A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Woman abuse in Canada : sociological reflections on the past, suggestions for the future

Woman abuse in Canada started receiving much sociological attention in the mid-1980s. This article describes past scholarly achievements, assesses current contributions, and suggests progressive ways of responding to future challenges. Special attention is given to how broader political economic forces help shape and constrain research on a variety of highly injurious male-to-female assaults that occur in private settings.

Direct evidence for base-mediated decomposition of alkyl hydroperoxides (ROOH) in the gas phase

Alkyl hydroperoxides (ROOH) are attributed a key role in the biochemical oxidation of lipids during oxidative stress.1 In this chemistry ROOH compounds, where the R groups are unsaturated fatty acids, are viewed as transient ntermediates which are readily degraded, due to the lability of the RO-OH bond, to yield potentially genotoxic aldehydes and ketones.2 Generally, the decomposition of alkyl hydroperoxides is thought to be mediated by radical abstraction or electron transfer processes usually involving enzymes, transition metals, or recently, Vitamin C.3 In this paper we present the first unambiguous experimental and computational evidence for base-mediated heterolytic decomposition of simple alkyl hydroperoxides by the mechanism outlined in Scheme 1.

Base-induced decomposition of alkyl hydroperoxides in the gas phase. Part 3. Kinetics and dynamics in HO-+CH3OOH, C2H5OOH, and tert-C4H9OOH reactions

The E-CO(2) elimination reactions of alkyl hydroperoxides proceed via abstraction of an (x-hydrogen by a base: X- + (RRHCOOH)-R-1-H-2 -> HX + (RRC)-R-1-C-2=O + HO-. Efficiencies and product distributions for the reactions of the hydroxide anion with methyl, ethyl, and tert-butyl hydroperoxides are studied in the gas phase. On the basis of experiments using three isotopic analogues, HO- + CH3OOH, HO- + CD3OOH, and H18O- + CH3OOH. the overall intrinsic reaction efficiency is determined to be 80% or greater. The E(CO)2 decomposition is facile for these methylperoxide reactions, and predominates over competing proton transfer at the hydroperoxide moiety. The CH3CH2OOH reaction displays a similar E(CO)2 reactivity, whereas proton transfer and the formation of HOO- are the exclusive pathways observed for (CH3)(3)COOH, which has no (x-hydrogen. All results are consistent with the E-CO(2) mechanism, transition state structure, and reaction energy diagrams calculated using the hybrid density functional B3LYP approach. Isotope labeling for HO- + CH3OOH also reveals some interaction between H2O and HO- within the E(CO)2 product complex [H2O center dot center dot center dot CH2=O center dot center dot center dot HO-]. There is little evidence, however. for the formation of the most exothermic products H2O + CH2(OH)O-, which would arise from nuclephilic condensation of CH2=O and HO-. The results suggest that the product dynamics are not totally statistical but are rather direct after the E-CO(2) transition state. The larger HO- + CH3CH2OOH system displays more statistical behavior during complex dissociation.

The knowledge base of subject-matter experts in teaching : A case study of a professional scientist as a beginning teacher

One method of addressing the shortage of science and mathematics teachers is to train scientists and other science-related professionals to become teachers. Advocates argue that as discipline experts these career changers can relate the subject matter knowledge to various contexts and applications in teaching. In this paper, through interviews and classroom observations with a former scientist and her students, we examine how one career changer used her expertise in microbiology to teach microscopy. These data provided the basis for a description of the teacher’s instruction which was then analysed for components of domain knowledge for teaching. Consistent with the literature, the findings revealed that this career changer needed to develop her pedagogical knowledge. However, an interesting finding was that the teacher’s subject matter as a science teacher differed substantively from her knowledge as a scientist. This finding challenges the assumption that subject matter is readily transferable across professions and provides insight into how to better prepare and support career changers to transition from scientist to science teacher.

COPD self-management education : Vietnamese nurses' intention to educate, influencing factors and knowledge base

This thesis used a cross-sectional survey to examine how Vietnamese nurses educate COPD patients about the self-management of their disease. Further, the study also describes the characteristics of Vietnamese nurses working in COPD specialty areas as well as examining their COPD knowledge and the factors which influence their delivery of COPD self-management education when caring for COPD patients. The study found that while Vietnamese nurses are likely to deliver self-management education to the COPD patients they care for, there are areas for improvement in nurses' knowledge in all areas of COPD management and self management education.

Methods for sociological inquiry on emotion in educational settings

Sociological approaches to inquiry on emotion in educational settings are growing. Despite a long tradition of research and theory in disciplines such as psychology and sociology, the methods and approaches for naturalistic investigation of emotion are in a developmental phase in educational settings. In this article, recent empirical studies on emotion in educational contexts are canvassed. The discussion focuses on the use of multiple methods within research conducted in high school and university classrooms highlighting recent methodological progress. The methods discussed include facial expression analysis, verbal and non-verbal conduct, and self-report methods. Analyses drawn from different studies, informed by perspectives from microsociology, highlight the strengths and limitations of any one method. The power and limitations of multi-method approaches is discussed.

Building the science and innovation base: work, skills and employment issues

This Special Issue of New Technology, Work and Employment has been prompted by the increasing awareness in many countries of the need to maintain and grow their science and innovation base. The development of science, engineering, technology and mathematics (STEM) skills and capacity is seen as vital for economic development and prosperity through its impact on national and regional research and development (R&D), technological advancement, and innovation potential.

Understanding the quantitative skill base on introductory statistics : a case study from business statistics

Basic mathematical skills are critical to a student’s ability to successfully undertake an introductory statistics course. Yet in business education this vitally important area of mathematics and statistics education is under-researched. The question therefore arises as to what level of mathematical skill a typical business studies student will possess as they enter the tertiary environment, and whether there are any common deficiencies that we can identify with a view to tackling the problem. This paper will focus on a study designed to measure the level of mathematical ability of first year business students. The results provide timely insight into a growing problem faced by many tertiary educators in this field.

Expression of mammalian glutathione S-transferase 5-5 in Salmonella typhimurium TA1535 leads to base-pair mutations upon exposure to dihalomethanes

Dihalomethanes can produce liver tumors in mice but not in rats, and concern exists about the risk of these compounds to humans. Glutathione (GSH) conjugation of dihalomethanes has been considered to be a critical event in the bioactivation process, and risk assessment is based upon this premise; however, there is little experimental support for this view or information about the basis of genotoxicity. A plasmid vector containing rat GSH S-transferase 5-5 was transfected into the Salmonella typhimurium tester strain TA1535, which then produced active enzyme. The transfected bacteria produced base-pair revertants in the presence of ethylene dihalides or dihalomethanes, in the order CH2Br2 > CH2BrCl > CH2Cl2. However, revertants were not seen when cells were exposed to GSH, CH2Br2, and an amount of purified GSH S-transferase 5-5 (20-fold excess in amount of that expressed within the cells). HCHO, which is an end product of the reaction of GSH with dihalomethanes, also did not produce mutations. S-(1-Acetoxymethyl)GSH was prepared as an analog of the putative S-(1-halomethyl)GSH reactive intermediates. This analog did not produce revertants, consistent with the view that activation of dihalomethanes must occur within the bacteria to cause genetic damage, presenting a model to be considered in studies with mammalian cells. S-(1-Acetoxymethyl)GSH reacted with 2′-deoxyguanosine to yield a major adduct, identified as S-[1-(N2-deoxyguanosinyl)methyl]GSH. Demonstration of the activation of dihalomethanes by this mammalian GSH S-transferase theta class enzyme should be of use in evaluating the risk of these chemicals, particularly in light of reports of the polymorphic expression of a similar activity in humans.

Misleading conduct arising from public statements : establishing the knowledge base of the target audience

Despite the very substantial body of primary sources and secondary literature on Australia’s much-litigated statutory provisions proscribing misleading or deceptive conduct, the courts have provided little in the way of assistance about how to establish the knowledge base of the target audience at whom the public statement was directed. The purpose of this case note is to compare and contrast two recent decisions of the High Court of Australia that highlight the difficulties faced by applicants in attempting to establish a contravention of the relevant legislation where conduct is directed at a segment of the public or the public as a whole.

Sex work and health in a rural context: results of qualitative study undertaken in New South Wales

The paper reports health related findings of the first study undertaken of rural sex workers in an income-rich nation. In-depth interviews were conducted with eighteen purposively selected women who work in the rural sex industry. Rural sex services have a unique structure which informs the experiences of sex workers. Recent advances in telecommunications technology have impacted upon the organisation and structure of the sex industry in rural environments. Notable has been the growth of escort services in rural areas, which has diversified the rural sex industry from its traditional base of brothel operations. The general absence of street prostitution in rural settings has meant that the profile of rural sex workers tends to resemble that of escorts or call girls in urban settings, with workers having a relatively high level of control over working conditions and compliance with public health initiatives. Important issues which impact upon the rural sex industry include confidentiality and the more limited market for sexual services likely to be encountered in rural settings. These issues may impact on the sexual health of rural sex workers in terms of risk practices and access to health services.