International transfer pricing : the Australian approach and lessons for Canada

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.

Nonprofit organisations in Australia : what do we know nine years later and what should we find out now?

I welcomed this chance to look back over the past nine years of third sector research in Australia and the opportunity to participate in this gathering to chart another nine years. There will be two parts to this paper. Part one will review what I said in 1991 (Lyons, 1991) and summarise what has happened since to see if my hopes were realised. Part two will attempt to sketch a framework for a research agenda, informed by the same motivation as my 1991 paper. It will conclude with some reflections about how to build a stronger institutional framework to sustain third sector research...

Volunteers :what we need to find out(and why we need to do it)

Public interest in volunteering in Australia has markedly escalated over the past five years, reflected in a number of publications in the popular, professional and academic press. This interest is welcome, and in many ways, is long overdue. Volunteers, or employing a term we find more useful, voluntarism is important for a number of reasons, not least of which is its structural role in the social institutions we have developed to support people, manage dependencies and facilitate a range of developmental activities across the life span. Voluntarism is an extremely complex social phenomenon. Conceptually, it transcends the sum of its parts, in that it is more than a simple aggregation of instances of individual behaviours. Our core argument here is that this complexity is such that equally intricate and multi-faceted perspectives and models need to be employed to further our understanding. In academic speak, this means that we need to develop analytical frameworks that draw on the breadth and depth of the social sciences...

Monte Carlo simulations of dynamic radiotherapy treatments

The effects of tumour motion during radiation therapy delivery have been widely investigated. Motion effects have become increasingly important with the introduction of dynamic radiotherapy delivery modalities such as enhanced dynamic wedges (EDWs) and intensity modulated radiation therapy (IMRT) where a dynamically collimated radiation beam is delivered to the moving target, resulting in dose blurring and interplay effects which are a consequence of the combined tumor and beam motion. Prior to this work, reported studies on the EDW based interplay effects have been restricted to the use of experimental methods for assessing single-field non-fractionated treatments. In this work, the interplay effects have been investigated for EDW treatments. Single and multiple field treatments have been studied using experimental and Monte Carlo (MC) methods. Initially this work experimentally studies interplay effects for single-field non-fractionated EDW treatments, using radiation dosimetry systems placed on a sinusoidaly moving platform. A number of wedge angles (60º, 45º and 15º), field sizes (20 × 20, 10 × 10 and 5 × 5 cm2), amplitudes (10-40 mm in step of 10 mm) and periods (2 s, 3 s, 4.5 s and 6 s) of tumor motion are analysed (using gamma analysis) for parallel and perpendicular motions (where the tumor and jaw motions are either parallel or perpendicular to each other). For parallel motion it was found that both the amplitude and period of tumor motion affect the interplay, this becomes more prominent where the collimator tumor speeds become identical. For perpendicular motion the amplitude of tumor motion is the dominant factor where as varying the period of tumor motion has no observable effect on the dose distribution. The wedge angle results suggest that the use of a large wedge angle generates greater dose variation for both parallel and perpendicular motions. The use of small field size with a large tumor motion results in the loss of wedged dose distribution for both parallel and perpendicular motion. From these single field measurements a motion amplitude and period have been identified which show the poorest agreement between the target motion and dynamic delivery and these are used as the „worst case motion parameters.. The experimental work is then extended to multiple-field fractionated treatments. Here a number of pre-existing, multiple–field, wedged lung plans are delivered to the radiation dosimetry systems, employing the worst case motion parameters. Moreover a four field EDW lung plan (using a 4D CT data set) is delivered to the IMRT quality control phantom with dummy tumor insert over four fractions using the worst case parameters i.e. 40 mm amplitude and 6 s period values. The analysis of the film doses using gamma analysis at 3%-3mm indicate the non averaging of the interplay effects for this particular study with a gamma pass rate of 49%. To enable Monte Carlo modelling of the problem, the DYNJAWS component module (CM) of the BEAMnrc user code is validated and automated. DYNJAWS has been recently introduced to model the dynamic wedges. DYNJAWS is therefore commissioned for 6 MV and 10 MV photon energies. It is shown that this CM can accurately model the EDWs for a number of wedge angles and field sizes. The dynamic and step and shoot modes of the CM are compared for their accuracy in modelling the EDW. It is shown that dynamic mode is more accurate. An automation of the DYNJAWS specific input file has been carried out. This file specifies the probability of selection of a subfield and the respective jaw coordinates. This automation simplifies the generation of the BEAMnrc input files for DYNJAWS. The DYNJAWS commissioned model is then used to study multiple field EDW treatments using MC methods. The 4D CT data of an IMRT phantom with the dummy tumor is used to produce a set of Monte Carlo simulation phantoms, onto which the delivery of single field and multiple field EDW treatments is simulated. A number of static and motion multiple field EDW plans have been simulated. The comparison of dose volume histograms (DVHs) and gamma volume histograms (GVHs) for four field EDW treatments (where the collimator and patient motion is in the same direction) using small (15º) and large wedge angles (60º) indicates a greater mismatch between the static and motion cases for the large wedge angle. Finally, to use gel dosimetry as a validation tool, a new technique called the „zero-scan method. is developed for reading the gel dosimeters with x-ray computed tomography (CT). It has been shown that multiple scans of a gel dosimeter (in this case 360 scans) can be used to reconstruct a zero scan image. This zero scan image has a similar precision to an image obtained by averaging the CT images, without the additional dose delivered by the CT scans. In this investigation the interplay effects have been studied for single and multiple field fractionated EDW treatments using experimental and Monte Carlo methods. For using the Monte Carlo methods the DYNJAWS component module of the BEAMnrc code has been validated and automated and further used to study the interplay for multiple field EDW treatments. Zero-scan method, a new gel dosimetry readout technique has been developed for reading the gel images using x-ray CT without losing the precision and accuracy.

Prediction of pull-out force of multi-walled carbon nanotube (MWCNT) in sword-in-sheath mode

The pull-out force of some outer walls against other inner walls in multi-walled carbon nanotubes (MWCNTs) was systematically studied by molecular mechanics simulations. The obtained results reveal that the pull-out force is proportional to the square of the diameter of the immediate outer wall on the sliding interface, which highlights the primary contribution of the capped section of MWCNT to the pull-out force. A simple empirical formula was proposed based on the numerical results to predict the pull-out force for an arbitrary pull-out in a given MWCNT directly from the diameter of the immediate outer wall on the sliding interface. Moreover, tensile tests for MWCNTs with and without acid-treatment were performed with a nanomanipulator inside a vacuum chamber of a scanning electron microscope (SEM) to validate the present empirical formula. It was found that the theoretical pull-out forces agree with the present and some previous experimental results very well.

Charitable grants and donations from maching gaming sources : Does it all work out in the wash up?

Material for this paper comes partly from a report commissioned by the Department of Family Services, Aboriginal and Islander Affairs. The report is the result of a multi-strategy research project designed to assess the impact of gaming machines on the fundraising capacity of charitable and community organisations in Queensland. The first Queensland gaming machine was commissioned on 11 February 1992. By 30 November 1994 there were: · 636 clubs operating 13,162 gaming machines · 436 hotels/taverns operating 3,468 gaming machines.1 It was anticipated that the introduction of gaming machines would impact on charities and community organisations. The adverse impacts would be through competition with charity gaming and disposable income that might otherwise be directed towards donations. Some also expressed concern that charities would be relied on to finance social services for problem gamblers. This paper seeks to describe the donations and grants derived by charities from Gaming Machine revenues. Such revenues primarily come from either government distributions from its gaming machine taxes and levies or gaming machine club donations. A final comment is made on the opinions of charitable fundraising professionals about the impact of gaming machine levies on club donations.

"Money pouring out of its ears" : on the taxation of really profitable nonprofit organisations in Australia

Under current law Australia appears to be a tax haven for certain non-governmental institutions. Millions of ordinary business income may go untaxed and the deductibility for donations is unlimited - both are very generous tax measures in an international context. The basic problems of most Australian nonprofit organisations are not taxation; they are just that: nonprofit. Anybody interested in the non-governmental sector should be willing to face the question: What is an equitable tax treatment? The short-term tactic of ducking the question may not be the best or most beneficial long term strategy.

A penalty-based grouping genetic algorithm for multiple composite SaaS components clustering in Cloud

Software as a Service (SaaS) in Cloud is getting more and more significant among software users and providers recently. A SaaS that is delivered as composite application has many benefits including reduced delivery costs, flexible offers of the SaaS functions and decreased subscription cost for users. However, this approach has introduced a new problem in managing the resources allocated to the composite SaaS. The resource allocation that has been done at the initial stage may be overloaded or wasted due to the dynamic environment of a Cloud. A typical data center resource management usually triggers a placement reconfiguration for the SaaS in order to maintain its performance as well as to minimize the resource used. Existing approaches for this problem often ignore the underlying dependencies between SaaS components. In addition, the reconfiguration also has to comply with SaaS constraints in terms of its resource requirements, placement requirement as well as its SLA. To tackle the problem, this paper proposes a penalty-based Grouping Genetic Algorithm for multiple composite SaaS components clustering in Cloud. The main objective is to minimize the resource used by the SaaS by clustering its component without violating any constraint. Experimental results demonstrate the feasibility and the scalability of the proposed algorithm.

Please take out your phones : on the spot solicitation of student feedback in class

The use of mobile devices such as smart phones and tablets in classrooms has been met with mixed sentiments. Some instructors and teachers see them as a distraction and regularly ban their usage. Others who see their potential to enhance learning have started to explore ways to integrate them into their teaching in an attempt to improve student engagement. In this paper we report on a pilot study that forms part of a university-wide project reconceptualising its approach to the student evaluation of learning and teaching. In a progressive decision to embrace mobile technology, the university decided to trial a smart phone app designed for students to check-in to class and leave feedback on the spot. Our preliminary findings from trialling the app indicate that the application establishes a more immediate feedback loop between students and teachers. However, the app’s impact depends on how feedback is shared with students and how the teaching team responds.

Review of 'Speaking Out: Stopping Homophobic and Transphobic Abuse In Queensland'

Speaking Out documents the outcomes of the largest ever study to examine homophobic and transphobic abuse and reporting in Queensland, Australia. It reports the results of a quantitative survey on victimisation of lesbian, gay, bisexual, transgender, intersex, and queer (LGBTIQ) people and how this victimisation is reported to police. Follow-up qualitative interviews and focus groups were also conducted with LGBTIQ people to examine the impact of this abuse and the reporting to police. This research is timely as we can sometimes assume LGBTIQ victimisation is a historical problem and may be settled by the idea that relations with police are in good shape. This book clearly demonstrates that we have some way to go before we can be assured these issues have been resolved...

Mental health and well-being in resident mine workers : out of the fly-in fly-out box

Objective: To explore psychosocial issues perceived to impact the mental health and well-being of resident (non-fly-in fly-out) mine workers at a local mine in regional Queensland. Design: A descriptive qualitative study using semistructured interviews. Setting: The research was conducted on-site at an opencut coal mine in regional Queensland. Participants: Ten miners (nine men) currently employed in workshop, production or supervisory roles. Main outcome measures: Self-reported issues affecting psychological well-being. Results: Participants’ occupation and the surrounding context appeared to have both positive and negative influences on their well-being. Overall findings could be grouped into four key themes: (i) the importance of relationships; (ii) the impact of lifestyle; (iii) work characteristics; and (iv) mental health attitudes. While not without strains on mental health, in general, participants reported that their current situation was superior to their previous mining jobs. This was attributed to close relationships among locally recruited workers, respect for management practices and rosters that allowed adequate sleep recovery and family time between shifts. Conclusions: This study is the first to examine mental health and well being in non-fly-in fly-out mining populations. It suggests that while some issues appear inherent in the mining occupation, personal and organisational support can help workers have a more positive workplace experience. Further work looking at more extensive comparisons over various mining contexts will greatly assist in the development of programs and support structures for rural and regional mine workers.