美国对跨国并购融资中滥用税收协定的管制措施及评析

针对跨国并购融资中滥用税收协定行为,在美国,可适用国内法层面的反导管原则与国际法层面的管制措施——双边税收协定中透视法、渠道法条款来管制。国内法层面的反导管原则从规范具体交易的角度,而国际法层面的管制措施则从规范可获得税收协定利益的适格主体角度,两者形成一股强大的合力,可对跨国并购中导管融资安排施加有效管制。中国目前尚未在国内税法中制定反导管规则,美国立法例值得中国借鉴。     

I tweet like a white person tbh! #whitewashed: examining the language of internalized racism and the policing of ethnic identity on Twitter

Using data extracted from Twitter, this study analyzes the English expression whitewashed as it occurs with and without a hashtag (e.g.: #whitewashed vs. whitewashed) through corpus analysis. As whitewashed has evolved to take on racial connotations to mean being too assimilated to a dominant white culture, I investigate whether the presence of a hashtag has an effect on how often this racial meaning of English whitewashed is employed. Based on collocative data, the findings suggest that the use of #whitewashed carries a meaning predominately informed by internalized racism and works to bind ethnic minorities to racial stereotypes. The study explores #whitewashed as a metacomment on human behavior, as #whitewashed serves to characterize beliefs about what actions are considered socially marked when performing an ethnic identity. In contrast to #whitewashed is the colloquial expression fobby, which characterizes an individual as being “too ethnic”; both (#)whitewashed and (#)fobby are discussed in tandem in this paper, for they create a double bind that marks the boundaries of ethnic identity. In this paper, I suggest that Twitter users mediate the demands of internalized racism by using #whitewashed to mark their tweets.     

Negotiation and Conflict Resolution Education in the Age of the MOOC

Even as online learning is increasingly embraced by institutions of higher education, the past decade has seen the arrival of yet another new educational vehicle: massive online open courses (MOOCs). These courses are designed to disseminate knowledge at an unprecedented scale — even as they engender concerns about quality, learning efficacy, and the future of higher education. In this article, I discuss the MOOC phenomenon and describe a MOOC on negotiation that I developed and taught, exploring the advantages that such a course offers for negotiation and conflict resolution education in particular.     

社会工作对青少年网络成瘾问题的干预

青少年网络成瘾给青少年的身体、心理和社会性发展带来了极大威胁。究其原因,主要是青少年身心发展不成熟、网络的极大吸引力以及家庭教育失位、学校教育失力与社会环境的复杂共同作用的结果。因此,社会工作者要通过各种方式做好预防工作,并在正确判断青少年网络成瘾＂真假性＂的基础上,激发青少年治疗网瘾的动机,以有效治疗网络成瘾的青少年,并评估成效,跟进服务。     

Converging on euroscepticism: Online polity contestation during European Parliament elections

Does the increasing politicisation of Europe signify a step towards the legitimation of the Union? This could be the case if the increased public intensity of debate and polarisation of opinion brought about by politicisation do not fragment the audience and if arguments presented in public are sufficiently clear about the desired nature of the polity. To answer this question, the focus of this article is on dynamic contestation in the public sphere using original data of news platforms and political blogs in 12 EU Member States and transnational websites during the European Parliament election campaign of 2009. The results are, first, that diffuse eurosceptic evaluations dominate public debates despite large variation in the intensity of debate across Member States. Second, a majority of evaluations made, particularly those by citizens leaving comments online, are negative in all countries included in this study. A gap between elites and citizens persists, but it appears less pronounced than often proclaimed in the literature. And third, democracy is a primary concern in EU polity contestation, especially for those evaluating the EU negatively. Although little evidence is found of a fragmentation of audiences, the prominence of diffuse euroscepticism poses a major challenge to legitimation of the Union.     

Single Outcome Agreements and Partnership Working in Scottish Local Government – Year One

Single Outcome Agreements (SOAs) are a mechanism that it is argued will deliver key national and local priorities based on a new relationship between central and local government in Scotland. SOAs are to be developed and implemented through partnership working exercised by Community Planning Partnerships (CPPs). A survey of the first (2008) SOA participants from local authorities and their Community Planning partners was conducted in 2008, with a particular focus on the interrelationships between the 2008 SOA development process and partnership working at the local level. Findings of this study suggest that there was a positive link between the strength of existing CPPs and partner engagement in the 2008 SOA development. However, partner engagement in the 2008 SOA development process did not affect survey respondents' confidence that the ongoing SOA development and implementation will strengthen partnership working in the long -term. This study also suggests that in addition to the practical difficulties such as limited time and staff resources, mistrust between local partners, and local players' scepticism about the central government's intention to free up local government may be barriers to the success of the SOA. Overall, respondents in this study showed realistic but hopeful attitudes to what the SOA was about and what could be achieved through it over time. The information gathered through this study should be merited as baseline data which captured the SOA participants' early experience and expectations.     

Firestorm Response: Managing Brand Reputation during an nWOM Firestorm by Responding to Online Complaints Individually or as a Cluster

ABSTRACT

This study provides evidence of how marketers should respond to a sudden discharge of negative word-of-mouth (nWOM) communication that spreads rapidly across social media platforms, known as an online “firestorm.” The study aimed to determine whether a company’s response policy during an online firestorm influenced their brand reputation among observers of the firestorm. An experiment offered three different company approaches to the firestorm. The study used a conclusive quantitative design by manipulating independent variables in a controlled environment in order to infer causality through an online survey to 300 participants. The study shows that when faced with the option of replying to a cluster of complaints or each individual complaint, a more positive brand reputation is engendered through individual replies. While research in digital marketing has progressed to provide companies with strategies to use digital platforms as a marketing tool, the negative side of social media—in this case online firestorms—is still largely left unattended. Addressing the direct issue of how to respond to online firestorms is therefore of significant relevance to marketing practitioners and academics.     

The Internet,alternative public sphere and political dynamism: Korea's non-gaek * (polemist ) websites

Abstract

This paper explores the development of Korea's online alternative public sphere and illuminates the characteristics of this space, ‘activated’ by non-gaek websites. These websites host highly partisan discourses which are produced and disseminated by a focused political agenda that aims at political reform. Such a method of conducting discourse has led to the dissimilitude of the alternative public sphere, resulting in the birth of a multiplicity of spheres that represent divergent political views. This paper argues that although the overall extent of the alternative public sphere is expanded by non-gaek websites, it is becoming at the same time an exclusive and intolerant space. Furthermore, it is argued that to facilitate functional operation of the alternative public sphere, an institutionalization of rules and norms that can solve such problems is necessary.     

网络交易中经营者与消费者的权益平衡

经营者与消费者作为网络交易的双方主体,在市场经济体制下对其权益全面加以保护具有异乎寻常的重要性。然而,现行理论总是立足于消费者一方的权益保护,而忽视经营者一方的权益保护。为平衡网络交易中消费者与经营者的权益,挖掘现行网络交易中的双方权益平衡的缺陷,本文参考外国相关法律法规,从网络交易运行模式和法律视角探寻网络交易中经营者与消费者的权益平衡方式,以完善网络交易市场,促进市场经济秩序的完善。