Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

‘They get fed up with playing.’ Parents’ views on play-based learning in the Preparatory Year

Within early childhood education two ideas are firmly held: play is the best way for children to learn and parents are partners in the child’s learning. While these ideas have been explored, limited research to date has investigated the confluence of the two - how parents of young children view the concept of play. This paper investigates parents’ views on play by analysing the views of small group of parents of Prep Year children in Queensland, Australia. The parents in this study held varying definitions of what constitutes play, and complex and contradictory notions of its value. Positive views of play were linked to learning without knowing it, engaging in hands-on activities, and preparation for Year One through a strong focus on academic progress. Some parents held that Prep was play-based, while others did not. The complexities and diversity of parental opinion in this study echo the ongoing commentary about how play ought to be defined. Moreover, the notion that adults may interpret play in different ways is also reflected here. The authors suggest that for early childhood educators these complexities require an ongoing engagement, debate and reconceptualisation of the place of play in light of broader curricular and socio-political agendas.

The enterprise information security policy as a strategic business policy within the corporate strategic plan (extended abstract)

Information security has been recognized as a core requirement for corporate governance that is expected to facilitate not only the management of risks, but also as a corporate enabler that supports and contributes to the sustainability of organizational operations. In implementing information security, the enterprise information security policy is the set of principles and strategies that guide the course of action for the security activities and may be represented as a brief statement that defines program goals and sets information security and risk requirements. The enterprise information security policy (alternatively referred to as security policy in this paper) that represents the meta-policy of information security is an element of corporate ICT governance and is derived from the strategic requirements for risk management and corporate governance. Consistent alignment between the security policy and the other corporate business policies and strategies has to be maintained if information security is to be implemented according to evolving business objectives. This alignment may be facilitated by managing security policy alongside other corporate business policies within the strategic management cycle. There are however limitations in current approaches for developing and managing the security policy to facilitate consistent strategic alignment. This paper proposes a conceptual framework for security policy management by presenting propositions to positively affect security policy alignment with business policies and prescribing a security policy management approach that expounds on the propositions.

Jury option needs early verdict

The decision in Rubin v Buchanan [2011] QSC 275 confirms that a trial by jury should be considered at the outset of a proceeding.

Practice and Procedure: Worker's Compensation and Rehabilitation Act 2003 (Qld) s275

In Australian Meat Holdings Pty Ltd v Sayers [2007] QSC 390 Daubney J considered the obligation imposed on a claimant under s 275 of the Workers’ Compensation and Rehabilitation Act 2003 (Qld) to provide the insurer with an authority to obtain information and documents. The decision leads to practical results.

The developmental and acute phases of insulin-induced laminitis involve minimal metalloproteinase activity

Metalloproteinases have been implicated in the pathogenesis of equine laminitis and other inflammatory conditions, through their role in the degradation and remodelling of the extracellular matrix environment. Matrix metalloproteinases (MMPs) and their inhibitors are present in normal equine lamellae, with increased secretion and activation of some metalloproteinases reported in horses with laminitis associated with systemic inflammation. It is unknown whether these enzymes are involved in insulin-induced laminitis, which occurs without overt systemic inflammation. In this study, gene expression of MMP-2, MMP-9, MT1-MMP, ADAMTS-4 and TIMP-3 was determined in the lamellar tissue of normal control horses (n = 4) and horses that developed laminitis after 48 h of induced hyperinsulinaemia (n = 4), using quantitative Real Time-Polymerase Chain Reaction (qRT-PCR). Protein concentrations of MMP-2 and MMP-9 were also examined using gelatin zymography in horses subject to prolonged hyperinsulinaemia for 6 h (n = 4), 12 h (n = 4), 24 h (n = 4) and 48 h (n = 4), and in normal control horses (n = 4). The only change in gene expression observed was an upregulation of MMP-9 (p < 0.05) in horses that developed insulin-induced laminitis (48 h). Zymographical analysis showed an increase (p < 0.05) in pro MMP-9 during the acute phase of laminitis (48 h), whereas pro MMP-2 was present in similar concentration in the tissue of all horses. Thus, MMP-2, MT1-MMP, TIMP-3 and ADAMTS-4 do not appear to play a significant role in the pathogenesis of insulin-induced laminitis. The increased expression of MMP-9 may be associated with the infiltration of inflammatory leukocytes, or may be a direct result of hyperinsulinaemia. The exact role of MMP-9 in basement membrane degradation in laminitis is uncertain as it appears to be present largely in the inactive form.

Pedigree-free animal models : the relatedness matrix reloaded

Animal models typically require a known genetic pedigree to estimate quantitative genetic parameters. Here we test whether animal models can alternatively be based on estimates of relatedness derived entirely from molecular marker data. Our case study is the morphology of a wild bird population, for which we report estimates of the genetic variance-covariance matrices (G) of six morphological traits using three methods: the traditional animal model; a molecular marker-based approach to estimate heritability based on Ritland's pairwise regression method; and a new approach using a molecular genealogy arranged in a relatedness matrix (R) to replace the pedigree in an animal model. Using the traditional animal model, we found significant genetic variance for all six traits and positive genetic covariance among traits. The pairwise regression method did not return reliable estimates of quantitative genetic parameters in this population, with estimates of genetic variance and covariance typically being very small or negative. In contrast, we found mixed evidence for the use of the pedigree-free animal model. Similar to the pairwise regression method, the pedigree-free approach performed poorly when the full-rank R matrix based on the molecular genealogy was employed. However, performance improved substantially when we reduced the dimensionality of the R matrix in order to maximize the signal to noise ratio. Using reduced-rank R matrices generated estimates of genetic variance that were much closer to those from the traditional model. Nevertheless, this method was less reliable at estimating covariances, which were often estimated to be negative. Taken together, these results suggest that pedigree-free animal models can recover quantitative genetic information, although the signal remains relatively weak. It remains to be determined whether this problem can be overcome by the use of a more powerful battery of molecular markers and improved methods for reconstructing genealogies.

Human papillomavirus prevalence, viral load and pre-cancerous lesions of the cervix in women initiating highly active antiretroviral therapy in South Africa : a cross-sectional study

Background Cervical cancer and infection with human immunodeficiency virus (HIV) are both important public health problems in South Africa (SA). The aim of this study was to determine the prevalence of cervical squamous intraepithelial lesions (SILs), high-risk human papillomavirus (HR-HPV), HPV viral load and HPV genotypes in HIV positive women initiating anti-retroviral (ARV) therapy. Methods A cross-sectional survey was conducted at an anti-retroviral (ARV) treatment clinic in Cape Town, SA in 2007. Cervical specimens were taken for cytological analysis and HPV testing. The Digene Hybrid Capture 2 (HC2) test was used to detect HR-HPV. Relative light units (RLU) were used as a measure of HPV viral load. HPV types were determined using the Roche Linear Array HPV Genotyping test. Crude associations with abnormal cytology were tested and multiple logistic regression was used to determine independent risk factors for abnormal cytology. Results The median age of the 109 participants was 31 years, the median CD4 count was 125/mm3, 66.3% had an abnormal Pap smear, the HR-HPV prevalence was 78.9% (Digene), the median HPV viral load was 181.1 RLU (HC2 positive samples only) and 78.4% had multiple genotypes. Among women with abnormal smears the most prevalent HR-HPV types were HPV types 16, 58 and 51, all with a prevalence of 28.5%. On univariate analysis HR-HPV, multiple HPV types and HPV viral load were significantly associated with the presence of low and high-grade SILs (LSIL/HSIL). The multivariate logistic regression showed that HPV viral load was associated with an increased odds of LSIL/HSIL, odds ratio of 10.7 (95% CI 2.0 – 57.7) for those that were HC2 positive and had a viral load of ≤ 181.1 RLU (the median HPV viral load), and 33.8 (95% CI 6.4 – 178.9) for those that were HC2 positive with a HPV viral load > 181.1 RLU. Conclusion Women initiating ARVs have a high prevalence of abnormal Pap smears and HR-HPV. Our results underscore the need for locally relevant, rigorous screening protocols for the increasing numbers of women accessing ARV therapy so that the benefits of ARVs are not partially offset by an excess risk in cervical cancer.

First year design "Visualisation II": The hybridisation of analogue and digital tools

This paper discusses first year students’ responses and outcomes to the integration of digital technologies in their second semester foundational visualisation class; ‘Visualisation II’. As the second class in the Visualisation series, previous analogue knowledge taught in ‘Visualisation I’ is compounded with new digital technologies establishing the introduction to a myriad of hybrid visualisation tools and techniques for design exploration and design artefact. This research examines the differentiation between analogue and digital design, common precedents of the two, and reflects upon the environment and class structure with the learning experiences and confidence of surveyed participants.

Hanging out is hard to do : Methodology in non-avatar environments

Ethnography is now a well-established research methodology for virtual environments, and the vast majority of accounts have one aspect in common, whether textual or graphic environments – that of the embodied avatar. In this article, I first discuss the applicability of such a methodology to non-avatar environments such as Eve Online, considering where the methodology works and the issues that arise in its implementation – particularly for the consideration of sub-communities within the virtual environment. Second, I consider what alternative means exist for getting at the information that is obtained through an ethnographic study of the virtual environment. To that end, I consider the practical and ethical implications of utilizing existing accounts, the importance of the meta-game discourse, including those sources outside of the control of the environment developer, and finally the utility in combining personal observations with accounts of other ethnographers, both within and between environments.

Applied Reliability of Transmission Substations

Reliability is an integral component of modern power system design, planning and management. This paper uses the Markov approach to substation reliability evaluation using dedicated reliability software. This technique was applied to yield reliability indices for an existing and important substation in the POWERLINK QUEENSLAND 275 kV transmission network. Reliability indices were also determined for several reinforcement alternatives for this substation with the aim of improving substation reliability. The economic feasibility of achieving higher levels of reliability was also taken into account.