Proactive Transfer Pricing Risk Management in PATA Countries

2014 ◽  
Vol 13 (2) ◽  
pp. 25-55 ◽  
Author(s):  
Susan C. Borkowski ◽  
Mary Anne Gaffney

ABSTRACT Transnational corporations (TNCs) have long considered transfer pricing as a key tax concern. If stability in transfer pricing is a necessary condition for dynamic cross-border trading, then recent financial reporting changes, updated transfer pricing guidelines, and new reporting requirements for uncertain tax positions are destabilizing influences that must be addressed by companies in order to mitigate their transfer pricing-related exposures and risk. This study reports the results of a survey of tax executives from the four countries comprising the Pacific Association of Tax Administrators (PATA), three of which have transfer pricing regulations based on Organisation for Economic Co-operation and Development (OECD) guidelines. The study seeks to explain how TNCs are managing their transfer pricing risks proactively in today's volatile environment, and if their actions are successful. Findings include contradictory evidence regarding audit risk reduction strategies recommended by tax authorities and the utility of those strategies in actually reducing corporate audit risk. These were surprising results, given that tax authorities and transfer pricing consulting firms tout certain transfer pricing agreements as the best way to mitigate transfer pricing audit risk. At best, are these agreements neutral relative to audit risk? At worst, are tax authorities using these agreements as a source of confidential data for possible future use in both transfer pricing and non-transfer pricing audits?

2020 ◽  
Author(s):  
Mark C Billings ◽  
Matthew S Carroll ◽  
Travis B Paveglio

Abstract This article identifies specific social characteristics in two wildland urban interface communities that may have significant impacts on the ability of those communities to adapt to wildfire. Researchers used a mixed-methods approach to triangulate results to identify potential views and motives surrounding three important behaviors and values related to crafting potential strategies to mitigate wildfire risk. The analysis of quantitative data in the form of responses to Likert-type questions and qualitative data in the form of responses to questions asked during focus group sessions yielded a deeper understanding of the way the terms independence and trust are conceptualized from one community to another. Understanding what these concepts mean in the context of a given community is essential to understanding how to move forward with strategies to reduce risk and eliminate potential barriers to doing so. Study Implications Two important social characteristics of wildland urban interface (WUI) communities are trust and independence. Trust and independence look different in different types of communities. The two terms also encapsulate a range of meanings that vary depending on local social context. Being able to identify what types of trust and independence are present in a particular WUI community can help practitioners craft wildfire risk reduction strategies that are most likely to be well received and successfully integrated into individual WUI communities. This article offers examples of how these characteristics manifest themselves in two different communities in the Pacific Northwest.


2010 ◽  
Vol 5 (1) ◽  
pp. 104
Author(s):  
Daniel S Menees ◽  
Eric R Bates ◽  
◽  

Coronary artery disease (CAD) affects millions of US citizens. As the population ages, an increasing number of people with CAD are undergoing non-cardiac surgery and face significant peri-operative cardiac morbidity and mortality. Risk-prediction models can be used to help identify those patients at increased risk of peri-operative cardiovascular complications. Risk-reduction strategies utilising pharmacotherapy with beta blockade and statins have shown the most promise. Importantly, the benefit of prophylactic coronary revascularisation has not been demonstrated. The weight of evidence suggests reserving either percutaneous or surgical revascularisation in the pre-operative setting for those patients who would otherwise meet independent revascularisation criteria.


Author(s):  
N.S. Bieliaieva

The article explores the possibilities and problems of the process of harmonization of the HR audit in the field of international practice, taking into account the specifics of the market environment of Ukraine. The views of different authors on the problem of HR auditing were investigated. The idea was justified that the harmonization of accounting and financial reporting of economic entities is closely linked with the globalization of economic processes and the economy as a whole on a global scale, the processes of informatisation and digitalization of society, the same as for HR processes. During considering the concept of “HR audit” it should not be forgetting about the legislative component — HR audit is aimed, inter alia, at identifying violations with the law for timely management of weaknesses in the policy of the enterprise in the field of labor. Categorization of observations by impact of importance (high-risk, medium-risk, low-risk — categorization) was investigated; examples for high-risk observations (on the example of: workforce planning, service contract modalities) and medium-risk (on the example of: recruitment process governance, alignment of strategy and work plans, HR functional capacity in Country Offices, talent acquisition in Cos, recruitment processes in Cos, employee on-boarding, training and separation, national non-staff salary scales and pay adjustments, staffing and structure review exercises, social security transfers to service contracts, automation, information and data management, oversight of HR functions in Cos) are given in consideration with agreed actions of HRM and auditor. The ratings (satisfactory, partially satisfactory or unsatisfactory) of an HR audit that are part of the system of evaluating the adequacy of company’s audit risk management, control and governance processes were investigated. The point that the human resource auditing is something that many companies do annually, just as they audit their financial information (despite of their field of activity) is overlined in the article. The harmonization of the HR audit in the field of international practice is a process of unification of methods and principles of auditing in the form of standards is observed.


2001 ◽  
Vol 76 (1) ◽  
pp. 59-80 ◽  
Author(s):  
D. Paul Newman ◽  
Evelyn Patterson ◽  
Reed Smith

We consider how auditors assess the risk of fraudulent financial reporting and plan their audit where a possibly fraudulent auditee anticipates the assessment and planning process. The auditor uses the auditee's (possibly fraudulent) earnings report to revise his beliefs about the likelihood of fraud when formulating an audit plan. We find that as underlying earnings increase, a fraudulent auditee increases reported earnings. In turn, as the auditee's reported earnings increase, the auditor increases audit effort. We also find that the auditee (who knows the auditor will use the report for audit planning) selects reports that increase his own expected payoff, relative to reports he would select if the auditor did not observe the report before finalizing the audit plan. By contrast, the auditor is no better off using the auditee's report for audit planning. Inherent risk, detection risk, and overall audit risk can increase when the auditor uses the auditee's report. Thus, because of the dynamic interaction between the auditor and auditee, procedures that aid in assessing audit risk may not reduce that risk or result in more efficient audits.


Forests ◽  
2021 ◽  
Vol 12 (7) ◽  
pp. 934
Author(s):  
Andy McEvoy ◽  
Becky K. Kerns ◽  
John B. Kim

Optimized wildfire risk reduction strategies are generally not resilient in the event of unanticipated, or very rare events, presenting a hazard in risk assessments which otherwise rely on actuarial, mean-based statistics to characterize risk. This hazard of actuarial approaches to wildfire risk is perhaps particularly evident for infrequent fire regimes such as those in the temperate forests west of the Cascade Range crest in Oregon and Washington, USA (“Westside”), where fire return intervals often exceed 200 years but where fires can be extremely intense and devastating. In this study, we used wildfire simulations and building location data to evaluate community wildfire exposure and identify plausible disasters that are not based on typical mean-based statistical approaches. We compared the location and magnitude of simulated disasters to historical disasters (1984–2020) in order to characterize plausible surprises which could inform future wildfire risk reduction planning. Results indicate that nearly half of communities are vulnerable to a future disaster, that the magnitude of plausible disasters exceeds any recent historical events, and that ignitions on private land are most likely to result in very high community exposure. Our methods, in combination with more typical actuarial characterizations, provide a way to support investment in and communication with communities exposed to low-probability, high-consequence wildfires.


Author(s):  
Ali Işın ◽  
Adnan Turgut ◽  
Amy E. Peden

Drowning is a public-health threat and a leading cause of injury-related death. In Turkey, drowning results in 900 fatalities annually, and the rate is rising. As data on rescue-related drowning are scarce, this retrospective study explores the epidemiology of fatal drowning among rescuers in Turkey. As there are no routinely collected death registry data on drowning in Turkey, data were sourced from media reports of incidents between 2015 and 2019. Rescuer fatalities were analysed by age, sex, activity prior to rescue, location, incident day of week and season, and place of death. Statistical analyses comprised X2 tests of significance (p < 0.05) and calculation of relative risk (95% confidence interval) using fatality rates. In total, 237 bystander rescuers drowned (90% male; 35% 15–24 years). In 33% of cases, the primary drowning victim (PDV) was successfully rescued, while in 46% of cases the rescue resulted in multiple drowning fatalities (mean = 2.29; range 1–5 rescuers). Rescues were more likely to be successful in saving the PDV if undertaken at the beach/sea (X2 = 29.147; p < 0.001), while swimming (X2 = 12.504; p = 0.001), or during summer (X2 = 8.223; p = 0.029). Risk of bystander rescue-related fatal drowning was twice as high on weekdays compared to on weekends (RR = 2.04; 95%CI: 1.56–2.67). While bystanders play an important role in reducing drowning, undertaking a rescue is not without risk and can lead to multiple drowning incidents. Training in rescue and resuscitation skills (especially the prioritization of non-contact rescues) coupled with increasing awareness of drowning risk, are risk-reduction strategies which should be explored in Turkey.


2010 ◽  
Vol 28 (10) ◽  
pp. 1070-1077 ◽  
Author(s):  
Maria Tria Tirona ◽  
Rajesh Sehgal ◽  
Oscar Ballester

2021 ◽  
Vol 17 (1) ◽  
pp. 39-54
Author(s):  
Josiah D. Strawser, MD ◽  
Lauren Block, MD, MPH

Objective: To explore the impact of the New York State Prescription Drug Monitoring Program (IStop) on the self-reported management of patients with chronic pain by primary care providers.Design: Mixed-methods study with survey collection and semistructured interviews.Setting: Multiple academic hospitals in New York.Participants: One hundred and thirty-six primary care providers (residents, fellows, attendings, and nurse practitioners) for survey collection, and eight primary care clinicians (residents, attending, and pharmacist) for interviews. Interventions: Introduction of IStop.Main outcome measure(s): Change in usage of four risk reduction strategies (pain contracts, urine tests, monthly visits, and co-management) as reported by primary care providers for patients with chronic pain.Results: After the introduction of IStop, 25 percent (32/128) of providers increased usage of monthly visits, 28 percent (36/128) of providers increased usage of pain management co-management with other healthcare providers, and 46 percent (60/129) of providers increased usage of at least one of four risk reduction strategies. Residents indicated much higher rates of change in risk reduction strategies due to IStop usage; increasing in the use of monthly visits (32 vs. 13 percent, p = 0.02) and co-management (36 vs. 13 percent, p = 0.01) occurred at a much higher rate in residents than attending physicians. Interview themes revealed an emphasis on finding opioid alternatives when possible, the need for frequent patient visits in effective pain management, and the importance of communication between the patient and provider to protect the relationship in chronic pain management.Conclusions: After the introduction of IStop, primary care providers have increased usage of risk reduction strategies in the care of chronic pain patients.


2021 ◽  
Vol 14 (11) ◽  
pp. e243408
Author(s):  
Anna Katrina Hay ◽  
Anna McDougall ◽  
Peter Hinstridge ◽  
Sanjeev Rajakuldendran ◽  
Wai Yoong

Brachial plexus injury is a rare but potentially serious complication of laparoscopic surgery. Loss of motor and/or sensory innervation can have a significant impact on the patient’s quality of life following otherwise successful surgery. A 38-year-old underwent elective laparoscopic management of severe endometriosis during which she was placed in steep head-down tilt Lloyd-Davies position for a prolonged period. On awakening from anaesthesia, the patient had no sensation or movement of her dominant right arm. A total plexus brachialis injury was suspected. As advised by a neurologist, an MRI brachial plexus, nerve conduction study and electromyography were requested. She was managed conservatively and made a gradual recovery with a degree of residual musculocutaneous nerve neuropathy. The incidence of brachial plexus injury following laparoscopy is unknown but the brachial plexus is particularly susceptible to injury as a result of patient positioning and prolonged operative time. Patient positioning in relation to applied clinical anatomy is explored and risk reduction strategies described.


Author(s):  
Dorothy Ann Drago ◽  
Carol Pollack-Nelson ◽  
Sarah Beth Newens

This study examines infant fatalities that occurred while sharing a sleep surface. Fatality data reported to the U.S. Consumer Product Safety Commission (CPSC) during the time period January, 2013 through December, 2017 and involving infants through age 10 months were reviewed. 1,587 Cases were analyzed on the following variables: infant age and sex; sleep environment by product; cause of death; fatality pattern; and breastfeeding, where it was mentioned. 97% Of deaths were due to some form of asphyxia. Adult beds were associated with 78% of shared sleep fatalities, and the primary fatality pattern was overlay (35.4%)/probable overlay (8.8%). Infants <3 months made up 65% of fatalities. The data reflect that bedsharing continues, despite AAP guidelines to the contrary, and that overlay is the primary hazard pattern to be addressed. This paper discusses potential risk reduction strategies that may reduce the potential for overlay fatalities.


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