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.

Developing wikis to foster web-based learning communities : an iterative approach

This paper discusses ongoing research at Deakin University, which focuses on developing wikis to foster web-based learning communities. Research to date has used wikis to facilitate collaborative icebreaker exercises, discussions, and to create knowledge repositories. Student feedback has contributed to the iterative revision of the wiki interface, the icebreaker exercise and the development of new tasks for students to complete using the wiki. The analysis and discussion of the experiments presented in this paper focuses on usage trends such as the signature, viewing and editing patterns exhibited by the student cohort. The community building potential of wikis is discussed, highlighting the specific wiki features that can be used to foster a sense of community in a web-based learning environment. Finally, issues surrounding the development of web-based learning communities, which have emerged through the wiki study, are discussed and future directions are outlined.

An improved approach for the discovery of causal models via MML

Discovering a precise causal structure accurately reflecting the given data is one of the most essential tasks in the area of data mining and machine learning. One of the successful causal discovery approaches is the information-theoretic approach using the Minimum Message Length Principle[19]. This paper presents an improved and further experimental results of the MML discovery algorithm. We introduced a new encoding scheme for measuring the cost of describing the causal structure. Stiring function is also applied to further simplify the computational complexity and thus works more efficiently. The experimental results of the current version of the discovery system show that: (1) the current version is capable of discovering what discovered by previous system; (2) current system is capable of discovering more complicated causal models with large number of variables; (3) the new version works more efficiently compared with the previous version in terms of time complexity.

Adding value to online privacy for consumers: remedying deficiences in online privacy policies with an holistic approach

We present findings from a longitudinal, empirical study of online privacy policies. Our research found that although online privacy policies have improved in quality and effectiveness since 2000, they still fall well short of the level of privacy assurance desired by consumers. This study has identified broad areas of deficiency in existing online privacy policies, and offers a solution in the form of an holistic framework for the development, factors and content of online privacy policies for organizations. Our study adds to existing theory in this area and, more immediately, will assist businesses concerned about the effect of privacy issues on consumer Web usage.

Team teaching in teacher education: towards an interdisciplinary approach

‘Team teaching’ across disciplines at Australian universities is rare. Academics are rigorous in developing specific disciplinary expertise that often prevents collaboration outside of their disciplinary area. In pre-service primary education courses, academics often teach in traditional and exclusive disciplinary approaches. This separation is at odds however with the impetus for a pedagogical move forward towards an interdisciplinary approach in primary schools. The authors contend that primary
teacher educators must model effective interdisciplinary practice to their student teachers and unpack the processes of how to make meaningful connections together. This paper presents the work of two teacher educators who are involved in a broader, innovative, team teaching, field based collaboration with schools and non-school settings for the Bachelor of Teaching (Postgraduate) at Deakin University. In this paper, the authors firstly discuss their rationale for adopting a team teaching approach and describe how they are working towards an interdisciplinary model, bringing together the two areas; music and literacy and providing examples from their team teaching experience. The paper concludes with reflections and recommendations for future team teaching at the tertiary level.

Wages, career progression, training and work family policies : an integrated approach to explaining gender discrimination

While the Equal Employment Opportunities (EEO) literature suggests that considerable progress has been made towards addressing gender-based discrimination (primarily through legal instruments), direct and indirece forms of discrimination persist and tend to be perpetuated through organisational practices (Tomaskovic-Devey 2001). Women are still receive less remuneration than men and are disadvantaged with respect to fundamental entitlements such as promotion and training and education. Furthermore, as more women enter employment the issue of work and family balance has become an organisational priority. There is a large body of research literature in the disciplines of economics, sociology, industrial relations, human resource management, organisational studies and public administration that examines the sources, nature and extent of gender-based discrimination in labour markets. This paper seeks to integrate this literature by taking a multi-disciplinary approach to the problem of women, EEO and discrimination. It is argued that our understanding of discrimination is greatly enhanced by theories and models that incorporate both economic and organisational explanations. Furthermore, it is argued that discrimination in terms of promotion, pay and training are endogenous. That is, the interrelationship between these variables needs to be taken into account simultaneously to accurately estimate the degree of direct and indirect discrimination that women face. The paper provides a review of the literature on the key themes of pay equity, career progression, education and training and work-family policy, and seeks to provide a synthesis of key themes. Emerging from this literature are a number of testable hypotheses. The paper concludes with suggestions for future research.

Towards the confirmation of the MOA model : an applied approach

The aim of this paper is to develop a grounded understanding of the role that the MOA constructs play in influencing environmentally responsible  behaviour. Data collected is used to qualitatively confirm the MOA Model (Rothschild, 1999) in an environmental management application and provide a basis to inform the development of a comprehensive quantitative causal investigation. This study will seek to determine the specific contributions of each MOA factor in the study context. The case study chosen for this investigation is representative of other social marketing applications for the MOA framework. The case study concerns the behaviour of agrarian land managers with respect to the rabbit pest problem affecting rural Australia. The paper concludes by confirming the appropriateness of the constructs within the MOA Model.

An algebraic approach for delay-independent and delay-dependent stability of linear time-delay systems

This paper addresses the problem of asymptotic stability of a linear system with many delay units. A novel algebraic test is proposed for the delay-independent stability of the system, based on the root distribution of the system's characteristic equation. If the system is only stable dependent of delay, the whole stable regions of the system can be perfectly obtained. Two algorithms are derived to examine the delay-independent stability, and to compute the whole stable regions if the system is of delay-dependent stability. These algorithms are computationally efficient and applicable to both certain and uncertain systems. Some illustrative examples demonstrate the validity of the approach.