Transfer Pricing in the Decentralized Multinational Corporation

This paper considers how the multinational corporation's transfer price responds to changes in international corporate effective tax rates. It extends the decentralized decision-making analysis of transfer pricing in the context of different tax rates. It adopts and extends Bond's (1980) model of the decentralized multinational corporation that assumes centralized transfer pricing. The direction of transfer price change is as expected, while the magnitude of change is likely to be less than predicted by the Horst (1971), centralized decision-making model. The paper extends the model further by assuming negotiated transfer pricing, where the analysis is partitioned into perfect and imperfect information cases. The negotiated transfer pricing result reverts to the Horst (1971), or centralized decision-making, result, under perfect information. Under imperfect information, the centralized decision-making result obtains when top management successfully informs division general managers or it successfully implements a non-monetary reward scheme to encourage division general managers to cooperate. Under simplifying assumptions, centralized decision-making dominates decentralized decision-making, while negotiated transfer pricing weakly dominates centralized transfer pricing.

International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions

We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible's arm's length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.

Catalogue of Hebraica and Judaica in the library of the Corporation of the City of London

by A. Löwy

A review of the Malaria Chemoprophylaxis Compliance Program at ExxonMobil Corporation

ExxonMobil, a Fortune 500 oil and gas corporation, has a global workforce with employees assigned to projects in areas at risk for infectious diseases, particularly malaria. As such, the corporation has put in place a program to protect the health of workers and ensure their safety in malaria endemic zones. This program is called the Malaria Control Program (MCP). One component of this program is the more specific Malaria Chemoprophylaxis Compliance Program (MCCP), in which employees enroll following consent to random drug testing for compliance with the company's chemoprophylaxis requirements. Each year, data is gathered on the number of employees working in these locations and are selected randomly and tested for chemoprophylaxis compliance. The selection strives to test each eligible worker once per year. Test results that come back positive for the chemoprophylaxis drug are considered "detects" and tests that are negative for the drug and therefore show the worker is non-compliant at risk for severe malaria infection are considered "non-detect". ^ The current practice report used aggregate data to calculate statistics on test results to reflect compliance among both employees and contractors in various malaria-endemic areas. This aggregate, non-individualized data has been compiled and reflects the effectiveness and reach of ExxonMobil's Malaria Chemoprophylaxis Compliance Program. In order to assess compliance, information on the number of non-detect test results was compared to the number of tests completed per year. The data shows that over time, non-detect results have declined in both employee and contractor populations, and vary somewhat by location due to size and scope of the MCCP implemented in-country. Although the data indicate a positive trend for the corporation, some recommendations have been made for future implementation of the program.^

Romanian glocalization : Case study on the Rosia Montana Gold Corporation Mining Project

At the end of the communist era, which was characterised as a closed social experiment, Romania found itself in the middle of a globalization process. Its industrial capacities have been considerably reduced through a poor and spendthrift management. There was a mass exodus of the labour force abroad and the educational background for the remaining part was no longer in agreement with the labour market. On these grounds, the vectors of globalization, in the form of foreign investments, entered Romania effortlessly. There even were local communities where the arrival of foreign investors was expected like a second coming of Christ. This is the context in which a Canadian company set forth the mining project Rosia Montana Gold Corporation. The implementation of the project should have started in 2005. Nevertheless, the project has not been effectively launched yet. This situation is based on what we call Romanian glocalization, namely a specific confrontation between global and local on Romanian land

Romanian glocalization : Case study on the Rosia Montana Gold Corporation Mining Project

At the end of the communist era, which was characterised as a closed social experiment, Romania found itself in the middle of a globalization process. Its industrial capacities have been considerably reduced through a poor and spendthrift management. There was a mass exodus of the labour force abroad and the educational background for the remaining part was no longer in agreement with the labour market. On these grounds, the vectors of globalization, in the form of foreign investments, entered Romania effortlessly. There even were local communities where the arrival of foreign investors was expected like a second coming of Christ. This is the context in which a Canadian company set forth the mining project Rosia Montana Gold Corporation. The implementation of the project should have started in 2005. Nevertheless, the project has not been effectively launched yet. This situation is based on what we call Romanian glocalization, namely a specific confrontation between global and local on Romanian land

Romanian glocalization : Case study on the Rosia Montana Gold Corporation Mining Project

At the end of the communist era, which was characterised as a closed social experiment, Romania found itself in the middle of a globalization process. Its industrial capacities have been considerably reduced through a poor and spendthrift management. There was a mass exodus of the labour force abroad and the educational background for the remaining part was no longer in agreement with the labour market. On these grounds, the vectors of globalization, in the form of foreign investments, entered Romania effortlessly. There even were local communities where the arrival of foreign investors was expected like a second coming of Christ. This is the context in which a Canadian company set forth the mining project Rosia Montana Gold Corporation. The implementation of the project should have started in 2005. Nevertheless, the project has not been effectively launched yet. This situation is based on what we call Romanian glocalization, namely a specific confrontation between global and local on Romanian land

President Chain Store Corporation's Hsu Chong-Jen: A Case Study of a Salaried Manager in Taiwan

Salaried managers have been increasing in top management of many Taiwanese companies. Why and how have their roles become more important? In order to answer these questions, it is necessary to examine the complicated relationships between salaried managers and the founders' families who appoint them to top-management positions. This paper examines the case of Hsu Chung-Jen, the president of President Chain Store Corporation. PCSC operates Taiwan's 7-ELEVENs, the largest convenience store chain on the island. He may be regarded as the most advanced salaried manager in Taiwan today.

High speed railroad bridges. Conception, bases of design, typological possibilities and construction methods

Diseño conceptual de puentes de alta velocidad ferroviarios. Railroad bridges, in general, and those for high speed railways, in particular, demand very special conditions. The traffic loads are much higher than for road bridges. Loads due to braking and acceleration determine, due to their magnitude, the structural layout. Because of the speed of the vehicles there are specific dynamic effects which need to be considered. In order to ensure passenger comfort, compatible with speeds of up to 350 km/h, it is necessary to meet very demanding conditions with respect to stiffness, displacements and dynamic behavior. In this paper these conditions are briefly described and different typological possibilities to satisfy them are presented as well as the main construction methods applicable to this kind of bridges.

Effects of traffic loads on reinforced concrete railroad culverts

In the context of the present conference paper culverts are defined as an opening or conduit passing through an embankment usually for the purpose of conveying water or providing safe pedestrian and animal crossings under rail infrastructure. The clear opening of culverts may reach values of up to 12m however, values around 3m are encountered much more frequently. Depending on the topography, the number of culverts is about 10 times that of bridges. In spite of this, their dynamic behavior has received far less attention than that of bridges. The fundamental frequency of culverts is considerably higher than that of bridges even in the case of short span bridges. As the operational speed of modern high-speed passenger rail systems rises, higher frequencies are excited and thus more energy is encountered in frequency bands where the fundamental frequency of box culverts is located. Many research efforts have been spent on the subject of ballast instability due to bridge resonance, since it was first observed when high-speed trains were introduced to the Paris/Lyon rail line. To prevent this phenomenon from occurring, design codes establish a limit value for the vertical deck acceleration. Obviously one needs some sort of numerical model in order to estimate this acceleration level and at that point things get quite complicated. Not only acceleration but also displacement values are of interest e.g. to estimate the impact factor. According to design manuals the structural design should consider the depth of cover, trench width and condition, bedding type, backfill material, and compaction. The same applies to the numerical model however, the question is: What type of model is appropriate for this job? A 3D model including the embankment and an important part of the soil underneath the culvert is computationally very expensive and hard to justify taking into account the associated costs. Consequently, there is a clear need for simplified models and design rules in order to achieve reasonable costs. This paper will describe the results obtained from a 2D finite element model which has been calibrated by means of a 3D model and experimental data obtained at culverts that belong to the high-speed railway line that links the two towns of Segovia and Valladolid in Spain

Metro Pictures Corporation offers Vicente Blasco Ibáñez' "The four horsemen of the Apocalypse" [Texto impreso]

Tít. tomado de la cub.

Three Dichotomies in Lawyers’ Ethics (With Particular Attention to the Corporation as Client)

Three usually unexpressed, and too often unnoticed, conceptual dichotomies underlie our perception and understanding of lawyers’ ethics. First, the existence of a special body of professional ethics and professional regulation presupposes some special need or risk. Criminal and civil law are apparently insufficient. Ordinary day-to-day morality and ordinary ethics, likewise, are not considered to be enough. What is the risk entailed by the notion of a profession that is special; who needs protection, and from what? Two quite different possible answers to this question provide the first of the three dichotomies examined in this article: one can understand the risk as primarily to a vulnerable client from a powerful professional; or, to the contrary, from a powerful client-lawyer combination toward vulnerable others. Second, what is the foundational orientation of lawyers? Are lawyers serving primarily their particular clients, and those clients’ preferences, choices and autonomy? Or is the primary allegiance of lawyers to some community or collective goal or interest distinct from the particular goals or interests of the client? The third dichotomy concerns not the substance of the risk, or the primary orientation, but the appropriate means of responding to that risk or that fundamental obligation. Should professional ethics be implemented primarily through rules? Or, should we rely on character and the discretion of lawyers to make a thought out, all things considered, decision? Each of these three presents a fundamental difference in how we perceive and address issues of lawyers’ ethics. Each affects our understanding and analysis on multiple levels, from (1) determining the appropriate or requisite conduct in a particular situation, to (2) framing a specific rule or approach for a particular category of situations, to (3) more general or abstract theory or policy. A person’s inclinations in regard to the dichotomies affects the conclusions that person will reach on each of those levels of analysis, yet those inclinations and assumptions are frequently unexamined and unarticulated. One’s position on each of the dichotomies tends to structure the approach and outcome without the issues and choice having been explicitly addressed or possibly even noticed. This article is an effort to ameliorate that problem. Part I addresses the question of what is the risk in the work of lawyers, or the function of lawyers, for which professional ethics is the answer. The concluding section focuses on the particular problem of the corporation as client. Part II then asks the related and possibly consequent question of what is the foundational orientation or allegiance of the lawyer? Is it to the individual client? Or is it to some larger community interest? Again, the concluding section focuses on the corporation. Part III turns to the means or method for addressing the obligations and possible problems of the professional ethics of lawyers. Should lawyers’ ethics guide and confine the conduct of lawyers primarily through rules? Or should it function primarily through reliance on the knowledge, judgment and character of lawyers? If the latter were the guide, ethical decisions would be made on a situation by situation basis under the discretion of each lawyer. Toward the end of each discussion possibilities for bridging the dichotomy are considered (and with such bridges each dichotomy may come to look more like a spectrum or continuum.). At several points after its introduction in Parts I and II, the special problem of the corporation as client is revisited and possible solutions suggested. Illustrating the usefulness of keeping the dichotomies in view, Part IV applies them to several exemplary situations of ethical difficulty in actual lawyer practice. For readers finding it difficult to envision the consequences of these distinctions, turning ahead to Part IV may be useful in making the discussion more concrete. Some commonalities across the dichotomies and connections among them are then developed in the concluding section, Part V.

Three Dichotomies in Lawyers’ Ethics (With Particular Attention to the Corporation as Client)

Three usually unexpressed, and too often unnoticed, conceptual dichotomies underlie our perception and understanding of lawyers’ ethics. First, the existence of a special body of professional ethics and professional regulation presupposes some special need or risk. Criminal and civil law are apparently insufficient. Ordinary day-to-day morality and ordinary ethics, likewise, are not considered to be enough. What is the risk entailed by the notion of a profession that is special; who needs protection, and from what? Two quite different possible answers to this question provide the first of the three dichotomies examined in this article: one can understand the risk as primarily to a vulnerable client from a powerful professional; or, to the contrary, from a powerful client-lawyer combination toward vulnerable others. Second, what is the foundational orientation of lawyers? Are lawyers serving primarily their particular clients, and those clients’ preferences, choices and autonomy? Or is the primary allegiance of lawyers to some community or collective goal or interest distinct from the particular goals or interests of the client? The third dichotomy concerns not the substance of therisk, or the primary orientation, but the appropriate means of responding to that risk or that fundamental obligation. Should professional ethics be implemented primarily through rules? Or, should we rely on character and the discretion of lawyers to make a thought out, all things considered, decision? Each of these three presents a fundamental difference in how we perceive and address issues of lawyers’ ethics. Each affects our understanding and analysis on multiple levels, from (1) determining the appropriate or requisite conduct in aparticular situation, to (2) framing a specific rule or approach for a particular category of situations, to (3) more general or abstract theory or policy. A person’s inclinations in regard to the dichotomies affects the conclusions that person will reach on each of those levels of analysis, yet those inclinations and assumptions are frequently unexamined and unarticulated. One’s position on each of the dichotomies tends to structure the approach and outcome without the issues and choice having been explicitly addressed or possibly even noticed. This article is an effort to ameliorate that problem. Part I addresses the question of what is the risk in the work of lawyers, or the function of lawyers, for which professional ethics is the answer. The concluding section focuses on the particular problem of the corporation as client. Part II then asks the related and possibly consequent question of what is the foundational orientation or allegiance of the lawyer? Is it to the individual client? Or is it to some larger community interest? Again, the concluding section focuses on thecorporation. Part III turns to the means or method for addressing the obligations and possible problems of the professional ethics of lawyers. Should lawyers’ ethics guide and confine the conduct of lawyers primarily through rules? Or should it function primarily through reliance on the knowledge, judgment and character of lawyers? If the latter were the guide, ethical decisions would be made on a situation by situation basis under the discretion of each lawyer. Toward the end of each discussion possibilities for bridging the dichotomy are considered (and with such bridges each dichotomy may come to look more like a spectrum or continuum.). At several points after its introduction in Parts I and II, the special problem of the corporation as client is revisited and possible solutions suggested. Illustrating the usefulness of keeping the dichotomies in view, Part IV applies them to several exemplary situations of ethical difficulty in actual lawyer practice. For readers finding it difficult to envision the consequences of these distinctions, turning ahead to Part IV may be useful in making the discussion more concrete. Some commonalities across the dichotomies and connections among them are then developed in the concluding section, Part V.