The value of visual fleece assessment in addition to objective measurements in identifying Angora goats of greater clean mohair production

Visual assessment of the fleece of Merino sheep is an accepted method to aid genetic improvement but there is little evidence to support the use of visual assessment for improving mohair production. This paper examines the extent that visual traits, including staple length, character (staple crimp), staple definition, tippiness, style and staple entanglement, are related to clean fleece weight in animals of similar live weight and mean fibre diameter (MFD) from the same flock. Measurements were made over 9 shearing periods on a population of castrated Angora males (wethers) goats representing the current range and diversity of genetic origins in Australia, including South African, Texan and interbred admixtures of these and Australian sources (these different genetic origins are defined as Breed in this work). Data on genetic origin, sire, dam, lifetime characteristics (date of birth, dam age, birth weight, birth parity (single or twin), weaning weight), live weight, fleece growth and visual fleece attributes were recorded. A restricted maximum likelihood (REML) model was developed to relate clean fleece weight with age, MFD, average fleece-free live weight, lifetime characteristics and visual fleece attributes. There were separate linear responses of clean fleece weight to MFD and staple length for each age group, a quadratic response to the square root of average fleece-free live weight, an effect of sire breed and linear responses to dam age, staple definition score and character. Depending on age at shearing, the increase in clean fleece weight was between about 50 and 80. g for each increase of 1. μm in MFD. At similar MFD, clean fleece weight was generally greater at summer shearings compared with winter shearings. There was a strong increase in clean fleece weight with average fleece-free live weight up to around 50. kg but little response in clean fleece weight for animals larger than 50. kg. There was some evidence of a smaller increase in clean fleece weight as the age of dam increased. There was an effect of Breed in the model but this effect disappeared when a random sire effect was included in the model. There was a positive response to staple length at some age groups but the response did not differ from zero in other age groups. This response varied from negligible to about 70. g per 1. cm increase in staple length. Clean fleece weight increased about 40. g per unit increase in staple definition score and increased about 30. g for every 4 units increase in the number of staple crimps. There was no evidence that clean fleece weight was affected by staple style, staple tip score or staple entanglement score or lifetime factors such as birth weight, date of birth, birth parity, or weaning weight. The results show that using a combination of measuring MFD and visually assessing the fleece for staple length, staple definition and crimps can help identify the most profitable Angora goats. In this process, the objective measurement of MFD appears essential. Visual assessment will provide some extra benefit in identifying these animals above that provided by measuring MFD alone. Animal size should be considered by mohair producers when identifying more productive mohair producing animals. © 2014 Elsevier B.V.

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.