Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)

As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

Rights versus reality : the difficulty of providing 'access to English' in Queensland courts

This project reviewed the success of the Aboriginal English in the Courts booklet which was published by the Department of Justice and Attorney-General in 2000, with a view to improving access to the courts for speakers of Aboriginal English in Queensland. Surveys and interview were conducted with judges, magistrates, prosecutors, legal aid lawyers and courts registry staff. The feedback from the research has shown that the handbook has had little impact on ‘access to English’ in Queensland courts. The problems relate to the tension between protecting the rights of the accused under an adversarial system and legitimately introducing the issues of language uncertainty to the court in a non-prejudicial manner. In addition, the interviews have brought to light emerging language issues in remote communities that cannot be remedied under existing language policy mechanisms, such as the provision of interpreters or friends of court.

The NetWorkPlace(TM) Phenomenon: any time and any place - reality or a seductive myth?

A new spatial logic encompassing redefined concepts of time and place, space and distance, requires a comprehensive shift in the approach to designing workplace environments for today’s adaptive, collaborative organizations operating in a dynamic business world. Together with substantial economic and cultural shifts and an increased emphasis on lifestyle considerations, the advances in information technology have prompted a radical re-ordering of organizational relationships and the associated structures, processes, and places of doing business. Within the duality of space and an augmentation of the traditional notions of place, organizational and institutional structures pose new challenges for the design professions. The literature reveals that there has always been a mono-organizational focus in relation to workplace design strategies and the burgeoning trend towards inter-organizational collaboration, enabled the identification of a gap in the knowledge relative to workplace design. The NetWorkPlaceTM© constitutes a multi-dimensional concept having the capacity to deal with the fluidity and ambiguity characteristic of the network context, as both a topic of research and the way of going about it.

Reality Bytes: Using Technology in Mooting

This article considers how law schools can facilitate the development of technology skills by using technology to enhance access to mooting in settings that replicate legal practice. The authors conducted research into the use of technology by Australian law schools for mooting and evaluated an internal mooting competition using Elluminate, an online communication platform available to students through Blackboard. The analysis of the results of the survey and the Elluminate competition will demonstrate that technology can be used in mooting to provide an authentic learning experience. The paper concludes that while it is essential to teach technology skills as part of legal education, it is important that the benefits of using technology are made clear in order for it to be accepted and embraced by the students. Technology must also be available to all students considering the widening participation in higher education and consequent increasing diversity of law students.

Green leases : becoming a reality

Only a few years ago there were only a handful of buildings in Australia, mainly leased by or from the Commonwealth Government to which a green lease might have application. Now with the passing of the Building Energy Efficiency Disclosure Act 2010 (Cth) all commercial office premises in excess of 2000 square metres have 12 months from 1 November 2010 to obtain a Building Energy Efficiency Certificate as part of Stage 1 of the Federal Government’s National Framework for Energy Efficiency This significant change has focused attention on changes required to the conditions of leases where the building has a NABERS rating. This article considers material from the United Kingdom, the United States and Canada where there are similar policy changes in play and makes suggestions as to how certain clauses of a standard lease of a commercial office block may be altered to meet this new regime.

Evaluation of an Augmented Reality Collaborative Process Modelling System

Identifying, modelling and documenting business processes usually requires the collaboration of many stakeholders that may be spread across companies in inter-organizational business settings. While there are many process modelling tools available, the support they provide for remote collaboration is still limited. This paper investigates the application of virtual environment and augmented reality technologies to remote business process modelling, with an aim to assisting common collaboration tasks by providing an increased sense of immersion in a shared workspace. We report on the evaluation of a prototype system with five key informants. The results indicate that this approach to business process modelling is suited to remote collaborative task settings, and stakeholders may indeed benefit from using augmented reality interfaces.

Benign Epilepsy with Centro-temporal Spikes: Spike Triggered fMRI Shows Somato-sensory Cortex Activity

Summary:  Objective: We performed spike triggered functional MRI (fMRI) in a 12 year old girl with Benign Epilepsy with Centro-temporal Spikes (BECTS) and left-sided spikes. Our aim was to demonstrate the cerebral origin of her interictal spikes. Methods: EEG was recorded within the 3 Tesla MRI. Whole brain fMRI images were acquired, beginning 2–3 seconds after spikes. Baseline fMRI images were acquired when there were no spikes for 20 seconds. Image sets were compared with the Student's t-test. Results: Ten spike and 20 baseline brain volumes were analysed. Focal activiation was seen in the inferior left sensorimotor cortex near the face area. The anterior cingulate was more active during baseline than spikes. Conclusions: Left sided epileptiform activity in this patient with BECTS is associated with fMRI activation in the left face region of the somatosensory cortex, which would be consistent with the facial sensorimotor involvement in BECT seizures. The presence of BOLD signal change in other regions raises the possibility that the scalp recorded field of this patient with BECTs may reflect electrical change in more than one brain region.

A Kallikrein 15 (KLK15) single nucleotide polymorphism located close to a novel exon shows evidence of association with poor ovarian cancer survival

KLK15 over-expression is reported to be a significant predictor of reduced progression-free survival and overall survival in ovarian cancer. Our aim was to analyse the KLK15 gene for putative functional single nucleotide polymorphisms (SNPs) and assess the association of these and KLK15 HapMap tag SNPs with ovarian cancer survival. Results In silico analysis was performed to identify KLK15 regulatory elements and to classify potentially functional SNPs in these regions. After SNP validation and identification by DNA sequencing of ovarian cancer cell lines and aggressive ovarian cancer patients, 9 SNPs were shortlisted and genotyped using the Sequenom iPLEX Mass Array platform in a cohort of Australian ovarian cancer patients (N = 319). In the Australian dataset we observed significantly worse survival for the KLK15 rs266851 SNP in a dominant model (Hazard Ratio (HR) 1.42, 95% CI 1.02-1.96). This association was observed in the same direction in two independent datasets, with a combined HR for the three studies of 1.16 (1.00-1.34). This SNP lies 15bp downstream of a novel exon and is predicted to be involved in mRNA splicing. The mutant allele is also predicted to abrogate an HSF-2 binding site. Conclusions We provide evidence of association for the SNP rs266851 with ovarian cancer survival. Our results provide the impetus for downstream functional assays and additional independent validation studies to assess the role of KLK15 regulatory SNPs and KLK15 isoforms with alternative intracellular functional roles in ovarian cancer survival.

An invasive grass shows colonization advantages over native grasses under conditions of low resource availability

Increased or fluctuating resources may facilitate opportunities for invasive exotic plants to dominate. This hypothesis does not, however, explain how invasive species succeed in regions characterized by low resource conditions or how these species persist in the lulls between high resource periods. We compare the growth of three co-occurring C4 perennial bunchgrasses under low resource conditions: an exotic grass, Eragrostis curvula (African lovegrass) and two native grasses, Themeda triandra and Eragrostis sororia. We grew each species over 12 weeks under low nutrients and three low water regimes differentiated by timing: continuous, pulsed, and mixed treatments (switched from continuous to pulsed and back to continuous). Over time, we measured germination rates, time to germination (first and second generations), height, root biomass, vegetative biomass, and reproductive biomass. Contrary to our expectations that the pulsed watering regime would favor the invader, water-supply treatments had little significant effect on plant growth. We did find inherent advantages in a suite of early colonization traits that likely favor African lovegrass over the natives including faster germination speed, earlier flowering times, faster growth rates and from 2 weeks onward it was taller. African lovegrass also showed similar growth allocation strategies to the native grasses in terms of biomass levels belowground, but produced more vegetative biomass than kangaroo grass. Overall our results suggest that even under low resource conditions invasive plant species like African lovegrass can grow similarly to native grasses, and for some key colonization traits, like germination rate, perform better than natives.

Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment.

Interactive product browsing and configuration using remote augmented reality sales services

Real-time remote sales assistance is an underdeveloped component of online sales services. Solutions involving web page text chat, telephony and video support prove problematic when seeking to remotely guide customers in their sales processes, especially with configurations of physically complex artefacts. Recently, there has been great interest in the application of virtual worlds and augmented reality to create synthetic environments for remote sales of physical artefacts. However, there is a lack of analysis and development of appropriate software services to support these processes. We extend our previous work with the detailed design of configuration context services to support the management of an interactive sales session using augmented reality. We detail the context and configuration services required, presenting a novel data service streaming configuration information to the vendor for business analytics. We expect that a fully implemented configuration management service, based on our design, will improve the remote sales experience for both customers and vendors alike via analysis of the streamed information.

Verifying a Student Engagement, Success and Retention Maturity Model (SESR-MM): A reality check of the model using data derived from three universities

Australian higher education institutions (HEIs) have entered a new phase of regulation and accreditation which includes performance-based funding relating to the participation and retention of students from social and cultural groups previously underrepresented in higher education. However, in addressing these priorities, it is critical that HEIs do not further disadvantage students from certain groups by identifying them for attention because of their social or cultural backgrounds, circumstances which are largely beyond the control of students. In response, many HEIs are focusing effort on university-wide approaches to enhancing the student experience because such approaches will enhance the engagement, success and retention of all students, and in doing so, particularly benefit those students who come from underrepresented groups. Measuring and benchmarking student experiences and engagement that arise from these efforts is well supported by extensive collections of student experience survey data. However no comparable instrument exists that measures the capability of institutions to influence and/or enhance student experiences where capability is an indication of how well an organisational process does what it is designed to do (Rosemann & de Bruin, 2005). We have proposed that the concept of a maturity model (Marshall, 2010; Paulk, 1999) may be useful as a way of assessing the capability of HEIs to provide and implement student engagement, success and retention activities and we are currently articulating a Student Engagement, Success and Retention Maturity Model (SESR-MM), (Clarke, Nelson & Stoodley, 2012; Nelson, Clarke & Stoodley, 2012). Our research aims to address the current gap by facilitating the development of an SESR-MM instrument that aims (i) to enable institutions to assess the capability of their current student engagement and retention programs and strategies to influence and respond to student experiences within the institution; and (ii) to provide institutions with the opportunity to understand various practices across the sector with a view to further improving programs and practices relevant to their context. Our research extends the generational approach which has been useful in considering the evolutionary nature of the first year experience (FYE) (Wilson, 2009). Three generations have been identified and explored: First generation approaches that focus on co-curricular strategies (e.g. orientation and peer programs); Second generation approaches that focus on curriculum (e.g. pedagogy, curriculum design, and learning and teaching practice); and third generation approaches—also referred to as transition pedagogy—that focus on the production of an institution-wide integrated holistic intentional blend of curricular and co-curricular activities (Kift, Nelson & Clarke, 2010). Our research also moves beyond assessments of students’ experiences to focus on assessing institutional processes and their capability to influence student engagement. In essence, we propose to develop and use the maturity model concept to produce an instrument that will indicate the capability of HEIs to manage and improve student engagement, success and retention programs and strategies. The issues explored in this workshop are (i) whether the maturity model concept can be usefully applied to provide a measure of institutional capability for SESR; (ii) whether the SESR-MM can be used to assess the maturity of a particular set of institutional practices; and (iii) whether a collective assessment of an institution’s SESR capabilities can provide an indication of the maturity of the institution’s SESR activities. The workshop will be approached in three stages. Firstly, participants will be introduced to the key characteristics of maturity models, followed by a discussion of the SESR-MM and the processes involved in its development. Secondly, participants will be provided with resources to facilitate the development of a maturity model and an assessment instrument for a range of institutional processes and related practices. In the final stage of the workshop, participants will “assess” the capability of these practices to provide a collective assessment of the maturity of these processes. References Australian Council for Educational Research. (n.d.). Australasian Survey of Student Engagement. Retrieved from http://www.acer.edu.au/research/ausse/background Clarke, J., Nelson, K., & Stoodley, I. (2012, July). The Maturity Model concept as framework for assessing the capability of higher education institutions to address student engagement, success and retention: New horizon or false dawn? A Nuts & Bolts presentation at the 15th International Conference on the First Year in Higher Education, “New Horizons,” Brisbane, Australia. Department of Education, Employment and Workplace Relations. (n.d.). The University Experience Survey. Advancing quality in higher education information sheet. Retrieved from http://www.deewr.gov.au/HigherEducation/Policy/Documents/University_Experience_Survey.pdf Kift, S., Nelson, K., & Clarke, J. (2010) Transition pedagogy - a third generation approach to FYE: A case study of policy and practice for the higher education sector. The International Journal of the First Year in Higher Education, 1(1), pp. 1-20. Marshall, S. (2010). A quality framework for continuous improvement of e-Learning: The e-Learning Maturity Model. Journal of Distance Education, 24(1), 143-166. Nelson, K., Clarke, J., & Stoodley, I. (2012). An exploration of the Maturity Model concept as a vehicle for higher education institutions to assess their capability to address student engagement. A work in progress. Submitted for publication. Paulk, M. (1999). Using the Software CMM with good judgment, ASQ Software Quality Professional, 1(3), 19-29. Wilson, K. (2009, June–July). The impact of institutional, programmatic and personal interventions on an effective and sustainable first-year student experience. Keynote address presented at the 12th Pacific Rim First Year in Higher Education Conference, “Preparing for Tomorrow Today: The First Year as Foundation,” Townsville, Australia. Retrieved from http://www.fyhe.com.au/past_papers/papers09/ppts/Keithia_Wilson_paper.pdf

Practical considerations for integrating alternate reality gaming into science education

In this article, I present my experience with integrating an alternate reality gaming (ARG) framework into a pre-service science teacher education course. My goal is to provide an account of my experiences that can inform other science education practitioners at the tertiary and secondary levels that wish to adopt a similar approach in their classes. A game was designed to engage pre-service teachers with issues surrounding the declining enrolments in science, technology, engineering and mathematics disciplines (i.e., the STEM crisis; Tytler, 2007) and ways of re-engaging learners with STEM subjects. The use of ARG in science education is highly innovative. Literature on the use of ARG for educational purposes is scarce so in the article I have drawn on a range of available literature on gaming and ARG to define what it is and to suggest how it can be included in school science classrooms.