Transfer Pricing Solutions in the Global Economy

This paper will provide a brief history of the problems which transfer pricing issues have caused for both international companies and taxing jurisdictions. It will also examine efforts by the United States tax system to remedy this two-sided problem. The United States has primarily attempted to deal with the problem from its fiscal perspective, the underpayment of United States income tax by foreign companies through transfer pricing abuse. The double taxation problem for taxpayers has an effective, albeit cumbersome, solution in the competent authority process. However, the very fact that double taxation problems still exist, suggests the need for more effective dispute resolution methods between the taxing jurisdictions and the related taxpayers, whether it be the existing competent authority procedure or new methods. Potential long term solutions to these transfer pricing problems will also be examined

Transfer Pricing Solutions in the Global Economy

This paper will provide a brief history of the problems which transfer pricing issues have caused for both international companies and taxing jurisdictions. It will also examine efforts by the United States tax system to remedy this two-sided problem. The United States has primarily attempted to deal with the problem from its fiscal perspective, the underpayment of United States income tax by foreign companies through transfer pricing abuse. The double taxation problem for taxpayers has an effective, albeit cumbersome, solution in the competent authority process. However, the very fact that double taxation problems still exist, suggests the need for more effective dispute resolution methods between the taxing jurisdictions and the related taxpayers, whether it be the existing competent authority procedure or new methods. Potential long term solutions to these transfer pricing problems will also be examined

Electrogeneration of hydrogen peroxide for applications in water/wastewater treatment

Hydrogen peroxide (H2O2) is an effective, environmentally friendly oxidant used directly and in advanced oxidation processes for water and wastewater treatment. Although most H2O2 is currently manufactured offsite, concentrated, and trucked to sites where it must be safely stored and handled, it may also be generated on site electrochemically, commonly over a gas diffusion electrode (GDE). This technology has the potential to make processes more economical, feasible, available, and flexible depending on the application and the site. H2O2 electrogeneration has been heavily studied but there are particular knowledge gaps around performance of commercially available, unmodified, metal-free GDEs, contradictory evidence about optimum pH and cathode potential, a lack of studies using continuous mode reactors, weak quantification mass flows inside reactors, and a lack of studies looking at in situ treatment that take advantage of anodic oxidation and that do not require advanced oxidation. The present work addresses these gaps in two phases of experimentation (Chapters 3 and 4) and provides a brief comment on economic viability (Chapter 5) Firstly, effects of hydraulic retention time, cathode potential, reactor geometry, and pH in a continuous mode dual chamber reactor, including kinetic quantification and mass balance modelling are studied in Chapter 3. Performance shows a tradeoff where concentrations up to ~6500 mg L-1 may be generated but at a CE approaching 0% while CE near 100% can be maintained when H2O2 is produced at ~22 mg L-1. Additionally, a microbial electrochemical cell (MEC) is demonstrated to have a comparable current density to abiotic tests. Secondly, in Chapter 4, sulfur(IV) is demonstrated to be treated by both electrogenerated H2O2 and anodic oxidation in a single chamber electrolysis cell. CE is improved 3-8 times compared to H2O2 production alone, and near complete removal (at a low CE of 61.1%) or near 200% CE (at a low removal rate of only 27%) are achieved under various operating conditions, with intermediate values obtained by changing operating conditions. In summary, this work is establishes the maximum performance H2O2 electrogeneration under realistic conditions and shows how in situ treatment improves system efficiency by reducing H2O2 loss and taking advantage of anodic oxidation. The advantages of in situ production (and treatment) are complemented by a predicted comparable operating cost to traditional H2O2 technologies, suggesting that this technology is ready for scaling up and commercialization and has to potential to help secure safe water resources for the future

Signposts: Resource for staff developers

This guide is for staff developers who work with new tertiary teachers, and provides guidelines on how to use 'Signposts: A professional development resource for new teaching staff in the tertiary sector'. It is the result of a project funded by the Ako Aotearoa Northern Hub

Hydrogen peroxide production in a pilot-scale microbial electrolysis cell

The final publication is available at Elsevier via https://dx.doi.org/10.1016/j.btre.2018.e00276 © 2018. This manuscript version is made available under the CC-BY-NC-ND 4.0 license https://creativecommons.org/licenses/by-nc-nd/4.0/A pilot-scale dual-chamber microbial electrolysis cell (MEC) equipped with a carbon gas-diffusion cathode was evaluated for H2O2 production using acetate medium as the electron donor. To assess the effect of cathodic pH on H2O2 yield, the MEC was tested with an anion exchange membrane (AEM) and a cation exchange membrane (CEM), respectively. The maximum current density reached 0.94–0.96 A/m2 in the MEC at applied voltage of 0.35–1.9 V, regardless of membranes. The highest H2O2 conversion efficiency was only 7.2 ± 0.09% for the CEM-MEC. This low conversion would be due to further H2O2 reduction to H2O on the cathode or H2O2 decomposition in bulk liquid. This low H2O2 conversion indicates that large-scale MECs are not ideal for production of concentrated H2O2 but could be useful for a sustainable in-situ oxidation process in wastewater treatment.Ontario Early Researcher Awar

Statistical Properties of Schr\"odinger Real and Imaginary Cat States

We study the Photon statistics in the superpositions of coherent states $|\alpha\rangle$ and $|\alpha^*\rangle$ named ``Schr\"odinger real and imaginary cat states''. The oscillatory character of photon distribution function (PDF) emerging due to the quantum interference between the two components is shown, and the phenomenon of the quadrature squeezing is observed for the moderate values of $|\alpha|\sim 1$. Despite the quantity ${\langle\triangle n^2\rangle}/{\langle n\rangle}$ tends to the unit value (like in the Poissonian PDF) at $|\alpha|\gg 1$, the photon statistics is essentially non-Poissonian for all values of $|\alpha|$. The factorial moments and cumulants of the PDF are calculated, and the oscillations of their ratio are demonstrated.Comment: 13 pages, LaTE

Cognitive visual tracking and camera control

Cognitive visual tracking is the process of observing and understanding the behaviour of a moving person. This paper presents an efficient solution to extract, in real-time, high-level information from an observed scene, and generate the most appropriate commands for a set of pan-tilt-zoom (PTZ) cameras in a surveillance scenario. Such a high-level feedback control loop, which is the main novelty of our work, will serve to reduce uncertainties in the observed scene and to maximize the amount of information extracted from it. It is implemented with a distributed camera system using SQL tables as virtual communication channels, and Situation Graph Trees for knowledge representation, inference and high-level camera control. A set of experiments in a surveillance scenario show the effectiveness of our approach and its potential for real applications of cognitive vision

Raising Cultural Awareness in Undergraduate Students through an Online Pen Pal Program

International written communication networks, such as pen pal programs, help spread cultural awareness by connecting people from around the world. Competent intercultural communication is the foundation for strong global partnerships. It encourages diversity, increases academic achievement, and gives individuals a competitive edge in the global workforce. This study examines changes in the cultural awareness of 50 U.S. undergraduate participants enrolled in an intercultural communication course at a northwestern university after they exchange private, online pen pal letters with 50 international partners from across the globe. The U.S. participants were divided into Group A (test-group) and Group B (control-group) and then a pretest was administered to both groups to assess their cultural awareness before the letter exchange began. The Group A exchange was conducted over a two-week period, after which the U.S. participants were re-tested. The Group B began their exchange after the second test. The results of the tests were analyzed to determine whether the pen pal program increased cultural awareness in the U.S. undergraduate participants. Although no statistical increase was found, a lot of information and data was collected that future researchers and educators can use to develop their own programs

Experimental results for nulling the effective thermal expansion coefficient of fused silica fibres under a static stress

We have experimentally demonstrated that the effective thermal expansion coefficient of a fused silica fibre can be nulled by placing the fibre under a particular level of stress. Our technique involves heating the fibre and measuring how the fibre length changes with temperature as the stress on the fibre was systematically varied. This nulling of the effective thermal expansion coefficient should allow for the complete elimination of thermoelastic noise and is essential for allowing second generation gravitational wave detectors to reach their target sensitivity. To our knowledge this is the first time that the cancelation of the thermal expansion coefficient with stress has been experimentally observed