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.

Effective discrimination of acoustic emission source signals for structural health monitoring

Acoustic emission (AE) is the phenomenon where stress waves are generated due to rapid release of energy within a material caused by sources such as crack initiation or growth. AE technique involves recording the stress waves by means of sensors and subsequent analysis of the recorded signals to gather information about the nature of the source. Though AE technique is one of the popular non destructive evaluation (NDE) techniques for structural health monitoring of mechanical, aerospace and civil structures; several challenges still exist in successful application of this technique. Presence of spurious noise signals can mask genuine damage‐related AE signals; hence a major challenge identified is finding ways to discriminate signals from different sources. Analysis of parameters of recorded AE signals, comparison of amplitudes of AE wave modes and investigation of uniqueness of recorded AE signals have been mentioned as possible criteria for source differentiation. This paper reviews common approaches currently in use for source discrimination, particularly focusing on structural health monitoring of civil engineering structural components such as beams; and further investigates the applications of some of these methods by analyzing AE data from laboratory tests.

Fast pyrolysis for better utilization of tamarind seed from renewable energy point of view

The conversion of tamarind seeds into pyrolytic oil by fixed bed fire-tube heating reactor has been taken into consideration in this study. The major components of the system were fixed bed fire-tube heating reactor, liquid condenser and collectors. The raw and crushed tamarind seed in particle form was pyrolized in an electrically heated 10 cm diameter and 27 cm high fixed bed reactor. The products are oil, char and gases. The parameters varied were reactor bed temperature, running time, gas flow rate and feed particle size. The parameters were found to influence the product yields significantly. The maximum liquid yield was 45 wt% at 4000C for a feed size of 1.07cm3 at a gas flow rate of 6 liter/min with a running time of 30 minute. The pyrolysis oil was obtained at these optimum process conditions were analyzed for physical and chemical properties to be used as an alternative fuel.

The effect of ribbing on the energy flow between two rectangular plates coupled at right angle

This paper presents an analytical model to study the effect of stiffening ribs on vibration transmission between two rectangular plates coupled at right angle. Interesting wave attenuation patterns were observed by placing the stiffening rib either on the source or on the receiving plate. The result can be used to improve the understanding of vibration and for vibration control of more complex structures such as transformer tanks and machine covers.

A high frequency current source converter with adjustable magnitude to drive high power piezoelectric transducers

A general electrical model of a piezoelectric transducer for ultrasound applications consists of a capacitor in parallel with RLC legs. A high power voltage source converter can however generate significant voltage stress across the transducer that creates high leakage currents. One solution is to reduce the voltage stress across the piezoelectric transducer by using an LC filter, however a main drawback is changing the piezoelectric resonant frequency and its characteristics. Thereby it reduces the efficiency of energy conversion through the transducer. This paper proposes that a high frequency current source converter is a suitable topology to drive high power piezoelectric transducers efficiently.

Kinetic energy of He atoms in liquid He-4-He-3 mixtures

Deep inelastic neutron scattering measurements on liquid 3He-4He mixtures in the normal phase have been performed on the VESUVIO spectrometer at the ISIS pulsed neutron source at exchanged wave vectors of about q≃120.0Å-1. The neutron Compton profiles J(y) of the mixtures were measured along the T=1.96K isotherm for 3He concentrations, x, ranging from 0.1 to 1.0 at saturated vapor pressures. Values of kinetic energies 〈T〉 of 3He and 4He atoms as a function of x, 〈T〉(x), were extracted from the second moment of J(y). The present determinations of 〈T〉(x) confirm previous experimental findings for both isotopes and, in the case of 3He, a substantial disagreement with theory is found. In particular 〈T〉(x) for the 3He atoms is found to be independent of concentration yielding a value 〈T〉3(x=0.1)≃12K, much lower than the value suggested by the most recent theoretical estimates of approximately 19 K.

Shahejie−Shahejie/Guantao/Wumishan and Carboniferous/Permian Coal−Paleozoic Total Petroleum Systems in the Bohaiwan Basin, China (based on geologic studies for the 2000 World Energy Assessment Project of the U.S. Geological Survey)

This report discusses the geologic framework and petroleum geology used to assess undiscovered petroleum resources in the Bohaiwan basin province for the 2000 World Energy Assessment Project of the U.S. Geological Survey. The Bohaiwan basin in northeastern China is the largest petroleum-producing region in China. Two total petroleum systems have been identified in the basin. The first, the Shahejie–Shahejie/Guantao/Wumishan Total Petroleum System, involves oil and gas generated from mature pods of lacustrine source rock that are associated with six major rift-controlled subbasins. Two assessment units are defined in this total petroleum system: (1) a Tertiary lacustrine assessment unit consisting of sandstone reservoirs interbedded with lacustrine shale source rocks, and (2) a pre-Tertiary buried hills assessment unit consisting of carbonate reservoirs that are overlain unconformably by Tertiary lacustrine shale source rocks. The second total petroleum system identified in the Bohaiwan basin is the Carboniferous/Permian Coal–Paleozoic Total Petroleum System, a hypothetical total petroleum system involving natural gas generated from multiple pods of thermally mature coal beds. Low-permeability Permian sandstones and possibly Carboniferous coal beds are the reservoir rocks. Most of the natural gas is inferred to be trapped in continuous accumulations near the center of the subbasins. This total petroleum system is largely unexplored and has good potential for undiscovered gas accumulations. One assessment unit, coal-sourced gas, is defined in this total petroleum system.

A sustainable tourism development in Alacati, Turkey : (Re)invention of public space with clean energy

Although there is an increasing recognition of the impacts of climate change on communities, residents often resist changing their lifestyle to reduce the effects of the problem. By using a landscape architectural design medium, this paper argues that public space, when designed as an ecological system, has the capacity to create social and environmental change and to increase the quality of the human environment. At the same time, this ecological system can engage residents, enrich the local economy, and increase the social network. Through methods of design, research and case study analysis, an alternative master plan is proposed for a sustainable tourism development in Alacati, Turkey. Our master plan uses local geographical, economic and social information within a sustainable landscape architectural design scheme that addresses the key issues of ecology, employment, public space and community cohesion. A preliminary community empowerment model (CEM) is proposed to manage the designs. The designs address: the coexistence of local agricultural and sustainable energy generation; state of the art water management; and the functional and sustainable social and economic interrelationship of inhabitants, NGOs, and local government.

Smart coordination of energy storage units (ESUs) for voltage and loading management in distribution networks

This paper proposes a distributed control approach to coordinate multiple energy storage units (ESUs) to avoid violation of voltage and thermal constraints, which are some of the main power quality challenges for future distribution networks. ESUs usually are connected to a network through voltage source converters. In this paper, both ESU converters active and reactive power are used to deal with the above mentioned power quality issues. ESUs' reactive power is proposed to be used for voltage support, while the active power is to be utilized in managing network loading. Two typical distribution networks are used to apply the proposed method, and the simulated results are illustrated in this paper to show the effectiveness of this approach.

BoP and MNCs: where is the market and where the source of innovation?

ln 2004 Prahalad made managers aware of the great economic opportunity that the population at the BoP (Base of the Pyramid) could represent for business in the tom of new potential consumers. However, MNCs (Multi-National Corporations) have continued to fail in penetrating low income markets, arguably because applied strategies are often the same adopted at the top of the pyramid. Even in those few cases where products get re-envisioned, theie introduction in contexts of extreme poverty only induces new needs and develops new dependencies. At best the rearrangement of business models by MNCs has meant the realization of CSR (Corporate Social Responsibly) schemes that have validity from a marketing perspective, but still lack the crucial element of social embeddedness (London & Hart, 2004). Today the challenge is lo reach the lowest population tier with reinvented business models based on principles of value co-creation. Starting from a view of the potential consumer at the BoP as a ring of continuity in the value chain process – a resource that can itself produce value - this paper concludes proposing an alternative innovative approach to operate in developing markets that overturns the roles of MNCs and the BoP. The proposed perspective of ‘reversed' source of innovation and primary target market builds on two fundamental tenets: traditional knowledge is rich and greatly unexploded, and markets at the lop of the pyramid are saturated with unnecessary products / practices that have lost contact with the natural environment.

BoP and MNCs: where is the market and where the source of innovation?

ln 2004 Prahalad made managers aware of the great economic opportunity that the population at the BoP (Base of the Pyramid) could represent for business in the tom of new potential consumers. However, MNCs (Multi-National Corporations) have continued to fail in penetrating low income markets, arguably because applied strategies are often the same adopted at the top of the pyramid. Even in those few cases where products get re-envisioned, theie introduction in contexts of extreme poverty only induces new needs and develops new dependencies. At best the rearrangement of business models by MNCs has meant the realization of CSR (Corporate Social Responsibly) schemes that have validity from a marketing perspective, but still lack the crucial element of social embeddedness (London & Hart, 2004). Today the challenge is lo reach the lowest population tier with reinvented business models based on principles of value co-creation. Starting from a view of the potential consumer at the BoP as a ring of continuity in the value chain process – a resource that can itself produce value - this paper concludes proposing an alternative innovative approach to operate in developing markets that overturns the roles of MNCs and the BoP. The proposed perspective of ‘reversed' source of innovation and primary target market builds on two fundamental tenets: traditional knowledge is rich and greatly unexploded, and markets at the lop of the pyramid are saturated with unnecessary products / practices that have lost contact with the natural environment.

Source apportionment of airborne particulate matter : an overview of Australian and New Zealand studies

Despite the existence of air quality guidelines in Australia and New Zealand, the concentrations of particulate matter have exceeded these guidelines on several occasions. To identify the sources of particulate matter, examine the contributions of the sources to the air quality at specific areas and estimate the most likely locations of the sources, a growing number of source apportionment studies have been conducted. This paper provides an overview of the locations of the studies, salient features of the results obtained and offers some perspectives for the improvement of future receptor modelling of air quality in these countries. The review revealed that because of its advantages over alternative models, Positive Matrix Factorisation (PMF) was the most commonly applied model in the studies. Although there were differences in the sources identified in the studies, some general trends were observed. While biomass burning was a common problem in both countries, the characteristics of this source varied from one location to another. In New Zealand, domestic heating was the highest contributor to particle levels on days when the guidelines were exceeded. On the other hand, forest back-burning was a concern in Brisbane while marine aerosol was a major source in most studies. Secondary sulphate, traffic emissions, industrial emissions and re-suspended soil were also identified as important sources. Some unique species, for example, volatile organic compounds and particle size distribution were incorporated into some of the studies with results that have significant ramifications for the improvement of air quality. Overall, the application of source apportionment models provided useful information that can assist the design of epidemiological studies and refine air pollution reduction strategies in Australia and New Zealand.

A sustainable tourism development in Alacati, Turkey: (Re) invention of public space with clean energy

Although there is an increasing recognition of the impacts of climate change on communities, residents often resist changing their lifestyle to reduce the effects of the problem. By using a landscape architectural design medium, this paper argues that public space, when designed as an ecological system, has the capacity to create social and environmental change and to increase the quality of the human environment. At the same time, this ecological system can engage residents, enrich the local economy, and increase the social network. Through methods of design, research and case study analysis, an alternative master plan is proposed for a sustainable tourism development in Alacati, Turkey. Our master plan uses local geographical, economic and social information within a sustainable landscape architectural design scheme that addresses the key issues of ecology, employment, public space and community cohesion. A preliminary community empowerment model (CEM) is proposed to manage the designs. The designs address: the coexistence of local agricultural and sustainable energy generation; state of the art water management; and the functional and sustainable social and economic interrelationship of inhabitants, NGOs, and local government.

Estimation of biodiesel properties from chemical composition – An artificial neural network (ANN) approach

Biodiesel, produced from renewable feedstock represents a more sustainable source of energy and will therefore play a significant role in providing the energy requirements for transportation in the near future. Chemically, all biodiesels are fatty acid methyl esters (FAME), produced from raw vegetable oil and animal fat. However, clear differences in chemical structure are apparent from one feedstock to the next in terms of chain length, degree of unsaturation, number of double bonds and double bond configuration-which all determine the fuel properties of biodiesel. In this study, prediction models were developed to estimate kinematic viscosity of biodiesel using an Artificial Neural Network (ANN) modelling technique. While developing the model, 27 parameters based on chemical composition commonly found in biodiesel were used as the input variables and kinematic viscosity of biodiesel was used as output variable. Necessary data to develop and simulate the network were collected from more than 120 published peer reviewed papers. The Neural Networks Toolbox of MatLab R2012a software was used to train, validate and simulate the ANN model on a personal computer. The network architecture and learning algorithm were optimised following a trial and error method to obtain the best prediction of the kinematic viscosity. The predictive performance of the model was determined by calculating the coefficient of determination (R2), root mean squared (RMS) and maximum average error percentage (MAEP) between predicted and experimental results. This study found high predictive accuracy of the ANN in predicting fuel properties of biodiesel and has demonstrated the ability of the ANN model to find a meaningful relationship between biodiesel chemical composition and fuel properties. Therefore the model developed in this study can be a useful tool to accurately predict biodiesel fuel properties instead of undertaking costly and time consuming experimental tests.

The influence of Monte Carlo source parameters on detector design and dose perturbation in small field dosimetry

To obtain accurate Monte Carlo simulations of small radiation fields, it is important model the initial source parameters (electron energy and spot size) accurately. However recent studies have shown that small field dosimetry correction factors are insensitive to these parameters. The aim of this work is to extend this concept to test if these parameters affect dose perturbations in general, which is important for detector design and calculating perturbation correction factors. The EGSnrc C++ user code cavity was used for all simulations. Varying amounts of air between 0 and 2 mm were deliberately introduced upstream to a diode and the dose perturbation caused by the air was quantified. These simulations were then repeated using a range of initial electron energies (5.5 to 7.0 MeV) and electron spot sizes (0.7 to 2.2 FWHM). The resultant dose perturbations were large. For example 2 mm of air caused a dose reduction of up to 31% when simulated with a 6 mm field size. However these values did not vary by more than 2 % when simulated across the full range of source parameters tested. If a detector is modified by the introduction of air, one can be confident that the response of the detector will be the same across all similar linear accelerators and the Monte Carlo modelling of each machine is not required.