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.

Competition Hertz : the culture and practice of car audio competitions

The present paper explores extreme car audio systems and the culture and practices that surround car audio competitions. I begin by examining whether, and how, car audio can be thought of as a 'music scene' and in what ways the culture and practice of car audio may fit within post-subcultural discourses. Following this, I offer a description of car audio competitions, revealing some of the practices that define this aspect of car audio scenes. In particular, I concentrate on sound pressure level (SPL) competitions and some of the interesting aspects of the SPL scene. Finally, I briefly examine how the powerful effects (and affects) of bass frequencies are an important part of the attraction of loud car audio systems and how car audio systems contribute to the territorializing of urban spaces.

Spatially-explicit modelling of grassland classes - an improved method of integrating a climate-based classification model with interpolated climate surfaces

Spatially-explicit modelling of grassland classes is important to site-specific planning for improving grassland and environmental management over large areas. In this study, a climate-based grassland classification model, the Comprehensive and Sequential Classification System (CSCS) was integrated with spatially interpolated climate data to classify grassland in Gansu province, China. The study area is characterized by complex topographic features imposed by plateaus, high mountains, basins and deserts. To improve the quality of the interpolated climate data and the quality of the spatial classification over this complex topography, three linear regression methods, namely an analytic method based on multiple regression and residues (AMMRR), a modification of the AMMRR method through adding the effect of slope and aspect to the interpolation analysis (M-AMMRR) and a method which replaces the IDW approach for residue interpolation in M-AMMRR with an ordinary kriging approach (I-AMMRR), for interpolating climate variables were evaluated. The interpolation outcomes from the best interpolation method were then used in the CSCS model to classify the grassland in the study area. Climate variables interpolated included the annual cumulative temperature and annual total precipitation. The results indicated that the AMMRR and M-AMMRR methods generated acceptable climate surfaces but the best model fit and cross validation result were achieved by the I-AMMRR method. Twenty-six grassland classes were classified for the study area. The four grassland vegetation classes that covered more than half of the total study area were "cool temperate-arid temperate zonal semi-desert", "cool temperate-humid forest steppe and deciduous broad-leaved forest", "temperate-extra-arid temperate zonal desert", and "frigid per-humid rain tundra and alpine meadow". The vegetation classification map generated in this study provides spatial information on the locations and extents of the different grassland classes. This information can be used to facilitate government agencies' decision-making in land-use planning and environmental management, and for vegetation and biodiversity conservation. The information can also be used to assist land managers in the estimation of safe carrying capacities which will help to prevent overgrazing and land degradation.

Determining safety climate factors in the repair, maintenance, minor alteration, and addition sector of Hong Kong

The accident record of the repair, maintenance, minor alteration, and addition (RMAA) sector has been alarmingly high; however, research in the RMAA sector remains limited. Unsafe behavior is considered one of the key causes of accidents. Thus, the organizational factors that influence individual safety behavior at work continue to be the focus of many studies. The safety climate, which reflects the true priority of safety in an organization, has drawn much attention. Safety climate measurement helps to identify areas for safety improvement. The current study aims to identify safety climate factors in the RMAA sector. A questionnaire survey was conducted in the RMAA sector in Hong Kong. Data were randomly split into the calibration and the validation samples. The RMAA safety climate factors were determined by exploratory factor analysis on the calibration sample. Three safety climate factors of the RMAA works were identified: (1) management commitment to occupational health and safety (OHS) and employee involvement, (2) application of safety rules and work practices, and; (3) responsibility for health and safety. Confirmatory factor analysis (CFA) was then conducted on the validation sample. The CFA model showed satisfactory goodness of fit, reliability, and validity. The suggested RMAA safety climate factors can be utilized by construction industry practitioners in developed economies to measure the safety climate of their RMAA projects, thereby enhancing the safety of RMAA works.

Extension of constructability to include operation and maintenance for infrastructure projects

This project was a step forward in developing an extension of the concept of constructability to include the post-occupancy stages of operation and maintenance. This was through an in-depth study of Australian health projects and interviews with professionals in the field. The thesis investigated how the operation and maintenance stakeholders can enter the initial planning, design and construction phases resulting in more efficient and effective delivery of infrastructure projects.

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).

Periprosthetic fracture torque for short versus standard cemented hip stems : an experimental in vitro study

In an attempt to preserve proximal femoral bone stock and achieve a better fit in smaller femora, especially in the Asian population, several new shorter stem designs have become available. We investigated the torque to periprosthetic femoral fracture of the Exeter short stem compared with the conventional length Exeter stem in a Sawbone model. 42 stems; 21 shorter and 21 conventional stems both with three different offsets were cemented in a composite Sawbone model and torqued to fracture. Results showed that Sawbone femurs break at a statistically significantly lower torque to failure with a shorter compared to conventional length Exeter stem of the same offset. Both standard and short stem designs are safe to use as the torque to failure is 7-10 times that seen in activities of daily living.

Open access to infinite content (or "in praise of law reviews")

This Article is about legal scholarly publication in a time of plenitude. It is an attempt to explain why the most pressing questions in legal scholarly publishing are about how we ensure access to an infinity of content. It explains why standard assumptions about resource scarcity in publication are wrong in general, and how the changes in the modality of publication affect legal scholarship. It talks about the economics of open access to legal material, and how this connects to a future where there is infinite content. And because student-edited law reviews fit this future better than their commercially-produced, peer-refereed cousins, this Article is, in part, a defense of the crazy-beautiful institution that is the American law review.

Feeding beliefs and practices of Chinese immigrant mothers : validation of a modified version of the child feeding questionnaire

The Child Feeding Questionnaire (CFQ) developed by Birch and colleagues (2001) is a widely used tool for measuring parental feeding beliefs, attitudes and practices. However, the appropriateness of the CFQ for use with Chinese populations is unknown. This study tested the construct validity of a novel Chinese version of the CFQ using confirmatory factor analysis (CFA). Participants included a convenience sample of 254 Chinese-Australian mothers of children aged 1-4 years. Prior to testing, the questionnaire was translated into Chinese using a translation-back-translation method, one item was re-worded to be culturally appropriate, a new item was added (monitoring), and five items that were not age-appropriate for the sample were removed. Based on previous literature, both a 7-factor and an 8-factor model were assessed via CFA. Results showed that the 8-factor model, which separated restriction and use of food rewards, improved the conceptual clarity of the constructs and provided a good fit to the data. Internal consistency of all eight factors was acceptable (Cronbach’s α: .60−.93). This modified 8-factor CFQ appears to be a linguistically and culturally appropriate instrument for assessing feeding beliefs and practices in Chinese-Australian mothers of young children.

Development of a dose assessment tool for the auditing of radiotherapy treatment dosimetric quality

The reporting and auditing of patient dose is an important component of radiotherapy quality assurance. The manual extraction of dose-volume metrics is time consuming and undesirable when auditing the dosimetric quality of a large cohort of patient plans. A dose assessment application was written to overcome this, allowing the calculation of various dose-volume metrics for large numbers of plans exported from treatment planning systems. This application expanded on the DICOM-handling functionality of the MCDTK software suite. The software extracts dose values in the volume of interest by using a ray casting point-in-polygon algorithm, where the polygons have been defined by the contours in the RTSTRUCT file...

Evaluating a model of parental influence on youth physical activity

Objective To test a conceptual model linking parental physical activity orientations, parental support for physical activity, and children's self-efficacy perceptions with physical activity participation. Participants and setting The sample consisted of 380 students in grades 7 through 12 (mean age, 14.0±1.6 years) and their parents. Data collection took place during the fall of 1996. Main outcome measures Parents completed a questionnaire assessing their physical activity habits, enjoyment of physical activity, beliefs regarding the importance of physical activity, and supportive behaviors for their child's physical activity. Students completed a 46-item inventory assessing physical activity during the previous 7 days and a 5-item physical activity self-efficacy scale. The model was tested via observed variable path analysis using structural equation modeling techniques (AMOS 4.0). Results An initial model, in which parent physical activity orientations predicted child physical activity via parental support and child self-efficacy, did not provide an acceptable fit to the data. Inclusion of a direct path from parental support to child physical activity and deletion of a nonsignificant path from parental physical activity to child physical activity significantly improved model fit. Standardized path coefficients for the revised model ranged from 0.17 to 0.24, and all were significant at the p<0.0001 level. Conclusions Parental support was an important correlate of youth physical activity, acting directly or indirectly through its influence on self-efficacy. Physical activity interventions targeted at youth should include and evaluate the efficacy of individual-level and community-level strategies to increase parents’ capacity to provide instrumental and motivational support for their children's physical activity.

Parameter estimation of thrust models of uninhabited airborne systems

This paper presents a method for the estimation of thrust model parameters of uninhabited airborne systems using specific flight tests. Particular tests are proposed to simplify the estimation. The proposed estimation method is based on three steps. The first step uses a regression model in which the thrust is assumed constant. This allows us to obtain biased initial estimates of the aerodynamic coeficients of the surge model. In the second step, a robust nonlinear state estimator is implemented using the initial parameter estimates, and the model is augmented by considering the thrust as random walk. In the third step, the estimate of the thrust obtained by the observer is used to fit a polynomial model in terms of the propeller advanced ratio. We consider a numerical example based on Monte-Carlo simulations to quantify the sampling properties of the proposed estimator given realistic flight conditions.

Self-determination as a moderator of demands and control : implications for employee strain and engagement

Does job control act as a stress-buffer when employees' type and level of work self-determination is taken into account? It was anticipated that job control would only be stress-buffering for employees high in self-determined and low in non-self-determined work motivation. In contrast, job control would be stress-exacerbating for employees who were low in self-determined and high in non-self-determined work motivation. Employees of a health insurance organization (N = 123) completed a survey on perceptions of role overload, job control, work self-determination, and a range of strain and engagement indicators. Results revealed that, when individuals high in self-determination perceived high job control, they experienced greater engagement (in the form of dedication to their work). In addition, when individuals high in non-self-determination perceived high job demands, they experienced more health complaints. A significant 3-way interaction demonstrated that, for individuals low in non-self-determination, high job control had the anticipated stress-buffering effect on engagement (in the form of absorption in their work). In addition, low job control was stress-exacerbating. However, contrary to expectations, for those high in non-self-determination, high job control was just as useful as low job control as a stress-buffer. The practical applications of these findings to the organizational context are discussed.

General self-efficacy influences affective task reactions during a work simulation : the temporal effects of changes in workload at different levels of control

This study investigated the effects of workload, control, and general self-efficacy on affective task reactions (i.e., demands-ability fit, active coping, and anxiety) during a work simulation. The main goals were: (1) to determine the extent general self-efficacy moderates the effects of demand and control on affective task reactions, and; (2) to determine if this varies as a function of changes in workload. Participants (N=141) completed an inbox activity under conditions of low or high control and within low and high workload conditions. The order of trials varied so that workload increased or decreased. Results revealed individuals with high general self-efficacy reported better demands-abilities fit and active coping as well as less anxiety. Three interactive effects were found. First, it was found that high control increased demands-abilities fit from trial 1 to trial 2, but only when workload decreased. Second, it was found that low efficacious individuals active coping increased in trial 2, but only under high control. Third, it was found that high control helped high efficacious individuals manage anxiety when workload decreased. However, for individuals with low general self-efficacy, neither high nor low control alleviated anxiety (i.e., whether workload increased or decreased over time).

Traffic incident clearance time and arrival time prediction based on hazard models

Accurate prediction of incident duration is not only important information of Traffic Incident Management System, but also an ffective input for travel time prediction. In this paper, the hazard based prediction odels are developed for both incident clearance time and arrival time. The data are obtained from the Queensland Department of Transport and Main Roads’ STREAMS Incident Management System (SIMS) for one year ending in November 2010. The best fitting distributions are drawn for both clearance and arrival time for 3 types of incident: crash, stationary vehicle, and hazard. The results show that Gamma, Log-logistic, and Weibull are the best fit for crash, stationary vehicle, and hazard incident, respectively. The obvious impact factors are given for crash clearance time and arrival time. The quantitative influences for crash and hazard incident are presented for both clearance and arrival. The model accuracy is analyzed at the end.