Canada and the United States—Trading Partners and Transfer Pricing Opponents?

Given the significant trading relationships between Canada and the United States, their transnational corporations and their tax authorities share more than a border. However, differences in transfer pricing regulations, tax rates, and regulatory enforcement philosophies have exacerbated many existing risks, and created new risks for executives in these corporations. These risks must be managed proactively, yet attempts at risk management are often incompatible with one tax authority or the other. Assuming that an operational transfer pricing framework is in place, there are several proactive strategies available to mitigate transfer pricing risk and potentially satisfy both tax authorities. An operational framework and proactive strategies, including documentation and advance pricing agreements, are discussed from the Canadian and US perspective, including expert interviews.     

Permeability changes in simulated granite faults during and after frictional sliding

Thermal–hydrological–mechanical coupling processes suggest that fault permeability should undergo dynamic change as a result of seismic slip. In igneous rocks, a fault's slip surface may have much higher permeability than the surrounding rock matrix and therefore operate as a conduit for fluids. We conducted laboratory experiments to investigate changes in fracture permeability (or transmissivity) of a fault in granite due to shear slip and cyclic heating and cooling. Our experiments showed that high initial fracture transmissivity (>10^?18 m³) was associated with a high friction coefficient and that transmissivity decreased during slip. We propose that this reduction in transmissivity reflects the presence of gouge in fracture voids, increasing the area of contact in the fault plane and reducing the hydraulic aperture. In contrast, when initial fracture transmissivity was low (<10^?18 m³), we observed that friction was lower and transmissivity increased during slip. The high transmissivity and high friction may be explained by large areas of bare rock being in contact on the slip surface. Slip velocity had little influence on the evolution of permeability, probably because gouge produced at different slip velocities had similar grain size distributions, or because gouge leaked from the slip surface. Transmissivity decreased with increasing temperature in heating tests, probably due to thermal expansion increasing normal stress on the fracture. Frictional heating did not influence transmissivity during the shearing tests.     

Building G at Makaynūn: a late pre‐Islamic settlement above the ruins of a South Arabian town

This article presents the results of the excavation of a residence dated between the second and fourth centuries AD, constructed over the ruins of the South Arabian town of Makaynūn, in central Hadramawt (Yemen). The building yielded a large quantity of material including objects proving contacts between the central Hadramawt and regions located to the north‐east, such as central Oman, the Gulf area and India.     

'A Suitable Person for Suitable Cases': The Gendering of Juvenile Courts in England, c. 1910-39

This article examines the relationship between the introductionof women Justices of the Peace (JPs) in 1919 and the gendereddevelopment of juvenile courts in England, c. 1910–39.It argues that the campaigns for the appointment of women asJPs and for new methods of dealing with delinquent childrenwere closely connected from 1910 onwards, when the proposalwas first made that ‘suitable’ persons should beappointed to hear ‘suitable’ cases in magistratescourts. Using evidence drawn from government records and othersources, the article examines the interaction of the two campaignsand of feminist and penal reform groups in securing the remodellingof London's juvenile justice system in the Juvenile Courts (Metropolis)Act of 1920. It argues that these arrangements, and similarones adopted elsewhere in England, consciously reflected presumedfamilial and gender roles. It concludes that the replicationof the ‘traditional’ family in the composition ofthe court may have limited the ability of the youth justicesystem to be innovative in its approach to juvenile delinquencyin the period up to 1939. ^* a.f.logan{at}kent.ac.uk     

Work Design and the Labouring Body: Examining the Impacts of Work Organization on Danish Cleaners’ Health

Globalization and neoliberalism are having significant impacts upon the cleaning industry, as in the drive for greater work “efficiency”. One way in which cleaning companies have sought to increase efficiency is through the introduction of new equipment and forms of work organization. However, such moves appear to be having negative impacts upon cleaners’ bodies, and many report significant work‐related health problems. In light of this, here we explore the bodily consequences of two possible strategies for giving cleaners a healthier workday—increasing variation within cleaners’ current work tasks or allowing them to engage in a broader range of tasks through job enlargement. Drawing upon a literature review performed as part of a recent European Union project concerning the degree of physical strain to which cleaners are exposed during cleaning, a Danish laboratory study focusing on the loads to which cleaners’ shoulder muscles, backs, and hearts were exposed by different cleaning tasks, and a field study investigating the effects of job enlargement in Danish hospitals, we show that cleaning work is characterized by repetitive work for the muscles of the body's upper extremities and by high levels of dynamic and static force upon these muscles, regardless of which modes of cleaning (old or new style of cleaning tools) are used. Equally, monitoring of heart rates and assessment of the psychosocial environment suggest that simply interchanging current cleaning tasks does not provide sufficient variation in cleaners’ work to prevent work‐related musculoskeletal or cardiovascular damage, nor to create a less mentally stressful work environment. Although introducing greater work variation through job enlargement (such as combining cleaning with kitchen and portering tasks) is often presented as an effective way to minimize musculoskeletal and cardiovascular damage, our field study shows that even this does not provide sufficient variation in physical work conditions, although improvement in some cleaners’ mental health was noted. Therefore, we conclude, prevention of musculoskeletal and cardiovascular disorders demands a much more comprehensive strategy of work redesign than that proposed by some employers and government agencies. Whether this is likely, given competitive pressures towards increased outsourcing and privatization, is, of course, the question.     

Interpreting pachyderm single carcass sites in the African Lower and Early Middle Pleistocene record: A multidisciplinary approach to the site of Nadung’a 4 (Kenya)

Nadung’a 4 is one of the single carcass pachyderm sites recorded in East Africa during the Lower and Early Middle Pleistocene. The site has yielded an abundant lithic assemblage in close association with the partial carcass of an elephant. Conjoined pedological, geoarchaeological, spatial, technological, and taphonomical analyses have been carried out to address the relationship between hominids and elephant. The resulting data are consistent with a non-fortuitous association between both categories of remains. The lithic artefacts do not match a classical Acheulean tool-kit, as would be expected for the time period ascribed to the site, and the functional patterns inferred from their analysis make this site radically different from other purported butchery sites. The implications of these original features are discussed.