1000 resultados para unitary codes


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Unusual event detection in crowded scenes remains challenging because of the diversity of events and noise. In this paper, we present a novel approach for unusual event detection via sparse reconstruction of dynamic textures over an overcomplete basis set, with the dynamic texture described by local binary patterns from three orthogonal planes (LBPTOP). The overcomplete basis set is learnt from the training data where only the normal items observed. In the detection process, given a new observation, we compute the sparse coefficients using the Dantzig Selector algorithm which was proposed in the literature of compressed sensing. Then the reconstruction errors are computed, based on which we detect the abnormal items. Our application can be used to detect both local and global abnormal events. We evaluate our algorithm on UCSD Abnormality Datasets for local anomaly detection, which is shown to outperform current state-of-the-art approaches, and we also get promising results for rapid escape detection using the PETS2009 dataset.

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This paper focuses on codes of practice in domestic (in-country) and international (out of country) philanthropic giving/grantmaking, their similarities and differences. Codes of principle and practice are interesting not so much because they accurately reflect differences in practice on the ground, but rather because they indicate what is considered important or relevant, as well as aspirational. Codes tell us what people are most concerned about – what is seen to be in need of regulation or reminder.

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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.

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Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

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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.

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We propose to use a simple and effective way to achieve secure quantum direct secret sharing. The proposed scheme uses the properties of fountain codes to allow a realization of the physical conditions necessary for the implementation of no-cloning principle for eavesdropping-check and authentication. In our scheme, to achieve a variety of security purposes, nonorthogonal state particles are inserted in the transmitted sequence carrying the secret shares to disorder it. However, the positions of the inserted nonorthogonal state particles are not announced directly, but are obtained by sending degrees and positions of a sequence that are pre-shared between Alice and each Bob. Moreover, they can confirm that whether there exists an eavesdropper without exchanging classical messages. Most importantly, without knowing the positions of the inserted nonorthogonal state particles and the sequence constituted by the first particles from every EPR pair, the proposed scheme is shown to be secure.

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We discuss algorithms for combining sequential prediction strategies, a task which can be viewed as a natural generalisation of the concept of universal coding. We describe a graphical language based on Hidden Markov Models for defining prediction strategies, and we provide both existing and new models as examples. The models include efficient, parameterless models for switching between the input strategies over time, including a model for the case where switches tend to occur in clusters, and finally a new model for the scenario where the prediction strategies have a known relationship, and where jumps are typically between strongly related ones. This last model is relevant for coding time series data where parameter drift is expected. As theoretical contributions we introduce an interpolation construction that is useful in the development and analysis of new algorithms, and we establish a new sophisticated lemma for analysing the individual sequence regret of parameterised models.

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We observe that MDS codes have interesting properties that can be used to construct ideal threshold schemes. These schemes permit the combiner to detect cheating, identify cheaters and recover the correct secret. The construction is later generalised so the resulting secret sharing is resistant against the Tompa-Woll cheating.

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Many educators are currently interested in using computer-mediated communications (CMCs) to support learning and creative practice. In my work I have been looking at how we might create drama through using cyberspaces, working with teachers and students in secondary school contexts. In trying to understand issues that have arisen and ways of working with the data I have found a number of frameworks helpful for analysing the online interactions. These frameworks draw from O'Toole's work on contexts negotiated in the creation of drama and other frameworks drawn from Wertsch, Bakhtin and Vygotsky's work on speech utterances, dialogic processes and internalisation of learning. The contexts and factors which must be negotiated in online communications within learning contexts are quite complex and educators may need to provide parameters and protocols to ensure appropriate languages, genres and utterances are utilised. The paper explores some of the types of languages, genres and utterances that emerged from a co-curricula drama project and issues that arose, including the importance of establishing processes for giving and receiving critical feedback This paper is of relevance to those whose research strategies may involve the use of computer-mediated communications as well as those utilising cyberspaces in educational contexts.

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This paper analyses recent corporate governance codes issued by 20 countries for evidence of convergence in corporate governance systems in Europe. The analysis shows that there has been a degree of convergence towards an Anglo-Saxon model of corporate governance as the audit committee concept is widely accepted in countries with both unitary and two-tier governance systems. Further, the latest audit committee recommendations in countries that have issued several governance codes show a strengthening of the recommendations for an audit committee over time in line with the Anglo-Saxon audit committee concept and convergence with the debate in the US and UK on issues such as the independence and financial expertise of members. However, consistent with the literature on the convergence of European corporate governance systems, at an operational level there is limited consistency in the recommended structure and role of audit committees.

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This paper describes the limitations of using the International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD-10-AM) to characterise patient harm in hospitals. Limitations were identified during a project to use diagnoses flagged by Victorian coders as hospital-acquired to devise a classification of 144 categories of hospital acquired diagnoses (the Classification of Hospital Acquired Diagnoses or CHADx). CHADx is a comprehensive data monitoring system designed to allow hospitals to monitor their complication rates month-to-month using a standard method. Difficulties in identifying a single event from linear sequences of codes due to the absence of code linkage were the major obstacles to developing the classification. Obstetric and perinatal episodes also presented challenges in distinguishing condition onset, that is, whether conditions were present on admission or arose after formal admission to hospital. Used in the appropriate way, the CHADx allows hospitals to identify areas for future patient safety and quality initiatives. The value of timing information and code linkage should be recognised in the planning stages of any future electronic systems.

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A crucial issue with hybrid quantum secret sharing schemes is the amount of data that is allocated to the participants. The smaller the amount of allocated data, the better the performance of a scheme. Moreover, quantum data is very hard and expensive to deal with, therefore, it is desirable to use as little quantum data as possible. To achieve this goal, we first construct extended unitary operations by the tensor product of n, n ≥ 2, basic unitary operations, and then by using those extended operations, we design two quantum secret sharing schemes. The resulting dual compressible hybrid quantum secret sharing schemes, in which classical data play a complementary role to quantum data, range from threshold to access structure. Compared with the existing hybrid quantum secret sharing schemes, our proposed schemes not only reduce the number of quantum participants, but also the number of particles and the size of classical shares. To be exact, the number of particles that are used to carry quantum data is reduced to 1 while the size of classical secret shares also is also reduced to l−2 m−1 based on ((m+1, n′)) threshold and to l−2 r2 (where r2 is the number of maximal unqualified sets) based on adversary structure. Consequently, our proposed schemes can greatly reduce the cost and difficulty of generating and storing EPR pairs and lower the risk of transmitting encoded particles.

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In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

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Multinational financial institutions (MNFIs) play a significant role in financing the activities of their clients in developing nations. Consistent with the ‘follow-the-customer’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. However, not only are MNFIs persistent users of tax havens, but also, more than other industries, have the opportunity to reduce tax through transfer pricing measures. This paper establishes a case for an industry-specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. In doing so, it considers the practicalities of implementing this by examining both definitional issues and possible formulas for MNFIs. This paper argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined, as well as the factors that should be included in an allocation formula, and the appropriate weighting. This paper concludes that unitary taxation with formulary apportionment is a viable industry-specific alternative for MNFIs.