The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

Expression of high mobility group box 1 in inflamed dental pulp and its chemotactic effect on dental pulp cells

High mobility group box 1 protein (HMGB1) is a chromatin protein which can be released extracellularly, eliciting a pro-inflammatory response and promoting tissue repair process. This study aimed to examine the expression and distribution of HMGB1 and its receptor RAGE in inflamed dental pulp tissues, and to assess its effects on proliferation, migration and cytoskeleton of cultured human dental pulp cells (DPCs). Our data demonstrated that cytoplasmic expression of HMGB1 was observed in inflamed pulp tissues, while HMGB1 expression was confined in the nuclei in healthy dental pulp. The mRNA expression of HMGB1 and RAGE were significantly increased in inflamed pulps. In in vitro cultured DPCs, expression of HMGB1 in both protein and mRNA level was up-regulated after treated with lipopolysaccharide (LPS). Exogenous HMGB1 enhanced DPCs migration in a dose-dependent manner and induced the reorganization of f-actin in DPCs. Our results suggests that HMGB1 are not only involved in the process of dental pulp inflammation, but also play an important role in the recruitment of dental pulp stem cells, promoting pulp repair and regeneration.

Fate of swallowed interleukin 8 and TNFα, and effect on the Wistar rat gut

To evaluate the passage of cytokines through the gastrointestinal tract, we investigated the digestion of interleukin-8 (IL-8) and tumour necrosis factor α (TNFα), in vitro and in vivo, and their propensity to induce intestinal inflammation. We serially immuno-assayed IL-8 and TNFα solutions co-incubated with each of three pancreatin preparations at pH 4.5 and pH 8. We gavaged IL-8, TNFα and marker into 15 Wistar rats, and measured their faecal cytokine concentrations by ELISA and histologically examined their guts. IL-8 immunoreactivity was extinguished by all pancreatin preparations after 1 h of incubation at 37 °C. TNFα concentration progressively fell from 1 to 4 h with all enzyme preparations. Buffer control samples maintained their cytokine concentrations throughout incubation. No IL-8 or TNFα was detected in any rat faecal pellets. There was no significant proinflammatory effect of the gavaged cytokines on rat intestine. IL-8 and TNFα in aqueous solution could well be fully digested in the CF gut when transit time is normal and exogenous enzymes are provided, although cytokines swallowed in viscous sputum may be protected from such digestion

Study of texture evolution in metastable beta-Ti alloy as a function of strain path and its effect on alpha transformation texture

Texture evolution in a low cost beta titanium alloy was studied for different modes of rolling and heat treatments. The alloy was cold rolled by unidirectional and multi-step cross rolling. The cold rolled material was either aged directly or recrystallized and then aged. The evolution of texture in alpha and beta phases were studied. The rolling texture of beta phase that is characterized by the gamma fiber is stronger for MSCR than UDR; while the trend is reversed on recrystallization. The mode of rolling affects alpha transformation texture on aging with smaller alpha lath size and stronger alpha texture in UDR than in MSCR. The defect structure in beta phase influences the evolution of a texture on aging. A stronger defect structure in beta phase leads to variant selection with the rolled samples showing fewer variants than the recrystallized samples.

Malnutrition in children with chronic liver disease accepted for liver transplantation : clinical profile and effect on outcome

The nutritional profiles of 37 children (aged 0.5-14.0 years) with chronic liver disease at the time of acceptance for orthotopic liver transplantation (OLTP) have been evaluated using clinical, biochemical and body composition methods. Nutritional progress while waiting for a donor has been related to outcome, whether transplanted or not. At the time of acceptance, most children were underweight (mean standard deviation (s.d.) weight = -1.4 ± 0.2) and stunted (mean s.d. height = - 2.2 ± 0.4), had low serum albumin (27/35) and had reduced body fat and depleted body cell mass (measured by total body potassium - mean % expected for age = 58 ± 5%, n = 15). Mean ad libitum nutrient intake was 63 ± 5% of recommended daily intake (RDI). Those who died while waiting (n = 8) had significantly lower mean initial s.d. weight compared with those transplanted. The overall actuarial 1 year survival of those who were transplanted (mean waiting time = 75 days) was 81% but those who were initially well nourished (s.d. weight >-1.0) had an actuarial 1 year survival of 100%. There were no significant differences in actuarial survival in relationship to age, type of transplant (whole liver or segmental), liver biochemistry or the presence or absence of ascites. Of the total group accepted for OLTP, whether transplanted or not, the overall 1 year survival for those who were relatively well nourished was 88% and for those undernourished (initial s.d. weight <-1.0) was 38% (P<0.003). Declining nutritional status during the waiting period also adversely affected outcome. We conclude that malnutrition and/or declining nutritional status is a major factor adversely affecting survival in children awaiting OLTP. In transplant units where waiting time is greater than 40 days, earlier referral, prioritization of cases and the use of adult donor livers may reduce this risk and efforts to maintain or improve nutritional status deserve further study.

Agent-based modelling of worker interactions and related impacts on workplace dynamics

This study uses agent based modelling to simulate the worker interactions within a workplace and to investigate how the interactions can have impact on the workplace dynamics. Two new models (Bounded Confidence with Bias model and Relative Agreement with Bias model) are built based on the theoretical foundation of two existing models. A new factor, namely bias, is added into the new models which raises several issues to be studied.

Spool valve mechanism used in a 20 K Gifford-McMahon cycle cryorefrigerator and its effect on the P-V diagram

The design and fabrication of a spool valve for a two-stage Gifford-McMahon cycle cryorefrigerator is described. The effect of this valve on the P-V diagram and practical methods of reducing the P-V degradation are also discussed.

Trap Design Effect on the Capture of Carpophilus spp. (Coleoptera: Nitidulidae) Using Synthetic Aggregation Pheromones and a Coattractant

In a series of experiments conducted in stone fruit orchards in southern Australia, water-based funnel-type traps baited with synthetic aggregation pheromone and fermenting bread dough, trapped 3- to 7-fold as many Carpophihus beetles (primarily C. dauidsoni) than wind-oriented pipe traps or dry funnel traps. The efficacy of dry funnel traps but not pipe traps, appeared to be improved by using water-filled collecting bottles. The potential for using water-based funnel traps in population suppression of Carpophilus spp. in stone fruit orchards through mass trapping is discussed.

Limb-loss in pond-reared blue swimmer crabs Portunus pelagicus (L.): Effect on growth in an indoor shedding system

Limb-loss in crustaceans can reduce moult increment and delay or advance the timing of moulting, both aspects that are likely to impact upon soft-shell crab production. Pond-reared blue swimmer crabs Portunus pelagicus were harvested and maintained in a crab shedding system. The wet weight, carapace width (CW) and the occurrence of limb-loss were assessed before stocking in the shedding system and after each of the next three moults. Many of the crabs were initially missing one or two limbs and these did not grow as much as the crabs that were intact at the start of the trial. Despite its strong correlation with wet weight, CW changes proved to be misleading. Limb-loss reduced the %CW increment but not the per cent weight increment (where the later is calculated from the actual pre-moult weight). Pre-moult weight explained much of the variation in post-moult weight, with crabs moulting to approximately double their weight. Limb-loss reduced 'growth' and production from the pond because it reduced pre-moult weight but limb-loss did not alter the weight change on shedding a given weight of crabs, although some of that change now included regeneration of limbs. One can hypothesize that much of the size variation seen in pond-reared crabs may be due to accumulated effects of repeated limb-loss, rather than genetic variation.

Pressure effect on the phase transition of trissarcosine calcium chloride

The dielectric measurement of ferroelectric trissarcosine calcium chloride (TSCC) was made under various pressures up to 6 kbar. A striking decrease in the peak value of the permittivity, epsilon r, at the transition temperature, Tc, was observed with increasing pressure. The value of Tc increases linearly with a pressure coefficient dTc/dp=11.1K kbar-1 at low pressures. This increase in Tc supports the suggestion that the ferroelectric transition is of the pure order-disorder type. It is suggested on the basis of the behaviour of epsilon r with pressure that the order of the ferroelectric transition changes from second to first order on application of pressure.

Penetration Rate Effect on Miniature Cone Tip Resistance for Different Cohesionless Materials

Cone penetrometer tests were carried out in a 140 mm diameter triaxial chamber by using a miniature cone of diameter 19.5 mm. The rate of cone penetration was varied from 0.01 mm/s to 0.1 mm/s. Tests were performed in (i) clean sand, (ii) silty sand, and (iii) sand added with fly ash. Two different effective vertical pressures (sigma(nu)), 100 kPa and 300 kPa, were employed. It was noted that for clean and silty sand, the effect of penetration rate on the ultimate tip resistance (q(cu)) of the cone was found to remain only marginal. On the other hand, for sand added with 30% fly ash, the variation in q(cu) values with penetration rate was found to become quite significant. The effect of penetratio rate on q(cu) in all the cases was found to increase with a decrease in the rate of cone penetration. It was noted that with an increase in sigma(nu), the effect of penetration rate on q(cu) was found to become smaller. The effect of the cone penetration rate on q(cu) generally reduces with an increase in the relative density of the material.

Rice husk biochar and crop residue amendment in subtropical cropping soils: Effect on biomass production, nitrogen use efficiency and greenhouse gas emissions

We investigated the effect of maize residues and rice husk biochar on biomass production, fertiliser nitrogen recovery (FNR) and nitrous oxide (N2O) emissions for three different subtropical cropping soils. Maize residues at two rates (0 and 10 t ha−1) combined with three rates (0, 15 and 30 t ha-1) of rice husk biochar were added to three soil types in a pot trial with maize plants. Soil N2O emissions were monitored with static chambers for 91 days. Isotopic 15N-labelled urea was applied to the treatments without added crop residues to measure the FNR. Crop residue incorporation significantly reduced N uptake in all treatments but did not affect overall FNR. Rice husk biochar amendment had no effect on plant growth and N uptake but significantly reduced N2O and carbon dioxide (CO2) emissions in two of the three soils. The incorporation of crop residues had a contrasting effect on soil N2O emissions depending on the mineral N status of the soil. The study shows that effects of crop residues depend on soil properties at the time of application. Adding crop residues with a high C/N ratio to soil can immobilise N in the soil profile and hence reduce N uptake and/or total biomass production. Crop residue incorporation can either stimulate or reduce N2O emissions depending on the mineral N content of the soil. Crop residues pyrolysed to biochar can potentially stabilise native soil C (negative priming) and reduce N2O emissions from cropping soils thus providing climate change mitigation potential beyond the biochar C storage in soils. Incorporation of crop residues as an approach to recycle organic materials and reduce synthetic N fertiliser use in agricultural production requires a thorough evaluation, both in terms of biomass production and greenhouse gas emissions.

Size effect on the lattice parameter of KCl during mechanical milling

The size effect on the lattice parameter of ionic KCl nanocrystals was studied systematically during mechanical milling of Pure KCl powder under vacuum. The results suggest anomalous lattice expansion, with the lattice parameter increasing from 6.278 angstrom at d = 6 mu m to 6.30307 angstrom at d = 85 mn. The defects generated during ball milling of KCl and surface stress are deemed to be responsible for this lattice parameter expansion. (C) 2009 Acta Materialia Inc. Published by Elsevier Ltd. All rights reserved.

Environmental and fishing effects on the dynamics of brown tiger prawn (Penaeus esculentus) in Moreton Bay (Australia)

This analysis of the variations of brown tiger prawn (Penaeus esculentus) catch in Moreton Bay multispecies trawl fishery estimated catchability using a delay difference model. It integrated several factors responsible for variations in catchability: targeting of fishing effort, increasing fishing power and changing availability. An analysis of covariance was used to define fishing events targeted at brown tiger prawns. A general linear model estimated inter-annual variations of fishing power. Temperature-induced changes in prawn behaviour played an important role on the dynamics of this fishery. Maximum likelihood estimates of targeted catchability (4.09 ± 0.42 × 10−4 boat-day−1) were twice as large as non-targeted catchability (1.86 ± 0.25 × 10−4 boat-day−1). The causes of recent declines in fishing effort in this fishery were discussed.

Surface treatments for pistons and their effect on engine performance

Surface treatment alters the frictional behaviour of pistons in I.C. engines and can be used to improve engine performance. Surface treatments applied to aluminium alloy pistons of a high speed diesel engine and their effect on the engine performance are described. Certain piston surface treatments improve engine performance and also reduce the run-in period.