Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 1)

Formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. The conclusion that the unitary taxation model may be theoretically superior to the current arm's-length model that applies to multinational banks, despite significant implementation, compliance, and enforcement issues, is based on the unitary taxation model providing greater alignment with the unique features of these banks. The formulary apportionment model looks to the economic substance of the multinational entity and, in this sense, adopts a substance-over- form approach. Formulary apportionment further recognizes the impossibility of using arm's-length pricing for economically interdependent multinational entities. A final advantage to formulary apportionment, which is also a consequence of this model achieving greater inter-nation equity, is the elimination of double taxation.

Wilkins Hill : on the cusp of meaning

If contemporary artworks are often considered to be puzzles or riddles, then Wilkins Hill take this to a new level. Their recent exhibition Windows impersonating other windows, confronts viewers with an extremely ludic configuration: a spa bath full of almonds, towel racks placed before photos of Martin Heidegger distorted in neat grids, a video of a water tower in a Hamburg park, wooden cut-out speech bubbles and monitors that continuously play interviews with the artists themselves. What does it all mean?

Morphological design control for large-scale city development : a new proposal

Whereas many good examples can be found of the study of urban morphology informing the design of new residential areas in Europe, it is much more difficult to find examples relating to other land uses and outside of Europe. This paper addresses a particular issue, the control and coordination of large and complex development schemes within cities, and, in doing so, considers commercial and mixed-use schemes outside of Europe. It is argued that urban morphology has much to offer for both the design of such development and its implementation over time. Firstly, lessons are drawn from the work of Krier and Rossi in Berlin, the form-based guidance developed in Chelmsford, UK, and the redesign and coordination of the Melrose Arch project in Johannesburg, SA. A recent development at Boggo Road in Brisbane, Australia, is then subjected to a more detailed examination. It is argued that the scheme has been unsatisfactory in terms of both design and implementation. An alternative framework based on historical morphological studies is proposed that would overcome these deficiencies. It is proposed that this points the way to a general approach that could be incorporated within the planning process internationally.

Preparation and characterisation of composites from starch and sugar cane fibre

The aim of this study was to prepare and characterise composites of Soluble potato starch or hydroxypropylated maize starch with milled sugar cane fibre (i.e., bagasse). Prior to the preparation of the starch-fibre composites, the ‘cast’ and the ‘hot-pressed’ methods were investigated for the preparation of starch films in order to select the preferred preparation method. The physicochemical and mechanical properties of films conditioned at different relative humidities (RHs) were determined through moisture uptake, crystallinity, glass transition temperature (Tg), thermal properties, molecular structure and tensile tests. Hot-pressed starch films have ~5.5% less moisture, twice the crystallinity (~59%), higher Tg and Young’s modulus than cast starch films. The VH-type starch polymorph was observed to be present in the hot-pressed films. The addition of bagasse fibre to both starch types, prepared by hot-pressing, reduced the moisture uptake by up to 30% (cf., cast film) at 58% RH. The addition of 5 wt% fibre increased the tensile strength and Young’s modulus by 16% and 24% respectively. It significantly decreased the tensile strain by ~53%. Fourier Transform infrared (FT-IR) spectroscopy revealed differences in hydrogen bonding capacity between the films with fibre and those without fibre. The results have been explained on the basis of the intrinsic properties of starch and bagasse fibres.

Accounting for calibration uncertainty in phylogenetic estimation of evolutionary divergence times

The estimation of phylogenetic divergence times from sequence data is an important component of many molecular evolutionary studies. There is now a general appreciation that the procedure of divergence dating is considerably more complex than that initially described in the 1960s by Zuckerkandl and Pauling (1962, 1965). In particular, there has been much critical attention toward the assumption of a global molecular clock, resulting in the development of increasingly sophisticated techniques for inferring divergence times from sequence data. In response to the documentation of widespread departures from clocklike behavior, a variety of local- and relaxed-clock methods have been proposed and implemented. Local-clock methods permit different molecular clocks in different parts of the phylogenetic tree, thereby retaining the advantages of the classical molecular clock while casting off the restrictive assumption of a single, global rate of substitution (Rambaut and Bromham 1998; Yoder and Yang 2000).

The evolutionary history of the extinct ratite moa and New Zealand Neogene paleogeography

The ratite moa (Aves: Dinornithiformes) were a speciose group of massive graviportal avian herbivores that dominated the New Zealand (NZ) ecosystem until their extinction �600 years ago. The phylogeny and evolutionary history of this morphologically diverse order has remained controversial since their initial description in 1839. We synthesize mitochondrial phylogenetic information from 263 subfossil moa specimens from across NZ with morphological, ecological, and new geological data to create the first comprehensive phylogeny, taxonomy, and evolutionary timeframe for all of the species of an extinct order. We also present an important new geological/paleogeographical model of late Cenozoic NZ, which suggests that terrestrial biota on the North and South Island landmasses were isolated for most of the past 20–30 Ma. The data reveal that the patterns of genetic diversity within and between differentmoaclades reflect a complex history following a major marine transgression in the Oligocene, affected by marine barriers, tectonic activity, and glacial cycles. Surprisingly, the remarkable morphological radiation of moa appears to have occurred much more recently than previous early Miocene (ca. 15 Ma) estimates, and was coincident with the accelerated uplift of the Southern Alps just ca. 5–8.5 Ma. Together with recent fossil evidence, these data suggest that the recent evolutionary history of nearly all of the iconic NZ terrestrial biota occurred principally on just the South Island.

Getting stuck in together : improving work integrated learning from an Australian institution and faculty perspective

According to a recent report Australian higher education is not in crisis. However, we could be doing it better. The report Mapping Australian Higher Education (Norton, 2012) highlights comparative weaknesses such as levels f student engagement; interactions between students and academic staff; and academic staff preferences for research over teaching. The report points out that despite these concerns most graduates continue to get good, well-paid jobs, student satisfaction is improving, and levels of public confidence in Australian higher education are high. It also stresses that ‘the promise of higher education is that it provides adaptable cognitive skills, not that it always provides the job specific skills graduates will need in their future employment’ (Norton, 2012, p.58). This is worth keeping in mind as we contribute to the significant growth in curriculum initiatives aimed at preparing graduates for the world of work. Work Integrated Learning (WIL) is not a new concept but there is increased pressure on higher education globally to address graduate employability skills. The sector is under pressure in an increasingly competitive environment to demonstrate the relevance of courses, accountability and effective use of public funds (Peach & Gamble, 2011). In the Australian context this also means responding to the skills shortage in areas such as engineering, health, construction and business (DEEWR, 2010). This paper provides a brief overview of collaborative efforts over several years to improve the activity of WIL at the Queensland University of Technology (QUT). These efforts have resulted in changes to curriculum, pedagogy, systems and processes, and the initiation of local, regional, national, and international networks. The willingness of students, staff, and industry partners to ‘get stuck in’ and try new approaches in these different contexts can be understood as a form of boundary spanning. That is, the development of the capability to mediate between different forms of expertise and the demands of different contexts in order to nurture student learning and improve the outcomes of higher education through WIL (Peach, Cates, Ilg, Jones, Lechleiter, 2011).

Moisture uptake and tensile properties of starch-sugar cane fibre films

THERE is an increasing need for biodegradable plastics because they are environmentally friendly and can replace petroleum-based non-degradable plastics which pollute the environment. Starch-derived films reinforced with sugar cane bagasse fibre, which are biodegradable, have been prepared and characterised by gravimetric analysis for moisture uptake, X-ray powder diffraction for crystallinity, and tensile testing for mechanical properties. Results have shown that the addition of bagasse fibre (5 wt%, 10 wt% or 20 wt%) to either (modified) potato starch (Soluble starch) or hydroxypropylated maize starch reduced moisture uptake by up to 30% at 58% relative humidity (RH). Also, the tensile strength and the Young’s Modulus increased up to 63% and 80% respectively, with the maximum value obtained with 5 wt% fibre at 58% RH. However, the tensile strain of the films significantly decreased by up to 84%. The results have been explained based on the crystallinity of the films and the intrinsic properties of starch and bagasse fibres.

Real-time detection of concealed chemical hazards under ambient light conditions using Raman spectroscopy

Current concerns regarding terrorism and international crime highlight the need for new techniques for detecting unknown and hazardous substances. A novel Raman spectroscopy-based technique, spatially offset Raman spectroscopy (SORS), was recently devised for non-invasively probing the contents of diffusely scattering and opaque containers. Here, we demonstrate a modified portable SORS sensor for detecting concealed substances in-field under different background lighting conditions. Samples including explosive precursors, drugs and an organophosphate insecticide (chemical warfare agent surrogate) were concealed inside diffusely scattering packaging including plastic, paper and cloth. Measurements were carried out under incandescent and fluorescent light as well as under daylight to assess the suitability of the probe for different real-life conditions. In each case, it was possible to identify the substances against their reference Raman spectra in less than one minute. The developed sensor has potential for rapid detection of concealed hazardous substances in airports, mail distribution centers and customs checkpoints.

Resolution of the chiral (1R,2S) enantiomer of cis-cyclohexane-1,2-dicarboxylic acid in the brucinium salt 2,3-dimethoxy-10-oxostrychnidinium (1R,2S)-2-carboxycyclohexane-1-carboxylate dihydrate

The structure of the 1:1 brucinium salt of cis-cyclohexane-1,2-dicarboxylic acid, 2,3-dimethoxy-10-oxostrychnidinium (1R,2S)-2-carboxycyclohexane-1-carboxylate dihydrate, has revealed the resolved (1R,2S) enantiomer of the acid. Crystals of the compound are orthorhombic, space group P212121, with unit cell dimensions a = 8.1955(3), b = 12.4034(3), c = 29.9073(9)Å, and Z = 4. The asymmetric unit comprises the brucinium cation, the hydrogen cis-cyclohexane-1,2-dicarboxylate cation, in which the carboxylate group is disordered over two sites (58, 42%), and two water molecules of solvation, one of which is occupies two 50% occupancy sites. The classic undulating brucinium cation substructures are present with the anion and the water molecules occupying the interstitial cavities and are hydrogen-bonded to them in a two-dimensional network structure.

Developing targeted countermeasures to improve motorcycle safety

The fatality and injury rate of motorcyclists per registered vehicle are higher than those of other motor vehicles by 13 and 7 times respectively. The crash involvement rate of motorcyclists as a victim party is 58% at intersections and as an offending party is 67% at expressways. Previous research efforts showed that the motorcycle safety programs are not very effective in improving motorcycle safety. This is perhaps due to inefficient design of safety program as specific causal factors may not be well explored. The objective of this study is to propose more sophisticated countermeasures and awareness programs for improving motorcycle safety after analyzing specific causal factors for motorcycle crashes at intersections and expressways. Methodologically this study applies the binary logistic model to explore the at-fault or not-at-fault crash involvement of motorcyclists at those locations. A number of explanatory variables representing roadway characteristics, environmental factors, motorcycle descriptions, and rider demographics have been evaluated. Results shows that the night time crash occurrence, presence of red light camera, lane position, rider age, licence class, and multivehicle collision significantly affect the fault of motorcyclists involved in crashes at intersections. On the other hand, the night time crash occurrence, lane position, speed limit, rider age, licence class, engine capacity, riding with pillion passenger, foreign registered motorcycles, and multivehicle collision has been found to be significant at expressways. Legislate to wear reflective clothes and using reflective markings on the motorcycles and helmets are suggested as an effective countermeasure for reducing their vulnerability. The red light cameras at intersections reduce the vulnerability of motorcycles and hence motorcycle flow and motorcycle crashes should be considered during installation of red light cameras. At signalized intersections, motorcyclists may be taught to follow correct movement and queuing rather than weaving through the traffic as it leads them to become victims of other motorists. The riding simulators in the training centers can be useful to demonstrate the proper movement and queuing at junctions. Riding with pillion passenger and excess speed at expressways are found to significantly influence the at at-fault crash involvement of the motorcyclists. Hence the motorcyclists should be advised to concentrate more on riding while riding with pillion passenger and encouraged to avoid excess speed at expressways. Very young and very older group of riders are found to be at-fault than middle aged groups. Hence this group of riders should be targeted for safety improvement. This can be done by arranging safety talks and programs in motorcycling clubs in colleges and universities as well as community riding clubs with high proportion of elderly riders. It is recommended that the driving centers may use the findings of this study to include in licensure program to make motorcyclists more aware of the different factors which expose the motorcyclists to crash risks so that more defensive riding may be needed.

Effects of Mobile Phone Distraction at the Onset of Amber Light: Analysis of Driving Simulator Data

Distraction whilst driving on an approach to a signalized intersection is particularly dangerous, as potential vehicular conflicts and resulting angle collisions tend to be severe. This study examines the decisions of distracted drivers during the onset of amber lights. Driving simulator data were obtained from a sample of 58 drivers under baseline and handheld mobile phone conditions at the University of IOWA - National Advanced Driving Simulator. Explanatory variables include age, gender, cell phone use, distance to stop-line, and speed. An iterative combination of decision tree and logistic regression analyses are employed to identify main effects, non-linearities, and interactions effects. Results show that novice (16-17 years) and younger (18-25 years) drivers’ had heightened amber light running risk while distracted by cell phone, and speed and distance thresholds yielded significant interaction effects. Driver experience captured by age has a multiplicative effect with distraction, making the combined effect of being inexperienced and distracted particularly risky. Solutions are needed to combat the use of mobile phones whilst driving.

Work related musculoskeletal disorders amongst therapists in physically demanding roles: Qualitative analysis of risk factors and strategies for prevention

Background Physiotherapy and occupational therapy are two professions at high risk of work related musculoskeletal disorders (WRMD). This investigation aimed to identify risk factors for WRMD as perceived by the health professionals working in these roles (Aim 1), as well as current and future strategies they perceive will allow them to continue to work in physically demanding clinical roles (Aim 2). Methods A two phase exploratory investigation was undertaken. The first phase included a survey administered via a web based platform with qualitative open response items. The second phase involved four focus group sessions which explored topics obtained from the survey. Thematic analysis of qualitative data from the survey and focus groups was undertaken. Results Overall 112 (34.3%) of invited health professionals completed the survey; 66 (58.9%) were physiotherapists and 46 (41.1%) were occupational therapists. Twenty-four health professionals participated in one of four focus groups. The risk factors most frequently perceived by health professionals included: work postures and movements, lifting or carrying, patient related factors and repetitive tasks. The six primary themes for strategies to allow therapists to continue to work in physically demanding clinical roles included: organisational strategies, workload or work allocation, work practices, work environment and equipment, physical condition and capacity, and education and training. Conclusions Risk factors as well as current and potential strategies for reducing WRMD amongst these health professionals working in clinically demanding roles have been identified and discussed. Further investigation regarding the relative effectiveness of these strategies is warranted.