The taxation of multinational banks : alternative apportionment through a unitary taxation regime aligning with economic reality

The taxation of multinational banks currently is governed by the general principles of international tax. However, it is arguable that there are characteristics exclusive to multinational banks that may warrant the consideration of a separate taxing regime. This article argues that because of the unique nature of multinational banks, the traditional international tax rules governing jurisdiction to tax and allocation of income do not produce a result which is optimal, as it does not reflect economic reality. That is, the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment. Formulary apportionment is considered as an alternative that reflects economic reality by recognising the unique nature of multinational banks and allocating the income to the location of the economic activity. The unique nature of multinational banking is recognised in the fact that formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Starting from this recognition, the purpose of this article is to demonstrate that formulary apportionment is a theoretically superior (or optimal) model for the taxation of multinational banks. An optimal regime, for the purposes of this article, is considered to be one that distributes the taxing rights in an equitable manner between the relevant jurisdictions, while, simultaneously allowing decisions of the international banks to be tax neutral. In this sense, neutrality is viewed as an economic concept and equity is regarded as a legal concept. A neutral tax system is one in which tax rules do not affect economic choices about commercial activities. Neutrality will ideally be across jurisdictions as well as across traditional and non-traditional industries. The primary focus of this article is jurisdictional neutrality. A system that distributes taxing rights in an equitable manner between the relevant jurisdictions ensures that each country receives its fair share of tax revenue. Given the increase in multinational banking, jurisdictions should be concerned that they are receiving their fair share. Inter-nation equity is concerned with re-determining the proper division of the tax base among countries. Richard and Peggy Musgrave argue that sharing of the tax base by countries of source should be seen as a matter of inter-nation equity requiring international cooperation. The rights of the jurisdiction of residency will also be at issue. To this extent, while it is agreed that inter-nation equity is an essential attribute to an international tax regime, there is no universal agreement as to how to achieve it. The current system attempts to achieve such equity through a combined residency and source regime, with the transfer pricing rules used to apportion income between the relevant jurisdictions. However, this article suggests, that as an alternative to the current regime, equity would be achieved through formulary apportionment. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. Yet these are two separate issues. As such, this article is divided into two core parts. The first part examines the theoretical soundness of the formulary apportionment model concluding that it is theoretically superior to the arm’s length pricing requirement of the traditional transfer pricing regime. The second part examines the practical implications of accepting formulary apportionment as an optimal model with a view to disclosing the issues that arise when a formulary apportionment regime is adopted. Prior to an analysis of the theoretical and practical application of formulary apportionment to multinational banks, the unique nature of these banks is considered. The article concludes that, while there are significant implementation, compliance, and enforcement issues to overcome, the unitary taxation model may be theoretically superior to the current arm’s length model which applies to multinational banks. This conclusion is based on the unitary taxation model providing greater alignment with the unique features of these banks.

Geoproof : proofs of geographic location for cloud computing environment

Cloud computing has emerged as a major ICT trend and has been acknowledged as a key theme of industry by prominent ICT organisations. However, one of the major challenges that face the cloud computing concept and its global acceptance is how to secure and protect the data that is the property of the user. The geographic location of cloud data storage centres is an important issue for many organisations and individuals due to the regulations and laws that require data and operations to reside in specific geographic locations. Thus, data owners may need to ensure that their cloud providers do not compromise the SLA contract and move their data into another geographic location. This paper introduces an architecture for a new approach for geographic location assurance, which combines the proof of storage protocol (POS) and the distance-bounding protocol. This allows the client to check where their stored data is located, without relying on the word of the cloud provider. This architecture aims to achieve better security and more flexible geographic assurance within the environment of cloud computing.

Quality of work life among primary health care nurses in the Jazan region, Saudi Arabia : a crosssectional study

Background: Quality of work life (QWL) is defined as the extent to which employee is satisfied with personal and working needs through participating in the workplace while achieving the organisation’s goals. QWL has been found to influence the commitment and productivity of employees in healthcare organisations, as well as in other industries. However, reliable information on the QWL of PHC nurses is limited. The purpose of this study was to assess the QWL among PHC nurses in the Jazan region, Saudi Arabia. Methods: A descriptive research design, namely, a cross-sectional survey was used in this study. Data were collected using Brooks’ survey of quality of nursing work life (QNWL) and demographic questions. A convenience sample was recruited from 143 PHC centres in Jazan, Saudi Arabia. The Jazan region is located in the southern part of Saudi Arabia. A response rate of 91% (N = 532/585) was achieved (effective RR = 87%, n = 508). Data analysis consisted of descriptive statistics, t-test and one way-analysis of variance. Total scores and sub-scores for QWL Items and item summary statistics were computed and reported, using SPSS version 17 for Windows. Results: Findings suggested that the respondents were dissatisfied with their work life. The major influencing factors were unsuitable working hours/shifts, lack of facilities for nurses, inability to balance work with family needs, inadequacy of family-leave time, poor staffing, management and supervision practices, lack of professional development opportunities, and inappropriate working environment in terms of the level of security, patient care supplies and equipment, and recreation facilities (Break-area). Other essential factors include the community’s view of nursing and inadequate salary. More positively, the majority of nurses were satisfied with their co-workers, satisfied to be nurses and had a sense of belonging in their workplaces. Significant differences were found according to gender, age, marital status, dependent children, dependent adults, nationality, ethnicity, nursing tenure, organisational tenure, positional tenure, and payment per month. No significant differences were found according to education level and location of PHC. Conclusions: These findings can be used by PHC managers and policy makers for developing and appropriately implementing successful plans to improve the QWL. This will help to enhance the home and work environments, improve individual and organisation performance and increase nurses’ commitment.

Thermodynamic modeling of ethanol fumigation in a diesel engine

Due to rapidly diminishing international supplies of fossil fuels, such as petroleum and diesel, the cost of fuel is constantly increasing, leading to higher costs of living, as a result of the significant reliance of many industries on motor vehicles. Many technologies have been developed to replace part or all of a fossil fuel with bio-fuels. One of the dual fuel technologies is fumigation of ethanol in diesel engines, which injects ethanol into the intake air stream of the engine. The advantage of this is that it avoids any costly modification of the engine high pressure diesel injection system, while reducing the volume of diesel required and potentially increasing the power output and efficiency. This paper investigates the performance of a diesel engine, converted to implement ethanol fumigation. The project will use both existing experimental data, along with generating computer modeled results using the program AVL Boost. The data from both experiments and the numerical simulation indicate desirable results for the peak pressure and the indicated mean effective pressure (IMEP). Increase in ethanol substitution resulted in elevated combustion pressure and an increase in the IMEP, while the variation of ethanol injection location resulted in negligible change. These increases in cylinder pressure led to a higher work output and total efficiency in the engine as the ethanol substitution was increased. In comparing the numerical and experimental results, the simulation showed a slight elevation, due to the inaccuracies in the heat release models. Future work is required to improve the combustion model and investigate the effect of the variation of the location of ethanol injection.

Does calcium deposition play a role in the stability of atheroma? Location may be the key

Background: Rupture of vulnerable atheromatous plaque in the carotid and coronary arteries often leads to stroke and heart attack respectively. The role of calcium deposition and its contribution to plaque stability is controversial. This study uses both an idealized and a patient-specific model to evaluate the effect of a calcium deposit on the stress distribution within an atheromatous plaque. Methods: Using a finite-element method, structural analysis was performed on an idealized plaque model and the location of a calcium deposit within it was varied. In addition to the idealized model, in vivo high-resolution MR imaging was performed on 3 patients with carotid atheroma and stress distributions were generated. The individual plaques were chosen as they had calcium at varying locations with respect to the lumen and the fibrous cap. Results: The predicted maximum stress was increased by 47.5% when the calcium deposit was located in the thin fibrous cap in the model when compared with that in a model without a deposit. The result of adding a calcium deposit either to the lipid core or remote from the lumen resulted in almost no increase in maximal stress. Conclusion: Calcification at the thin fibrous cap may result in high stress concentrations, ultimately increasing the risk of plaque rupture. Assessing the location of calcification may, in the future, aid in the risk stratification of patients with carotid stenosis.

The value of having no wild rabbits in south-east Queensland

Rabbits released in Australia in 1859 spread to most areas of suitable habitat by 1910 causing great damage to the environment and primary industries. Measurement of damage is essential to justify spending money and utilising resources to remove rabbits. Damage to pasture and biodiversity may be irreversible and therefore difficult to measure without comparison with an area that has never suffered such damage. A rabbit proof fence completed in 1906 protected a large part of south east Queensland from rabbits. The Darling Downs Moreton Rabbit Board (DDMRB) continues to maintain the fence and keep the area relatively free of rabbits. This area is unique because it is highly suitable for rabbits and yet it has never ‘experienced’ the damage caused by plagues of uncontrolled rabbits. A study site was established where the DDMRB fence separates an area heavily used by rabbits (‘dirty side’) from an area that has never been infested by rabbits (‘clean side’). The number and location of all rabbit warrens and log piles were recorded. The absence of warrens from the ‘clean side’ shows clearly that the rabbit proof fence has prevented rabbits from establishing warren systems. The ‘dirty side’ is characterised by a high number of warrens, a high density of rabbits, fewer pasture species and low macropod activity. Future work will determine whether the rabbit populations are viable in the absence of rabbit warrens. We plan to radio collar rabbits on both sides of the fence to measure their survival rate. In selected warrens and log piles of varying degrees of complexity and size, rabbits will be trapped and information on reproduction and age structure will be collected. This will allow better targeting of the source of rabbits during control operations. Once the initial comparative analysis of the site has been completed, all rabbit warrens will be destroyed on the dirty side of the fence. After rabbits are removed from this area, monitoring will continue to determine if pasture and biodiversity on opposite sides of the fence begin to mirror each other.

Ranking of Prospective New Generation Location for a Power Network in a Deregulated System

In developing countries high rate of growth in demand of electric energy is felt, and so the addition of new generating units becomes necessary. In deregulated power systems private generating stations are encouraged to add new generations. Finding the appropriate location of new generator to be installed can be obtained by running repeated power flows, carrying system studies like analyzing the voltage profile, voltage stability, loss analysis etc. In this paper a new methodology is proposed which will mainly consider the existing network topology into account. A concept of T-index is introduced in this paper, which considers the electrical distances between generator and load nodes.This index is used for ranking significant new generation expansion locations and also indicates the amount of permissible generations that can be installed at these new locations. This concept facilitates for the medium and long term planning of power generation expansions within the available transmission corridors. Studies carried out on a sample 7-bus system, EHV equivalent 24-bus system and IEEE 39 bus system are presented for illustration purpose.

Experimental investigation of cowl shape and location on inlet characteristics at hypersonic Mach number

An experimental study is presented to show the effect of the cowl location and shape on the shock interaction phenomena in the inlet region for a 2D, planar scramjet inlet model. Investigations include schlieren visualization around the cowl region and heat transfer rate measurement inside the inlet chamber.Both regular and Mach reflections are observed when the forebody ramp shock reflects from the cowl plate. Mach stem heights of 3.3 mm and 4.1 mm are measured in 18.5 mm and 22.7 mm high inlet chambers respecively. Increased heat transfer rate is measured at the same location of chamber for cowls of longer lenghs is indicating additional mass flow recovery by the inlet.

Phenyl-Ring-Bearing Cationic Surfactants: Effect of Ring Location on the Micellar Structure

A series of isomeric cationic surfactants (S1-S5) bearing a long alkyl chain that carries a 1,4-phenylene unit and a trimethyl ammonium headgroup was synthesized; the location of the phenyl ring within the alkyl tail was varied in an effort to understand its influence on the amphiphilic properties of the surfactants. The cmc's of the surfactants were estimated using ionic conductivity measurements and isothermal calorimetric titrations (ITC); the values obtained by the two methods were found to be in excellent agreement. The ITC measurements provided additional insight into the various thermodynamic parameters associated with the micellization process. Although all five surfactants have exactly the same molecular formula, their micellar properties were seen to vary dramatically depending on the location of the phenyl ring; the cmc was seen to decrease by almost an order of magnitude when the phenyl ring was moved from the tail end (cmc of S1 is 23 mM) to the headgroup region (cmc of S5 is 3 mM). In all cases, the enthalpy of micellization was negative but the entropy of micellization was positive, suggesting that in all of these systems the formation of micelles is both enthalpically and entropically favored. As expected, the decrease in cmc values upon moving the phenyl ring from the tail end to he headgroup region is accompanied by an increase in the thermodynamic driving force (Delta G) for micellization. To understand further the differences in the micellar structure of these surfactants, small-angle neutron scattering (SANS) measurements were carried out; these measurements reveal that the aggregation number of the micelles increases as the cmc decreases. This increase in the aggregation number is also accompanied by an increase in the asphericity of the micellar aggregate and a decrease in the fractional charge. Geometric packing arguments are presented to account for these changes in aggregation behavior as a function of phenyl ring location.

Location and conformation of pantothenate and its derivatives in Mycobacterium tuberculosis pantothenate kinase: insights into enzyme action

Previous studies of complexes of Mycobacterium tuberculosis PanK (MtPanK) with nucleotide diphosphates and non-hydrolysable analogues of nucleoside triphosphates in the presence or the absence of pantothenate established that the enzyme has dual specificity for ATP and GTP, revealed the unusual movement of ligands during enzyme action and provided information on the effect of pantothenate on the location and conformation of the nucleotides at the beginning and the end of enzyme action. The X-ray analyses of the binary complexes of MtPanK with pantothenate, pantothenol and N-nonylpantothenamide reported here demonstrate that in the absence of nucleotide these ligands occupy, with a somewhat open conformation, a location similar to that occupied by phosphopantothenate in the `end' complexes, which differs distinctly from the location of pantothenate in the closed conformation in the ternary `initiation' complexes. The conformation and the location of the nucleotide were also different in the initiation and end complexes. An invariant arginine appears to play a critical role in the movement of ligands that takes place during enzyme action. The work presented here completes the description of the locations and conformations of nucleoside diphosphates and triphosphates and pantothenate in different binary and ternary complexes, and suggests a structural rationale for the movement of ligands during enzyme action. The present investigation also suggests that N-alkylpantothenamides could be phosphorylated by the enzyme in the same manner as pantothenate.

Selection of Static VAR Compensator Location and Size for System Voltage Stability Improvement

This paper presents a methodology for selection of static VAR compensator location based on static voltage stability analysis of power systems. The analysis presented here uses the L-index of load buses, which includes voltage stability information of a normal load flow and is in the range of 0 (no load of system) to 1 (voltage collapse). An approach has been presented to select a suitable size and location of static VAR compensator in an EHV network for system voltage stability improvement. The proposed approach has been tested under simulated conditions on a few power systems and the results for a sample radial network and a 24-node equivalent EHV power network of a practical system are presented for illustration purposes. © 2000 Published by Elsevier Science S.A. All rights reserved.

Identification of fault location in power distribution system with distributed generation using support vector machines

This paper presents a multi-class support vector machine (SVMs) approach for locating and diagnosing faults in electric power distribution feeders with the penetration of Distributed Generations (DGs). The proposed approach is based on the three phase voltage and current measurements which are available at all the sources i.e. substation and at the connection points of DG. To illustrate the proposed methodology, a practical distribution feeder emanating from 132/11kV-grid substation in India with loads and suitable number of DGs at different locations is considered. To show the effectiveness of the proposed methodology, practical situations in distribution systems (DS) such as all types of faults with a wide range of varying fault locations, source short circuit (SSC) levels and fault impedances are considered for studies. The proposed fault location scheme is capable of accurately identify the fault type, location of faulted feeder section and the fault impedance. The results demonstrate the feasibility of applying the proposed method in practical in smart grid distribution automation (DA) for fault diagnosis.

The impact of latent heating on the location and strength of the tropical easterly jet

The tropical easterly jet (TEJ) is a prominent atmospheric circulation feature observed during the Asian summer monsoon. It is generally assumed that sensible heating over the Tibetan Plateau directly influences the location of the TEJ. However, other studies have suggested the importance of latent heating in determining the jet location. In this paper, the relative importance of latent heating on the maintenance of the TEJ is explored through simulations with a general circulation model. The simulation of the TEJ by the Community Atmosphere Model, version 3.1 is discussed in detail. These simulations showed that the location of the TEJ is well correlated with the location of the precipitation. Significant zonal shifts in the location of the precipitation resulted in similar shifts in the zonal location of the TEJ. These zonal shifts had minimal effect on the large-scale structure of the jet. Further, provided that precipitation patterns were relatively unchanged, orography did not directly impact the location of the TEJ. These changes were robust even with changes in the cumulus parameterization. This suggests the potential important role of latent heating in determining the location and structure of the TEJ. These results were used to explain the significant differences in the zonal location of the TEJ in the years 1988 and 2002. To understand the contribution of the latitudinal location of latent heating on the strength of the TEJ, aqua-planet simulations were carried out. It has been shown that for similar amounts of net latent heating, the jet is stronger when heating is in the higher tropical latitudes. This may partly explain the reason for the jet to be very strong during the JJA monsoon season.

The numerical modelling of multi-physics phenomena: The shape casting process

In this paper a computer simulation tool capable of modelling multi-physics processes in complex geometry has been developed and applied to the casting process. The quest for high-quality complex casting components demanded by the aerospace and automobile industries, requires more precise numerical modelling techniques and one that need to be generic and modular in its approach to modelling multi-processes problems. For such a computer model to be successful in shape casting, the complete casting process needs to be addressed, the major events being:-• Filling of hot liquid metal into a cavity mould • Solidification and latent heat evolution of liquid metal • Convection currents generated in liquid metal by thermal gradients • Deformation of cast and stress development in solidified metal • Macroscopic porosity formation The above phenomena combines the analysis of fluid flow, heat transfer, change of phase and thermal stress development. None of these events can be treated in isolation as they inexorably interact with each other in a complex way. Also conditions such as design of running system, location of feeders and chills, moulding materials and types of boundary conditions can all affect on the final cast quality and must be appropriately represented in the model.

Latin American migration in the central area of Iquique: New fronts of residential location and unequal forms of access to housing

Historically the central area of the city of Iquique has been established as residential space migrants choosing from different backgrounds , however since the late 2000s migration flows are diversified being mostly Latin American immigrants who live in precarious conditions , accessing tugurizados properties , deteriorated in an increasingly growing informal market. The results presented here are derived from quantitative residential location of migrants , as well as the implementation of 13 in-depth interviews . From these results emerge that Latin American migrants access to the same places where once lived internal migrants, however they inhabit a restrictive market , uneven and inadequate living conditions lease, but allows them to articulate residence and proximity to industrial networks , social and popular trade.