Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S. Petroleum Industry

Economic research on transfer-pricing behavior by multinational corporadons has emphasized theoretical modeling and institutional description. This paper presents the fiit systematic empirical analysis of transfer prices, using data from the petroleum industry. On the basis of oil imported into the United States over the period 1973 - 1984, we test two propositions: i) Are prices set by integrated companies for their internal transfers different from those prevailing in arm 's-length (i.e., inter-company) trade, when other variables, such as oil quality, are controlled for? ii) Do average effective corporate income tar rates explain observed patterns of transfer pricing? Regression analysis leads to the following conclusions: i) Transfer and arm's-length prices differ significantly for oil origznating in some countries but not all. When multiplied by the relevant import volumes, these differences are relatively smalL The revenue transferred through deviations from arm's-length prices represents two percent or less of the value of the crude oil imported by multinational companies each year. ii) The observed differences between arm's-length and transfer prices are not easily explained by average effective tax rates in exporting countries. Our results provide little support for the claim that multinational petroleum companies set their transfer prices to evade taxes. We offer several hypotheses to explain our findings.

The Internal Proper Motions Of Stars In The Open Cluster M35

Relative proper motions, based on 108 orbits of Hubble Space Telescope Fine Guidance Sensor data extending from 1992 to 2006, are reported for 74 stars in the open cluster M35 (NGC 2168). A subset of 22 of these objects are then used to compute the cluster's internal proper motion dispersions in both right ascension and declination. We find that these dispersions are equal to within their measurement errors. The average one-dimensional dispersion is 0.018 +/- 0.002 arcsec century(-1). When combined with the M35 radial velocity dispersion of 0.65 +/- 0.10 km s(-1) found by Geller et al., this produces a cluster distance of 762 +/- 145 pc. Using isochrone fits to the cluster main sequence, this distance suggests that M35 has an age of about 133 Myr. Although this age is consistent with that typically found for M35, the formal error in the dynamical distance of +/- 19% can accommodate ages between 65 Myr and 201 Myr.McDonald Observator

Indentor-escape, delamination and orogenic collapse of the ca. 600-500 Ma East African/Antarctic Orogen in Mozambique and Dronning Maud Land (East Antarctica)

The East African/Antarctic Orogen (EAAO) is one of the largest orogenic belts on the planet, resulting from the collision of various parts of East and West- Protogondwana between ca. 600 and 550 Ma. The central and southern parts of the orogen are typified by high-grade rocks, representing the overprinted margins of the various colliding continental blocks. New fieldwork and geochronology in northern Mozambique reveals a protracted polyphase Ediacaran/Cambrian deformation history. New age constraints reveal high-grade metamorphism at 600-550 Ma, overprinting and older basement

Lattice QCD at the end of 2003

I review recent developments in lattice QCD. I first give an overview of its formalism, and then discuss lattice discretizations of fermions. We then turn to a description of the quenched approximation and why it is disappearing as a vehicle for QCD phenomenology. I describe recent claims for progress in simulations which include dynamical fermions and the interesting theoretical problems they raise. I conclude with brief descriptions of the calculations of matrix elements in heavy flavor systems and for kaons.Comment: Review for Int J Mod Phys A. 58 pages, latex, WSPC macros,, 22 postscript figure

A minimum principle for superharmonic functions subject to interface conditions

AbstractLet D be a bounded domain in R2 with smooth boundary. Let B1, …, Bm be non-intersecting smooth Jordan curves contained in D, and let D′ denote the complement of ∪i − 1m Bi respect to D. Suppose that u ϵ C2(D′) ∩ C(D̄) and Δu ⩽ 0 in D′ (where Δ is the Laplacian), while across each “interface” Bi, i = 1,…, m, there is “continuity of flux” (as suggested by the theory of heat conduction). It is proved here that the presence of the interfaces does not alter the conclusions of the classical minimum principle (for Δu ⩽ 0 in D). The result is extended in several regards. Also it is applied to an elliptic free boundary problem and to the proof of uniqueness for steady-state heat conduction in a composite medium. Finally this minimum principle (which assumes “continuity of flux”) is compared with one due to Collatz and Werner which employs an alternative interface condition