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.

A spatial-indexing model for measuring neighbourhood-level land-use and transport integration

Significant attention has been given in urban policy literature to the integration of land-use and transport planning and policies���with a view to curbing sprawling urban form and diminishing externalities associated with car-dependent travel patterns. By taking land-use and transport interaction into account, this debate mainly focuses on how a successful integration can contribute to societal well-being, providing efficient and balanced economic growth while accomplishing the goal of developing sustainable urban environments and communities. The integration is also a focal theme of contemporary urban development models, such as smart growth, liveable neighbourhoods, and new urbanism. Even though available planning policy options for ameliorating urban form and transport-related externalities have matured���owing to growing research and practice worldwide���there remains a lack of suitable evaluation models to reflect on the current status of urban form and travel problems or on the success of implemented integration policies. In this study we explore the applicability of indicator-based spatial indexing to assess land-use and transport integration at the neighbourhood level. For this, a spatial index is developed by a number of indicators compiled from international studies and trialled in Gold Coast, Queensland, Australia. The results of this modelling study reveal that it is possible to propose an effective metric to determine the success level of city plans considering their sustainability performance via composite indicator methodology. The model proved useful in demarcating areas where planning intervention is applicable, and in identifying the most suitable locations for future urban development and plan amendments. Lastly, we integrate variance-based sensitivity analysis with the spatial indexing method, and discuss the applicability of the model in other urban contexts.

Air navigation services in Australia and the United States : a comparative case study

The central document governing the global organization of Air Navigation Services (ANS) is the Convention on International Civil Aviation, commonly referred to as the ���Chicago Convention,��� whose original version was signed in that city in 1944. In the Convention, Contracting States agreed to ensure the minimum standards of ANS established by ICAO, a specialized United Nations agency created by the Convention. Emanating from obligations under the Chicago Convention, ANS has traditionally provided by departments of national governments. However, there is a widespread trend toward transferring delivery of ANS services outside of line departments of national governments to independent agencies or corporations. The Civil Air Navigation Services Organisation (CANSO), which is the trade association for independent ANS providers, currently counts approximately 60 members, and is steadily growing. However, whatever delivery mechanisms are chosen, national governments remain ultimately responsible for ensuring that adequate ANS services are available. The provision by governments of ANS reflects the responsibility of the state for safety, international relations, and indirectly, the macroeconomic benefits of ensuring a sound infrastructure for aviation. ANS is a ���public good��� and an ���essential good��� provided to all aircraft using a country���s airfields and airspace. However, ANS also represents a service that directly benefits only a limited number of users, notably aircraft owners and operators. The idea that the users of the system, rather than the taxpaying public, should incur the costs associated with ANS provision is inherent in the commercialization process. However, ICAO sets out broad principles for the establishment of user charges, which member states are expected to comply with. ICAO states that only distance flown and aircraft weights are acceptable parameters for use in a charging system. These two factors are considered to be easy to measure, bear a reasonable relationship to the value of service received, and do not discriminate due to factors such as where the flight originated or the nation of aircraft registration.

Development of a Remote Sensing Core Curriculum submitted for the sessions on educational initiatives in Geoscience and Remote Sensing

A Remote Sensing Core Curriculum (RSCC) development project is currently underway. This project is being conducted under the auspices of the National Center for Geographic Information and Analysis (NCGIA). RSCC is an outgrowth of the NCGIA GIS Core Curriculum project. It grew out of discussions begun at NCGIA, Initiative 12 (I-12): 'Integration of Remote Sensing and Geographic Information Systems'. This curriculum development project focuses on providing professors, teachers and instructors in undergraduate and graduate institutions with course materials from experts in specific subject matter for areas use in the class room.

Remote sensing and core data needed to support planning and policy decision making

A variety of sustainable development research efforts and related activities are attempting to reconcile the issues of conserving our natural resources without limiting economic motivation while also improving our social equity and quality of life. Land use/land cover change, occurring on a global scale, is an aggregate of local land use decisions and profoundly impacts our environment. It is therefore the local decision making process that should be the eventual target of many of the ongoing data collection and research efforts which strive toward supporting a sustainable future. Satellite imagery data is a primary source of data upon which to build a core data set for use by researchers in analyzing this global change. A process is necessary to link global change research, utilizing satellite imagery, to the local land use decision making process. One example of this is the NASA-sponsored Regional Data Center (RDC) prototype. The RDC approach is an attempt to integrate science and technology at the community level. The anticipated result of this complex interaction between research and the decision making communities will be realized in the form of long-term benefits to the public.

Perceptions of online learning in an Australian university: an international students��� (Asian Region) perspective ��� enjoyment

Several researchers have reported that cultural and language differences can affect online interactions and communications between students from different cultural backgrounds. Other researchers have asserted that online learning is a tool that can improve teaching and learning skills, but its effectiveness depends on how the tool is used. To delve into these aspects further, this study set out to investigate the kinds of learning difficulties encountered by the international students and how they actually coped with online learning. The modified Online Learning Environment Survey (OLES) instrument was used to collect data from the sample of 109 international students at a university in Brisbane. A smaller group of 35 domestic students was also included for comparison purposes. Contrary to assumptions from previous research, the findings revealed that there were only few differences between the international Asian and Australian students with regards to their perceptions of online learning. Recommendations based on the findings of this research study were made for Australian universities where Asian international students study online. Specifically the recommendations highlighted the importance of upskilling of lecturers��� ability to structure their teaching online and to apply strong theoretical underpinnings when designing learning activities such as discussion forums, and for the university to establish a degree of consistency with regards to how content is located and displayed in a learning management system like Blackboard.

The Performance Nexus - A framework for improving energy efficiency in existing commercial buildings by considering a whole-of-building approach

Efforts to reduce carbon emissions in the buildings sector have been focused on encouraging green design, construction and building operation; however, the business case is not very compelling if considering the energy cost savings alone. In recent years green building has been driven by a sense that it will improve the productivity of occupants,i something with much greater economic returns than energy savings. Reducing energy demand in green commercial buildings in a way that encourages greater productivity is not yet well understood as it involves a set of complex and interdependent factors. This paper outlines an investigation into these factors and focuses on better understanding the performance of and interaction between: design elements, internal environmental quality, occupant experience, tenant/leasing agreements, and building regulation and management. In doing so the paper presents a framework for improving energy efficiency in existing commercial buildings by considering a range of interconnected and synergistic elements.

Genetic technologies and the regulation of reproductive decision-making in Australia

This article provides a critical analysis of the current Australian regulatory landscape at the interface between genetics and reproductive decision- making. The authors argue that a comparative analysis with other countries and international law and a contextual examination of the way law regulates concepts such as disease and health, abnormality and normality is necessary before we can develop appropriate policy and legislative responses in this area. Specific genetic testing technologies are considered including prenatal genetic testing, preimplantation genetic diagnosis and inheritable genetic modification. An increasing number of members of the Australian community are using genetic testing technologies when they decide to have a baby. The authors argue that as concepts of disease and health vary among members of the community and the potential to test for traits other than illness increases, a new tension arises between an ethic of individual choice and a role for government in regulating reproductive decision-making.

Regulating small things : genes, gametes and nanotechnology

Biotechnology and nanotechnology both intersect with other technologies in ways that open new possibilities for further technological progress. The potential for increased convergence between technological fields highlights the need for regulatory frameworks to be integrated, flexible and responsive. Within a federal legal system such as Australia���s, there is a need to ensure that we adopt a coordinated national approach to the crafting of regulatory solutions. In addition, there is a need for global cooperation in the development of international standards and regulatory harmonisation. Finally, this article considers the role that law plays in negotiating risk in relation to new technologies.

Globalising the body : globalisation and reproductive rights

Globalisation is a phenomenon of the contemporary world. Everywhere around us there seem to be signs of the power of the forces of globalisation: in our media and popular culture; in our international linkages across continents through international travel and telecommunications; in our globalised trade; and with the global movement of people, a process which itself ranges from the movement of international tourists to the international movement of refugees and other displaced persons. The processes of globalisation seem to simultaneously unify and divide us. There is no doubt that we live in a globalised world and that we are connected to others in previously unimaginable ways by transportation, telecommunications and economics. Yet, while this global context increasingly links us to others, there is also a very real sense in which separation, difference and the local have also gained a new significance; we are locked in a tension between the universal and the particular that has come to typify contemporary society. This article explores the meanings of globalisation and this dynamic ��� or tension ��� between the universal and the particular in terms of its implications for the body and, in particular, its significance for women and their reproductive rights.

Taxation determinations as de facto regulation : private equity exits in Australia

The Australian Taxation Office (AT)) attempted to challenge both the private equity fund reliance on double tax agreements and the assertion that profits were capital in nature in its dispute with private equity group TPG. Failure to resolve the dispute resulted in the ATO issuing two taxation determinations: TD 2010/20 which states that the general anti-avoidance provisions can apply to arrangements designed to alter the intended effect of Australia's international tax agreements net; and TD 2010/21 which states that the profits on the sale of shares in a company group acquired in a leveraged buyout is assessable income. The purpose of this article is to determine the effectiveness of the administrative rulings regime as a regulatory strategy. This article, by using the TPG-Myer scenario and subsequent tax determinations as a case study, collects qualitative data which is then analysed (and triangulated) using tonal and thematic analysis. Contemporaneous commentary of private equity stakeholders, tax professionals, and media observations are analysed and evaluated within a framework of responsive regulation and utilising the current ATO compliance model. Contrary to the stated purpose of the ATO rulings regime to alleviate complexities in Australian taxation law and provide certainty to taxpayers, and despite the de facto law status afforded these rulings, this study found that the majority of private equity stakeholders and their advisors perceived that greater uncertainty was created by the two determinations. Thus, this study found that in the context of private equity fund investors, a responsive regulation measure in the form of taxation determinations was not effective.

The project approach in early childhood education for sustainability : examplars from Korea and Australia

Sustainability is a global issue that urgently needs addressing, and for which the most serious consequences are for children and future generations. This insightful research text tackles one of the most significant contemporary issues of our times ��� the nexus between society and environment ��� and how early childhood education can contribute to sustainable living. By offering international and multidisciplinary research perspectives on Early Childhood Education for Sustainability, each chapter explores and investigates the complex topic of sustainability and its relationship to early childhood education. A particular emphasis that runs through this text is young children as empowered citizens, capable of both contributing to and creating change for sustainability. The chapter authors work from, or are aligned with, a transformative education paradigm that suggests the socio-constructivist frameworks currently underpinning Early Childhood Education require reframing in light of the social transformations necessary to address humanity���s unsustainable, unjust and unhealthy living patterns. This research text is designed to be provocative and challenging; in so doing it seeks to encourage exploration of current understandings about Early Childhood Education for Sustainability, offers new dimensions for more deeply informed practice, and proposes avenues for further research in this field.

Considering research enquiry into biophilic urbanism and office worker productivity

In cities, people spend a significant portion of their time indoors, much of which is in office buildings. The quality and nature of these spaces have the potential to be a strong determinant of people���s health and wellbeing. There is a body of evidence that suggests experiences of nature increase the rate of attention recovery, reduce stress, depression and anxiety, and increase cognitive abilities. Further, the presence of nature inside buildings (such as pot plants and internal green walls) can improve indoor air quality, potentially reducing illness and increasing cognitive function. Urban design that integrates nature into the built environment to provide these benefits, among others, is called ���biophilic urbanism��� and is the subject of growing international interest and research. The potential for these benefits to increase worker productivity in office buildings is of particular interest, as this could significantly increase the financial performance of office building-based organisations. However, productivity is a complex concept that is difficult to define, and affected by a multitude of factors, which make it difficult to measure. This inability to quantify productivity increases from investments in nature- experiences in office buildings is currently a significant barrier to such investments. Within this context, this paper considers opportunities for research to explore the relationship between office-based nature experiences and productivity, by reviewing existing research in this field and reflecting on the authors��� own experiences. This review has a particular focus on the importance of quantifying this link in order to encourage private property owners to voluntarily integrate nature into buildings to provide city-wide ecosystem service benefits. The paper begins with a contextual overview of how biophilic urbanism can potentially increase worker productivity. Existing methods of measuring and evaluating the performance of biophilic urbanism within the context of office buildings are then explored, along with a discussion of issues with such methods that are currently limiting investment in biophilic urbanism to increase worker productivity and wellbeing. This includes a summary of a survey within a Perth office building to explore the impact of views of nature through a window. Drawing on these insights, the paper makes recommendations regarding opportunities for focusing future investigations to enhance understanding of how biophilic urbanism can contribute to increased wellbeing and productivity in office buildings. This paper builds on work conducted as part of the Sustainable Built Environment National Research Centre Project 1.5, Harnessing the Potential of Biophilic Urbanism in Australia, which considered the role of nature integrated into the built environment in responding to emerging challenges of climate change, resource shortages and population pressures, while providing a host of co- benefits to a range of stakeholders.

Considering research enquiry into biophilic urbanism and office worker productivity

In cities, people spend a significant portion of their time indoors, much of which is in office buildings. The quality and nature of these spaces have the potential to be a strong determinant of people���s health and wellbeing. There is a body of evidence that suggests experiences of nature increase the rate of attention recovery, reduce stress, depression and anxiety, and increase cognitive abilities. Further, the presence of nature inside buildings (such as pot plants and internal green walls) can improve indoor air quality, potentially reducing illness and increasing cognitive function. Urban design that integrates nature into the built environment to provide these benefits, among others, is called ���biophilic urbanism��� and is the subject of growing international interest and research. The potential for these benefits to increase worker productivity in office buildings is of particular interest, as this could significantly increase the financial performance of office building-based organisations. However, productivity is a complex concept that is difficult to define, and affected by a multitude of factors, which make it difficult to measure. This inability to quantify productivity increases from investments in nature- experiences in office buildings is currently a significant barrier to such investments. Within this context, this paper considers opportunities for research to explore the relationship between office-based nature experiences and productivity, by reviewing existing research in this field and reflecting on the authors��� own experiences. This review has a particular focus on the importance of quantifying this link in order to encourage private property owners to voluntarily integrate nature into buildings to provide city-wide ecosystem service benefits. The paper begins with a contextual overview of how biophilic urbanism can potentially increase worker productivity. Existing methods of measuring and evaluating the performance of biophilic urbanism within the context of office buildings are then explored, along with a discussion of issues with such methods that are currently limiting investment in biophilic urbanism to increase worker productivity and wellbeing. This includes a summary of a survey within a Perth office building to explore the impact of views of nature through a window. Drawing on these insights, the paper makes recommendations regarding opportunities for focusing future investigations to enhance understanding of how biophilic urbanism can contribute to increased wellbeing and productivity in office buildings. This paper builds on work conducted as part of the Sustainable Built Environment National Research Centre Project 1.5, Harnessing the Potential of Biophilic Urbanism in Australia, which considered the role of nature integrated into the built environment in responding to emerging challenges of climate change, resource shortages and population pressures, while providing a host of co- benefits to a range of stakeholders.

Translations of industry-based student learning and academic performances

We hypothesized that Industry based learning and teaching, especially through industry assigned student projects or training programs, is an integral part of science, technology, engineering and mathematics (STEM) education. In this paper we show that industry-based student training and experience increases students��� academic performances independent to the organizational parameters and contexts. The literature on industry-based student training focuses on employability and the industry dimension, and neglects in many ways the academic dimension. We observed that the association factors between academic attributes and contributions of industry-based student training are central and vital to the technological learning experiences. We explore international initiatives and statistics collected of student projects in two categories: Industry based learning performances and on campus performances. The data collected were correlated to five (5) universities in different industrialized countries, e.g., Australia N=545, Norway N=279, Germany N=74, France N=107 and Spain N=802 respectively. We analyzed industry-based student training along with company assigned student projects compared with in comparisons to campus performance. The data that suggests a strong correlation between industry-based student training per se and improved performance profiles or increasing motivation shows that industry-based student training increases student academic performance independent of organizational parameters and contexts. The programs we augmented were orthogonal to each other however, the trend of the students��� academic performances are identical. An isolated cohort for the reported countries that opposed our hypothesis warrants further investigation.