scholarly journals Alesco and Mark Resources: Cross-Border Tax Arbitrage, Economic Reality, and Anti-Avoidance Rules in New Zealand and Canada

2021 ◽  
Author(s):  
◽  
Sarah Miles

<p>This essay compares the role given to the concept of economic reality in New Zealand and Canadian cross-border tax arbitrage decisions, particularly Alesco and Mark Resources. Alesco and Mark Resources both address the problem of drawing the line between acceptable tax mitigation and unacceptable avoidance, and adopt economic substance as a key indicator of where this line lies. This essay considers how the concept of economic reality pervades these cases and evaluates the influence of legislative and judicial context to the significance afforded to the concept of economic reality in the two decisions, as well as reviewing how the economic realities jurisprudence has evolved following these cases.</p>

2021 ◽  
Author(s):  
◽  
Sarah Miles

<p>This essay compares the role given to the concept of economic reality in New Zealand and Canadian cross-border tax arbitrage decisions, particularly Alesco and Mark Resources. Alesco and Mark Resources both address the problem of drawing the line between acceptable tax mitigation and unacceptable avoidance, and adopt economic substance as a key indicator of where this line lies. This essay considers how the concept of economic reality pervades these cases and evaluates the influence of legislative and judicial context to the significance afforded to the concept of economic reality in the two decisions, as well as reviewing how the economic realities jurisprudence has evolved following these cases.</p>


2018 ◽  
Vol 2018 (99 (155)) ◽  
pp. 97-118
Author(s):  
Piotr Staszkiewicz ◽  
Rumiana Górska

This paper examines whether the auditee’s financial situation affects the auditor’s non-audit fee and independ- ence. Three sets of tests were used to address the issue. The first examines whether there are cross-border and intertemporal differences in relationships between non-audit fees and audit fees. The second tests whether there is a relationship between non-audit fees and report modification. The third addresses the relationships between audit fees and the auditee’s financial situation. The results suggest a lack of coexistence of all three motives for the purchase of non-audit fee services, and substantial similarities of auditor and auditee behaviors across Po- land and New Zealand. We documented the lack of a significant link between auditee failure risk and the quality of the audit report. Our findings indicate an operational rather than a strategic nature of non-audit services to incumbent clients.


2021 ◽  
Author(s):  
◽  
Bronwin M. Boswell

<p>I have been involved in policing and crime prevention for many years. I was a sworn member of Victoria Police (Australia), a crime prevention coordinator in a New Zealand community, and am currently employed by New Zealand Police (NZP). My interest in international policing grew as I realised more and more police were serving in a number of roles overseas. At first, I thought this a nice departure from normal duties for those lucky enough to take up opportunities to contribute to policing in other countries. Deeper thought followed about the juxtaposition of western models of policing, international relations and the customs of developing countries. The more I tried to find out the more questions were raised. Soon it was evident that little had been written about international policing and even less about international policing in relation to the Pacific. The need for research that combines the study of cross-border policing of crime and criminality with international relations scholarship has been identified by Peter Andreas and Ethan Nadelmann in their 2006 co-authored book. A growing body of literature examines policing and development in the Pacific, but is mainly centred on conflicts in Melanesia with particular emphasis on the Regional Assistance Mission to Solomon Islands (RAMSI). Apparently, no single work discusses the needs of police services in the Pacific in relation to domestic policing and international cooperation. This work seeks to fill that gap.</p>


2022 ◽  
Vol 30 (2) ◽  
pp. 1-19
Author(s):  
Carson Duan ◽  
Bernice Kotey ◽  
Kamaljeet Sandhu

This research examines the important concept of transnational digital entrepreneurship (TDE). The paper integrates the host and home country entrepreneurial ecosystems with the digital ecosystem to the framework of the transnational digital entrepreneurial ecosystem. The authors argue that cross-border e-commerce platforms provide critical foundations in the digital entrepreneurial ecosystem. Entrepreneurs who count on this ecosystem are defined as transnational digital entrepreneurs. Interview data were dissected for the purpose of case studies to make understanding from twelve Chinese immigrant entrepreneurs living in Australia and New Zealand. The results of the data analysis reveal that cross-border entrepreneurs are in actual fact relying on the significant framework of the transnational digital ecosystem. Cross-border e-commerce platforms not only play a bridging role between home and host country ecosystems but provide entrepreneurial capitals as digital ecosystem promised.


2021 ◽  
Author(s):  
◽  
Vinka Cisternas Torres

<p>Uninterrupted growth of international trade and the constant threats to global supply chains have led to the emergence of numerous voluntary compliance guidelines based on standards and compliance. Initiatives, such as, the Authorised Economic Operators is the result of the global efforts to facilitate, prevent and secure international trade against cross-border crime. The Authorised Economic Operator is an initiative of the World Customs Organisation and its member countries. Its core philosophy is developing public to private partnerships for the safety of international trade and trade facilitation. These initiatives are growing in scope with a variety of programmes developed by governments. The objective of these programmes is encouraging an ethos of voluntary compliance based on standards, best practices and self-governance. Certified firms can obtain a trusted trader status and cross-border benefits when they demonstrate that their supply chain is secure. New Zealand has its own programme called the Secure Export Scheme. While this programme is voluntary in nature, firms entering the programme are required to adopt, maintain, and comply with the standards of security for their supply chain. This thesis investigates the compliance behaviour of New Zealand exporters with the standards of security of the Secure Export Scheme.  The Authorised Economic Programme is a new concept, and while there is scholarly research of other types of voluntary standards, research in this particular area is minimal. To the best of the researcher’s knowledge, this is one of the first studies to examine the compliance behaviour of firms that have been part of the programme since inception. Accordingly, this study is guided by the various views of the compliance theory and proffers a conceptual framework to delineate the different actors and factors that influence firms’ compliance behaviour. The study measured compliance and non-compliance of firms to understand the underlying patterns with specific best practices. This study contributes towards our current understanding of compliance behaviour. While, overall, the compliance of the New Zealand exporters with the best practices is high, there are some areas of concern. The study further identified that a number of firms were not compliant with certain best practices. This finding indicates that other factors, such as, the way the governing body presents its written requirements might influence the compliance behaviour with those specific best practices. The conceptual model proposed in this study lays the foundation for further research seeking to probe compliance behaviour of Authorised Economic Operators.</p>


2021 ◽  
Author(s):  
Takahiko Koyama ◽  
Reitaro Tokumasu ◽  
Kotoe Katayama ◽  
Ayumu Saito ◽  
Michiharu Kudo ◽  
...  

Tokyo Olympic and Paralympic Games, postponed for COVID-19 pandemic, were finally held in summer of 2021. Just before the games, alpha variant was being replaced with more contagious delta variant (B.1.617.2). AY.4 substrain AY.29, which harbors two additional characteristic mutations of 5239C>T (NSP3 Y840Y) and 5514T>C (NSP3 V932A), emerged in Japan and became the dominant strain in Tokyo by the time of the Olympic Games. As of October 18, 98 AY.29 samples are identified in 16 countries outside of Japan. Phylogenetic analysis and ancestral searches identified 46 distinct introductions of AY.29 strains into those 16 countries. United States has 44 samples with 10 distinct introductions, and United Kingdom has 13 distinct AY.29 strains introduced in 16 samples. Other countries or regions with multiple introductions of AY.29 are Canada, Germany, South Korea, and Hong Kong while Italy, France, Spain, Sweden, Belgium, Peru, Australia, New Zealand, and Indonesia have only one distinct strain introduced. There exists no unambiguous evidence that Olympic and Paralympic Games induced cross-border transmission of the delta substrain AY.29. Since most of unvaccinated countries are also under sampled for genome analysis with longer lead time for data sharing, it will take longer to capture the whole picture of cross-border transmissions of AY.29.


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