Formula Apportionment in the European Union: A Dream Come True or the EU’s Worst Nightmare?

The European Commission recently endorsed a future company tax policy that would allow companies to consolidate their tax bases and apportion the income across the EU using an allocation mechanism. This policy would replace the separate accounting method with formula apportionment of EU group profits as the main method of taxing multinational companies in the European Union. However, many details of the approaches remain to be presented, and these details may turn what appears to be a simple solution into an extremely complex one. This paper explores some technical details that arise in adopting formula apportionment in the European Union.

Cross-Border Loss Offset and Formulary Apportionment: How do they affect multijurisdictional firm investment spending and interjurisdictional tax competition ?

Motivated by the EU Commission‘s suggested company tax reforms, this paper investigates how cross-border loss offset and formulary apportionment of a consolidated tax base affect the investment and transfer pricing behaviour of a multijurisdictional firm, and how they affect the behaviour of governments potentially engaged in tax competition. The paper shows that cross-border loss offset mitigates both the reactions of a multijurisdictional firm to tax changes and the amount of tax competition engaged in by governments. However, formulary apportionment (with a consolidated tax base) boosts the sensitivity of firms to tax changes and increases the scope for interjurisdictional tax competition as well. For governments, formulary apportionment operates like a risk-sharing or partial equalisation mechanism.cross border loss offset, multinational firms, tax competition

Formulary Apportionment and Group Taxation in the European Union: Insights from the United States and Canada.

In 2001, the European Commission endorsed a future company tax strategy that would allow EU companies the option of calculating their EU profits on a common consolidated tax base and allow Member States to tax their share of that base at national rates. Implementing this strategy requires developing a formula to distribute the common tax base across the Member States. Although EU Member States currently do not use formulary methods to distribute a common consolidate tax base across national boundaries, Canada and the United States have extensive experience using formulary methods to distribute income across sub-national boundaries. Thus, the European Union can turn to North America to gain valuable insights into the design of a formulary apportionment system with common base taxation. This paper evaluates key issues that may arise when implementing common consolidated base taxation with formulary apportionment in the EU. These issues include the formula design, the definition of the company group and the definition and scope of the tax base. The paper also discusses potential economic consequences that may arise and suggests a potential apportionment system for the European Union.European Union, Corporate Taxation, Formulary apportionment, common consolidated base taxation, EU company tax reform

Integrating person directed care into the client experience

Culture Change leaders in long term care have identified creative ways to implement a model of Person Directed Care to improve the client experience by providing choice, instilling dignity, and fostering deep relationships among its community members. One organization created an environment of care called ”The Small House” and educated its’ workforce using the Green House® Project Legacy Alignment program to redesign the organizational structure, experience and environment. Interviews were conducted with elders, staff, and family members (N=20) about their experiences living, working or visiting a Small House as compared to experiences in their previous dwelling, a traditional nursing home. They were asked to describe the biggest difference between the Small House and the traditional nursing home model, and the differences in the two models in terms of the food, personal care, and relationships. Study participants were also asked to rate on a likert scale satisfaction with their experiences in the traditional nursing home and the Small House. Results showed that satisfaction ratings were higher among all groups living, working, or visiting the Small House compared to the traditional nursing home setting. The themes that emerged most often in comparing the Small House homes to the traditional nursing home included choice, homelike atmosphere, positive sensory environment, and evidence of close relationships in the Small House. The Small House homes studied in this qualitative investigation appear to have captured the important elements that create real home and consistent care partners who know the elders deeply to keep them comfortable and engaged

Proceedings of the 3rd Biennial Conference of the Society for Implementation Research Collaboration (SIRC) 2015: advancing efficient methodologies through community partnerships and team science

It is well documented that the majority of adults, children and families in need of evidence-based behavioral health interventionsi do not receive them [1, 2] and that few robust empirically supported methods for implementing evidence-based practices (EBPs) exist. The Society for Implementation Research Collaboration (SIRC) represents a burgeoning effort to advance the innovation and rigor of implementation research and is uniquely focused on bringing together researchers and stakeholders committed to evaluating the implementation of complex evidence-based behavioral health interventions. Through its diverse activities and membership, SIRC aims to foster the promise of implementation research to better serve the behavioral health needs of the population by identifying rigorous, relevant, and efficient strategies that successfully transfer scientific evidence to clinical knowledge for use in real world settings [3]. SIRC began as a National Institute of Mental Health (NIMH)-funded conference series in 2010 (previously titled the “Seattle Implementation Research Conference”; $150,000 USD for 3 conferences in 2011, 2013, and 2015) with the recognition that there were multiple researchers and stakeholdersi working in parallel on innovative implementation science projects in behavioral health, but that formal channels for communicating and collaborating with one another were relatively unavailable. There was a significant need for a forum within which implementation researchers and stakeholders could learn from one another, refine approaches to science and practice, and develop an implementation research agenda using common measures, methods, and research principles to improve both the frequency and quality with which behavioral health treatment implementation is evaluated. SIRC’s membership growth is a testament to this identified need with more than 1000 members from 2011 to the present.ii SIRC’s primary objectives are to: (1) foster communication and collaboration across diverse groups, including implementation researchers, intermediariesi, as well as community stakeholders (SIRC uses the term “EBP champions” for these groups) – and to do so across multiple career levels (e.g., students, early career faculty, established investigators); and (2) enhance and disseminate rigorous measures and methodologies for implementing EBPs and evaluating EBP implementation efforts. These objectives are well aligned with Glasgow and colleagues’ [4] five core tenets deemed critical for advancing implementation science: collaboration, efficiency and speed, rigor and relevance, improved capacity, and cumulative knowledge. SIRC advances these objectives and tenets through in-person conferences, which bring together multidisciplinary implementation researchers and those implementing evidence-based behavioral health interventions in the community to share their work and create professional connections and collaborations