Transfer pricing: strategies, practices, and tax minimization

Using a survey of tax executives from multinational corporations, we document that some firms set their transfer pricing strategy to minimize tax payments, but more firms focus on tax compliance. We estimate that a firm focusing on minimizing taxes has a GAAP effective tax rate that is 6.6 percentage points lower and generates about $43 million more in tax savings, on average, than a firm focusing on tax compliance. Available COMPUSTAT data on sample firms confirm our survey‐based inferences. We also find that transfer pricing‐related tax savings are greater when higher foreign income, tax haven use, and R&D activities are combined with a tax minimization strategy. Finally, compliance‐focused firms report lower FIN 48 tax reserves than tax‐minimizing firms, consistent with the former group using less uncertain transfer pricing arrangements. Collectively, our study provides direct evidence that multinational firms have differing internal priorities for transfer pricing, and that these differences are strongly related to the taxes reported by these firms.First author draf

Differential Treatment in Environmental Law: Addressing Critiques and Conceptualizing the Next Steps

Differential treatment in international environmental law is the broader manifestation of the principle of common but differentiated responsibilities (CBDRs). It reflects equity concerns that have underlain most environmental debates on a North-South basis for several decades. Over the past couple of decades, different forms of differentiation have been introduced in environmental law instruments to the point where it has become an essential element of any international environmental agreement. At the same time, differential treatment has been the object of sustained criticism, arguing that it should be temporary, that it fails to target beneficiaries appropriately, and undermines environmental outcomes. This article takes the opposite view and argues that differentiation remains crucial in a world where widespread inequalities remain. Beneficiaries need to be identified on the basis of environmental and social indicators and differentiation should constitute the basis on which environmental measures are adopted. Worsening environmental conditions and an evolving global context call for adding new elements to the existing framework for differentiation. This requires thinking beyond the current structure centered around nation states and conceptualizing differentiation around common heritage equity. It also requires expanding differentiation beyond the field of environmental law, to include all areas of sustainable development law. Further, differential treatment needs to be implemented in a way that benefits the most disadvantaged in every country. These measures are necessary to foster a vibrant international environmental law that addresses the equity needs of all states in years to come

Seasonal Patterns of Invasive Pneumococcal Disease

Pneumococcal infections increase each winter, a phenomenon that has not been well explained. We conducted population-based active surveillance for all cases of invasive pneumococcal disease in seven states; plotted annualized weekly rates by geographic location, age, and latitude; and assessed correlations by time-series analysis. In all geographic areas, invasive pneumococcal disease exhibited a distinct winter seasonality, including an increase among children in the fall preceding that for adults and a sharp spike in incidence among adults each year between December 24 and January 7. Pneumococcal disease correlated inversely with temperature (r –0.82 with a 1-week lag; p<0.0001), but paradoxically the coldest states had the lowest rates, and no threshold temperature could be identified. The pattern of disease correlated directly with the sinusoidal variations in photoperiod (r +0.85 with a 5-week lag; p<0.0001). Seemingly unrelated seasonal phenomena were also somewhat correlated. The reproducible seasonal patterns in varied geographic locations are consistent with the hypothesis that nationwide seasonal changes such as photoperiod-dependent variation in host susceptibility may underlie pneumococcal seasonality, but caution is indicated in assigning causality as a result of such correlations

Biomorpher: interactive evolution for parametric design

Combining graph-based parametric design with metaheuristic solvers has to date focussed solely on performance based criteria and solving clearly defined objectives. In this paper, we outline a new method for combining a parametric modelling environment with an interactive Cluster-Orientated Genetic Algorithm (COGA). In addition to performance criteria, evolutionary design exploration can be guided through choice alone, with user motivation that cannot be easily defined. As well as numeric parameters forming a genotype, the evolution of whole parametric definitions is discussed through the use of genetic programming. Visualisation techniques that enable mixing small populations for interactive evolution with large populations for performance-based optimisation are discussed, with examples from both academia and industry showing a wide range of applications

Changes in muscle contractile characteristics and jump height following 24 days of unilateral lower limb suspension

We measured changes in maximal voluntary and electrically evoked torque and rate of torque development because of limb unloading. We investigated whether these changes during single joint isometric muscle contractions were related to changes in jump performance involving dynamic muscle contractions and several joints. Six healthy male subjects (21 ± 1 years) underwent 3 weeks of unilateral lower limb suspension (ULLS) of the right limb. Plantar flexor and knee extensor maximal voluntary contraction (MVC) torque and maximal rate of torque development (MRTD), voluntary activation, and maximal triplet torque (thigh; 3 pulses at 300 Hz) were measured next to squat jump height before and after ULLS. MVC of plantar flexors and knee extensors (MVCke) and triplet torque decreased by 12% (P = 0.012), 21% (P = 0.001) and 11% (P = 0.016), respectively. Voluntary activation did not change (P = 0.192). Absolute MRTD during voluntary contractions decreased for plantar flexors (by 17%, P = 0.027) but not for knee extensors (P = 0.154). Absolute triplet MRTD decreased by 17% (P = 0.048). The reduction in MRTD disappeared following normalization to MVC. Jump height with the previously unloaded leg decreased significantly by 28%. No significant relationships were found between any muscle variable and jump height (r < 0.48), but decreases in torque were (triplet, r = 0.83, P = 0.04) or tended to be (MVCke r = 0.71, P = 0.11) related to decreases in jump height. Thus, reductions in isometric muscle torque following 3 weeks of limb unloading were significantly related to decreases in the more complex jump task, although torque in itself (without intervention) was not related to jump performance

The flesh of painting: Caillebotte’s Modern Olympia

The language of putrefaction, often applied through a culinary analogy, appeared consistently in the critical reception of modern-life and Impressionist painting. For example, two critics used the term faisandé, referring to well-hung meat, to describe Manet’s nude figure of Olympia in 1865. The analogies that they posed between morgue bodies, female figures, meat, and fleshy paint material became central modes of denigrating Impressionist paintings of women in the ensuing decades. Gustave Caillebotte’s Veal in a Butcher’s Shop (c. 1882), depicting anthropomorphized, gendered, and sexualized animal flesh, can be considered in this context. In my reading, the painting enacts the critical responses to his colleagues’ figures, foregrounding the violent operations through which bodies might be reduced to meat, whether literal or metaphorical. In their comparisons to rotting flesh, nineteenth-century critics expressed a visceral reaction to works of art that Veal in a Butcher’s Shop demands

From tropical shelters to temperate defaunation: the relationship between agricultural transition stage and the distribution of threatened mammals

Aim Agriculture is a key threat to biodiversity, however its relationship with biodiversity patterns is understudied. Here, we evaluate how the extent, intensity, and history of croplands relate to the global distribution of threatened mammals. We propose two hypotheses to explain these relationships: shelter, which predicts that threatened species concentrate in areas with low human land use; and threat, according to which threatened species should concentrate in areas of high human land use. Location Global. Time period c.B.C.6000 - 2014. Major taxa studied Terrestrial mammals. Methods We used boosted regression trees (BRT) that include spatial autocorrelation to investigate the relationship between the proportion of threatened terrestrial mammals (as defined by the IUCN Red List) and multiple metrics describing agricultural extent, intensity and history derived from remote sensing data and statistical projections. Data were analysed with a grain size of ~110 x 110 km at both global and biogeographic-realm scales. Results Agricultural extent and intensity were the most relevant indicator types, with specific metrics important for each realm. Forest cover (extent) was identified as important in several regions. Tropical regions in early agricultural transition stages (e.g., frontier landscapes) were consistent with the shelter hypothesis, whereas patterns found for regions in later stages (e.g., intensified agricultural landscapes) were mostly found in temperate regions and agreed with the threat hypothesis. Main conclusions These results highlight the need to consider multiple land-use indicators when addressing threats to biodiversity and to separately assess areas with divergent human and ecological histories in global-scale studies. Different relationships associated with different agricultural transition stages suggest that high concentrations of threatened species may have contrasting meanings in different regions worldwide. We propose a new unifying hypothesis following a cyclic relationship along agricultural transition stages resulting in alternating negative and positive relationships between agriculture and threatened species richness