The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad

Migration of intangible assets from the United States to foreign countries has become easier due to the ability of U.S. firms to create hybrid entities in their affiliates abroad and to reach favorable cost sharing agreements with them. This strategy was particularly encouraged by the U.S. adoption of "check-the-box" regulations in 1997. Rather than receive royalties from affiliates abroad, US parent firms have an incentive to retain abroad in low-tax countries a greater share of the return to their US R&D. Evidence from several sources for years that span the 1997 policy change indicate a significant response by US corporations in utilizing this strategy. BEA data indicate affiliate earnings and profits grew more rapidly than royalty payments to US parents. Payments to U.S. parents for technical services rose even faster, as would be called for under cost sharing agreements. Regression analysis of affiliate data shows that parent R&D was a more important determinant of royalty payments to U.S. parents than it was for affiliate earnings and profits in 1996, but by 2002 it played a larger role in earnings and profits than in royalties. Cost sharing payments from affiliates in Ireland and from pure tax havens (Bermuda, the Cayman Islands, and Luxembourg) are particularly significant, both economically and statistically.

A perspective on multinational enterprise’s national identity dilemma

This conceptual paper identifies gaps and contributes to the literature on ‘identity’ dilemmas faced by multinational enterprises operating in a globalised world. Various characteristics and business strategies of multinational enterprises are delineated and analysed through the lens of social identity theory and international business concepts such as market and institutional logic. Our analysis, based on multiple cases, and derived from a variety of industries and countries, associates the identity dilemma to informed business strategy. Our findings suggest that while multinational enterprises face identity dilemmas that they sometimes use to their advantage, it also poses several challenges. Through our conceptualisation, we derive five distinct propositions to shape future research directions

Detection of regulator genes and eQTLs in gene networks

Genetic differences between individuals associated to quantitative phenotypic traits, including disease states, are usually found in non-coding genomic regions. These genetic variants are often also associated to differences in expression levels of nearby genes (they are "expression quantitative trait loci" or eQTLs for short) and presumably play a gene regulatory role, affecting the status of molecular networks of interacting genes, proteins and metabolites. Computational systems biology approaches to reconstruct causal gene networks from large-scale omics data have therefore become essential to understand the structure of networks controlled by eQTLs together with other regulatory genes, and to generate detailed hypotheses about the molecular mechanisms that lead from genotype to phenotype. Here we review the main analytical methods and softwares to identify eQTLs and their associated genes, to reconstruct co-expression networks and modules, to reconstruct causal Bayesian gene and module networks, and to validate predicted networks in silico.Comment: minor revision with typos corrected; review article; 24 pages, 2 figure

Grand Challenges in Immersive Analytics

The definitive version will be published in CHI 2021, May 8–13, 2021, Yokohama, JapanInternational audienceImmersive Analytics is a quickly evolving field that unites several areas such as visualisation, immersive environments, and humancomputer interaction to support human data analysis with emerging technologies. This research has thrived over the past years with multiple workshops, seminars, and a growing body of publications, spanning several conferences. Given the rapid advancement of interaction technologies and novel application domains, this paper aims toward a broader research agenda to enable widespread adoption. We present 17 key research challenges developed over multiple sessions by a diverse group of 24 international experts, initiated from a virtual scientific workshop at ACM CHI 2020. These challenges aim to coordinate future work by providing a systematic roadmap of current directions and impending hurdles to facilitate productive and effective applications for Immersive Analytics

Market access agreements for pharmaceuticals in Europe: diversity of approaches and underlying concepts

<p>Abstract</p> <p>Background</p> <p>Market Access Agreements (MAA) between pharmaceutical industry and health care payers have been proliferating in Europe in the last years. MAA can be simple discounts from the list price or very sophisticated schemes with inarguably high administrative burden.</p> <p>Discussion</p> <p>We distinguished and defined from the health care payer perspective three kinds of MAA: Commercial Agreements (CA), Payment for Performance Agreements (P4P) and Coverage with Evidence Development (CED). Apart from CA, the agreements assumed collection and analysis of real-life health outcomes data, either from a cohort of patients (CED) or on per patient basis (P4P). We argue that while P4P aim at reducing drug cost to payers without a systematic approach to addressing uncertainty about drugs' value, CED were implemented provisionally to reduce payer's uncertainty about value of a medicine within a defined time period.</p> <p>Summary</p> <p>We are of opinion that while CA and P4P have a potential to reduce payers' expenditure on costly drugs while maintaining a high list price, CED address initial uncertainty related to assessing the real-life value of new drugs and enable a final HTA recommendation or reimbursement and pricing decisions. Further, we suggest that real cost to health care payers of drugs in CA and P4P should be made publicly available in a systematic manner, to avoid a perverse impact of these MAA types on the international reference pricing system.</p