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.

The identity of the empire : the Italian colonial experience in the design of places

The Italian Colonial Experience in the design of the built environment is analysed as a case study of State image promotion.

An Italian legal case note

The present paper intends to enlighten a particular aspect of charitable organizations which is their registration in the regional lists for voluntary organizations. The aforementioned decision ruled that these organizations are entitled to adopt the form of cooperative society and consequently, when all the other legal requirements are complete, charitable organizations are to be enrolled. The registration has been subject to many criticisms and it is necessary to bring some light on a topic that hides behind it many legal and cultural repercussions concerning the role and the activities of nonprofit organizations in the Italian context.

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.

A comparison of submicrometer particle dose between Australian and Italian people

Alveolar and tracheobronchial-deposited submicrometer particle number and surface area data received by different age groups in Australia are shown. Activity patterns were combined with microenvironmental data through a Monte-Carlo method. Particle number distributions for the most significant microenvironments were obtained from our measurement survey data and people activity pattern data from the Australian Human Activity Pattern Survey were used. Daily alveolar particle number (surface area) dose received by all age groups was equal to 3.0×1010 particles (4.5×102 mm2), varying slightly between males and females. In contrast to gender, the lifestyle was found to significantly affect the daily dose, with highest depositions characterizing adults. The main contribution was due to indoor microenvironments. Finally a comparison between Italian and Australian people in terms of received particle dose was reported; it shows that different cooking styles can affect dose levels: higher doses were received by Italians, mainly due to their particular cooking activity.

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.

Participatory photography and self-empowerment in different nations

Volunteering Qld’s Project Creatives continues to explore the critical role creative disciplines and creative people play in providing new models of engagement and action in social change and community work. This article explores three different non-profit organisations that have used collaborative photography to enable locals to empower themselves. Written by Alice Baroni a volunteer with the Education, Research and Policy Unit of Volunteering Qld. Alice is undertaking a PhD at the Queensland University of Technology, exploring (photo) journalism, participatory content creation and community photography in Brazil’s low income suburbs. She is part of the ARC Centre of Excellence for Creative Industries and Innovation, and a Brazilian research group ‘Storytellers and Narratives: Contemporary Journalism’. Two of the initiatives explored in this publication are Viva Favela and Imagens do Povo that are ideologically and physically supported by, respectively, Viva Rio and Observatório de Favelas, based in Rio de Janeiro, Brazil. ‘Favela’ is often translated simply as ‘slum’ or ‘shantytown’, but these terms connote negative characteristics such as shortage, poverty, and deprivation, which end up stigmatising these low-income suburbs. Fotografi Senza Frontiere (FSF) (Photographers Without Borders) is an Italian non-governmental organisation that gathers together a group of photographers who aim to provide youth from extreme regions in Nicaragua, Algeria, Argentina, Panama, Uganda, and Palestine with skills to photograph and document their own reality by establishing permanent photo laboratories. This idea, which is similar to that of Viva Favela and Imagens do Povo, is to enable youth to become professional photographers as a means of self-representation and self-empowerment. Afterwards, students become educators in established photographic labs so as to pass on what they have learnt through FSF’s photographic courses.

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.