Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

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.

Globalization of science education : comment and a commentary

The globalized nature of modern society has generated a number of pressures that impact internationally on countries’ policies and practices of science education. Among these pressures are key issues of health and environment confronting global science, global economic control through multinational capitalism, comparative and competitive international testing of student science achievement, and the desire for more humane and secure international society. These are not all one-way pressures and there is evidence of both more conformity in the intentions and practices of science education and of a greater appreciation of how cultural differences, and the needs of students as future citizens can be met. Hence while a case for economic and competitive subservience of science education can be made, the evidence for such narrowing is countered by new initiatives that seek to broaden its vision and practices. The research community of science education has certainly widened internationally and this generates many healthy exchanges, although cultural styles of education other than Western ones are still insufficiently recognized. The dominance of English language within these research exchanges is, however, causing as many problems as it solves. Science education, like education as a whole, is a strongly cultural phenomenon, and this provides a healthy and robust buffer to the more negative effects of globalization

Does section 420A impose ‘strict liability’ upon controllers for acts or omissions of agents and experts?

This article addresses in depth the question of whether section 420A of the Corporations Act 2001 (Cth) imposes ‘strict liability’ upon a controller for the failure of an agent or expert to take reasonable care. The weight of existing authority appears to suggest that controllers are liable under s 420A for the carelessness of their agents or expert advisers. However, a closer analysis of the text of the provision and relevant Australian and UK case law demonstrates that this aspect of the statutory construction of s 420A remains very much an open question. This article ultimately contends for a construction of s 420A which requires a controller to adequately supervise and scrutinise, but which does not render a blameless controller strictly liable for all careless acts and omissions of agents and expert advisers.

Achieving quality improvement in the mask manufacturing industry by using Six Sigma technique

The Six Sigma technique is one of the quality management strategies and is utilised for improving the quality and productivity in the manufacturing process. It is inspired by the two major project methodologies of Deming’s "Plan – Do – Check – Act (PDCA)" Cycle which consists of DMAIC and DMADV. Those two methodologies are comprised of five phases. The DMAIC project methodology will be comprehensively used in this research. In brief, DMAIC is utilised for improving the existing manufacturing process and it involves the phases Define, Measure, Analyse, Improve, and Control. Mask industry has become a significant industry in today’s society since the outbreak of some serious diseases such as the Severe Acute Respiratory Syndrome (SARS), bird flu, influenza, swine flu and hay fever. Protecting the respiratory system, then, has become the fundamental requirement for preventing respiratory deceases. Mask is the most appropriate and protective product inasmuch as it is effective in protecting the respiratory tract and resisting the virus infection through air. In order to satisfy various customers’ requirements, thousands of mask products are designed in the market. Moreover, masks are also widely used in industries including medical industries, semi-conductor industries, food industries, traditional manufacturing, and metal industries. Notwithstanding the quality of masks have become the prioritisations since they are used to prevent dangerous diseases and safeguard people, the quality improvement technique are of very high significance in mask industry. The purpose of this research project is firstly to investigate the current quality control practices in a mask industry, then, to explore the feasibility of using Six Sigma technique in that industry, and finally, to implement the Six Sigma technique in the case company to develop and evaluate the product quality process. This research mainly investigates the quality problems of musk industry and effectiveness of six sigma technique in musk industry with the United Excel Enterprise Corporation (UEE) Company as a case company. The DMAIC project methodology in the Six Sigma technique is adopted and developed in this research. This research makes significant contribution to knowledge. The main results contribute to the discovering the root causes of quality problems in a mask industry. Secondly, the company was able to increase not only acceptance rate but quality level by utilising the Six Sigma technique. Hence, utilising the Six Sigma technique could increase the production capacity of the company. Third, the Six Sigma technique is necessary to be extensively modified to improve the quality control in the mask industry. The impact of the Six Sigma technique on the overall performance in the business organisation should be further explored in future research.

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

On 1 November 2011 the Minister for Financial Services and Superannuation, the Honourable Bill Shorten MP, announced that Australia would be undertaking a reform of the ‘transfer pricing rules in the income tax law and Australia’s future tax treaties to bring them into line with international best practice, improving the integrity and efficiency of the tax system.’ Mr Shorten stated that the reason for the reform was that ‘recent court decisions suggest our existing transfer pricing rules may be interpreted in a way that is out-of-kilter with international norms.’ Further, he stated that ‘the Government has asked the Treasury to review how the transfer pricing rules can be improved, including but not limited to how to be more in line with international best practice.’ He urged all interested parties to participate in this consultation process. On 16 March 2012, an Exposure Draft and accompanying Explanatory Memorandum outlining the proposed amendments to implement the first stage of the transfer pricing reforms were released. Within the proposed changes is the explicit embedding of the use of the OECD’s Model Tax Convention on Income and on Capital and Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to help determine the arm’s length price. Does this mean that Australia engages in an international tax regime?

The iatrogenic reflex and belief that repression can coercively suppress asymmetric coercive violence : does very robust action by the government decrease functional support for insurgents?

Non-state insurgent actors are too weak to compel powerful adversaries to their will, so they use violence to coerce. A principal objective is to grow and sustain violent resistance to the point that it either militarily challenges the state, or more commonly, generates unacceptable political costs. To survive, insurgents must shift popular support away from the state and to grow they must secure it. State actor policies and actions perceived as illegitimate and oppressive by the insurgent constituency can generate these shifts. A promising insurgent strategy is to attack states in ways that lead angry publics and leaders to discount the historically established risks and take flawed but popular decisions to use repressive measures. Such decisions may be enabled by a visceral belief in the power of coercion and selective use of examples of where robust measures have indeed suppressed resistance. To avoid such counterproductive behaviours the cases of apparent 'successful repression' must be understood. This thesis tests whether robust state action is correlated with reduced support for insurgents, analyses the causal mechanisms of such shifts and examines whether such reduction is because of compulsion or coercion? The approach is founded on prior research by the RAND Corporation which analysed the 30 insurgencies most recently resolved worldwide to determine factors of counterinsurgent success. This new study first re-analyses their data at a finer resolution with new queries that investigate the relationship between repression and insurgent active support. Having determined that, in general, repression does not correlate with decreased insurgent support, this study then analyses two cases in which the data suggests repression seems likely to be reducing insurgent support: the PKK in Turkey and the insurgency against the Vietnamese-sponsored regime after their ousting of the Khmer Rouge. It applies 'structured-focused' case analysis with questions partly built from the insurgency model of Leites and Wolf, who are associated with the advocacy of US robust means in Vietnam. This is thus a test of 'most difficult' cases using a 'least likely' test model. Nevertheless, the findings refute the deterrence argument of 'iron fist' advocates. Robust approaches may physically prevent effective support of insurgents but they do not coercively deter people from being willing to actively support the insurgency.

The utilization of waste date seed as bio-oil and activated carbon by pyrolysis process

The renovation of biomass waste in the form of date seed waste into activated carbon and biofuel by fixed bed pyrolysis reactor has been focused in this study to obtain gaseous, liquid, and solid products. The date seed in particle form is pyrolysed in an externally heated fixed bed reactor with nitrogen as the carrier gas. The reactor is heated from 400◦C to 600◦C. A maximum liquid yield of 50wt.% and char of 30wt.% are obtained at a reactor bed temperature of 500◦C with a running time of 120 minutes. The oil is found to possess favorable flash point and reasonable density and viscosity. The higher calorific value is found to be 28.636 MJ/kg which is significantly higher than other biomass derived. Decolonization of 85–97% is recorded for the textile effluent and 75–90% for the tannery effluent, in all cases decreasing with temperature increase. Good adsorption capacity of the prepared activated carbon in case of diluted textile and tannery effluent was found.

Context-aware multicast protocol for emergency message dissemination in vehicular networks

Road traffic accidents can be reduced by providing early warning to drivers through wireless ad hoc networks. When a vehicle detects an event that may lead to an imminent accident, the vehicle disseminates emergency messages to alert other vehicles that may be endangered by the accident. In many existing broadcast-based dissemination schemes, emergency messages may be sent to a large number of vehicles in the area and can be propagated to only one direction. This paper presents a more efficient context aware multicast protocol that disseminates messages only to endangered vehicles that may be affected by the emergency event. The endangered vehicles can be identified by calculating the interaction among vehicles based on their motion properties. To ensure fast delivery, the dissemination follows a routing path obtained by computing a minimum delay tree. The multicast protocol uses a generalized approach that can support any arbitrary road topology. The performance of the multicast protocol is compared with existing broadcast protocols by simulating chain collision accidents on a typical highway. Simulation results show that the multicast protocol outperforms the other protocols in terms of reliability, efficiency, and latency.

CO2 emissions from the combustion of native Australian trees

Carbon dioxide (CO2), as a primary product of combustion, is a known factor affecting climate change and global warming. In Australia, CO2 emissions from biomass burning are a significant contributor to total carbon in the atmosphere and therefore, it is important to quantify the CO2 emission factors from biomass burning in order to estimate their magnitude and impact on the Australian atmosphere. This paper presents the quantification of CO2 emission factors for five common tree species found in South East Queensland forests, as well as several grasses taken from savannah lands in the Northern Territory of Australia, under controlled ‘fast burning’ and ‘slow burning’ laboratory conditions. The results showed that CO2 emission factors varied according to the type of vegetation and burning conditions, with emission factors for fast burning being 2574 ± 254 g/kg for wood, 394 ± 40 g/kg for branches and leaves, and 2181 ± 120 g/kg for grass. Under slow burning conditions, the CO2 emission factors were 218 ± 20 g/kg for wood, 392± 80 g/kg for branches and leaves, and 2027 ± 809 g/kg for grass.

Nutritional intervention incorporating expedited 10g protein counter (EP-10) to improve the albumin and transferrin of chronic hemodialysis patients

Objective: The expedited 10g protein counter (EP-10) is a quick and valid clinical tool for dietary protein quantification. This study aims to assess the clinical effectiveness of the EP-10 in improving serum albumin and transferrin in chronic hemodialysis patients. Methods: Forty-five patients with low serum albumin (< 38 g /L) were enrolled in this study. Parameters measured included dry weight, height, dietary intake, and levels of serum albumin, transferrin, potassium, phosphate and kinetic modeling (Kt/v). The nutritional intervention incorporated the EP-10 in two ways (1)lto quantify protein intake of patients and (2)ito educate patients to meet their protein requirements. Mean values of the nutritional parameters before and after intervention were compared using paired t-test. Results: Three months after nutritional intervention, mean albumin levels increased significantly from 32.2+4.8g/L to 37.0+3.2g/L (p<0.001). Thirty-eight (84%) patients showed an increase in albumin levels while two (4%) maintained their levels. Of the thirty-six (80%) patients with low transferrin levels (<200 mg/dL), 28 (78%) had an increase and two maintained their levels post-intervention. Mean transferrin levels increased significantly from 169.4+39.9mg/dL to 180.9+38.1mg/dL (p< 0.05). Conclusion: Nutritional intervention incorporating the EP-10 method is able to make significant improvements to albumin and transferrin levels of chronic hemodialysis patients.

The interactions between insulin and androgens in progression to castrate resistant prostate cancer

An association between the metabolic syndrome and reduced testosterone levels has been identified, and a specific inverse relationship between insulin and testosterone levels suggests that an important metabolic crosstalk exists between these two hormonal axes; however, the mechanisms by which insulin and androgens may be reciprocally regulated are not well described. Androgen-dependant gene pathways regulate the growth and maintenance of both normal and malignant prostate tissue, and androgen-deprivation therapy (ADT) in patients exploits this dependence when used to treat recurrent and metastatic prostate cancer resulting in tumour regression. A major systemic side effect of ADT includes induction of key features of the metabolic syndrome and the consistent feature of hyperinsulinaemia. Recent studies have specifically identified a correlation between elevated insulin and high-grade PCa and more rapid progression to castrate resistant disease. This paper examines the relationship between insulin and androgens in the context of prostate cancer progression. Prostate cancer patients present a promising cohort for the exploration of insulin stabilising agents as adjunct treatments for hormone deprivation or enhancers of chemosensitivity for treatment of advanced prostate cancer.

Paradoxical roles of tumour necrosis factor-alpha in prostate cancer biology

Tumour necrosis factor (TNF) is a pleiotropic cytokine with dual roles in cancer biology including prostate cancer (PCa). On the one hand, there is evidence that it stimulates tumour angiogenesis, is involved in the initiation of PCa from an androgen-dependent to a castrate resistant state, plays a role in epithelial to mesenchymal plasiticity, and may contribute to the aberrant regulation of eicosanoid pathways. On the other hand, TNF has also been reported to inhibit neovascularisation, induce apoptosis of PCa cells, and stimulate anti-tumour immunity. Much of the confusion surrounding its seemingly paradoxical roles in cancer biology stems from the dependence of its effects on the biological model within which TNF is investigated. This review will address some of these issues, and also discuss on the therapeutic implications.