International transfer pricing : the Australian approach and lessons for Canada

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.

A review of international speed enforcement policies and practices : evidence-based recommendations for best practice

Extensive research has highlighted the positive and exponential relationship between vehicle speed and crash risk and severity. Speed enforcement policies and practices throughout the world have developed dramatically as new technology becomes available, however speeding remains a pervasive problem internationally that significantly contributes to road trauma. This paper adopted a three-pronged approach to review speed enforcement policies and practices by: (i) describing and comparing policies and practices adopted in a cross-section of international jurisdictions; (ii) reviewing the available empirical evidence evaluating the effectiveness of various approaches, and; (iii) providing recommendations for the optimisation speed enforcement. The review shows the enforcement strategies adopted in various countries differ both in terms of the approaches used and how they are specifically applied. The literature review suggests strong and consistent evidence that police speed enforcement, in particular speed cameras, can be an effective tool for reducing vehicle speeds and subsequent traffic crashes. Drawing from this evidence, recommendations for best practice are proposed, including the specific instances in which various speed enforcement approaches typically produce the greatest road safety benefits, and perhaps most importantly, that speed enforcement programs must utilise a variety of strategies tailored to specific situations, rather than a one-size-fits-all approach.

Implementation of individualised medication administration guides for patients with dysphagia: Results from a pilot controlled trial

Introduction Patients with dysphagia (PWDs) have been shown to be four times more likely to suffer medication administration errors (MAEs).1 2 Individualised medication administration guides (I-MAGs) which outline how each formulation should be administered, have been developed to standardise medication administration by nurses on the ward and reduce the likelihood of errors. This pilot study aimed to determine the recruitment rates, estimate effect on errors and develop the intervention to design a future full scale randomised controlled trial to determine the costs and effects of I-MAG implementation. Ethical approval was granted by local ethics committee. Method Software was developed to enable I-MAG production (based on current best practice)3 4 for all PWDs on two care of the older person wards admitted during a six month period from January to July 2011. I-MAGs were attached to the medication administration record charts to be utilised by nurses when administering medicines. Staff training was provided for all staff on the intervention wards. Two care of the older person wards in the same hospital were used for control purposes. All patients with dysphagia were recruited for follow up purposes at discharge. Four ward rounds at each intervention and control ward were observed pre and post I-MAG implementation to determine the level of medication administration errors. NHS ethical approval for the study was obtained. Results 164 I-MAGs were provided for 75 patients with dysphagia (PWDs) in the two intervention wards. At discharge, 23 patients in the intervention wards and 7 patients in the control wards were approached for recruitment of which 17 (74%) & 5 (71.5%) respectively consented. Discussion Recruitment rates were low on discharge due to the dysphagia remitting during hospitalisation. The introduction of the I-MAG demonstrated no effect on the quality of administration on the intervention ward and interestingly practice improved on the control ward. The observation of medication rounds at least one month post I-MAG removal may have identified a reversal to normal practice and ideally observations should have been undertaken with I-MAGs in place. Identification of the reason for the improvement in the control ward is warranted.

Proceedings of the 3rd International Subtropical Cities Conference 2011 Subtropical Cities: Subtropical Urbanism -Beyond Climate Change

Climate has been, throughout modern history, a primary attribute for attracting residents to the “Sunshine States” of Florida (USA) and Queensland (Australia). The first major group of settlers capitalized on the winter growing season to support a year-­‐round agricultural economy. As these economies developed, the climate attracted tourism and retirement industries. Yet as Florida and Queensland have blossomed under beneficial climates, the stresses acting on the natural environment are exacting a toll. Southeast Florida and eastern Queensland are among the most vulnerable coastal metropolitan areas in the world. In these places the certainty of sea level rise is measurable with impacts, empirically observable, that will continue to increase regardless of any climate change mitigation.1 The cities of the subtropics share a series of paradoxes relating to climate, resources, environment, and culture. As the subtropical climate entices new residents and visitors there are increasing costs associated with urban infrastructure and the ravages of violent weather. The carefree lifestyle of subtropical cities is increasingly dependent on scarce water and energy resources and the flow of tangible goods that support a trade economy. The natural environment is no longer exploitable as the survival of the human environment is contingent upon the ability of natural ecosystems to absorb the impact of human actions. The quality of subtropical living is challenged by the mounting pressures of population growth and rapid urbanization yet urban form and contemporary building design fail to take advantage of the subtropical zone’s natural attributes of abundant sunshine, cooling breezes and warm temperatures. Yet, by building a global network of local knowledge, subtropical cities like Brisbane, the City of Gold Coast and Fort Lauderdale, are confidently leading the way with innovative and inventive solutions for building resiliency and adaptation to climate change. The Centre for Subtropical Design at Queensland University of Technology organized the first international Subtropical Cities conference in Brisbane, Australia, where the “fault-­‐lines” of subtropical cities at breaking points were revealed. The second conference, held in 2008, shed a more optimistic light with the theme "From fault-­‐lines to sight-­‐lines -­‐ subtropical urbanism in 20-­‐20" highlighting the leadership exemplified in the vitality of small and large works from around the subtropical world. Yet beyond these isolated local actions the need for more cooperation and collaboration was identified as the key to moving beyond the problems of the present and foreseeable future. The spirit of leadership and collaboration has taken on new force, as two institutions from opposite sides of the globe joined together to host the 3rd international conference Subtropical Cities 2011 -­‐ Subtropical Urbanism: Beyond Climate Change. The collaboration between Florida Atlantic University and the Queensland University of Technology to host this conference, for the first time in the United States, forges a new direction in international cooperative research to address urban design solutions that support sustainable behaviours, resiliency and adaptation to sea level rise, green house gas (GHG) reduction, and climate change research in the areas of architecture and urban design, planning, and public policy. With southeast Queensland and southern Florida as contributors to this global effort among subtropical urban regions that share similar challenges, opportunities, and vulnerabilities our mutual aim is to advance the development and application of local knowledge to the global problems we share. The conference attracted over 150 participants from four continents. Presentations by authors were organized into three sub-­‐themes: Cultural/Place Identity, Environment and Ecology, and Social Economics. Each of the 22 papers presented underwent a double-­‐blind peer review by a panel of international experts among the disciplines and research areas represented. The Centre for Subtropical Design at the Queensland University of Technology is leading Australia in innovative environmental design with a multi-­‐disciplinary focus on creating places that are ‘at home’ in the warm humid subtropics. The Broward Community Design Collaborative at Florida Atlantic University's College for Design and Social Inquiry has built an interdisciplinary collaboration that is unique in the United States among the units of Architecture, Urban and Regional Planning, Social Work, Public Administration, together with the College of Engineering and Computer Science, the College of Science, and the Center for Environmental Studies, to engage in funded action research through design inquiry to solve the problems of development for urban resiliency and environmental sustainment. As we move beyond debates about climate change -­‐ now acting upon us -­‐ the subtropical urban regions of the world will continue to convene to demonstrate the power of local knowledge against global forces, thereby inspiring us as we work toward everyday engagement and action that can make our cities more livable, equitable, and green.

Just label it: Consumer rights, GM food labelling, and international trade

In the United States, there has been fierce debate over state, federal and international efforts to engage in genetically modified food labelling (GM food labelling). A grassroots coalition of consumers, environmentalists, organic farmers, and the food movement has pushed for law reform in respect of GM food labelling. The Just Label It campaign has encouraged United States consumers to send comments to the United States Food and Drug Administration to label genetically modified foods. This Chapter explores the various justifications made in respect of genetically modified food labelling. There has been a considerable effort to portray the issue of GM food labelling as one of consumer rights as part of ‘the right to know’. There has been a significant battle amongst farmers over GM food labelling – with organic farmers and biotechnology companies, fighting for precedence. There has also been a significant discussion about the use of GM food labelling as a form of environmental legislation. The prescriptions in GM food labelling regulations may serve to promote eco-labelling, and deter greenwashing. There has been a significant debate over whether GM food labelling may serve to regulate corporations – particularly from the food, agriculture, and biotechnology industries. There are significant issues about the interaction between intellectual property laws – particularly in respect of trade mark law and consumer protection – and regulatory proposals focused upon biotechnology. There has been a lack of international harmonization in respect of GM food labelling. As such, there has been a major use of comparative arguments about regulator models in respect of food labelling. There has also been a discussion about international law, particularly with the emergence of sweeping regional trade proposals, such as the Trans-Pacific Partnership, and the Trans-Atlantic Trade and Investment Partnership. This Chapter considers the United States debates over genetically modified food labelling – at state, federal, and international levels. The battles often involved the use of citizen-initiated referenda. The policy conflicts have been policy-centric disputes – pitting organic farmers, consumers, and environmentalists against the food industry and biotechnology industry. Such battles have raised questions about consumer rights, public health, freedom of speech, and corporate rights. The disputes highlighted larger issues about lobbying, fund-raising, and political influence. The role of money in United States has been a prominent concern of Lawrence Lessig in his recent academic and policy work with the group, Rootstrikers. Part 1 considers the debate in California over Proposition 37. Part 2 explores other key state initiatives in respect of GM food labelling. Part 3 examines the Federal debate in the United States over GM food labelling. Part 4 explores whether regional trade agreements – such as the Trans-Pacific Partnership (TPP) and the Trans-Atlantic Trade and Investment Partnership (TTIP) – will impact upon

Crime Justice and Social Democracy: Proceedings of the 3rd International Conference, 9-10 July 2015

We are pleased to present these selected papers from the proceedings of the 3rd Crime, Justice and Social Democracy International Conference, held in July 2015 in Brisbane, Australia. Over 350 delegates attended the conference from 19 countries. The papers collected here reflect the diversity of topics and themes that were explored over three days. The Crime, Justice and Social Democracy International Conference aims to strengthen the intellectual and policy debates concerning links between justice, social democracy, and the reduction of harm and crime, through building more just and inclusive societies and proposing innovative justice responses. In 2015, attendees discussed these issues as they related to ideas of green criminology; indigenous justice; gender, sex and justice; punishment and society; and the emerging notion of ‘Southern criminology’. The need to build global connections to address these challenges is more evident than ever and the conference and these proceedings reflect a growing attention to interdisciplinary, novel, and interconnected responses to contemporary global challenges. Authors in these conference proceedings engaged with issues of online fraud, queer criminology and law, Indigenous incarceration, youth justice, incarceration in Brazil, and policing in Victoria, Australia, among others. The topics explored speak to the themes of the conference and demonstrate the range of challenges facing researchers of crime, harm, social democracy and social justice and the spaces of possibility that such research opens. Our thanks to the conference convenor, Dr Kelly Richards, for organising such a successful conference, and to all those presenters who subsequently submitted such excellent papers for review here. We would also particularly like to thank Jess Rodgers for their tireless editorial assistance, as well as the panel of international scholars who participated in the review process, often within tight timelines.

Essays on the Determinants of International Portfolio Investments

Investors significantly overweight domestic assets in their portfolios. This behavior which is commonly called “home bias” contradicts the prescriptions of portfolio theory. This thesis explores potential reasons for the “home bias” by examining the characteristics of the investing and the target countries and features of the interaction between them. A common theme of the four essays is a focus on the importance of information about foreign markets in explaining the share of these markets in investors’ portfolios. The results indicate that the size of the equity ownership in another country strongly relates to the distance to the financial capital of that country, and to trade in goods with and direct investments (FDI) to that country. The first essay empirically investigates the relationship between trade in real goods and portfolio investments. Overall, the evidence indicates a substantial role for trade in reducing the information cost relating to portfolio investments. The second essay examines the implications of the launch of the European Monetary Union (EMU) on international portfolio investments. The evidence on the allocation of Finnish international portfolio investments is more consistent with an information-based than a diversification motive explanation. The third essay employs new data for a large number of countries and further explores the role of trade on international portfolio investments. The results indicate that trade provides important information especially on firms in countries in which the corporate governance structure and the information environment of firms generate less reliable information. The fourth essay examines the relationship between direct investments (FDI) and portfolio investments. In contrast to the predications of portfolio theory, it provides evidence that FDI is a complement rather than a substitute for portfolio investments.

The Impact of the EMU on International Portfolio Investments

This paper analyses the impact of the launch of the European Monetary Union (EMU) on the allocation of international portfolio investments. The initiation of the EMU provides an opportunity for comparison of competing theoretical explanations for investment behavior. Models stressing the diversification motive would predict that the increased dependence between countries participating in the EMU should reduce the attractiveness of portfolio holdings in other EMU countries. Models based on asymmetric information would instead emphasize the increased intensity in the flow of information resulting from an increase in cross border transactions between the EMU countries. The consequent decline in information asymmetry should increase, rather than reduce portfolio holdings in other EMU countries. Our results based on the allocation of Finnish foreign portfolio investment support the information-based explanation against predictions based on the diversification motive.

Performance Persistence of International Stock Funds

People saving in mutual funds often look at historical performance before they decide which funds to invest in. The implicit assumption made is that superior performance is likely to be repeated in the future. The findings presented in this study, which investigates funds sold on the Swedish market, support such an approach provided that the time horizons are limited to one year. International stock funds that have performed strongly one year are likely to outperform their peers also the following years. But if the historical and future time horizons are extended to two or three years, the positive relationship between past and future performance vanishes in most cases. Persistence tests focusing on the aggregated performance of fund companies were also carried out. These tests produced results rather similar to those on the individual fund level.

Intraday Linkages across International Equity Markets

Utilizing concurrent 5-minute returns, the intraday dynamics and inter-market dependencies in international equity markets were investigated. A strong intraday cyclical autocorrelation structure in the volatility process was observed to be caused by the diurnal pattern. A major rise in contemporaneous cross correlation among European stock markets was also noticed to follow the opening of the New York Stock Exchange. Furthermore, the results indicated that the returns for UK and Germany responded to each other’s innovations, both in terms of the first and second moment dependencies. In contrast to earlier research, the US stock market did not cause significant volatility spillover to the European markets.

International Portfolio Investments and The Informational Value of Trade

A large volume of literature suggests that information asymmetry resulting from the spatial separation between investors and investments have a significant impact on the composition of investors’ domestic and international portfolios. I show that institutional factors affecting trading in tangible goods help explain a substantial portion of investors’ spatial bias. More importantly, I demonstrate that an information flow medium with breadth and richness directly linked to the bilateral commitment of resources between countries, that I measure by their trading intensity in tangible goods, is consistent with the prevailing country allocation in investors’ international portfolios.

The Impact of FDI on International Portfolio Investments

Some empirical research has argued that part of the reason for the observed "home bias" is that investors are able to indirectly achieve internationally diversified portfolios via domestically listed multinational firms. Another branch of this research attributes the "home bias" and country allocations to more deeply rooted informational causes. Using a four-year annual panel of Finnish international portfolios and Foreign Direct Investments in twenty-five countries, I provide evidence consistent with an information asymmetry explanation

Applying Habermas's critical theory to public administration and policy: A case study of Florida Everglades restoration program

The foundation of Habermas's argument, a leading critical theorist, lies in the unequal distribution of wealth across society. He states that in an advanced capitalist society, the possibility of a crisis has shifted from the economic and political spheres to the legitimation system. Legitimation crises increase the more government intervenes into the economy (market) and the "simultaneous political enfranchisement of almost the entire adult population" (Holub, 1991, p. 88). The reason for this increase is because policymakers in advanced capitalist democracies are caught between conflicting imperatives: they are expected to serve the interests of their nation as a whole, but they must prop up an economic system that benefits the wealthy at the expense of most workers and the environment. Habermas argues that the driving force in history is an expectation, built into the nature of language, that norms, laws, and institutions will serve the interests of the entire population and not just those of a special group. In his view, policy makers in capitalist societies are having to fend off this expectation by simultaneously correcting some of the inequities of the market, denying that they have control over people's economic circumstances, and defending the market as an equitable allocator of income. (deHaven-Smith, 1988, p. 14). Critical theory suggests that this contradiction will be reflected in Everglades policy by communicative narratives that suppress and conceal tensions between environmental and economic priorities. Habermas’ Legitimation Crisis states that political actors use various symbols, ideologies, narratives, and language to engage the public and avoid a legitimation crisis. These influences not only manipulate the general population into desiring what has been manufactured for them, but also leave them feeling unfulfilled and alienated. Also known as false reconciliation, the public's view of society as rational, and "conductive to human freedom and happiness" is altered to become deeply irrational and an obstacle to the desired freedom and happiness (Finlayson, 2005, p. 5). These obstacles and irrationalities give rise to potential crises in the society. Government's increasing involvement in Everglades under advanced capitalism leads to Habermas's four crises: economic/environmental, rationality, legitimation, and motivation. These crises are occurring simultaneously, work in conjunction with each other, and arise when a principle of organization is challenged by increased production needs (deHaven-Smith, 1988). Habermas states that governments use narratives in an attempt to rationalize, legitimize, obscure, and conceal its actions under advanced capitalism. Although there have been many narratives told throughout the history of the Everglades (such as the Everglades was a wilderness that was valued as a wasteland in its natural state), the most recent narrative, “Everglades Restoration”, is the focus of this paper.(PDF contains 4 pages)