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.     

CALIFORNIA IRREDENTA

Kevin Starr's Golden Dreams is the culmination to some forty years of scholarship on the unfolding theme of a “California Dream,” that imaginal component to the growth of the self‐identity and increasing international economic power of the most populous state in the American Union. Indeed, the period 1950–1963 that the book meticulously covers forms in many ways the most imposing manifestation of that Dream. This essay reviews the central features of Starr's account, particularly the infrastructural foundations in transportation, water supply, and higher education realized by a triumvirate of California governors, both Republican and Democrat, who regarded themselves as nonpartisan members of the “Party of California”; the expansion of California's major cities: Los Angeles, San Diego, and San Francisco; the characteristics of the Silent Generation and the culture of “cool Jazz” that dominated the period; as well as the rise of dissident elements among environmentalists, minorities, and Beats, that foretold the protest period of the 1960s. This essay then asks whether Starr has avoided the larger implications of his own narrative that California from this period on had become in most respects a putative nation‐state in its own right. From the global impact of its major media industry—Hollywood—to the continued advances of its economic clout throughout the rest of the century as at times the fifth largest economic entity in the world, California may need to be increasingly regarded as a world civilization in itself rather than as a regional civilization to which Starr's historical narrative has so far constricted it.     

Democracy's not for me: The Lowy Institute polls on Gen Y and democracy

For two consecutive years, the Lowy Institute Poll has revealed just how little Australians seem to value democracy. This has particularly been the case for Australia's so-called Generation Y. Understandably, these findings have aroused dismay among media, policy and academic commentators, with many automatically assuming the troubling nature of these findings. Despite this, little consideration has been given to what the results actually denote, and what they were not telling us about the rationale and justification behind the Gen Y responses. This critical commentary offers some preliminary thoughts and findings on what the Lowy Polls are not telling us; as well as on what they are telling us.

连续两年,罗伊民调所发现澳大利亚人对民主评价极低。澳大利亚所谓的“Y一代”尤其如此。可以想见,这样的发现让媒体以及政策和学术评论者失望不已,许多人会马上想到这些发现会造成的麻烦。其实,很少有人思考这类发现的真实所指,思考关于Y一代反应所没有讲出的东西。这篇批评性文章提供了一些初步的想法和发见：罗伊民调除了讲了什么,它还没讲什么？     

Thirty Years of Criticism of the Works of Florencio Sánchez

Through John Kronik's insights on self-conscious art, in particular his essay "Galdosian Reflections: Feijóo and the Fabrication of Fortunata," this article examines the self-conscious dimension of contemporary neorealist texts, in particular the use and role of the video game in the novel Ático, by Gabi Martínez.     

Generation of Multiple Earthquake Accelerograms Compatible with Spectrum Via the Wavelet Packet Transform and Stochastic Neural Networks

The principal purpose of this article is to present a novel methodology based on wavelet packet transform techniques and stochastic neural networks to generate more artificial earthquake accelerograms from available data, which are compatible with specified response spectra or the design spectra. The proposed method uses the decomposing capabilities of wavelet packet transform on earthquake accelerograms, and the learning abilities of stochastic neural network to expand the knowledge of the inverse mapping from response spectrum to coefficients of wavelet packet transform of earthquake accelerogram. This methodology results in a stochastic ensemble of wavelet packet transform coefficients of earthquake accelerograms and, they are used to the generate accelerograms applying the inverse wavelet packet transform. Finally, an interpretive example is presented which uses an ensemble of recorded accelerograms to train and test the neural network, aiming at the demonstration of the method effectiveness.     

The development of core concepts of yield management

Abstract

Yield management offers an Operations Manager a decision support framework for examining the revenue and conservation decision variables that integrate the characteristics of the Heritage Visitor Attraction (HVA) experience. The principles of yield management are drawn from the hotel and airline industries to demonstrate how the problem of fixed capacity is managed in other service sectors. This paper compares these principles against Heritage Visitor Attractions (HVAs), suggesting how they could adopt such concepts. As HVAs serve broader objectives, other than profit maximisation, financial pressures are encouraging the operations manager to devise imaginative and new ways of managing sites. Ten core principles of yield management are suggested that are appropriate to Heritage Visitor Attractions. These core principles are used to evaluate Historic Scotland's and the National Trust for Scotland's approach to revenue management.     

Contesting uneven development: The political geography of natural gas rents in Peru and Bolivia

Political and academic debates about the distribution of resource rents to producing areas have addressed the issue of whether or not the transfers unleash conflicts. While this kind of debate is valid, the present paper argues that such a discussion is missing the point regarding the processes behind said types of conflicts, as well as how such conflicts are framed at the sub-national political geography of the state. By more deeply exploring these dimensions, the argument of this paper is that the production of uneven development within sub-national areas is crucial for understanding the above-mentioned conflicts and how the central state internalises those conflicts, producing new political geographies of rent distribution. As such, different territorial discourses of autonomy emerge along with uneven development, but their capacity to reach institutional autonomy is grounded on the spatial politics of each state. Empirically, this paper analyses how natural gas rents are distributed to sub-national producing areas in Peru and Bolivia, and how the production of uneven development through natural gas rents at sub-national level re-activated previous territorial demands for autonomy, which were internalised by central states in different ways.     

刍议税务稽查体制的改革与创新

现行的税务稽查体制还存在着一些不足,与社会主义市场经济的要求尚有一定的差距。因此,必须着眼于时代要求,进一步加快税务稽查体制的改革与创新,提高税务稽查工作的效率和质量。     

Exhibiting enterprise: how New Zealand museums generate revenue

Museums in New Zealand are not a homogeneous group in terms of their level of incomegenerating activity or the nature of those activities. The gap of knowledge consequent on this situation led to the National Services unit of the Museum of New Zealand Te Papa Tongarewa, commissioning primary research into the revenue‐generation activities of the sector. This paper presents the results of that research, specifically the data gathered through a questionnaire. The results provide a profile of respondents in relation to their operating contexts, the sources of financial and non‐financial support they received (from the local community, local authorities and central government), and the types of income‐generating activities they undertook. The results contribute to a better understanding of both how organisations within the sector generate income (from traditional sources and new, more innovative activities) and what factors influence their ability to do so.     

Heritage Visitor Attractions: managing revenue in the new millennium

Heritage visitor attractions represent an integral component of the tourism product in many countries. This is particularly so in Scotland, where visitor attractions of a heritage genre continue to attract more visitors than others. However, with varying types of ownership, funding and organisational objectives, many unrelated to tourism, the management of heritage visitor attractions is particularly challenging. Based on a recent primary research study conducted in Scotland, this paper focuses on one particular component of management, that of revenue, and examines the appropriateness, role and utilisation of the concept of revenue management to the operational and strategic management of heritage visitor attractions. The paper concludes that while the majority of heritage visitor attractions employ a number of well-tested revenue-management techniques, there is limited evidence to suggest that pricing and revenue-generation policies reflect the attractions' organisational objectives. In particular, incumbent policies do not appear to reflect the wider needs of revenue management, such as the need to address seasonal and spatial limitations of demand.