Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)

As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

Economic fluctuations and productivity in the Malaysian construction sector

Growth in productivity is the key determinant of the long-term health and prosperity of an economy. The construction industry being one of major strategic importance, its productivity performance has a significant effect on national economic growth. The relationship between construction output and economy has received intensive studies, but there is lack of empirical study on the relationship between construction productivity and economic fluctuations. Fluctuations in construction output are endemic in the industry. In part they are caused by the boom and slump of the economy as a whole and in part by the nature of the construction product. This research aims to uncover how the productivity of construction sector is influenced in the course of economic fluctuations in Malaysia. Malaysia has adopted three economic policies – New Economic Policy (1971-1990), National Development Policy (1991-2000) and the National Vision Policy (2001-2010) since gaining independence in 1959. The Privatisation Master Plan was introduced in 1991. Operating within this historical context, the Malaysian construction sector has experienced four business cycles since 1960. A mixed-method design approach is adopted in this study. Quantitative analysis was conducted on the published official statistics of the construction industry and the overall economy in Malaysia between 1970 and 2009. Qualitative study involved interviews with a purposive sample of 21 industrial participants. This study identified a 32-year long building cycle appears in 1975-2006. It is superimposed with three shorter construction business cycles in 1975-1987, 1987-1999 and 1999-2006. The correlations of Construction labour productivity (CLP) and GDP per capita are statistically significant for the 1975-2006 building cycle, 1987-1999 and 1999-2006 construction business cycles. It was not significant in 1975-1987 construction business cycles. The Construction Industry Surveys/Census over the period from 1996 to 2007 show that the average growth rate of total output per employee expanded but the added value per employee contracted which imply high cost of bought-in materials and services and inefficient usage of purchases. The construction labour productivity is peaked at 2004 although there is contraction of construction sector in 2004. The residential subsector performed relatively better than the other sub-sectors in most of the productivity indicators. Improvements are found in output per employee, value added per employee, labour competitiveness and capital investment but declines are recorded in value added content and capital productivity. The civil engineering construction is most productive in the labour productivity nevertheless relatively poorer in the capital productivity. The labour cost is more competitive in the larger size establishment. The added value per labour cost is higher in larger sized establishment attributed to efficient in utilization of capital. The interview with the industrial participant reveals that the productivity of the construction sector is influenced by the economic environment, the construction methods, contract arrangement, payment chain and regulatory policies. The fluctuations of construction demand have caused companies switched to defensive strategy during the economic downturn and to ensure short-term survival than to make a profit for the long-term survival and growth. It leads the company to take drastic measures to curb expenses, downsizing, employ contract employment, diversification and venture overseas market. There is no empirical evidence supports downsizing as a necessary step in a process of reviving productivity. The productivity does not correlate with size of firm. A relatively smaller and focused firm is more productive than the larger and diversified organisation. However diversified company experienced less fluctuation in both labour and capital productivity. In order to improve the productivity of the construction sector, it is necessary to remove the negatives and flaws from past practices. The recommended measures include long-term strategic planning and coordinated approaches of government agencies in planning of infrastructure development and to provide regulatory environments which encourage competition and facilitate productivity improvement.

An analysis of tax expenditure versus direct expenditure

Each financial year concessions, benefits and incentives are delivered to taxpayers via the tax system. These concessions, benefits and incentives, referred to as tax expenditure, differ from direct expenditure because of the recurring fiscal impact without regular scrutiny through the federal budget process. There are approximately 270 different tax expenditures existing within the current tax regime with total measured tax expenditures in the 2005-06 financial year estimated to be around $42.1 billion, increasing to $52.7 billion by 2009-10. Each year, new tax expenditures are introduced, while existing tax expenditures are modified and deleted. In recognition of some of the problems associated with tax expenditure, a Tax Expenditure Statement, as required by the Charter of Budget Honesty Act 1988, is produced annually by the Australian Federal Treasury. The Statement details the various expenditures and measures in the form of concessions, benefits and incentives provided to taxpayers by the Australian Government and calculates the tax expenditure in terms of revenue forgone. A similar approach to reporting tax expenditure, with such a report being a legal requirement, is followed by most OECD countries. The current Tax Expenditure Statement lists 270 tax expenditures and where it is able to, reports on the estimated pecuniary value of those expenditures. Apart from the annual Tax Expenditure Statement, there is very little other scrutiny of Australia’s Federal tax expenditure program. While there has been various academic analysis of tax expenditure in Australia, when compared to the North American literature, it is suggested that the Australian literature is still in its infancy. In fact, one academic author who has contributed to tax expenditure analysis recently noted that there is ‘remarkably little secondary literature which deals at any length with tax expenditures in the Australian context.’ Given this perceived gap in the secondary literature, this paper examines fundamental concept of tax expenditure and considers the role it plays in to the current tax regime as a whole, along with the effects of the introduction of new tax expenditures. In doing so, tax expenditure is contrasted with direct expenditure. An analysis of tax expenditure versus direct expenditure is already a sophisticated and comprehensive body of work stemming from the US over the last three decades. As such, the title of this paper is rather misleading. However, given the lack of analysis in Australia, it is appropriate that this paper undertakes a consideration of tax expenditure versus direct expenditure in an Australian context. Given this proposition, rather than purport to undertake a comprehensive analysis of tax expenditure which has already been done, this paper discusses the substantive considerations of any such analysis to enable further investigation into the tax expenditure regime both as a whole and into individual tax expenditure initiatives. While none of the propositions in this paper are new in a ‘tax expenditure analysis’ sense, this debate is a relatively new contribution to the Australian literature on the tax policy. Before the issues relating to tax expenditure can be determined, it is necessary to consider what is meant by ‘tax expenditure’. As such, part two if this paper defines ‘tax expenditure’. Part three determines the framework in which tax expenditure can be analysed. It is suggested that an analysis of tax expenditure must be evaluated within the framework of the design criteria of an income tax system with the key features of equity, efficiency, and simplicity. Tax expenditure analysis can then be applied to deviations from the ideal tax base. Once it is established what is meant by tax expenditure and the framework for evaluation is determined, it is possible to establish the substantive issues to be evaluated. This paper suggests that there are four broad areas worthy of investigation; economic efficiency, administrative efficiency, whether tax expenditure initiatives achieve their policy intent, and the impact on stakeholders. Given these areas of investigation, part four of this paper considers the issues relating to the economic efficiency of the tax expenditure regime, in particular, the effect on resource allocation, incentives for taxpayer behaviour and distortions created by tax expenditures. Part five examines the notion of administrative efficiency in light of the fact that most tax expenditures could simply be delivered as direct expenditures. Part six explores the notion of policy intent and considers the two questions that need to be asked; whether any tax expenditure initiative reaches its target group and whether the financial incentives are appropriate. Part seven examines the impact on stakeholders. Finally, part eight considers the future of tax expenditure analysis in Australia.

Environmental law and the economic impact on Australian firms

In response to international awareness of environmental issues and the inadequacies of common law actions, legislation has been enacted by Australian governments to facilitate environmental protection. The Environmental Protection Act 1994 (Qld) and accompanying Environmental Protection (Interim) Regulation 1995 (Qld) is one example of government response to mounting public pressure to legislate for the environment. Investigation into the operation of the legislation exposes the costs faced by Australian firms in its application. The legislation identifies a number of environmentally relevant activities and imposes licensing and reporting requirements on firms undertaking such activities. In view of these legislative requirements and the increasing public awareness of environmental issues over the last decade in Australia, it could be expected that firms undertaking environmentally sensitive activities will place greater importance on the management of environmental issues. If so, the greater prominence placed on environmental management may be reflected in disclosures made by the firm to its shareholders and other interested parties. This article investigates the type and extent of costs currently imposed by the body of environmental laws in Australia with the discussion primarily focusing upon costs imposed due to the operation of environmental legislation in Queensland. Further, the article reports empirical analysis of management response to environmental issues where firms are undertaking environmentally sensitive activities.

Diesel engine problems, acoustic emission signals and simulated misfire faults

This paper discusses commonly encountered diesel engine problems and the underlying combustion related faults. Also discussed are the methods used in previous studies to simulate diesel engine faults and the initial results of an experimental simulation of a common combustion related diesel engine fault, namely diesel engine misfire. This experimental fault simulation represents the first step towards a comprehensive investigation and analysis into the characteristics of acoustic emission signals arising from combustion related diesel engine faults. Data corresponding to different engine running conditions was captured using in-cylinder pressure, vibration and acoustic emission transducers along with both crank-angle encoder and top-dead centre signals. Using these signals, it was possible to characterise the diesel engine in-cylinder pressure profiles and the effect of different combustion conditions on both vibration and acoustic emission signals.

A preliminary study into the environmental and economic consequences of a sugar factory depithing operation

Bagasse stockpile operations have the potential to lead to adverse environmental and social impacts. Dust releases can cause occupational health and safety concerns for factory workers and dust emissions impact on the surrounding community. Preliminary modelling showed that bagasse depithing would likely reduce the environmental risks, particularly dust emissions, associated with large scale bagasse stockpiling operations. Dust emission properties were measured and used for dispersion modelling with favourable outcomes. Modelling showed a 70% reduction in peak ground level concentrations of PM10 dust (particles with an aerodynamic diameter less than 10 µm) from operations on depithed bagasse stockpiles compared to similar operations on stockpiles of whole bagasse. However, the costs of a depithing operation at a sugar factory were estimated to be approximately $2.1 million in capital expenditure to process 100,000 t/y of bagasse and operating costs were approximately $200,000 p.a. The total capital cost for a 10,000 t/y operation was approximately $1.6 million. The cost of depithing based on a discounted cash flow analysis was $5.50 per tonne of bagasse for the 100,000 t/y scenario. This may make depithing prohibitively expensive in many situations if installed exclusively as a dust control measure.

Globalization of science education : comment and a commentary

The globalized nature of modern society has generated a number of pressures that impact internationally on countries’ policies and practices of science education. Among these pressures are key issues of health and environment confronting global science, global economic control through multinational capitalism, comparative and competitive international testing of student science achievement, and the desire for more humane and secure international society. These are not all one-way pressures and there is evidence of both more conformity in the intentions and practices of science education and of a greater appreciation of how cultural differences, and the needs of students as future citizens can be met. Hence while a case for economic and competitive subservience of science education can be made, the evidence for such narrowing is countered by new initiatives that seek to broaden its vision and practices. The research community of science education has certainly widened internationally and this generates many healthy exchanges, although cultural styles of education other than Western ones are still insufficiently recognized. The dominance of English language within these research exchanges is, however, causing as many problems as it solves. Science education, like education as a whole, is a strongly cultural phenomenon, and this provides a healthy and robust buffer to the more negative effects of globalization

An analysis of holding cost impact on housing affordability in relation to midsized Greenfield residential property developments in South East Queensland

The position of housing demand and supply is not consistent. The Australian situation counters the experience demonstrated in many other parts of the world in the aftermath of the Global Financial Crisis, with residential housing prices proving particularly resilient. A seemingly inexorable housing demand remains a critical issue affecting the socio-economic landscape. Underpinned by high levels of population growth fuelled by immigration, and further buoyed by sustained historically low interest rates, increasing income levels, and increased government assistance for first home buyers, this strong housing demand level ensures problems related to housing affordability continue almost unabated. A significant, but less visible factor impacting housing affordability relates to holding costs. Although only one contributor in the housing affordability matrix, the nature and extent of holding cost impact requires elucidation: for example, the computation and methodology behind the calculation of holding costs varies widely - and in some instances completely ignored. In addition, ambiguity exists in terms of the inclusion of various elements that comprise holding costs, thereby affecting the assessment of their relative contribution. Such anomalies may be explained by considering that assessment is conducted over time in an ever-changing environment. A strong relationship with opportunity cost - in turn dependant inter alia upon prevailing inflation and / or interest rates - adds further complexity. By extending research in the general area of housing affordability, this thesis seeks to provide a detailed investigation of those elements related to holding costs specifically in the context of midsized (i.e. between 15-200 lots) greenfield residential property developments in South East Queensland. With the dimensions of holding costs and their influence over housing affordability determined, the null hypothesis H0 that holding costs are not passed on can be addressed. Arriving at these conclusions involves the development of robust economic and econometric models which seek to clarify the componentry impacts of holding cost elements. An explanatory sequential design research methodology has been adopted, whereby the compilation and analysis of quantitative data and the development of an economic model is informed by the subsequent collection and analysis of primarily qualitative data derived from surveying development related organisations. Ultimately, there are significant policy implications in relation to the framework used in Australian jurisdictions that promote, retain, or otherwise maximise, the opportunities for affordable housing.

A case of community safety : displacing complex ‘social’ problems in Fortitude Valley

Public dialogue regarding the high concentration of drug use and crime in inner city locations is frequently legitimised through visibility of drug-using populations and a perception of high crime rates. The public space known as the Brunswick Street Mall (Valley mall), located in the inner city Brisbane suburb of Fortitude Valley, has long provided the focal point for discussions regarding the problem of illicit drug use and antisocial behaviour in Brisbane. During the late 1990s a range of stakeholders in Fortitude Valley became mobilised to tackle crime and illicit drugs. In particular they wanted to dismantle popular perceptions of the area as representing the dark and unsafe side of Brisbane. The aim of this campaign was to instil a sense of safety in the area and dislodge Fortitude Valley from its reputation as a =symbolic location of danger‘. This thesis is a case study about an urban site that became contested by the diverse aims of a range of stakeholders who were invested in an urban renewal program and community safety project. This case study makes visible a number of actors that were lured from their existing roles in an indeterminable number of heterogeneous networks in order to create a community safety network. The following analysis of the community safety network emphasises some specific actors: history, ideas, technologies, materialities and displacements. The case study relies on the work of Foucault, Latour, Callon and Law to draw out the rationalities, background contingencies and the attempts to impose order and translate a number of entities into the community safety project in Fortitude Valley. The results of this research show that the community safety project is a case of ontological politics. Specifically the data indicates that both the (reality) problem of safety and the (knowledge) solution to safety were created simultaneously. This thesis explores the idea that while violence continues to occur in the Valley, evidence that community safety got done is located through mapping its displacement and eventual disappearance. As such, this thesis argues that community safety is a =collateral reality‘.

Low rank Runge-Kutta methods, symplecticity and stochastic Hamiltonian problems with additive noise

In this paper we extend the ideas of Brugnano, Iavernaro and Trigiante in their development of HBVM($s,r$) methods to construct symplectic Runge-Kutta methods for all values of $s$ and $r$ with $s\geq r$. However, these methods do not see the dramatic performance improvement that HBVMs can attain. Nevertheless, in the case of additive stochastic Hamiltonian problems an extension of these ideas, which requires the simulation of an independent Wiener process at each stage of a Runge-Kutta method, leads to methods that have very favourable properties. These ideas are illustrated by some simple numerical tests for the modified midpoint rule.

Co-management to solve homelessness : wicked solutions to wicked problems

While governments are engaged in developing social policy responses to address wicked issues such as poverty, homelessness, drug addiction and crime, long term resolution of these issues through government policy making and state-based programmatic action has remained elusive. The use of vehicles for joint action and partnership between government and the community sector such as co-management has been offered as a way of harnessing productive capability and innovative capacity of both these sectors to resolve these complex problems. However, it is suggested that while there is a well advanced agenda with the intent for collaboration and partnership, working with the models for undertaking this joint action are not well understood and have not been fully developed or evaluated. This chapter examines new approaches to resolving the wicked issue of homelessness through applying the lens of co-management to understand the complexities of this issue and its resolution. The chapter analyses an attempt to move away from traditional bureaucratic structures of welfare departments, operating through single functional ‘silos’ to a new horizontal ‘hub-based’ model of service delivery that seeks to integrate actors across many different service areas and organizations. The chapter explores case studies of co-management in the establishment, development and operation of service hubs to address homelessness. We argue that the response to homelessness needs a ‘wicked solution’ that goes beyond simply providing shelter to those in need. The case of the hub models of community sector organizations working across organizational boundaries is evaluated to determine whether this approach can be considered successful co-managing of an innovative initiative, and understanding the requirements for developing, improving and extending this model. The role of the third sector in co-managing public services is examined through the in-depth case studies and the results are presented together with an assessment of how co-management can contribute to service quality and service management in public services.

Hearing voice and silence during stressful economic times

Purpose - It is ironic that in stressful economic times, when new ideas and positive behaviors could be most valuable, employees may not speak up, leading to reduced employee participation, less organizational learning, less innovation and less receptiveness to change. The supervisor is the organization’s first line of defense against a culture of silence and towards a culture of openness. This research asks what helps supervisors to hear prosocial voice and notice defensive silence. Design/methodology/approach - We conducted a cross-sectional field study of 142 supervisors. Findings - Our results indicate that prosocial voice is increased by supervisor tension and trust in employees, while defensive silence is increased by supervisor tension but reduced by unionization of employees and trust in employees. This indicates that, as hypothesized by others, voice and silence are orthogonal and not opposites of the same construct. Research limitations/implications - The data is measured at one point in time, and further longitudinal study would be helpful to further understand the phenomena. Practical implications - This research highlights the potential for supervisors in stressful situations to selectively hear voice and silence from employees. Originality/value - This study adds to our knowledge of prosocial voice and defensive silence by testing supervisors’ perceptions of these constructs during difficult times. It provides valuable empirical insights to a literature dominated by conceptual non-empirical papers. Limited research on silence might reflect how difficult it is to study such an ambiguous and passive construct as silence (often simply viewed as a lack of speech). also contribute to trust literature by identifying its role in increasing supervisor’s perceptions of prosocial voice and reducing perceptions of defensive silence.

Problems in the assessment of magnesium depletion in the rat by in vivo 31P NMR

Prior in vitro studies, utilizing 31Pn uclear magnetic resonance (31PN MR) to measure the chemical shift (CT) of 0-ATP and lengthening of the phosphocreatine spin-spin (7"') relaxation time, suggested an assessment of their efficacy in measuring magnesium depletion in vivo. Dietary magnesium depletion (Me$) produced markedly lower magnesium in plasma (0.44 vs 1. I3 mmol/liter) and bone (1 30 vs 190 pmol/g) but much smaller changes in muscle (41 vs 45 pmol/g, P < 0.01), heart (42.5 vs 44.6 prnol/g), and brain (30 vs 32 pmollg). NMR experiments in anesthetized rats in a Bruker 7-T vertical bore magnet showed that in M e $ rats there was a significant change in brain j3-ATP shift (16.15 vs 16.03 ppm, P < 0.05). These chemical shifts gave a calculated free [Mg"] of 0.71 mM (control) and 0.48 mM (MgZ+$). In muscle the change in j3-ATP shift was not significant (Me$ 15.99 ppm, controls 15.96 ppm), corresponding to a calculated free M P of 0.83 and 0.95 mM, respectively. Phosphccreatine Tz (Carr-Purcell, spin-echo pulse sequence) was no different with M e $ in muscle in vivo (surface coil) (M$+$ 136, control 142 ms) or in isolated perfused hearts (Helmholtz coil) (control 83, M e $ 92 ms). 3'P NMR is severely limited in its ability to detect dietary magnesium depletion in vivo. Measurement of j3-ATP shift in brain may allow studies of the effects of interaction in group studies but does not allow prediction of an individual magnesium status.