The inherent international tax regime and its constraints on Australia's sovereignty

Neither an international tax, nor an international taxing body exists. Rather, there are domestic taxing rules adopted by jurisdictions which, coupled with double tax treaties, apply to cross-border transactions and international taxation issues. International bodies such as the OECD and UN, which provide guidance on tax issues, often steer and supplement these domestic adoptions but have no binding international taxing powers. These pragmatic realities, together with the specific use of the word ‘regime’ within the tax community, lead many to argue that an international tax regime does not exist. However, an international tax regime should be defined no differently to any other area of international law and when we step outside the confines of tax law to consider the definition of a ‘regime’ within international relations it is possible to demonstrate that such a regime is very real. The first part of this article, by defining an international tax regime in a broader and more traditional context, also outlining both the tax policy and principles which frame that regime, reveals its existence. Once it is accepted that an international tax regime exists, it is possible to consider its adoption by jurisdictions and subsequent constraints it places on them. Using the proposed changes to transfer pricing laws as the impetus for assessing Australia’s adoption of the international tax regime, the constraints on sovereignty are assessed through a taxonomy of the level adoption. This reveals the subsequent constraints which flow from the broad acceptance of an international tax regime through to the specific adoption of technical detail. By undertaking this analysis, the second part of this article demonstrates that Australia has inherently adopted an international tax regime, with a move towards explicit adoption and a clear embedding of its principles within the domestic tax legislation.

Can a parent do too much for their child? An examination by parenting professionals of the concept of overparenting

Is there a point where parental effort can be too much? While the link between parenting effort and the wellbeing of children has been firmly established, contemporary discussion has proposed that extreme levels of parental protection of and responsiveness to children could be counterproductive. Research has not yet addressed this phenomenon to ascertain if overparenting is a genuinely different type of parenting approach. The purpose of the present study was to gain insight into the parenting actions considered by parenting professionals (psychologists and school guidance counsellors) to be overparenting. One hundred and twenty-eight professionals responded to an online survey about their observations of overparenting, with eighty-six respondents providing lists of the types of actions they believed were behavioural examples of the term. The survey data revealed that certain types of actions were considered to be indicative of overparenting, and that particular beliefs and outcomes may be involved in this parenting approach. Implications for parenting advice and education programs, and further research are discussed.

Safety impacts of alcohol and other drugs in construction : development of an industry policy and cultural change management program

There is increasing concern about the impact of employees‟ alcohol and other drug (AOD) consumption on workplace safety and performance, particularly within the construction industry. While most Australian jurisdictions have identified this as a critical safety issue, information is limited regarding the prevalence of AODs in the workplace and there is limited evidential guidance regarding how to effectively and efficiently address such an issue. The current research aims to scientifically evaluate the use of AODs within the Australian construction industry in order to reduce the potential resulting safety and performance impacts and engender a cultural change in the workforce - to render it unacceptable to arrive at a construction workplace with impaired judgement from AODs. The study will adopt qualitative and quantitative methods to firstly evaluate the extent of general AOD use in the industry. Secondly, the development of an appropriate industry policy will adopt a non-punitive and rehabilitative approach developed in consultation with employers and employees across the infrastructure and building sectors, with the aim it be adopted nationally for adoption at the construction workplace. Finally, an industry specific cultural change management program and implementation plan will be developed through a nationally collaborative approach. Final results indicate that a proportion of those sampled in the construction sector may be at risk of hazardous alcohol consumption. A total of 286 respondents (58%) scored above the cut-off cumulative score for risky or hazardous alcohol. Other drug use was also identified as a major issue. Results support the need for evidence-based, preventative educational initiatives that are tailored to the industry. This paper will discuss the final survey and interview results.

Success factors for ICT shared services in the higher education sector

Shared services is a prominent organizational arrangement for organizations, in particular for support functions. The success (or failure) of shared services is a critical concern as the move to shared services can entail large scale investment and involve fundamental organizational change. The Higher Education (HE) sector is particularly well poised to benefit from shared services as there is a need to improve organizational performance and strong potential from sharing. Through a multiple case study of shared services experiences in HE, this study identifies ten important antecedents of shared services success: (1) Understanding of shared services; (2) Organizational environment; (3) Top management support; (4) IT environment; (5) Governance; (6) Process centric view; (7) Implementation strategy; (8) Project management; (9) Change management; and (10) Communication. The study then develops a preliminary model of shared services success that addresses the interdependencies between the success factors. As the first empirical success model for shared services, it provides valuable guidance to practice and future research.

How can Australia sustain middle-schooling education?

Middle schooling is a crucial area of education where adolescents experiencing physiological and psychological hanges require expert guidance. As more research evidence is provided about adolescent learning, teachers are considered pivotal to adolescents’ educational development. The two levels of implementing reform measures need to be targeted, that is, at the inservice and preservice teacher levels. This quantitative study employs a 40-item, five-part Likert scale survey to understand preservice teachers’ (n=142) perceptions of their confidence to teach in the middle school at the conclusion of their tertiary education. The survey instrument was developed from the literature with connections to the Queensland College of Teachers professional standards. Results indicated that they perceived themselves as capable of creating a positive classroom environment with seven items greater than 80%, except with behaviour management (<80% for two items) and they considered their pedagogical knowledge to be adequate (i.e., 7 out of 8 items >84%). Items associated with implementing middle schooling curriculum had varied responses (e.g., implementing literacy and numeracy were 74% while implementing learning with real-world connections was 91%). This information may assist coursework designers. For example, if significant percentages of preservice teachers indicate they believe they were not well prepared for assessment and reporting in the middle school then course designers can target these areas more effectively.

Quantitative evaluation of matching methods and validity measures for stereo vision

The authors present a qualitative and quantitative comparison of various similarity measures that form the kernel of common area-based stereo-matching systems. The authors compare classical difference and correlation measures as well as nonparametric measures based on the rank and census transforms for a number of outdoor images. For robotic applications, important considerations include robustness to image defects such as intensity variation and noise, the number of false matches, and computational complexity. In the absence of ground truth data, the authors compare the matching techniques based on the percentage of matches that pass the left-right consistency test. The authors also evaluate the discriminatory power of several match validity measures that are reported in the literature for eliminating false matches and for estimating match confidence. For guidance applications, it is essential to have and estimate of confidence in the three-dimensional points generated by stereo vision. Finally, a new validity measure, the rank constraint, is introduced that is capable of resolving ambiguous matches for rank transform-based matching.

Optimising COBIT 5 for IT governance : examples from the public sector

Control Objectives for Information and related Technology (COBIT) has grown to be one of the most significant IT Governance (ITG) frameworks available and also the best suited for audit, as it provides comprehensive guidance around IT processes and related business goals. However, given the constraints of both time and resources within which the Australian public sector is forced to operate, implementing an audit framework the size of COBIT in its entirety is often considered too large a task. As an alternative to full implementation it is not uncommon for the public sector to “cherry pick” controls from the framework in an effort to reduce its size. This paper reports on research undertaken to evaluate the potential to use an optimised sub-set of COBIT 5 for ITG audit in Australian public sector organisations. A survey methodology was employed to determine the control-objectives considered to be the most important to a selection of public sector organisations. Twelve control-objectives were identified as being most important to Queensland public sector organisations. As ten of these were also identified by previous studies, it appears possible to derive an optimised sub-set from COBIT 5 that would be both enduring and relevant across geographical and organisational contexts.

Minimum important difference between patients with rheumatoid arthritis : the patient's perspective

OBJECTIVE: To determine the point at which differences in clinical assessment scores on physical ability, pain and overall condition are sufficiently large to correspond to a subjective perception of a meaningful difference from the perspective of the patient. METHODS: Forty patients with a diagnosis of rheumatoid arthritis participated in an evening of clinical assessment and one-on-one conversations with each other regarding their arthritic condition. The assessments included tender and swollen joint counts, clinician and patient global assessments, participant assessment of pain and the Health Assessment Questionnaire (HAQ) on physical ability. After each conversation, participants rated themselves relative to their conversational partner on physical ability, pain and overall condition. These subjective comparative ratings were compared to the differences of the individual clinical assessments. RESULTS: In total there were 120 conversations. Generally participants judged themselves as less disabled than others. They rated themselves as "somewhat better" than their conversation partner when they had a (mean) 7% better score on the HAQ, 6% less pain, and 9% better global assessment. In contrast, they rated themselves as "somewhat worse" when they had a (mean) 16% worse score on the HAQ, 16% more pain, and 29% worse global assessment. CONCLUSIONS: Patients view clinically important differences in an asymmetric manner. These results can provide guidance in interpreting results and planning clinical trials.

Positive experiences for participants in suicide bereavement groups : a grounded theory model of elements that contribute to the process of adjusting to the loss

Grounded Theory was used to examine the experiences of 13 participants who had attended psycho-educational support groups for those bereaved by suicide. Results demonstrated core and central categories which fit well with group therapeutic factors developed by Yalom (1995) and emphasised the importance of universality, imparting information and instilling hope, catharsis and self-disclosure, and broader meaning making processes surrounding acceptance or adjustment. Participants were commonly engaged in a lengthy process of oscillating between loss oriented and restoration focused reappraisals. The functional experience of the group comprised feeling normal within the group, providing a sense of permission to feel and to express emotions and thoughts and to bestow meaning. Structural variables of information and guidance and different perspectives on the suicide and bereavement were gained from other participants, the facilitators, group content and process. Personal changes, including in relationships and in their sense of self, assisted participants to develop an altered and more positive personal narrative.

Reasonable adjustments in assessment : putting law and policy into practice in Australia

The Australian Disability Standards for Education 2005 (Cth) require education providers to make reasonable adjustments in educational assessment so that students with disability can participate on the same basis as other students and be able to demonstrate what they know and can do. Reasonableness is governed by a determination of the balance of interests, benefits and detriment to the parties involved. The Standards require providers to consult with students and associates on adjustments, although guidance on how consultation should occur and how the views of students and associates are to be taken into account is vague. In this article, we identify three principles to be considered in order to put appropriate and effective reasonable adjustments in assessment into practice. While Australian law and assessment contexts are used to examine intentions, expectations and practices in educational assessment for students with disability, we argue that these three principles must be considered in any national education system to ensure equitable assessment practices and achieve equitable educational inclusion for students with disability.

Intercultural competence in engineering education : who are we teaching?

BACKGROUND There is little doubt that our engineering graduates’ ability to identify cultural differences and their potential to impact on engineering projects, and to work effectively with these differences is of key importance in the modern engineering practice. Within engineering degree programs themselves there is also a significant need to recognise the impact of changing student and staff profiles on what happens in the classroom. The research described in this paper forms part of a larger project exploring issues of intercultural competence in engineering. PURPOSE This paper presents an observational and survey study of undergraduate and postgraduate engineering students from four institutions working in groups on tasks with a purely technical focus, or with a cultural and humanitarian element. The study sought to explore how students rate their own intercultural competence and team process and whether any differences exist depending on the nature of the task they are working on. We also investigated whether any differences were evident between groups of first year, second year and postgraduate students. DESIGN/METHOD The study used the miniCQS instrument (Ang & Van Dyne, 2008) and a Bales Interaction Process Analysis based scale (Bales, 1950; Carney, 1976) to collect students self ratings of group process, task management, and cultural experience and behaviour. The Bales IPA was also used for coding video observations of students working in groups. Survey data were used to form descriptive variables to compare outcomes across the different tasks and contexts. Observations analysed in Nvivo were used to provide commentary and additional detail on the quantitative data. RESULTS The results of the survey indicated consistent mean scores on each survey item for each group of students, despite vastly different tasks, student backgrounds and educational contexts. Some small, statistically significant mean differences existed, offering some basic insights into how task and student group composition could affect self ratings. Overall though, the results suggest minimal shift in how students view group function and their intercultural experience, irrespective of differing educational experience. CONCLUSIONS The survey results, contrasted with group observations, indicate that either students are not translating their experience (in the group tasks) into critical self assessment of their cultural competence and teamwork, or that they become more critical of team performance and cultural competence as their competence in these areas grows, so their ratings remain consistent. Both outcomes indicate that students need more intensive guidance to build their critical self and peer assessment skills in these areas irrespective of their year level of study.

Proportionality of sanctions under the WADA Code : CAS jurisprudence and the need for a strict approach

This article suggests that the issue of proportionality in anti-doping sanctions has been inconsistently dealt with by the Court of Arbitration for Sport (CAS). Given CAS’s pre-eminent role in interpreting and applying the World Anti-Doping Code under the anti-doping policies of its signatories, an inconsistent approach to the application of the proportionality principle will cause difficulties for domestic anti-doping tribunals seeking guidance as to the appropriateness of their doping sanctions.

High load transit line passenger transmission and productiveness efficiencies

Performance of urban transit systems may be quantified and assessed using transit capacity and productive capacity in planning, design and operational management activities. Bunker (4) defines important productive performance measures of an individual transit service and transit line, which are extended in this paper to quantify efficiency and operating fashion of transit services and lines. Comparison of a hypothetical bus line’s operation during a morning peak hour and daytime hour demonstrates the usefulness of productiveness efficiency and passenger transmission efficiency, passenger churn and average proportion line length traveled to the operator in understanding their services’ and lines’ productive performance, operating characteristics, and quality of service. Productiveness efficiency can flag potential pass-up activity under high load conditions, as well as ineffective resource deployment. Proportion line length traveled can directly measure operating fashion. These measures can be used to compare between lines/routes and, within a given line, various operating scenarios and time horizons to target improvements. The next research stage is investigating within-line variation using smart card passenger data and field observation of pass-ups. Insights will be used to further develop practical guidance to operators.

High load transit line passenger transmission and productiveness efficiencies

Performance of urban transit systems may be quantified and assessed using transit capacity and productive capacity in planning, design and operational management activities. Bunker (4) defines important productive performance measures of an individual transit service and transit line, which are extended in this paper to quantify efficiency and operating fashion of transit services and lines. Comparison of a hypothetical bus line’s operation during a morning peak hour and daytime hour demonstrates the usefulness of productiveness efficiency and passenger transmission efficiency, passenger churn and average proportion line length traveled to the operator in understanding their services’ and lines’ productive performance, operating characteristics, and quality of service. Productiveness efficiency can flag potential pass-up activity under high load conditions, as well as ineffective resource deployment. Proportion line length traveled can directly measure operating fashion. These measures can be used to compare between lines/routes and, within a given line, various operating scenarios and time horizons to target improvements. The next research stage is investigating within-line variation using smart card passenger data and field observation of pass-ups. Insights will be used to further develop practical guidance to operators.

Spatio temporal feature evaluation for action recognition

Spatio-Temporal interest points are the most popular feature representation in the field of action recognition. A variety of methods have been proposed to detect and describe local patches in video with several techniques reporting state of the art performance for action recognition. However, the reported results are obtained under different experimental settings with different datasets, making it difficult to compare the various approaches. As a result of this, we seek to comprehensively evaluate state of the art spatio- temporal features under a common evaluation framework with popular benchmark datasets (KTH, Weizmann) and more challenging datasets such as Hollywood2. The purpose of this work is to provide guidance for researchers, when selecting features for different applications with different environmental conditions. In this work we evaluate four popular descriptors (HOG, HOF, HOG/HOF, HOG3D) using a popular bag of visual features representation, and Support Vector Machines (SVM)for classification. Moreover, we provide an in-depth analysis of local feature descriptors and optimize the codebook sizes for different datasets with different descriptors. In this paper, we demonstrate that motion based features offer better performance than those that rely solely on spatial information, while features that combine both types of data are more consistent across a variety of conditions, but typically require a larger codebook for optimal performance.