Issue Of theBulletin Research Articles

President’s Welcome

In this special issue of the Bulletin for International Taxation, the President of the International Fiscal Association (IFA), Professor Guglielmo Maisto, welcomes participants to the 76th IFA Congress taking place in Cape Town, South Africa, from 27 to 31 October 2024. This article focuses on international tax dispute prevention and resolution.

AARSE Conversations about the Challenges of the Small Religious Studies Program

The Conference presents scholarly dialogue pertinent to the field of Religious Studies. The piece in this issue of the Bulletin is taken from the March 2023 American Academy of Religions South East Conference at Mercer University in Atlanta, GA. Presiding over the discussion is Vaia Touna Associate Professor and Graduate Studies Director at the University of Alabama. Members of the panel include Matthew Baldwin, Professor Emeritus of Religion and Philosophy at Mars Hill University and Brandi Denison, Associate Professor of Philosophy and Religious Studies at the University of North Florida. In this panel the members discuss challenges which face smaller religious studies programs.

Testing Interdisciplinarity in the Field

The Interview connects Bulletin readers with scholars who have been shaping key aspects of our work in the field. Suzanne Owen at Leeds Trinity University in the UK takes some time to chat with us. Owen will be talking about her experiences in both U.S. and U.K. education systems, her path to the academy through Edinburgh courses, Canadian fieldwork, and the BASR. She and Newton also touch on the issues she sees in the UK Academy and where she hopes Religious Studies can go from here. We thank her for her time and willingness to be part of this issue of the Bulletin.

Turning Point: A Century of International Tax Policy Flies toward a Sharp Curve

In this special issue of the Bulletin for International Taxation, the President of the International Fiscal Association welcomes participants to the 75th IFA Congress to take place in Cancun, Mexico from 22-26 October 2023.

Special issue of the bulletin of earthquake engineering on non-ergodic ground motion models

Special issue of the bulletin of earthquake engineering on non-ergodic ground motion models

Exploring intersections and integration of sexual reproductive health and mental health among adolescents and young adults: Areas of collaboration and lessons learned.

This special issue of the Bulletin of the Menninger Clinic addresses mental health issues in the field of sexual and reproductive health. The goal is to highlight important overlaps between reproductive and gender health concerns and mental health symptomatology. The issue includes topics around social determinants of health and their effects on reproductive health; the reproductive health sequelae of eating disorders; mental health challenges faced by gender diverse youth and strategies to mitigate these effects; integration of sexual health services and mental health care; and lessons for mental health advocates from the sex education realm. This special issue features areas of intersectoral collaboration among public health, medical, and mental health professionals to positively impact patients' holistic wellness.

Editor’s Note

In this issue of the Bulletin for Biblical Research, we highlight the recent work of Dale C. Allison Jr., The Resurrection of Jesus: Apologetics, Polemics, History (London: T&T Clark, 2021). In the book, Allison returns to the ancient sources and early traditions to chart the development of faith in the resurrection. Beginning with critical methodology regarding the empty tomb and early confessions, he moves on to consider parallel traditions and stories and then presents his own considerations and reflections engaging with both “apologetic” and skeptical viewpoints.Four scholars offer essay-length reviews and engagements with Allison’s work. First, Allison briefly opens the discussion by summarizing and reflecting on his recent work. After the review and essays by Eklund, Joseph, Jipp, and Sosa Siliezar, Allison responds to the reviewers.This collection of essays from and with Allison was edited by former BBR editor Nijay K. Gupta with the help of his student, Cody Matchett.

Happy 100th birthday HIST!

Abstract The Division of the History of Chemistry of the American Chemical Society (HIST) is 100 years old in 2022. To celebrate, a special issue of the Bulletin for the History of Chemistry has been prepared and made available open access to anyone. Prominent chemist historians and historians of chemistry were invited to contribute essays on the theme “Novel Insights in the History of Chemistry: Looking Back Yet Mostly Looking Forward.”

Дифференциация зарплат рабочих и служащих Сибирского края (1925–1929 гг.): децильные коэффициенты и индекс Джини

The aim of the study is to identify specific features differentiating incomes of the part of the urban population of Siberia whose incomes were determined mainly by the size of wages. These are workers and employees of state enterprises and organizations. The chronological framework is the second half of the 1920s. Wage inequality is considered on the basis of data on its differentiation among workers in all branches of industry and office employees. An informative source for studying the issues of wage differentiation of workers in Siberian Krai is Byulleten’ statistiki truda Sibirskogo kraya [Bulletin of Labor Statistics of Siberian Krai] published in 1926–1928 and its continuation Byulleten’ statistiki truda i promyshlennosti [Bulletin of Labor and Industry Statistics] published in 1928– 1929. Their data confirm the high level of Siberian statistics of the NEP period, which has already been stated by researchers. Each issue of the Bulletin, in addition to statistical tables, charts and graphs, contains detailed comments by experts on the methods of data collection and processing. Based on the source information, I have formed two data arrays. The first of them is related to the differentiation of workers’ wages presented in the form of an interval scale. Surveys were conducted once a year in March for 4 years – from 1926 to 1929. As for the second set of data (those covering employees), they are available only for March 1926 and March 1927. During the study all available data were entered into appropriate tables and processed in the Microsoft Excel spreadsheet program. The decile coefficient and the Gini index were also calculated. For 4 years, the inequality in the wages of workers decreased significantly. The decile coefficient fell from 3.56 to 2.50, while the Gini index fell from 0.25 to 0.19. Among employees, there was a slight increase in the level of inequality. The situation with wage differentiation gradually stabilized over the entire period and remained unchanged in 1928–1929 having reached its limit. This indicates the victory of the leveling trend in the wage policy towards industrial workers in Siberian Krai.

Editorial December 2021

This issue of the EPPO Bulletin shows an important part of the work of EPPO; Regional Standards in the area of phytosanitary regulation to control invasive plant pests. These Standards have been developed by experts in EPPO Panels, were extensively discussed, comments received from EPPO countries were considered and, in the end, the Working Party approved the Standards and the EPPO Council endorsed them. This process is facilitated by the EPPO Secretariat but relies on contributions of experts from EPPO’s member countries and ensures that the Standards are implementable, reflect reality, support NPPOs and thereby contribute to a harmonized way of working. The EPPO Council approved in September 2021 too many Standards to have them all published in this issue of the Bulletin. The EPPO Standards on efficacy evaluation of plant protection products in the PP1 series and three PM8 Standards on commodity-specific measures for forestry species, approved by Council this year, will be published in the April 2022 issue of the Bulletin. These Standards are available via online early view at https://onlinelibrary.wiley.com/toc/13652338/0/0. Moreover, EPPO’s Annual Report for 2020 in English is included, while the versions in French for 2020 and 2019 are available on the EPPO website, describing the whole range of EPPO’s work. The EPPO Standards in this issue include amongst others pest-specific Diagnostic Protocols, Standards for quality management and accreditation of laboratories, Standards on inspection of places of production and consignments of specific commodities and, a Standard on reducing the risk of soil from processing factories for potato cultivation. This latter Standard illustrates clearly how growers, processors and National Plant Protection Organizations (NPPOs) can take their respective responsibility and can work together to reduce risks of returning soil to farms. The role of NPPOs remains crucial. Another interesting subject is covered by the new Standard in the PM5 series on the design and implementation of a buffer zone to minimize the probability of spread of a pest into or out of regulated areas. This Standard gives guidance to risk assessors and risk managers to assess what size of buffer zone is matching their needs and possibilities. Moreover, a revision on the Standard on biological control agents, to clarify the criteria to list biological control agents safely used in the EPPO region, and Standards on control of invasive alien plants are included. The article on the developments in the work area of invasive alien plants over the past ten years in Europe gives a good overview of the work done in Europe on assessing, controlling, preventing and regulating IAP and the role EPPO played in this. Furthermore, this issue continues to contribute to pest reporting by including several reports on first findings which are important to signal new or changed risks, e.g. of the giant date mealy bug and the bay sucker in Jordan, Drosophila suzukii in the Russian Caucasus and scale insects and mealy bugs in Kenya. EPPO continues to work with many experts inside and outside the EPPO region to support NPPOs in their work to prevent the introduction and spread of pests and to control them. We have greatly appreciated the efforts of all experts to continue to contribute to EPPO’s work remotely due to COVID-19 restrictions. EPPO is, however, looking forward to working together during physical meetings in the near future. This will enhance the formal and informal discussions and exchange of information and EPPO can fulfil its role as a platform to experts to strengthen and enlarge their network.

The 75th Anniversary of the Bulletin for International Taxation: “75 Years of International Taxation: Looking Back and Looking Ahead”

Johann Hattingh provides an overview of articles in the 75th anniversary special issue of the Bulletin for International Taxation that cover thematically arranged topics prepared by distinguished authors, while he also looks back at the development of the journal and its future.

Some Considerations on the Limitation of Substance-Based Carve-Out in the Income Inclusion Rule of Pillar Two

In this article, Professor Luís Eduardo Schoueri sets out his thoughts on the limitation of substance-based carve-out in the Income Inclusion Rule of the OECD’s proposals under Pillar Two for the 75th anniversary issue of the Bulletin for International Taxation.

Aligning the Location of Taxation with the Location of Value Creation: Are We There Yet!?!

In this 75th anniversary issue of the Bulletin for International Taxation, Angelo Nikolakakis examines critically the implications of the initiatives – the OECD/G20 Base Erosion and Profit Shifting Project and the (resulting) Pillars One and Two – that have been suggested as ways of reforming the international tax regime. The analysis is focussed in particular on the implications of these initiatives with regard to the goal of aligning the location of taxation with the location of value creation.

Have the OECD Model and the UN Model Served Their Purpose? Are They Still Fit for Purpose?

In this contribution to the 75th anniversary issue of the Bulletin for International Taxation, Stef van Weeghel considers whether the OECD Model and the UN Model are still fit for purpose. He also suggests ways in which the international tax system could be improved.

Beneficial Owner: The Enigma Storms Ahead

In this article for the 75th anniversary issue of the Bulletin for International Taxation, Charl du Toit questions and explores why, despite all the criticism that beneficial ownership has received, its use as a “policing term” appears to be ever increasing. It is now also widely used outside international tax in various areas under the exchange of information banner.

Twenty Years of Change to the Treatment of Services in the OECD Model and the UN Model

In this article for the 75th anniversary issue of the Bulletin for International Taxation, Carmel Peters provides her views on the various changes that have been made to the treatment of services in the OECD Model and the UN Model since the turn of the century.

The Future of the Taxation of Software Payments: Reflections on the Proposal to Amend Article 12 of the UN Model as Discussed by the UN Tax Committee in April 2021

In this contribution to the 75th anniversary issue of the Bulletin for International Taxation, Professor Jan de Goede comments on the taxation of software payments in light of the proposal to change article 12 of the UN Model as discussed by the UN Tax Committee in April 2021.

What Can We Learn from the History of Article 21 of the OECD Model?

John F. Avery Jones, in this contribution to the 75th anniversary issue of the Bulletin for International Taxation, provides his thoughts on what can be learned from the history of article 21 of the OECD Model, particularly that of article 21(2) which was added to the OECD Model (1977).

What Is a “Tax Paid in That Other State” under Article 23 of the OECD Model?

Professor Michael Lang provides us, in this 75th anniversary issue of the Bulletin for International Taxation, his view on the meaning and implications of the phrase “tax paid in that other state” in article 23 of the OECD Model.

Interpretation of Tax Treaties and the Decisions of Foreign Tax Courts as a “Subsequent Practice” under Articles 31 and 32 of the Vienna Convention on the Law of Treaties (1969)

Professor Guglielmo Maisto, in contributing to the 75th anniversary issue of the Bulletin for International Taxation, considers the topic of interpretation of tax treaties and the decisions of foreign tax courts as “subsequent practice” under articles 31 and 32 of the Vienna Convention on the Law of Treaties (1969).