Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

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.

Anglican boarding school a hotbed of sexual punishment

THE little Anglican boarding school of St Barnabas, in the misty mountain town of Ravenshoe, north Queensland, was allegedly a hotbed of physical and sexual abuse in the 1960s. North Queensland Bishop Bill Ray has confirmed the diocese has few files about the school -- which was closed mid-term in 1990 -- with suspicions they were dumped "down a well or an old mine shaft" in the district A history of brutal physical punishment and sexual abuse at the school dating from the 1960s is now emerging. Headmaster Robert Waddington, who arrived at the school from England to be headmaster in 1961, dished out daily canings to many of his young students and then allegedly raped some behind closed doors in his room or the sick bay, which were next to each other. Former St Barnabas student Bim Atkinson, now 58, and two other former students have levelled allegations against the man they called "the Wadd".

The tertiary debate : a case study analysis of factors considered when applying for university entry by traditional age school leavers in Brisbane

Many interacting factors contribute to a student's choice of a university. This study takes a systems perspective of the choice and develops a Bayesian Network to represent and quantify these factors and their interactions. The systems model is illustrated through a small study of traditional school leavers in Australia, and highlights similarities and differences between universities' perceptions of student choices, students' perceptions of factors that they should consider and how students really make choices. The study shows the range of information that can be gained from this approach, including identification of important factors and scenario assessment.

Cell image classification using histograms, higher order statistics and adaboost

A cell classification algorithm that uses first, second and third order statistics of pixel intensity distributions over pre-defined regions is implemented and evaluated. A cell image is segmented into 6 regions extending from a boundary layer to an inner circle. First, second and third order statistical features are extracted from histograms of pixel intensities in these regions. Third order statistical features used are one-dimensional bispectral invariants. 108 features were considered as candidates for Adaboost based fusion. The best 10 stage fused classifier was selected for each class and a decision tree constructed for the 6-class problem. The classifier is robust, accurate and fast by design.

Choosing science : understanding the declines in senior high school science enrolments

'Choosing Science' reports on the most thorough study yet undertaken in Australia to investigate Year 10 students' decisions about whether to take science subjects. The study was well supported by ASTA members, with around 590 teachers and 3800 students participating. It examined teachers' views on the persistent declines in science enrolments, and students' perceptions of school science and aspirations towards further study and careers. The report discusses students' attitudes to science, their enrolment deliberations, sources of advice and recommendations for change. The report identifies the most likely and unlikely contributors to enrolment declines, and makes 10 recommendations.

School-based youth health nurses and adolescent decision-making concerning reproductive and sexual health advice : how can the law guide healthcare practitioners in this context?

This paper outlines some of the issues faced by School-Based Youth Health Nurses working in Queensland, in relation to the legal principles surrounding the provision of reproductive and sexual health advice. The paper outlines a number of specific issues faced by nurses working within this setting and considers the legal principles underpinning the issues concerning consent and confidentiality. The discussion in this paper demonstrates how the legal principles – which are often viewed as complex and uncertain by nurses working within this field – may be used as a guide to underpin good practice and compliance with the law. Although this paper is considered in the context of nurses working within Queensland, the principles and factors outlined are relevant to healthcare practitioners working within all Australian jurisdictions.

Accused cleric built reputation at small school in Australia

The little Anglican boarding school of St Barnabas, in the mountain town of Ravenshoe, north Queensland, was where Robert Waddington built his reputation as an educationalist. He was headmaster there from 1961-70, but a growing number of former pupils are now coming forward to say they were subjected to sexual and physical abuse by him. Bim Atkinson, 58, said that his ordeal began after he was sent to the school and joined the choir. “I was absolutely petrified of the man,” Mr Atkinson recalls. “After I joined the choir, the abuse started. He would tell me to go to the sickbay, which had a connecting door to his bedroom and then I would end up in his room.”

Accused cleric link to top music school probe

THE senior Anglican clergyman at the centre of an international child sex scandal was also a governor of a prestigious English music college that is under investigation for the alleged abuse of scores of its students across decades. Robert Waddington, who is alleged to have sexually assaulted students and choirboys in Britain and Australia, was a governor of the scandal-hit Chetham's School of Music for nine years. Waddington recruited students from the school for his choir at Manchester Cathedral, and allegedly abused at least three of the boys until he retired in 1993. The police investigation into the school, which began after the conviction in February of Michael Brewer, a former Chetham's music director, for the sexual abuse of female students, has not previously looked at Waddington. A victim has told The Weekend Australian that he was aware Waddington abused several boys from Chetham's who, like him, had been in the choir. The Cambridge University-educated business analyst, who has offered to give evidence under oath to police and the Church of England's inquiry into Waddington, said the clergyman had kept a collection of pictures in his house of boys he had abused.

Pulse-coupled neural network performance for real-time identification of vegetation during forced landing

Safety concerns in the operation of autonomous aerial systems require safe-landing protocols be followed during situations where the mission should be aborted due to mechanical or other failure. This article presents a pulse-coupled neural network (PCNN) to assist in the vegetation classification in a vision-based landing site detection system for an unmanned aircraft. We propose a heterogeneous computing architecture and an OpenCL implementation of a PCNN feature generator. Its performance is compared across OpenCL kernels designed for CPU, GPU, and FPGA platforms. This comparison examines the compute times required for network convergence under a variety of images to determine the plausibility for real-time feature detection.

Global characteristics of school transformation in China

In many ways, China’s education system is quite different from systems of education in the West. Rich descriptions of school transformation, however, have revealed that the factors that fuelled transformation in schools in China are also evident in schools in Australia, England, Finland, Wales and the United States. This paper draws on an international project that examined how secondary schools from six countries achieved success by developing and drawing on their resources, referred to as four forms of capital: financial, intellectual, social and spiritual. It describes how five secondary schools in Chongqing, Western China, viewed each form of capital and how the four forms of capital were strengthened and aligned through outstanding governance to support the success of all students. The case is made that, although some aspects of the forms of capital found in schools in China may be viewed differently, the approaches adopted by these schools share a number of common elements with approaches to school transformation identified in Western schools. It is argued that these common elements from a range of international settings constitute a rich evidence base for understanding school transformation and for new insights in governance and leadership.

Bridging the gap in school achievement through the arts : summary report

Educational Transformations Pty Ltd was commissioned by The Song Room (TSR) to conduct a study of the impact of TSR programs in government schools in relatively disadvantaged communities in New South Wales (NSW) on indicators of student performance that have been identified in previous research as related to potential engagement in juvenile crime. Students in Grades 5 and 6 were the subjects of study. TSR is a not-for-profit organisation in receipt of grants from public and private sources that conducts free programs in the performing arts in schools where these are not currently offered. These programs are conducted by mutual agreement between TSR and participating schools. Across Australia, approximately 200 schools and 40,000 students are engaged for a minimum of six months each year. Students typically participate for approximately one hour per week in each class. Instruction is provided by a Teaching Artist (TA), contracted to TSR and working in partnership with the classroom teacher at the school of placement. TSR received a three-year grant from the Macquarie Group Foundation to investigate the efficacy of its interventions in improving social and education outcomes for children in a range of high need target group areas participating in its program...