An empirical investigation of transfer pricing regulations for Nigeria with a particular emphasis on the petroleum sector.

This research critically investigates the adoption and implementation of transfer pricing regulations in Nigeria with a particular emphasis on the petroleum sector. It opportunely chose Nigeria as a case study of transfer pricing issues in developing countries as Nigeria was devising and implementing its own transfer pricing regulation. In early 2012, Nigeria issued draft transfer pricing regulations for consultation with a view to publishing them at the end of the same year. In order to gauge the reaction of the stakeholders in Nigeria to the adoption and implementation of transfer pricing regulations and other related issues, a questionnaire was designed and administered to 140 respondents from eight different stakeholders groups including Nigerian tax authority, multinational companies in the petroleum sector and other organisations involved in tax matters. The questionnaire elicited their views on the (i) form of adoption of transfer pricing regulations; (ii) motive behind the adoption of the regulations; (iii) administrative resource capacity of the Nigerian tax authority; (iv) barriers that might hinder successful implementation of the regulations; and (v) needs for guidance and support. Institutional theory and resource-based view were employed as a theoretical lens through which to guide the study and to provide a platform against which to analyse the responses to the questionnaire and the interviews. The analysis of the responses to the questionnaire was thus undertaken subsequent to the adoption of the transfer pricing system which enabled informed reflection and critical analysis to be carried out on the results of the analysis. In addition, interviews with 16 experts were conducted subsequent to the issue and preliminary analysis of the responses to the questionnaire in order to gauge their reaction to the views being expressed by the respondents. This enabled a reflective analysis to be undertaken when assessing the information content emerging from the responses. The findings of the study indicate that the OECD transfer pricing framework, which is the transfer pricing system of choice amongst the developed countries, is not the most preferred framework for the regulation of transfer pricing in Nigeria. It also reveals that whilst the Nigerian tax authority has the administrative capacity to develop a transfer pricing team and other necessary platforms for the adoption and implementation of transfer pricing regulations, the lack of sufficient transfer pricing experts, political will and inadequate comparable information are the major potential barriers that might hinder the successful implementation of transfer pricing regulations in Nigeria. These findings should enable policy makers and other stakeholders in Nigeria to review their transfer pricing policies and find a way to overcome the identified potential barriers. This thesis is the first of its kind to empirically investigate the transfer pricing regulations in Nigeria with a particular emphasis on the petroleum sector. It also further establishes the use of institutional theory and resource-based view framework in transfer pricing studies and especially, by extending its application to the adoption and implementation of transfer pricing regulations with a particular emphasis on the petroleum sector

Each of My Hands is God

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A comparison of two protein supplements on the healing of stage III and IV pressure injuries in enterally fed, ventilator dependent long – term care residents

The purpose of this study was to evaluate the change in stage III or IV pressure injury size of enterally fed, ventilator dependent, long-term care residents after receiving one of two protein supplements in addition to enteral feeding meeting 100% of calculated needs. The two protein supplements were Beneprotein™ (powder) and Pro T Gold™ (liquid). The injuries were evaluated for change in size at two weeks and four weeks post initiation of protein supplement. Sixty subjects were reviewed – 30 for each supplement. Subjects included 20 males (33%) and 40 females (67%). The analysis indicated for the total sample, a significant reduction in injury size for those receiving Beneprotein™ compared to those receiving Pro T Gold™ (p\u3c0.05) after two weeks of supplementation. However, there was no significant difference between the supplement groups after four weeks of continued supplementation (p = .261). Injury healing for subjects with an existing comorbidity of diabetes or chronic kidney disease were compared to subjects without these comorbidities. Overall, the comorbidity group experienced greater injury healing compared to the non-comorbidity group after both two weeks (p\u3c0.05) and four weeks of supplementation (p\u3c0.05). This research showed that Beneprotein™ provided more rapid wound healing in the first two weeks of supplementation and that the comorbidity group experienced greater benefit from protein supplementation. Further research needs to be conducted with a larger sample size for a longer monitoring time

Distribution and Spread of an Invasive Shrub (Pyrus calleryana Decne) Across Environmental Gradients in Southern Indiana

Invasive species represent one of the greatest challenges to ecological management today. With new species introductions occurring every year, understanding the impacts, mechanisms of spread, and characteristics of invaded habitats is vital in developing appropriate control methods. One newly escaped invasive species, Pyrus calleryana, is rapidly expanding its invasive range and potentially altering forest structure and composition in southern Indiana. This research investigated characteristics of invaded environments and patterns of spread in P. calleryana. I found an association between P. calleryana and areas with high levels of light and high stocking of shade intolerant species. Data further revealed an association between P. calleryana and dryer aspects. These results indicate P. calleryana is associated with more xeric environments with high light availability and will likely be found in early successional environments. The genetic structure of the study population indicated it was likely composed of two populations. This population structure indicated the importance of density to the spread of P. calleryana as one population corresponded most closely with areas composed of high densities of P. calleryana and the second population was more associated with the expanding edge of the invasion. These results indicate that bird driven dispersal, introduction of new individuals via horticulture, and population density are the factors with the greatest influence on P. calleryana overcoming its self-incompatibility. Overall, P. calleryana has the potential to rapidly expand into disturbed environments and successfully invade, particularly when population densities are high

“LIQUID SUNSHINE, or SOMETHING ELSE,” a play by Kalli Anne Joslin

Liquid Sunshine, or Something Else is a historical play set in 1920s Florida that examines the intersections of race, gender, and immigration during American Prohibition. Set in an unnamed town that incorporates aspects of Tampa, Miami, and Key West, the owner of a local Cuban restaurant must grapple with increased police presence in her community as she is simultaneously asked to run an illegal still and shelter a family of Eastern European immigrants