My concern in Dead Drunk is not simply the subject matter of death, it is rather with the representation of drunks in the form of fictional phantoms in The Glass Canoe and Bliss as rendering the death drive visible. Close scrutiny of the representation of the drunk in Australian fiction, as discussed in relation to The Glass Canoe, and Bliss reveals a ‘constant recurrence of the same thing’ rendered uncannily visible. On inspection, what becomes visible is recurring deaths and subsequent resurrections. For the ghostly Australian drunk there is always the possibility of resurrection, but that resurrection is usually in the form of another drink. A drink promises resurrection, but instead delivers a return or recurrence of the drunken, ghostly state. / The presence of drinking and drunks in Australian fiction can be described as a haunting, the ghostly drunks as repetition of an anachronistic past. It is the repetition of the representations of drunks as ghostly presences in Australian fiction that is telling. Utilising Sigmund Freud’s theories developed in ‘The Uncanny’ (1919) and Beyond the Pleasure Principle (1920), I propose that if the uncanny is an encounter with one’s origins and the death drive is a backward looking return to origins; the drunks are a past that is repeatedly encountered in an uncanny moment. Utilising the modalities of the uncanny in regards to The Glass Canoe reveals the guises of the drunken ghosts. Making reference to an Australian colonial past, founded on intoxicant use and abuse the dissertation suggests alcoholism as a white man’s dreaming. A discussion of Bliss links the uncanny ghosts to a registration or surfacing of the death drive. In conclusion I suggest the psychoanalytic concept of sublimation as both an explanation for and a release from the symptomatic repetition. / Floundering, the creative work, is an extract from a novel in progress. The section presented is the opening to the novel. The narrative unfolds during one day, New Year’s Eve, and involves the interactions between the two brothers Jordy and Tom, and Old Fat. Loretta, the boys’ absent mother, haunts the novel and drives the narrative. Although the creative work does not explicitly depict dead drunks as discussed in the dissertation, the theory has by necessity permeated the creative, and the creative permeated the theory, forming a chiasma – a crossing over between strands of thought.

The Formulary Approach to the Taxation of Transnational Corporations: A Realistic Alternative? Synopsis The central hypotheses of this thesis are: that global formulary apportionment is the most appropriate method for the taxation of transnational corporations (TNCs) in lieu of the present system commonly referred to as the separate accounting/arm's length method; and that it is essential, in order to implement the proposed global formulary model, to create an international organisation which would fulfil, in the taxation field, a role equivalent to that of the World Trade Organisation (WTO) in international trade. The world economy is fast integrating and is increasingly dominated by the activities of transnational enterprises. These activities create a dual tax problem for various revenue authorities seeking to tax gains derived thereon: Firstly, when two or more countries entertain conflicting tax claims on the same base, there arises what is commonly referred to as a double taxation problem. Secondly, an allocation problem arises when different jurisdictions seek to determine the quantum of the gains to be allocated to each jurisdiction for taxation purposes. The traditional regime for solving both the double taxation and the allocation problem is enshrined in a series of bilateral treaties signed between various nations. These are, in general, based on the Organisation for Economic Co-operation and Development (OECD) Model Treaty.1 It is submitted, in this thesis, that while highly successful in an environment characterised by the coexistence of various national taxation systems, the traditional regime lacks the essential attributes suitable to the emerging 'borderless world'. The central theme of this thesis is the allocation problem. The OECD Model attempts to deal with this issue on a bilateral basis. Currently, the allocation problem is resolved through the application of Articles 7 and 9 of the OECD Model. In both instances the solution is based on the 'separate enterprise' standard, also known as the separate entity theory. This separate accounts/arm's length system was articulated in the 1930s when international trade consisted of flows of raw materials and other natural products as well as flows of finished manufactured goods. Such trade is highly visible and may be adequately valued both at the port of departure or at the port of entry in a country. It follows that within this particular system of international trade the application of the arm's length principle was relatively easy and proved to be extremely important in resolving both the double taxation and apportionment problems. Today, however, the conditions under which international trade is conducted are substantially different from those that prevailed until the 1960s. * Firstly, apart from the significant increase in the volume of traditionally traded goods, trade in services now forms the bulk of international exchanges. In addition, the advent of the information age has dramatically increased the importance of specialised information whose value is notoriously difficult to ascertain for taxation purposes. * Secondly, the globalisation phenomenon which gathered momentum over the last two decades has enabled existing TNCs to extend their global operations and has favoured the emergence of new transnational firms. Thus, intra-firm trade conducted outside market conditions accounts for a substantial part of international trade. * Thirdly, further economic integration has been achieved following the end of the Cold War and the acceleration of the globalisation phenomenon. In this new world economic order only TNCs have the necessary resources to take advantage of emerging opportunities. The very essence of a TNC is 'its ability to achieve higher revenues (or lower costs) from its different subsidiaries as a whole compared to the results that would be achieved under separate management on an arm's length basis.'2 Yet, the prevailing system for the taxation of TNCs overlooks this critical characteristic and is therefore incapable of fully capturing, for taxation purposes, the aggregate gains of TNCs. The potential revenue loss arising from the inability of the present system to account for and to allocate synergy gains is substantial. It follows that the perennial questions of international taxation can no longer be addressed within the constraints of the separate entity theory and a narrow definition of national sovereignty. Indeed, in order to mirror the developments occurring in the economic field, taxation needs to move from a national to an international level. Moreover, a profound reform of the system is imperative in order to avoid harmful tax competition between nations and enhance compliance from TNCs. Such a new international tax system needs to satisfy the test of simplicity, equity, efficiency, and administrative ease. To achieve these objectives international cooperation is essential. The hallmark of international cooperation has been the emergence, after World War II, of a range of international organisations designed to facilitate the achievement of certain goals deemed essential by various nations. The need for an organisation to deal specifically with taxation matters is now overwhelming. Consequently, this thesis recommends the creation of an international organisation to administer the proposed system. The main objective of this international organisation would be to initiate and coordinate the multilateral application of a formulary apportionment system which, it is suggested, would deal in a more realistic way with 'the difficult problems of determining the tax base and allocating it appropriately between jurisdictions'.3 The global formulary apportionment methodology is derived from the unitary entity theory. The unitary theory considers a TNC as a single business which, for convenience, is divided into 'purely formal, separately-incorporated subsidiaries'.4 Under the unitary theory the global income of TNCs needs to be computed, then such income is apportioned between the various component parts of the enterprise by way of a formula which reflects the economic contribution of each part to the derivation of profits. The question that arises is whether the world of international taxation is ready for such a paradigm shift. It is arguable that this shift has already occurred albeit cautiously and in very subtle ways. Thus, the latest of the OECD Guidelines on the transfer pricing question provides that 'MNE [Multinational Enterprise] groups retain the freedom to apply methods not described in this Report to establish prices provided those prices satisfy the arm's length principle in accordance with these Guidelines.'5 Arguably, the globalisation process has created 'the specific situation' allowed for by the OECD. This thesis, therefore, explores the relative obsolescence of the bilateral approach to the taxation of TNCs and then suggests that a multilateral system is better adapted to the emerging globalised economy. The fundamental building blocks of the model proposed in this thesis are the following: * First, the administration and coordination of the proposed system is to be achieved by the creation of a specialised tax organisation, called Intertax, to which member countries would devolve a limited part of their fiscal sovereignty. * Second, in order to enable the centralised calculation of TNC's profits, the proposed system requires the formulation of harmonised methods for the measurement of the global profits of TNCs. Therefore, the efforts of the International Accounting Standards Committee (IASC) to produce international accounting standards and harmonised consolidation rules must be recognised and, if needs be, refined and ultimately implemented. * Third, the major function of Intertax would be to determine the commercial profits of TNCs on a standardised basis and to apportion the latter to relevant countries by way of an appropriate formula/formulas. Once this is achieved, each country would be free, starting from its share of commercial profits, to determine the taxable income in accordance with the particular tax base that it adopts and, ultimately, the tax payable within its jurisdiction. In the proposed system, therefore, a particular country would be able to independently set whatever depreciation schedules or investment tax credits it chooses, and adopt whatever tax accounting rules it deems fit relative to its policy objectives. Moreover, this thesis argues that the global formulary apportionment model it proposes is not dramatically opposed to the arm's length principle. Indeed, it suggests that the constant assumption to the contrary, even with regard to the usual formulary apportionment methodology, is extravagant because both methodologies are based on a common endeavour, that is, to give a substantially correct reflex of a TNC's true profits. It has often been objected that global formulary apportionment is arbitrary and ignores market conditions. This thesis addresses such concerns by rejecting the application of a single all-purpose formula. Rather, it recognises that TNCs operating in different industries require different treatment and, therefore, suggests the adoption of different formulas to satisfy specific industry requirements. For example, the formula applicable to a financial institution would be different to that applicable to the pharmaceutical industry. Each formula needs to be based on the fundamental necessity to capture the functions, taking into consideration assets used, and risks assumed within that industry. In addition, if the need arises, each formula should be able to be fine-tuned to fit specific situations. Moreover, it is also pertinent to note that the OECD already accepts 'the selected application of a formula developed by both tax administrations in cooperation with a specific taxpayer or MNE group...such as it might be used in a mutual agreement procedure, advance transfer pricing agreement, or other bilateral or multilateral determination.'6 The system proposed in this thesis can thus be easily reconciled with the separate accounting/arm's length which the OECD so vehemently advocates. Both models have the same preoccupations so that what is herein proposed may simply be characterised as an institutionalised version of the system advocated by the OECD. Multilateral formulary apportionment addresses both the double taxation and the allocation problems in international taxation. It resolves the apportionment question 'without depending on an extraordinary degree of goodwill or compliance from taxpayers.'7 It is therefore submitted that, if applied on a multilateral basis with a minimum of central coordination, it also seriously addresses the double taxation problem. Indeed, it is a flexible method given that different formulas may be devised to suit the needs of TNCs operating in different sectors. Consequently, formulary apportionment understood in this sense, is a realistic alternative to the limitations of the present system.

Thesis (Ph. D.)--Ohio State University, 2007. / Title from first page of PDF file. Includes bibliographical references (p. 152-158).

Thesis (Ph. D.)--York University, 2002. Graduate Programme in Philosophy. / Typescript. Includes bibliographical references (leaves 240-266). Also available on the Internet. MODE OF ACCESS via web browser by entering the following URL: http://wwwlib.umi.com/cr/yorku/fullcit?pNQ82825.

Title from PDF of title page (University of Missouri--Columbia, viewed on Feb 15, 2010). The entire thesis text is included in the research.pdf file; the official abstract appears in the short.pdf file; a non-technical public abstract appears in the public.pdf file. Dissertation advisor: Dr. Vitor Trindade. Vita. Includes bibliographical references.

Thesis (Ph.D.)--University of Melbourne, School of Physics, 2009. / Typescript. Includes bibliographical references (leaves 171-174)

Thesis (Ph. D.)--Ohio State University, 2006. / Title from first page of PDF file. Includes bibliographical references (p. 127-129).

Original publication from author's Habilitationsschrift--Zürich, 1976. / Translation of Platon und Aristoteles in der Nuslehre Plotins. Includes bibliographical references (p. [295]-297) and indexes.

Thesis, Toulouse, 1914. / Bibliography: p.[227]-232.

Thesis (Ph. D.)--Ohio State University, 2005. / Title from first page of PDF file. Includes bibliographical references (p. 120-126).