Arm’s length pricing and multinational banks : an old fashioned approach in a modern world

In “Arm’s Length Pricing and Multinational Banks: An Old Fashioned Approach in a Modern World”, Kerrie Sadiq, describes the high level of integration of multinational financial institutions and argues that treating each element within a given operation as a separate entity for transfer pricing purposes is not economically or legally realistic. She proposes instead formulary apportionment as a device for managing this complexity.

Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

Optimising the length of Random Breath Tests : results from the Queensland Community Engagement Trial

Research suggests that the length and quality of police-citizen encounters affect policing outcomes. The Koper Curve, for example, shows that the optimal length for police presence in hot spots is between 14 and 15 minutes, with diminishing returns observed thereafter. Our study, using data from the Queensland Community Engagement Trial (QCET), examines the impact of encounter length on citizen perceptions of police performance. QCET involved a randomised field trial, where 60 random breath test (RBT) traffic stop operations were randomly allocated to an experimental condition involving a procedurally just encounter or a business-as-usual control condition. Our results show that the optimal length of time for procedurally just encounters during RBT traffic stops is just less than 2 minutes. We show, therefore, that it is important to encourage and facilitate positive police–citizen encounters during RBTat traffic stops, while ensuring that the length of these interactions does not pass a point of diminishing returns.

Using a video camera to measure the radius of the Earth

A simple but accurate method for measuring the Earth’s radius using a video camera is described. A video camera was used to capture a shadow rising up the wall of a tall building at sunset. A free program called ImageJ was used to measure the time it took the shadow to rise a known distance up the building. The time, distance and length of the sidereal day were used to calculate the radius of the Earth. The radius was measured as 6394.3 +/- 118 km, which is within 1.8% of the accepted average value of 6371 km and well within the experimental error. The experiment is suitable as a high school or university project and should produce a value for Earth’s radius within a few per cent at latitudes towards the equator, where at some times of the year the ecliptic is approximately normal to the horizon.

A novel, automated nutrition screening system as a predictor of nutritional risk in an oncology day treatment unit (ODTU)

Purpose Paper-based nutrition screening tools can be challenging to implement in the ambulatory oncology setting. The aim of this study was to determine the validity of the Malnutrition Screening Tool (MST) and a novel, automated nutrition screening system compared to a ‘gold standard’ full nutrition assessment using the Patient-Generated Subjective Global Assessment (PG-SGA). Methods An observational, cross-sectional study was conducted in an outpatient oncology day treatment unit (ODTU) within an Australian tertiary health service. Eligibility criteria were as follows: ≥18 years, receiving outpatient anticancer treatment and English literate. Patients self-administered the MST. A dietitian assessed nutritional status using the PGSGA, blinded to the MST score. Automated screening system data were extracted from an electronic oncology prescribing system. This system used weight loss over 3 to 6 weeks prior to the most recent weight record or age-categorised body mass index (BMI) to identify nutritional risk. Sensitivity and specificity against PG-SGA (malnutrition) were calculated using contingency tables and receiver operating curves. Results There were a total of 300 oncology outpatients (51.7 % male, 58.6±13.3 years). The area under the curve (AUC) for weight loss alone was 0.69 with a cut-off value of ≥1 % weight loss yielding 63 % sensitivity and 76.7 % specificity. MST (score ≥2) resulted in 70.6 % sensitivity and 69.5 % specificity, AUC 0.77. Conclusions Both the MST and the automated method fell short of the accepted professional standard for sensitivity (~≥80 %) derived from the PG-SGA. Further investigation into other automated nutrition screening options and the most appropriate parameters available electronically is warranted to support targeted service provision.

Estimating hidden message length in binary image embedded by using boundary pixels steganography

In this paper, we propose a new steganalytic method to detect the message hidden in a black and white image using the steganographic technique developed by Liang, Wang and Zhang. Our detection method estimates the length of hidden message embedded in a binary image. Although the hidden message embedded is visually imperceptible, it changes some image statistic (such as inter-pixels correlation). Based on this observation, we first derive the 512 patterns histogram from the boundary pixels as the distinguishing statistic, then we compute the histogram difference to determine the changes of the 512 patterns histogram induced by the embedding operation. Finally we propose histogram quotient to estimate the length of the embedded message. Experimental results confirm that the proposed method can effectively and reliably detect the length of the embedded message.

Estimating present day extreme water level exceedance probabilities around the coastline of Australia : tides, extra-tropical storm surges and mean sea level

The occurrence of extreme water levels along low-lying, highly populated and/or developed coastlines can lead to considerable loss of life and billions of dollars of damage to coastal infrastructure. Therefore it is vitally important that the exceedance probabilities of extreme water levels are accurately evaluated to inform risk-based flood management, engineering and future land-use planning. This ensures the risk of catastrophic structural failures due to under-design or expensive wastes due to over-design are minimised. This paper estimates for the first time present day extreme water level exceedence probabilities around the whole coastline of Australia. A high-resolution depth averaged hydrodynamic model has been configured for the Australian continental shelf region and has been forced with tidal levels from a global tidal model and meteorological fields from a global reanalysis to generate a 61-year hindcast of water levels. Output from this model has been successfully validated against measurements from 30 tide gauge sites. At each numeric coastal grid point, extreme value distributions have been fitted to the derived time series of annual maxima and the several largest water levels each year to estimate exceedence probabilities. This provides a reliable estimate of water level probabilities around southern Australia; a region mainly impacted by extra-tropical cyclones. However, as the meteorological forcing used only weakly includes the effects of tropical cyclones, extreme water level probabilities are underestimated around the western, northern and north-eastern Australian coastline. In a companion paper we build on the work presented here and more accurately include tropical cyclone-induced surges in the estimation of extreme water level. The multi-decadal hindcast generated here has been used primarily to estimate extreme water level exceedance probabilities but could be used more widely in the future for a variety of other research and practical applications.

Estimating present day extreme water level exceedance probabilities around the coastline of Australia : tropical cyclone-induced storm surges

The incidence of major storm surges in the last decade have dramatically emphasized the immense destructive capabilities of extreme water level events, particularly when driven by severe tropical cyclones. Given this risk, it is vitally important that the exceedance probabilities of extreme water levels are accurately evaluated to inform risk-based flood and erosion management, engineering and for future land-use planning and to ensure the risk of catastrophic structural failures due to under-design or expensive wastes due to over-design are minimised. Australia has a long history of coastal flooding from tropical cyclones. Using a novel integration of two modeling techniques, this paper provides the first estimates of present day extreme water level exceedance probabilities around the whole coastline of Australia, and the first estimates that combine the influence of astronomical tides, storm surges generated by both extra-tropical and tropical cyclones, and seasonal and inter-annual variations in mean sea level. Initially, an analysis of tide gauge records has been used to assess the characteristics of tropical cyclone-induced surges around Australia. However, given the dearth (temporal and spatial) of information around much of the coastline, and therefore the inability of these gauge records to adequately describe the regional climatology, an observationally based stochastic tropical cyclone model has been developed to synthetically extend the tropical cyclone record to 10,000 years. Wind and pressure fields derived for these synthetically generated events have then been used to drive a hydrodynamic model of the Australian continental shelf region with annual maximum water levels extracted to estimate exceedance probabilities around the coastline. To validate this methodology, selected historic storm surge events have been simulated and resultant storm surges compared with gauge records. Tropical cyclone induced exceedance probabilities have been combined with estimates derived from a 61-year water level hindcast described in a companion paper to give a single estimate of present day extreme water level probabilities around the whole coastline of Australia. Results of this work are freely available to coastal engineers, managers and researchers via a web-based tool (www.sealevelrise.info). The described methodology could be applied to other regions of the world, like the US east coast, that are subject to both extra-tropical and tropical cyclones.

A 5- versus 3-day course of oral corticosteroids for children with asthma exacerbations who are not hospitalised : a randomised controlled trial

Objective To determine whether a 5-day course of oral prednisolone is superior to a 3-day course in reducing the 2-week morbidity of children with asthma exacerbations who are not hospitalised. Design, setting and participants Double-blind randomised controlled trial of asthma outcomes following a 5-day course of oral prednisolone (1 mg/kg) compared with a 3-day course of prednisolone plus placebo for 2 days. Participants were children aged 2–15 years who presented to the emergency departments of three Queensland hospitals between March 2004 and February 2007 with an acute exacerbation of asthma, but were not hospitalised. Sample size was defined a priori for a study power of 90%. Main outcome measures Difference in proportion of children who were symptom-free at Day 7, as measured by intention-to-treat (ITT) and per-protocol analysis; quality of life (QOL) on Days 7 and 14. Results 201 children were enrolled, and there was an 82% completion rate. There was no difference between groups in the proportion of children who were symptom-free (observed difference, 0.04 [95% CI, − 0.09 to 0.18] by ITT analysis; 0.04 [95% CI, − 0.17 to 0.09] by per-protocol analysis). There was also no difference between groups in QOL (P = 0.42). The difference between groups for the primary outcome was within the equivalence range calculated post priori. Conclusion A 5-day course of oral prednisolone confers no advantage over a 3-day course for children with asthma exacerbations who are not hospitalised.

Physical activity levels among children attending family day care

Objective To objectively measure the physical activity (PA) levels of children attending family day care programs. Methods A total of 114 children from 47 family day care centers wore an accelerometer for the duration of their time in care. Time in moderate-to-vigorous PA (MVPA) and total PA was calculated using previously validated cut points. Results Children accumulated 5.8 ± 3.2 minutes of MVPA and 10.4 ± 4.4 minutes of total PA per hour of attendance. Boys exhibited significantly higher levels of PA than girls. Among healthy weight children, 4- and 5-year-olds exhibited significantly higher levels of PA than 2- and 3-year-olds. Overweight and obese 4- and 5-year-olds exhibited significantly lower levels of PA than their healthy weight counterparts. Conclusions and Implications Children attending family day care participate in low levels of PA during the child care day. The results highlight the need for effective programs to promote PA in family day care.

The Medics - "Foundations"

The Medics “Foundations” is a full-length album of popular music completed over a 13-month period and released in 2012, with work taking place in Byron Bay’s 301 studios and Brisbane’s Airlock studios. “Foundations” contributes to studies in the field of music production, as well as furthering research into the place of Indigenous youth culture within contemporary rock music. The music draws on elements of folk, post rock and hardcore to create a dynamic and cinematic sound, framed by lyrics that focus on spirituality, nature and a connection to the land. Artists such as At the Drive In and Mars Volta were referenced in the production of the record. Scholars such as Joe Bennett have argued that the relationship between songwriting practice and song product is an under-explored area in popular musicology, and, by using a practice-led research methodology, the production of “Foundations” extends these creative inquiries. “Foundations” was produced with the assistance of a competitive grant, the Cultural Minister’s Council Breakthrough initiative, which assists emerging Indigenous contemporary musicians. The album was well received and positively reviewed, resulting in the band signing a record deal with Warner Music and a publishing deal with Albert’s Music. It was album of the week on Triple J and several singles were placed on high rotation. A review on Themusic.com.au highlighted the production work: “Producer Yanto Browning has captured the impassioned live intent the band have built their reputation on and bottled it into 11 impeccable tracks, the album maintaining their onstage vigour while polishing it just enough to allow it to burn brightly through the speakers.” As a result of the record, The Medics were invited to play Splendour in the Grass, the national Big Day Out tour and a series of shows in South America.

Validation of a 3-day physical activity recall instrument in female youth

The purpose of this study was to examine the validity of the 3-Day Physical Activity Recall (3DPAR) self-report instrument in a sample of eighth and ninth grade girls (n = 70, 54.3% white, 37.1% African American). Criterion measures of physical activity were derived using the CSA 7164 accelerometer. Participants wore a CSA monitor for 7 consecutive days and completed the self-report physical activity recall for the last 3 of those days. Self-reported total METs, 30-min blocks of MVPA, and 30-min blocks of VPA were all significantly correlated with analogous CSA variables for 7 days (r = 0.35-0.51; P < 0.01) and 3 days (r = 0.27-0.46; P < 0.05) of monitoring. The results indicate that the 3DPAR is a valid instrument for assessing overall, vigorous, and moderate to vigorous physical activity in adolescent girls.

Validity of the previous day physical activity recall (PDPAR) in fifth-grade children

This study evaluated the validity of the Previous Day Physical Activity Recall (PDPAR) self-report instrument in quantifying after-school physical activity behavior in fifth-grade children. Thirty-eight fifth-grade students (mean age, 10.8 +/- 0.1; 52.6% female; 26.3% African American) from two urban elementary schools completed the PDPAR after wearing a CSA WAM 7164 accelerometer for a day. The mean within-subject correlation between self-reported MET level and total counts for each 30-min block was 0.57 (95% C.I., 0.51-0.62). Self-reported mean MET level during the after-school period and the number of 30-min blocks with activity rated at greater than or equal to 6 METs were significantly correlated with the CSA outcome variables. Validity coefficients for these variables ranged from 0.35 to 0.43 (p <.05). Correlations between the number of 30-min blocks with activity rated at greater than or equal to 3 METs and the CSA variables were positive but failed to reach statistical significance (r = 0.19-0.23). The PDPAR provides moderately valid estimates of relative participation in vigorous activity and mean MET level in fifth-grade children. Caution should be exercised when using the PDPAR to quantify moderate physical activity in preadolescent children.

Validity and reliability of the 3-day physical activity recall in Singaporean adolescents

Childhood obesity and physical inactivity are major health concerns for the Singaporean government (Ministry of Health, Singapore [MOH], 2001). Data from the 1998 Singaporean National Health Survey indicate that 10.8–14.7% of Singaporean children ages 6–16 years are either overweight or obese (MOH, 2001). Although true population estimates of youth physical activity are not available, descriptive epidemiological studies conducted in the 1990s suggest that a large percentage of school-aged children in Singapore fail to meet established guidelines for participation in physical activity...