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.

A waste management system for small and medium enterprises engaged in office building retrofit projects

Waste management and minimisation is considered to be an important issue for achieving sustainability in the construction industry. Retrofit projects generate less waste than demolitions and new builds, but they possess unique features and require waste management approaches that are different to traditional new builds. With the increasing demand for more energy efficient and environmentally sustainable office spaces, the office building retrofit market is growing in capital cities around Australia with a high level of refurbishment needed for existing aging properties. Restricted site space and uncertain delivery process in these projects make it a major challenge to manage waste effectively. The labour-intensive nature of retrofit projects creates the need for the involvement of small and medium enterprises (SMEs) as subcontractors in on-site works. SMEs are familiar with on-site waste generation but are not as actively motivated and engaged in waste management activities as the stakeholders in other construction projects in the industry. SMEs’ responsibilities for waste management in office building retrofit projects need to be identified and adapted to the work delivery processes and the waste management system supported by project stakeholders. The existing literature provides an understanding of how to manage construction waste that is already generated and how to increase the waste recovery rate for office building retrofit projects. However, previous research has not developed theories or practical solutions that can guide project stakeholders to understand the specific waste generation process and effectively plan for and manage waste in ongoing project works. No appropriate method has been established for the potential role and capability of SMEs to manage and minimise waste from their subcontracting works. This research probes into the characteristics of office building retrofit project delivery with the aim to develop specific tools to manage waste and incorporate SMEs in this process in an appropriate and effective way. Based on an extensive literature review, the research firstly developed a questionnaire survey to identify the critical factors of on-site waste generation in office building retrofit projects. Semi-structured interviews were then utilised to validate the critical waste factors and establish the interrelationships between the factors. The interviews served another important function of identifying the current problems of waste management in the industry and the performance of SMEs in this area. Interviewees’ opinions on remedies to the problems were also collected. On the foundation of the findings from the questionnaire survey and semi-structured interviews, two waste planning and management strategies were identified for the dismantling phase and fit-out phase of office building retrofit projects, respectively. Two models were then established to organize SMEs’ waste management activities, including a work process-based integrated waste planning model for the dismantling phase and a system dynamics model for the fit-out phase. In order to apply the models in real practice, procedures were developed to guide SMEs’ work flow in on-site waste planning and management. In addition, a collaboration framework was established for SMEs and other project stakeholders for effective waste planning and management. Furthermore, an organisational engagement strategy was developed to improve SME waste management practices. Three case studies were conducted to validate and finalise the research deliverables. This research extends the current literature that mostly covers waste management plans in new build projects, by presenting the knowledge and understanding of addressing waste problems in retrofit projects. It provides practical tools and guidance for industry practitioners to effectively manage the waste generation processes in office building retrofit projects. It can also promote industry-level recognition of the role of SMEs and their performance in on-site waste management.

Family coping: issues and challenges for cancer nursing

A large body of research now exists suggesting that families are dramatically affected by a diagnosis of cancer, and that they have a wide range of support needs. In particular, evidence suggests that the emotional strains of living with a family member who has cancer are an especially difficult coping challenge, and that such strains have a significant impact on the day-to-day lives of family members. Despite this evidence, there has been little analysis to date on the nature of the families' experience with cancer and what implications the unique features of family relationships and interactions in the context of cancer have for nursing practice. Some of these specific features of the families' experience with cancer are examined in this article. It is suggested that enormous scope exists for improving nurses' contribution to care for families of people with cancer. Specific recommendations for achieving such improvements include a critical review of the constraints that exist on efforts to care for families, and the development of approaches to care that appreciate the interconnectedness of family responses and the considerable needs of family members for emotional and practical support.

A security system based on human iris identification using wavelet transform

A security system based on the recognition of the iris of human eyes using the wavelet transform is presented. The zero-crossings of the wavelet transform are used to extract the unique features obtained from the grey-level profiles of the iris. The recognition process is performed in two stages. The first stage consists of building a one-dimensional representation of the grey-level profiles of the iris, followed by obtaining the wavelet transform zerocrossings of the resulting representation. The second stage is the matching procedure for iris recognition. The proposed approach uses only a few selected intermediate resolution levels for matching, thus making it computationally efficient as well as less sensitive to noise and quantisation errors. A normalisation process is implemented to compensate for size variations due to the possible changes in the camera-to-face distance. The technique has been tested on real images in both noise-free and noisy conditions. The technique is being investigated for real-time implementation, as a stand-alone system, for access control to high-security areas.

Analysis of steel structures for first- and second-order element (displacement and force) solutions

Finite element method (FEM) relies on an approximate function to fit into a governing equation and minimizes the residual error in the integral sense in order to generate solutions for the boundary value problems (nodal solutions). Because of this FEM does not show simultaneous capacities for accurate displacement and force solutions at node and along an element, especially when under the element loads, which is of much ubiquity. If the displacement and force solutions are strictly confined to an element’s or member’s ends (nodal response), the structural safety along an element (member) is inevitably ignored, which can definitely hinder the design of a structure for both serviceability and ultimate limit states. Although the continuous element deflection and force solutions can be transformed into the discrete nodal solutions by mesh refinement of an element (member), this setback can also hinder the effective and efficient structural assessment as well as the whole-domain accuracy for structural safety of a structure. To this end, this paper presents an effective, robust, applicable and innovative approach to generate accurate nodal and element solutions in both fields of displacement and force, in which the salient and unique features embodies its versatility in applications for the structures to account for the accurate linear and second-order elastic displacement and force solutions along an element continuously as well as at its nodes. The significance of this paper is on shifting the nodal responses (robust global system analysis) into both nodal and element responses (sophisticated element formulation).

Low-temperature plasmas in carbon nanostructure synthesis

Plasma-based techniques offer many unique possibilities for the synthesis of various nanostructures both on the surface and in the plasma bulk. In contrast to the conventional chemical vapor deposition and some other techniques, plasma-based processes ensure high level of controllability, good quality of the produced nanomaterials, and reduced environmental risk. In this work, the authors briefly review the unique features of the plasma-enhanced chemical vapor deposition approaches, namely, the techniques based on inductively coupled, microwave, and arc discharges. Specifically, the authors consider the plasmas with the ion/electron density ranging from 10^10 to 10^14 cm−3, electron energy in the discharge up to ∼10 eV, and the operating pressure ranging from 1 to 10^4 Pa (up to 105 Pa for the atmospheric-pressure arc discharges). The operating frequencies of the discharges considered range from 460 kHz for the inductively coupled plasmas, and up to 2.45 GHz for the microwave plasmas. The features of the direct-current arc discharges are also examined. The authors also discuss the principles of operation of these systems, as well as the effects of the key plasma parameters on the conditions of nucleation and growth of the carbon nanostructures, mainly carbon nanotubes and graphene. Advantages and disadvantages of these plasma systems are considered. Future trends in the development of these plasma-based systems are also discussed.

Plasma-made silicon nanograss and related nanostructures

Plasma-made nanostructures show outstanding potential for applications in nanotechnology. This paper provides a concise overview on the progress of plasma-based synthesis and applications of silicon nanograss and related nanostructures. The materials described here include black silicon, Si nanotips produced using a self-masking technique as well as self-organized silicon nanocones and nanograss. The distinctive features of the Si nanograss, two-tier hierarchical and tilted nanograss structures are discussed. Specific applications based on the unique features of the silicon nanograss are also presented.

High-rate, room temperature plasma-enhanced deposition of aluminum-doped zinc oxide nanofilms for solar cell applications

A custom-designed inductively coupled plasma (ICP)-assisted radio-frequency magnetron sputtering deposition system has been employed to synthesize aluminium-doped zinc oxide (ZnO:Al) nanofilms on glass substrates at room temperature. The effects of film thickness and ZnO target (partially covered by Al chips) power on the structural, electrical and optical properties of the ZnO:Al nanofilms are studied. A high growth rate (∼41 nm/min), low electrical sheet resistance (as low as 30 Ω/□) and high optical transparency (>80%) over the visible spectrum has been achieved at a film thickness of ∼615 nm and ZnO target power of 150 W. The synthesis of ZnO:Al nanofilms at room temperature and with high growth rates is attributed to the unique features of the ICP-assisted radio-frequency magnetron sputtering deposition approach. The results are relevant to the development of photovoltaic thin-film solar cells and flat panel displays.

Plasma-aided nanofabrication: "plasma-building block" approach

Unique features and benefits of the plasma-aided nanofabrication are considered by using the "plasma-building block" approach, which is based on plasma diagnostics and nanofilm characterization, cross-referenced by numerical simulation of generation and dynamics of building blocks in the gas phase, their interaction with nanostructured surfaces, and ab initio simulation of chemical structure of relevant nanoassemblies. The examples include carbon nanotip microemitter structures, semiconductor quantum dots and nanowires synthesized in the integrated plasma-aided nanofabrication facility.

Nanofabrication of single-crystalline flat-panel display microemitters : a plasma-building unit approach

This contribution is focused on plasma-enhanced chemical vapor deposition systems and their unique features that make them particularly attractive for nanofabrication of flat panel display microemitter arrays based on ordered patterns of single-crystalline carbon nanotip structures. The fundamentals of the plasma-based nanofabrication of carbon nanotips and some other important nanofilms and nanostructures are examined. Specific features, challenges, and potential benefits of using the plasma-based systems for relevant nanofabrication processes are analyzed within the framework of the "plasma-building unit" approach that builds up on extensive experimental data on plasma diagnostics and nanofilm/nanostructure characterization, and numerical simulation of the species composition in the ionized gas phase (multicomponent fluid models), ion dynamics and interaction with ordered carbon nanotip patterns, and ab initio computations of chemical structure of single crystalline carbon nanotips. This generic approach is also applicable for nanoscale assembly of various carbon nanostructures, semiconductor quantum dot structures, and nano-crystalline bioceramics. Special attention is paid to most efficient control strategies of the main plasma-generated building units both in the ionized gas phase and on nanostructured deposition surfaces. The issues of tailoring the reactive plasma environments and development of versatile plasma nanofabrication facilities are also discussed.

Retinal anatomy of the New Zealand kiwi: Structural traits consistent with their nocturnal behavior

Kiwi (Apteryx spp.) have a visual system unlike that of other nocturnal birds, and have specializations to their auditory, olfactory and tactile systems. Eye size, binocular visual fields and visual brain centers in kiwi are proportionally the smallest yet recorded among birds. Given the many unique features of the kiwi visual system, we examined the laminar organization of the kiwi retina to determine if they evolved increased light sensitivity with a shift to a nocturnal niche or if they retained features of their diurnal ancestor. The laminar organization of the kiwi retina was consistent with an ability to detect low light levels similar to that of other nocturnal species. In particular, the retina appeared to have a high proportion of rod photoreceptors compared to diurnal species, as evidenced by a thick outer nuclear layer, and also numerous thin photoreceptor segments intercalated among the conical shaped cone photoreceptor inner segments. Therefore, the retinal structure of kiwi was consistent with increased light sensitivity, although other features of the visual system, such as eye size, suggest a reduced reliance on vision. The unique combination of a nocturnal retina and smaller than expected eye size, binocular visual fields and brain regions make the kiwi visual system unlike that of any bird examined to date. Whether these features of their visual system are an evolutionary design that meets their specific visual needs or are a remnant of a kiwi ancestor that relied more heavily on vision is yet to be determined.

Generalized element load method for first- and second-order element solutions with element load effect

The finite element method in principle adaptively divides the continuous domain with complex geometry into discrete simple subdomain by using an approximate element function, and the continuous element loads are also converted into the nodal load by means of the traditional lumping and consistent load methods, which can standardise a plethora of element loads into a typical numerical procedure, but element load effect is restricted to the nodal solution. It in turn means the accurate continuous element solutions with the element load effects are merely restricted to element nodes discretely, and further limited to either displacement or force field depending on which type of approximate function is derived. On the other hand, the analytical stability functions can give the accurate continuous element solutions due to element loads. Unfortunately, the expressions of stability functions are very diverse and distinct when subjected to different element loads that deter the numerical routine for practical applications. To this end, this paper presents a displacement-based finite element function (generalised element load method) with a plethora of element load effects in the similar fashion that never be achieved by the stability function, as well as it can generate the continuous first- and second-order elastic displacement and force solutions along an element without loss of accuracy considerably as the analytical approach that never be achieved by neither the lumping nor consistent load methods. Hence, the salient and unique features of this paper (generalised element load method) embody its robustness, versatility and accuracy in continuous element solutions when subjected to the great diversity of transverse element loads.

Modeling approaches for pesticide exposure assessment in rice paddies

Pesticide use in paddy rice production may contribute to adverse ecological effects in surface waters. Risk assessments conducted for regulatory purposes depend on the use of simulation models to determine predicted environment concentrations (PEC) of pesticides. Often tiered approaches are used, in which assessments at lower tiers are based on relatively simple models with conservative scenarios, while those at higher tiers have more realistic representations of physical and biochemical processes. This chapter reviews models commonly used for predicting the environmental fate of pesticides in rice paddies. Theoretical considerations, unique features, and applications are discussed. This review is expected to provide information to guide model selection for pesticide registration, regulation, and mitigation in rice production areas.

Load estimation with uncertainties from opportunistic sampling data: A semiparametric approach

We consider estimating the total load from frequent flow data but less frequent concentration data. There are numerous load estimation methods available, some of which are captured in various online tools. However, most estimators are subject to large biases statistically, and their associated uncertainties are often not reported. This makes interpretation difficult and the estimation of trends or determination of optimal sampling regimes impossible to assess. In this paper, we first propose two indices for measuring the extent of sampling bias, and then provide steps for obtaining reliable load estimates that minimizes the biases and makes use of informative predictive variables. The key step to this approach is in the development of an appropriate predictive model for concentration. This is achieved using a generalized rating-curve approach with additional predictors that capture unique features in the flow data, such as the concept of the first flush, the location of the event on the hydrograph (e.g. rise or fall) and the discounted flow. The latter may be thought of as a measure of constituent exhaustion occurring during flood events. Forming this additional information can significantly improve the predictability of concentration, and ultimately the precision with which the pollutant load is estimated. We also provide a measure of the standard error of the load estimate which incorporates model, spatial and/or temporal errors. This method also has the capacity to incorporate measurement error incurred through the sampling of flow. We illustrate this approach for two rivers delivering to the Great Barrier Reef, Queensland, Australia. One is a data set from the Burdekin River, and consists of the total suspended sediment (TSS) and nitrogen oxide (NO(x)) and gauged flow for 1997. The other dataset is from the Tully River, for the period of July 2000 to June 2008. For NO(x) Burdekin, the new estimates are very similar to the ratio estimates even when there is no relationship between the concentration and the flow. However, for the Tully dataset, by incorporating the additional predictive variables namely the discounted flow and flow phases (rising or recessing), we substantially improved the model fit, and thus the certainty with which the load is estimated.

An extended regression approach to estimating loads and their uncertainties in Great Barrier Reef catchments

There are numerous load estimation methods available, some of which are captured in various online tools. However, most estimators are subject to large biases statistically, and their associated uncertainties are often not reported. This makes interpretation difficult and the estimation of trends or determination of optimal sampling regimes impossible to assess. In this paper, we first propose two indices for measuring the extent of sampling bias, and then provide steps for obtaining reliable load estimates by minimizing the biases and making use of possible predictive variables. The load estimation procedure can be summarized by the following four steps: - (i) output the flow rates at regular time intervals (e.g. 10 minutes) using a time series model that captures all the peak flows; - (ii) output the predicted flow rates as in (i) at the concentration sampling times, if the corresponding flow rates are not collected; - (iii) establish a predictive model for the concentration data, which incorporates all possible predictor variables and output the predicted concentrations at the regular time intervals as in (i), and; - (iv) obtain the sum of all the products of the predicted flow and the predicted concentration over the regular time intervals to represent an estimate of the load. The key step to this approach is in the development of an appropriate predictive model for concentration. This is achieved using a generalized regression (rating-curve) approach with additional predictors that capture unique features in the flow data, namely the concept of the first flush, the location of the event on the hydrograph (e.g. rise or fall) and cumulative discounted flow. The latter may be thought of as a measure of constituent exhaustion occurring during flood events. The model also has the capacity to accommodate autocorrelation in model errors which are the result of intensive sampling during floods. Incorporating this additional information can significantly improve the predictability of concentration, and ultimately the precision with which the pollutant load is estimated. We also provide a measure of the standard error of the load estimate which incorporates model, spatial and/or temporal errors. This method also has the capacity to incorporate measurement error incurred through the sampling of flow. We illustrate this approach using the concentrations of total suspended sediment (TSS) and nitrogen oxide (NOx) and gauged flow data from the Burdekin River, a catchment delivering to the Great Barrier Reef. The sampling biases for NOx concentrations range from 2 to 10 times indicating severe biases. As we expect, the traditional average and extrapolation methods produce much higher estimates than those when bias in sampling is taken into account.