The taxation of multinational banking income : is the traditional rationale correct?

This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at meeting client global demand. The second distinguishing feature is the non-traditional organisational structure that is adopted. This structure, also designed to meet client global demand, introduces issues previously not recognised in the traditional taxation system, which is designed for the structure of traditional multinational entities. The unique differences between traditional multinational entities and multinational banks means there may be the need for a distinct international tax regime. It is argued that there are “outmoded economic assumptions” upon which the present tax laws relating to multinational banks are based. An examination of the unique nature of multinational banks leads to the conclusion that the appropriate tax treatment of these banks is different from the appropriate tax treatment of multinational entities generally.

The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Resourcing Early Learners : New Networks, New Actors

The landscape of early childhood education and care is changing. Governments world-wide are assuming increasing authority in relation to child-rearing in the years before school entry, beyond the traditional role in assisting parents to do the best they can by their children. As part of a social agenda aimed at forming citizens well prepared to play an active part in a globalised knowledge economy, the idea of ‘early learning’ expresses the necessity of engaging caregivers right from the start of children’s lives. Nichols, Rowsell, Rainbird, and Nixon investigate this trend over three years, in two countries, and three contrasting regions, by setting themselves the task of tracing every service and agent offering resources under the banner of early learning. Far from a dry catalogue, the study involves in-depth ethnographic research in fascinating spaces such as a church-run centre for African refugee women and children, a state-of-the-art community library and an Australian country town. Included is an unprecedented inventory of an entire suburban mall. Richly visually documented, the study employs emerging methods such as Google-mapping to trace the travels of actual parents as they search for particular resources. Each chapter features a context investigated in this large, international study: the library, the mall, the clinic, and the church. The author team unravels new spaces and new networks at work in early childhood literacy and development.

Viruses of banana in East Africa

Bananas are one of the world's most important food crops, providing sustenance and income for millions of people in developing countries and supporting large export industries. Viruses are considered major constraints to banana production, germplasm multiplication and exchange, and to genetic improvement of banana through traditional breeding. In Africa, the two most important virus diseases are bunchy top, caused by Banana bunchy top virus (BBTV), and banana streak disease, caused by Banana streak virus (BSV). BBTV is a serious production constraint in a number of countries within/bordering East Africa, such as Burundi, Democratic Republic of Congo, Malawi, Mozambique, Rwanda and Zambia, but is not present in Kenya, Tanzania and Uganda. Additionally, epidemics of banana streak disease are occurring in Kenya and Uganda. The rapidly growing tissue culture (TC) industry within East Africa, aiming to provide planting material to banana farmers, has stimulated discussion about the need for virus indexing to certify planting material as virus-free. Diagnostic methods for BBTV and BSV have been reported and, for BBTV, PCR-based assays are reliable and relatively straightforward. However for BSV, high levels of serological and genetic variability and the presence of endogenous virus sequences within the banana genome complicate diagnosis. Uganda has been shown to contain the greatest diversity in BSV isolates found anywhere in the world. A broad-spectrum diagnostic test for BSV detection, which can discriminate between endogenous and episomal BSV sequences, is a priority. This PhD project aimed to establish diagnostic methods for banana viruses, with a particular focus on the development of novel methods for BSV detection, and to use these diagnostic methods for the detection and characterisation of banana viruses in East Africa. A novel rolling-circle amplification (RCA) method was developed for the detection of BSV. Using samples of Banana streak MY virus (BSMYV) and Banana streak OL virus (BSOLV) from Australia, this method was shown to distinguish between endogenous and episomal BSV sequences in banana plants. The RCA assay was used to screen a collection of 56 banana samples from south-west Uganda for BSV. RCA detected at least five distinct BSV isolates in these samples, including BSOLV and Banana streak GF virus (BSGFV) as well as three BSV isolates (Banana streak Uganda-I, -L and -M virus) for which only partial sequences had been previously reported. These latter three BSV had only been detected using immuno-capture (IC)-PCR and thus were possible endogenous sequences. In addition to its ability to detect BSV, the RCA protocol was also demonstrated to detect other viruses within the family Caulimoviridae, including Sugar cane bacilliform virus, and Cauliflower mosaic virus. Using the novel RCA method, three distinct BSV isolates from both Kenya and Uganda were identified and characterised. The complete genome of these isolates was sequenced and annotated. All six isolates were shown to have a characteristic badnavirus genome organisation with three open reading frames (ORFs) and the large polyprotein encoded by ORF 3 was shown to contain conserved amino acid motifs for movement, aspartic protease, reverse transcriptase and ribonuclease H activities. As well, several sequences important for expression and replication of the virus genome were identified including the conserved tRNAmet primer binding site present in the intergenic region of all badnaviruses. Based on the International Committee on Taxonomy of Viruses (ICTV) guidelines for species demarcation in the genus Badnavirus, these six isolates were proposed as distinct species, and named Banana streak UA virus (BSUAV), Banana streak UI virus (BSUIV), Banana streak UL virus (BSULV), Banana streak UM virus (BSUMV), Banana streak CA virus (BSCAV) and Banana streak IM virus (BSIMV). Using PCR with species-specific primers designed to each isolate, a genotypically diverse collection of 12 virus-free banana cultivars were tested for the presence of endogenous sequences. For five of the BSV no amplification was observed in any cultivar tested, while for BSIMV, four positive samples were identified in cultivars with a B-genome component. During field visits to Kenya, Tanzania and Uganda, 143 samples were collected and assayed for BSV. PCR using nine sets of species-specific primers, and RCA, were compared for BSV detection. For five BSV species with no known endogenous counterpart (namely BSCAV, BSUAV, BSUIV, BSULV and BSUMV), PCR was used to detect 30 infections from the 143 samples. Using RCA, 96.4% of these samples were considered positive, with one additional sample detected using RCA which was not positive using PCR. For these five BSV, PCR and RCA were both useful for identifying infected samples, irrespective of the host cultivar genotype (Musa A- or B-genome components). For four additional BSV with known endogenous counterparts in the M. balbisiana genome (BSOLV, BSGFV, BSMYV and BSIMV), PCR was shown to detect 75 infections from the 143 samples. In 30 samples from cultivars with an A-only genome component there was 96.3% agreement between PCR positive samples and detection using RCA, again demonstrating either PCR or RCA are suitable methods for detection. However, in 45 samples from cultivars with some B-genome component, the level of agreement between PCR positive samples and RCA positive samples was 70.5%. This suggests that, in cultivars with some B-genome component, many infections were detected using PCR which were the result of amplification of endogenous sequences. In these latter cases, RCA or another method which discriminates between endogenous and episomal sequences, such as immuno-capture PCR, is needed to diagnose episomal BSV infection. Field visits were made to Malawi and Rwanda to collect local isolates of BBTV for validation of a PCR-based diagnostic assay. The presence of BBTV in samples of bananas with bunchy top disease was confirmed in 28 out of 39 samples from Malawi and all nine samples collected in Rwanda, using PCR and RCA. For three isolates, one from Malawi and two from Rwanda, the complete nucleotide sequences were determined and shown to have a similar genome organisation to previously published BBTV isolates. The two isolates from Rwanda had at least 98.1% nucleotide sequence identity between each of the six DNA components, while the similarity between isolates from Rwanda and Malawi was between 96.2% and 99.4% depending on the DNA component. At the amino acid level, similarities in the putative proteins encoded by DNA-R, -S, -M, - C and -N were found to range between 98.8% to 100%. In a phylogenetic analysis, the three East African isolates clustered together within the South Pacific subgroup of BBTV isolates. Nucleotide sequence comparison to isolates of BBTV from outside Africa identified India as the possible origin of East African isolates of BBTV.

Unsung heroes : African Americans and entrepreneurship

Prior to Emancipation, slave and free African Americans (A As) started and ran successful businesses. Events of the last century, such as the Great Migration north and the modernization of the American industry, created traditionally lower AA participation in entrepreneurship, and much of the history of successful AA entrepreneurs has been lost. Only now is AA participation in entrepreneurship returning to previously high levels. In this entry we review current literature on AA entrepreneurship and attempt to answer questions like "What is the history of AA entrepreneurship?" "What are the barriers?" "What interventions were attempted?" "What are the individual and collective AA success stories?" and “What is the future of AA entrepreneurship?"

Working in the Australian suburbs: Creative industries workers’ adaptation of traditional work spaces

The cultural and creative industries contribution to the economic and social sustainability of cities is a well acknowledged phenomenon which has accelerated in the era of urban renewal since the late twentieth century. The second-tier city of Brisbane, Australia was for many years considered a cultural backwater in the national context, yet its recent urban development within a short period of time has produced a city that now has all the hallmarks of a ‘creative city’. Brisbane’s transformation has been shaped by urban and cultural policies that are largely focussed around its inner-metropolitan localities, producing a growth in cultural infrastructure and the aestheticisation of inner-city precincts. However, like most Australian cities, the majority of Brisbane’s population live, and increasingly work in the suburbs. This article is based on a large research project that shows that creative industries workers are well represented across suburban localities. The article examines the policy and planning implications for creative industries located in Australian outer suburbs and the communities in which they are located.

As trajetorias de carreiras tradicionais estao dando passegem as proteanas? Um estudo com gereentes no setor public Australiano com foco em diferencas quanto ao genero ( Have traditional career paths given way to protean ones?: Evidence from senior managers in the Australian public sector)

Purpose – This mixed-method study aims to determine the extent to which the career paths of senior managers conform with the traditional versus protean elements described in the careers literature and whether these paths vary by gender. Design/methodology/approach – A total of 15 senior managers (seven women and eight men) in a large public sector agency in Australia were interviewed about their career trajectories to date. Data were coded according to four major areas which characterise and distinguish between traditional and protean careers: development, orientation of the employee, definition of success, and organisational environment. A total of 81 managers (34 women and 47 men) from the same organisation were also surveyed. Variables of interest were those that could be triangulated with qualitative data such as the availability of career opportunities. Findings – Results suggest that, contrary to much existing literature which proposes that all careers have been fundamentally altered, the traditional career which relies on length of service, geographic mobility and a steady climb up the corporate ladder, is still the dominant model in some organisations. However, the trend towards protean careers is evident and is more pronounced for women than for men. Research limitations/implications – The specific nature of the organisation (large, male-dominated, public sector) may limit the generalisability of results. Practical implications – The framework used to explore career paths according to traditional/ protean elements in this study may assist human resource practitioners to develop appropriate strategies which maximise the professional development of employees. Originality/value – The results of this research challenge the universality of change in the nature of careers, particularly in public sector environments.

Heterosexual and nonheterosexual young university students’ involvement in traditional and cyber forms of bullying

Research has consistently found that school students who do not identify as self-declared completely heterosexual are at increased risk of victimization by bullying from peers. This study examined heterosexual and nonheterosexual university students’ involvement in both traditional and cyber forms of bullying, as either bullies or victims. Five hundred twenty-eight first-year university students (M= 19.52 years old) were surveyed about their sexual orientation and their bullying experiences over the previous 12 months. The results showed that nonheterosexual young people reported higher levels of involvement in traditional bullying, both as victims and perpetrators, in comparison to heterosexual students. In contrast, cyberbullying trends were generally found to be similar for heterosexual and nonheterosexual young people. Gender differences were also found. The implications of these results are discussed in terms of intervention and prevention of the victimization of nonheterosexual university students.

Victims’ perceptions of traditional and cyberbullying, and the psychosocial correlates of their victimisation

It is well recognised that there are serious correlates for victims of traditional bullying. These have been shown to include increased levels of depression, anxiety and psychosomatic symptoms, in addition to often severe physical harm and even suicide. Bullied students also feel more socially ineffective; have greater interpersonal difficulties, together with higher absenteeism from school and lower academic competence. In the emerging field of cyberbullying many researchers have hypothesised a greater impact and more severe consequences for victims because of the 24/7 nature and the possibility of the wider audience with this form of bullying. However, to date there is scarce empirical evidence to support this. This study sought to compare victims’ perceptions of the harshness and impact of bullying by traditional and cyber means. The major findings showed that although students who had been victimised by traditional bullying reported that they felt their bullying was harsher, crueller and had more impact on their lives than those students who had been cyberbullied, the correlates of their mental health revealed that cyber victims reported significantly more social difficulties, higher anxiety levels and depression than traditional victims. The implications for school counsellors and mental health workers are discussed.