Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)

As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

Creating and evaluating IT-related business value in developing markets : part 1

There is no doubt that information technology (IT) resources are important for organisations in any jurisdiction to manage their processes. Organisations consume considerable financial resources to acquire and manage their IT resources with various IT governance structures. Investment in IT, thus, is a strategic necessity. IT resources, however, do not contribute fully to business value on their own. Business value considers performance impacts of resources at various organisational levels (e.g., processes and firm levels). ITs are biased resources in that they require some form of manipulation to attain their maximum value. While we know that IT resources are important, a deeper understanding on two aspects of use of IT resources in organisations is important. First, is how to leverage the IT resources to attain its maximum value, and second, is where to evaluate IT-related business value in the organisation’s value chain. This understanding is important for organisation to sustain their operations in an ever-changing business environment. We address these issues in two parts. This paper discusses the first aspect of ways in which organisations can create and sustain their IT-related business value.

Creating and evaluating IT-related business value in developing markets - Part 2

A deeper understanding on two aspects of use of IT resources in organisations is important to ensure sustainable investment in these IT resources. The first is how to leverage the IT resources to attain its maximum value. We discussed this aspect of use of IT resources in part 1 of this series. This discussion suggested a complementary approach as a first stage of IT business value creation, and dynamic capabilities approach to secure sustainable IT-related business value from the IT resources. The second important aspect of IT business value is where to evaluate IT-related business value in the organisations value chains. This understanding is important for organisations to ensure appropriate accountability of the investment and management of IT resources. We address this issue in this second part of the two part series.

Review : "A criminological imagination : essays on justice, punishment and discourse by Part Carlen"

There are four contributors to this review symposium. David Brown's review focuses on the questions of abolitionism that cut across much of Carlen's scholarship on punishment and prisons. Kerry Carrington's review attempts to articulate Pat Carlen's contributions to feminism, critque and crimnology, a selection of which is republished in the third scetion 'A criminological imgination'. Kelly Hannah-Moffat's review provides a succint but broad ranging analysis of Carlen's contributions to knowledge, politics and penal reform. Jo Phoenix takes Carlen's contributions to women, crim and scoial control as her main source of inspiration from this large body of work to review.

Mapping the dynamics of the project management field : project management in action (part 6)

This is the sixth part of a Letter from the Editor series where the results are presented of an ongoing research undertaken in order to investigate the dynamic of the evolution of the field of project management and the key trends. Dynamics of networks is a key feature in strategic diagrams analysis. The radical change in the configuration of a network between two periods, or the change at subnetwork level reflects the dynamic of science. I present here an example of subnetwork comparison over the four periods of time considered in this study. I will develop and discuss an example of subnetwork transformation in future Letter from the Editor article..

Mapping the dynamics of the project management field : project management in action (part 5)

This is the fifth part of a Letter From the Editor series where the results are presented of an ongoing research undertaken in order to investigate the dynamic of the evolution of the field of project management and the key trends. I present some general findings and the strategic diagrams generated for each of the time periods introduced herein and discuss what we can learn from them on a general standpoint. I will develop and discuss some detailed findings in future Letter From the Editor articles...

Performance of elite seated discus throwers in F30s classes : part II: does feet positioning matter?

Background: Studies on the relationship between performance and design of the throwing frame have been limited. Part I provided only a description of the whole body positioning. Objectives: The specific objectives were (a) to benchmark feet positioning characteristics (i.e. position, spacing and orientation) and (b) to investigate the relationship between performance and these characteristics for male seated discus throwers in F30s classes. Study Design: Descriptive analysis. Methods: A total of 48 attempts performed by 12 stationary discus throwers in F33 and F34 classes during seated discus throwing event of 2002 International Paralympic Committee Athletics World Championships were analysed in this study. Feet positioning was characterised by tridimensional data of the front and back feet position as well as spacing and orientation corresponding to the distance between and the angle made by both feet, respectively. Results: Only 4 of 30 feet positioning characteristics presented a coefficient correlation superior to 0.5, including the feet spacing on mediolateral and anteroposterior axes in F34 class as well as the back foot position and feet spacing on mediolateral axis in F33 class. Conclusions: This study provided key information for a better understanding of the interaction between throwing technique of elite seated throwers and their throwing frame.

The emerging framework of cross-border insolvency in and around Australia : Saad Investments, Japan Airlines and Lehman Brothers – part one

Recent decades have witnessed a global acceleration of legislative and private sector initiatives to deal with Cross-Border insolvency. Legislative institutions include the various national implementations of the Model Law on Cross-Border Insolvency (Model Law) published by the United Nations Commission on International Trade (UNCITRAL).3 Private mechanisms include Cross-Border protocols developed and utilised by insolvency professionals and their advisers (often with the imprimatur of the judiciary), on both general and ad hoc bases. The Asia Pacific region has not escaped the effect of those developments, and the economic turmoil of the past few years has provided an early test for some of the emerging initiatives in that region. This two-part article explores the operation of those institutions through the medium of three recent cases.

The emerging framework of cross-border insolvency in and around Australia : Saad Investments, Japan Airlines and Lehman Brothers – Part Two

Recent decades have witnessed a global acceleration of legislative and private sector initiatives to deal with Cross-Border insolvency. Legislative institutions include the various national implementations of the Model Law on Cross-Border Insolvency (Model Law) published by the United Nations Commission on International Trade (UNCITRAL).3 Private mechanisms include Cross-Border protocols developed and utilised by insolvency professionals and their advisers (often with the imprimatur of the judiciary), on both general and ad hoc bases. The Asia Pacific region has not escaped the effect of those developments, and the economic turmoil of the past few years has provided an early test for some of the emerging initiatives in that region. This two-part article explores the operation of those institutions through the medium of three recent cases.

Silver Gelatin Print: A group exhibition curated by Karen Milder that investigates and captures the traditional processes using photograms, liquid emulsion, toning, hand-colouring and film. Part of the Queensland Festival of Photography 4 (QFP4).

Pillar of salt: (3 hand-applied silver gelatin photographs) Statement: For women moving into new experiences and spaces, loss and hardship is often a price to be paid. These courageous women look back to things they have overcome in order to continue to grow.

Ventilation distribution in rats : Part I - The effect of gas composition as measured with electrical impedance tomography

The measurement of ventilation distribution is currently performed using inhaled tracer gases for multiple breath inhalation studies or imaging techniques to quantify spatial gas distribution. Most tracer gases used for these studies have properties different from that of air. The effect of gas density on regional ventilation distribution has not been studied. This study aimed to measure the effect of gas density on regional ventilation distribution. Methods Ventilation distribution was measured in seven rats using electrical impedance tomography (EIT) in supine, prone, left and right lateral positions while being mechanically ventilated with either air, heliox (30% oxygen, 70% helium) or sulfur hexafluoride (20% SF6, 20% oxygen, 60% air). The effect of gas density on regional ventilation distribution was assessed. Results Gas density did not impact on regional ventilation distribution. The non-dependent lung was better ventilated in all four body positions. Gas density had no further impact on regional filling characteristics. The filling characteristics followed an anatomical pattern with the anterior and left lung showing a greater impedance change during the initial phase of the inspiration. Conclusion It was shown that gas density did not impact on convection dependent ventilation distribution in rats measured with EIT.

Ventilation distribution in rats : part 2 – a comparison of electrical impedance tomography and hyperpolarised helium magnetic resonance imaging

Background: Hyperpolarised helium MRI (He3 MRI) is a new technique that enables imaging of the air distribution within the lungs. This allows accurate determination of the ventilation distribution in vivo. The technique has the disadvantages of requiring an expensive helium isotope, complex apparatus and moving the patient to a compatible MRI scanner. Electrical impedance tomography (EIT) a non-invasive bedside technique that allows constant monitoring of lung impedance, which is dependent on changes in air space capacity in the lung. We have used He3MRI measurements of ventilation distribution as the gold standard for assessment of EIT. Methods: Seven rats were ventilated in supine, prone, left and right lateral position with 70% helium/30% oxygen for EIT measurements and pure helium for He3 MRI. The same ventilator and settings were used for both measurements. Image dimensions, geometric centre and global in homogeneity index were calculated. Results: EIT images were smaller and of lower resolution and contained less anatomical detail than those from He3 MRI. However, both methods could measure positional induced changes in lung ventilation, as assessed by the geometric centre. The global in homogeneity index were comparable between the techniques. Conclusion: EIT is a suitable technique for monitoring ventilation distribution and inhomgeneity as assessed by comparison with He3 MRI.

A comparative study on the mineralogy, chemistry and chronology of the Apollo 16 crystalline impact melt breccias. Part II: Chronology.

The controversy on how to interpret the ages of lunar highland breccias has recently been discussed by James [1]. Are the measured ages testimony of true events in lunar history; do they represent the age of the ancient crustal rocks, mixed ages of unequilibrated matrix-phenocryst relationships, or merely thermal events subsequent to the formational event ? It is certain from analyses of terrestrial impact melt breccias that the melt matrix of whole impact melt sheets is isotopically equilibrated due to the extensive mixing process of the early cratering stage [2,3]. It has been shown that isotopic equilibration takes place between impact melt matrix and target rock clasts therein, with the intensity of isotopic exchange depending on the degree of shock metamorphism, thermal metamorphism and the size of the clasts [4]. Therefore, impact melt breccias - if they are relatively clast-poor and mineralogically well studied - can be considered to be the most reliable source for information on the impact history of the lunar highland.