insecurity, how they cope with income difficulties and/or ensure finances do not become a serious problem, and whether the nature of the information provided by governments and universities helps explain the extent of income insecurity manifest amongst international students in Australia. We argue that a significant proportion of international students studying in Australia do experience income insecurity and suggest that for both moral and economic reasons the government and the university sector should pay increased attention to this aspect of student need.

Wellbeing of Australians : income security

The Australian Unity Wellbeing Index monitors the subjective wellbeing of the Australian population. Our first survey was conducted in April 2001 and this report concerns the 15th survey, undertaken in May 2006. Our previous survey had been conducted seven months earlier in October 2005. This intervening period contained a number of significant events. The first Australian terrorist threat was marked by the arrest of people in Sydney and Melbourne alleged to be plotting an attack. In December rioting took place in Sydney between Muslim and non-Muslim youths, but whether this was due more to religious differences or a ‘turf-war’ is unclear. Then, in May 2005, the new Industrial Relations legislation came into force. Each survey involves a telephone interview with a new sample of 2,000 Australians, selected to represent the national population geographic distribution. These surveys comprise the Personal Wellbeing Index, which measures people’s satisfaction with their own lives, and the National Wellbeing Index, which measures how satisfied people are with life in Australia. Other items include a standard set of demographic questions and other survey-specific questions. The specific topic for Survey 15 is the extent to which people feel that their source of income is secure.

Interjurisdictional allocation of multinational banking income : aligning taxation principles with economic activity

This thesis argues that one type of multinational entity – the multinational bank – poses particularly significant challenges to the international tax regime in terms of its current profit allocation rules. Multinational banks are a unique subset of multinational entities, and as a consequence of their unique traits, the traditional international tax regime foes not yield an optimal interjurisdictional allocation of taxing rights. The opportunity for tax minimisation, achievable because of the unique traits, and realised through exploitation of the traditional source and transfer pricing regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality. There are two distinct ways in which the traditional international tax regime fails to reflect economic activity. The first way that economic activity may not be reflected in the distribution of the taxing rights to income from multinational banking is through the application of traditional source rules. The traditional sources rules allocate income where transactions are completed rather than where the intermediation services are arranged. As a result of their unique commercial role as financial intermediaries, by separating intermediary economic activity from legal transactions with third parties, multinational banks may distort the true location of the activity giving rise to income. The second way in which the traditional tax regime may fail to reflect economic activity is through the traditional transfer pricing regime requiring related or internal transaction to be undertaken at an arm’s length price. The arm’s length pricing requirement is theoretically deficient in its failure to recognise the highly integrated nature of multinational banking. In practice, the arm’s length pricing requirement is also difficult, if not impossible, to apply to multinational banks because of the requirement of comparability. The difficulties associated with the current model have resulted in a subtle move by multinational banks towards global formulary apportionment. This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax purposes on the basis of income source, with source determined using a unitary taxation or global formulary apportionment system. It is argued that global formulary apportionment is a theoretically superior model that provides both jurisdiction to tax and allocated profits on the basis of the economic activity that generates the income.

The impact of gender inequality in education on income in Africa and the Middle East

We use data for a group of sub-Saharan African, North African and Middle Eastern countries to explore the impact of gender inequality in education on levels of income per capita. Two gender inequality indicators are used: the gap in female to male primary education enrolment ratios and the gap in female to male secondary education enrolment ratios. Estimation results indicate that gender inequality in primary and secondary education has a statistically significant negative effect on income, especially in North African and Middle Eastern countries. In relatively open economies, gender inequality in education seems to have an additional effect, but this effect is consistently positive, suggesting that while trade contributes to higher income it may be accompanied by greater inequality. Overall, the results in this paper provide further evidence that the international development community's focus on reducing gender inequality and achieving universal primary education is well founded.

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.

The trouble with income trusts

This paper sketches broadly the efficiency and equity effects of income trusts that make their use as a substitute for the direct holding of shares of a corporation problematic for tax policy purposes. The paper also considers the potential effectiveness of an equity recharacterization rule applicable to the high-yield junk debt that is the common feature of the basic income trust structure. The author suggests that this type of narrowly focused rule would be more target-efficient than other possible responses to income trusts, such as fundamental reform of the corporate income tax or the restrictions on the holding of trust units proposed in the 2004 budget. However, a principal difficulty in designing an equity recharacterization rule is ensuring that it applies equally to structures that realize the same effect as the basic income trust structure but do not use high-yield junk debt.
The author argues that income trusts are examples of tax-driven financial innovation in the sense that they replicate an existing set of securities and therefore have no nontax rationale. These securities are essentially redundant, and the innovative process of which they are a product does not constitute “genuine” financial innovation. This essential characteristic of income trusts distinguishes them from real estate investment trusts, which arguably do not present a tax policy problem (or at least not the same one). More particularly, income trust transactions are redundant in the sense that they do not complete capital markets by providing investors with a risk and return payoff profile that is otherwise unavailable. In the absence of any efficiency gains or desirable distributional effects associated with income trusts, the available tax benefit is the subject of a defensible government response intended to eliminate it. But without any clear evidence that income trusts are substituted generally for the corporate form, any response can defensibly be limited to a narrowly targeted one that introduces a “taxlaw friction” by shifting the debt-equity boundary that is the focus of the basic income trust structure. Because the precise dividing points along this boundary lack any obvious normative content, the suggested policy focus should be the development of a legislative response that redraws the debt-equity boundary in a manner that minimizes perceived efficiency losses otherwise associated with the use of income trusts.

Understanding the role of mediating risk factors and proxy effects in the association between socio-economic status and untreated hypertension

The association between socio-economic status (SES) and untreated hypertension varies according to a country's level of development and racial/ethnic group. We sought to confirm this variation in women from China and the United States (US) as well as to investigate the impact of SES on several mediating risk factors. We also investigate the extent to which SES explains racial/ethnic differences in untreated hypertension in the US. We used cross-sectional data from 1814 non-pregnant women in China (China Health and Nutrition Survey (CHNS), 1997) and 3266 non-pregnant women in the United States (National Health and Nutrition Examination Survey (NHANES III), 1988–1994) respectively. A variety of statistical modelling techniques was used to predict untreated hypertension as a function of several mediating factors and to simulate the impact of changes in SES. The age-adjusted prevalence of untreated hypertension was significantly higher (p<0.01) for low-income White and Black women compared to Mexican American or Chinese women. Untreated hypertension was not significantly associated with income or education in Mexican Americans or women in China. Obesity and light physical activity had the largest mediating effect on the association between SES and untreated hypertension for all racial/ethnic groups. However, this effect was not as strong as the proxy effect of income and education. SES did not completely explain racial/ethnic differences in hypertension in the US. While SES was more strongly associated with hypertension in Blacks than Whites, Blacks were still 1.97 (95% CI 1.47–2.64) times more likely to have untreated hypertension than Whites after adjusting for SES differences. The association between SES and untreated hypertension varied by country and racial/ethnic group. An important explanation for this variation was the differential effect of SES on mediating risk factors. SES disparities between Whites and Blacks in the US partly explain differences in the prevalence of untreated hypertension between these racial/ethnic groups.

An observer design procedure for a class of nonlinear time-delay systems

This paper considers a class of uncertain, nonlinear differential state delayed control systems and presents a reduced-order observer design procedure to asymptotically estimate any vector state functionals. The method proposed involves decomposition of the delayed portion of the system into two parts: a matched and mismatched part. Provided that the rank of the mismatched part is less than the number of the outputs, a reduced-order linear functional observer, with any prescribed stability margin, can be constructed by using a simple procedure. A numerical example is given to illustrate the new design procedure and its features.

The impact of the financial costs of multiple sclerosis on quality of life

This study examined the financial costs of multiple sclerosis (MS) and the impact of financial strain on the subjective quality of life of people with MS and their families. Due to the lack of research in this area, a qualitative research design was employed. Interviews were conducted with 16 health professionals, 26 people with MS, and 11 family members of people who had MS. Adjusting to actual or threatened loss of income caused financial stress. These financial struggles led to a lower quality of life among respondents. Problem solving, coping, and positive reappraisal helped people to adjust to financial changes. Professionals focused on increased funding for services, whereas people with MS focused on improved income support. These findings highlight the need for professionals to consider the financial strain associated with this disease and the impact of this strain on the quality of life of individuals with MS and their families.

Public finance and income redistribution in interwar Australia: towards a class analysis

In this paper I focus on a neglected aspect of Australian political history, the extent to which Australian governments actually redistributed income. The German sociologist Rudolf Goldscheid argued that 'the budget is the skeleton of the state stripped of all misleading ideologies'. In Australia a party that claimed to represent lower income earners, the Labor Party, was a major political force, but did Labor actually make a difference to the distribution of income across social classes, or did Labor's rhetoric of equity merely serve to incorporate workers into the capitalist system? A quantitative approach to the political history of labour may enable us to escape both nostalgia for old labourism (which the Howard years have encouraged) and a simple and undifferentiated rejection of labourism as a reformist agent of social integration.

This paper incorporates some material from a 2005 paper that examined overall expenditure patterns and taxation patterns across the states and Commonwealth from 1910 to 1940 but it goes beyond the aggregate approach of this paper to consider the extent which the varying patterns of taxation and public expenditure across Australia impacted on different social classes during the 1930s. It is very much a preliminary analysis based on existing compilations of taxation statistics. It is a static analysis and does not consider if nominally redistributive taxation and expenditure patterns might be rendered ineffective by consequent interstate migration.