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With repeal of the extraterritorial income exclusion expected in 2004, many U.S. companies selling abroad must rethink tax strategies related to export profit. Many firms with net operating loss (NOL) carryforwards, foreign tax credit (FTC) carryforwards, and interest-charge domestic international sales corporations (ICDs) can reduce marginal tax rates (MTRs) below rates otherwise applying to domestic sales. This article provides several case examples illustrating how U.S. exporters can minimize the MTR applicable to export profit. MTRs often depend on the period over which the company expects to absorb its NOL or FTC carryforward, the firm’s discount rate, and, in the case of ICDs, the prevailing T-bill rate. Assuming a 34% corporate tax rate, exporters with NOL (FTC) carryforwards can reduce the MTR on export profit to zero (17%) in some cases. Also, over the range of variables this article examines, the ICD reduces the MTR on export profit to between 34 and 21%. The cases illustrate how NOL and FTC carryforwards and ICDs affect exporters’ MTRs and provide educators with useful tools for discussing the tax aspects of exporting.

Variable-fidelity optimization (VFO) frameworks generally aim at taking full advantage of high-fidelity (HF) and low-fidelity (LF) models to solve computationally expensive problems. The purpose of this paper is to develop a novel modified trust-region assisted variable-fidelity optimization (MTR-VFO) framework that can improve the optimization efficiency for computationally expensive engineering design problems.

Though the LF model is rough and inaccurate, it probably contains the gradient information and trend of the computationally expensive HF model. In the proposed framework, the extreme locations of the LF kriging model are firstly utilized to enhance the HF kriging model, and then a modified trust-region (MTR) method is presented for efficient local search. The proposed MTR-VFO framework is verified through comparison with three typical methods on some benchmark problems, and it is also applied to optimize the configuration of underwater tandem wings.

The results indicate that the proposed MTR-VFO framework is more effective than some existing typical methods and it has the potential of solving computationally expensive problems more efficiently.

The extreme locations of LF models are utilized to improve the accuracy of HF models and a MTR method is first proposed for local search without utilizing HF gradient. Besides, a novel MTR-VFO framework is presented which is verified to be more effective than some existing typical methods and shows great potential of solving computationally expensive problems effectively.

This paper aims to address some of the needs of present and upcoming rover designs, and introduces novel concepts incorporated in a planetary surface exploration rover design that is currently under development.

The Multitasking Rover (MTR) is a highly re‐configurable system that aims to demonstrate functionality that will cover many of the current and future needs such as rough‐terrain mobility, modularity and upgradeability. lt comprises a surface mobility platform which is highly re‐configurable, which offers centre of mass re‐allocation and rough terrain stability, and also a set of science/tool packs – individual sub‐systems encapsulated in packs which the rover picks up, transports and deploys.

Early testing of the suspension system suggests exceptional performance characteristics.

Principles employed in the design of the MTR can be used in future rover systems to reduce associated mission costs and at the same time provide multiples the functionality.

The purpose of this paper is to investigate the time optimal trajectory of the multi-tethered robot (MTR) on a large spinning net structures in microgravity environment.

The MTR is a small space robot that uses several tethers attached to the corner-fixed satellites of a spinning net platform. The transition of the MTR from a start point to any arbitrary designated points on the platform surface can be achieved by controlling the tethers’ length and tension simultaneously. Numerical analysis of trajectory optimization problem for the MTR is implemented using the pseudospectral (PS) method.

The globally time optimal trajectory for MTR on a free-end spinning net platform can be obtained through the PS method.

The analysis in this paper is limited to a planar trajectory and the effects caused by attitude of the MTR will be neglected. To make the problem simple and to see the feasibility in the general case, in this paper, it is assumed there are no any limitations of mechanical hardware constraints such as the velocity limitation of the robot and tether length changing constraint, while only geometrical constraints are considered.

The optimal solution derived from numerical analysis can be used for a path planning, guidance and navigation control. This method can be used for more efficient on-orbit autonomous self-assembly system or extravehicular activities supports which using a tether-controlled robot.

This approach for a locomotion mechanism has the capability to solve problems of conventional crawling type robots on a loose net in microgravity.

The purpose of this paper is to identify possible tax synergies from acquisitions when the acquiring firm gains a non‐debt tax shield (NDTS) not directly associated with its own past performance, or a windfall NDTS. One possible benefit of a windfall NDTS is reduced reliance on interest tax shields to lower the firm's marginal tax rate (MTR).

This paper tests the likelihood of issuing debt following acquisitions of windfall non‐debt tax attributes with logistic regressions. Both acquirers and targets are publicly held US firms. Acquisitions are completed from 1987 to 2003, and debt issues are observed following the deal. Target firm tax attributes are defined as the total tax spread, tax loss carryforward (TLCF), and the MTR.

Target firm tax spread and TLCFs are inconsequential to the acquirer's likelihood of issuing future debt, suggesting that tax synergies are relatively unimportant motives for acquisitions. As predicted, the target firm MTR is not significant to acquirer debt issues.

This paper makes several contributions. First, the notion of tax synergies from acquisitions is unresolved. This paper continues the search for tax synergies in acquisitions by examining the importance of acquired NDTS in the post‐acquisition period. Second, this paper examines the influence of NDTS on debt issuance in a post‐event framework. Third, this paper provides additional evidence that corporate managers have leverage targets.

The purpose of this paper is to explore the influence of the experience economy and co-creation concepts on guided tours (GTs) and to analyze the process of the on-site (co-)creation of experience between the service provider and the consumer taking into account the consumer perspective.

The objective of the study is fulfilled by reviewing the literature on experience economy and co-creation within a cultural heritage context and then using it to design appropriate research tools to collect empirical data through qualitative interviews within the context of a single case study. The Medieval Town of Rhodes (MTR), Greece, serves as the case in this study. In fact, this study analyzes primary data from 25 interviews with participants in GTs in the MTR.

The GT participant’s views of their GT experience were explored, and it was evaluated whether they fit any of the three generations of experience economy with an emphasis on co-creation of experience. The findings show that, in the MTR-GT services, the characteristics of mainly the first and second generation experience economies are found, while little emphasis is given to the third generation experience economy. Based on the empirical results, the RIF model (R: “Resources,” I: “Interactions,” F: “Feelings”) was created: this proposes that both the process of experience co-creation and optimal GT experiences are realized by providing participants with appropriate resources, multiple types of interactions and opportunities to generate positive and pleasant feelings. This model illustrates the intertwining, multi-dimensional facets of an optimal co-created GT experience that service providers and tour operators should provide to their customers.

The present study has several limitations that need to be mentioned. First, this research is a single case study; the MTR serves as the case, focusing on one cultural heritage service, GTs. This fact can put the study’s validity in question. Moreover, as the research is conducted by a single person, there is the risk of subjective bias. Another limitation is that this study is not a longitudinal one; the latter could lead to more accurate findings. The number and the nationality of participants constitute the 4th and final limitation of the research. More specifically, the sample is not perceived to be representative of the population nor generalizable, while visitors from more nationalities could have been interviewed. In relation to this, the judgmental sampling method was used because the population of the study could not be defined. This serves as the fifth limitation of the study.

Tour operators and tour guides can exploit the characteristics of GT activities included in the proposed RIF model. By incorporating these elements in GT experiences, the process of experience co-creation could be effectively supported. An optimal GT experience that incorporates intertwining and multi-dimensional facets could be provided. To begin with, the physical setting where the tour takes place must be well preserved, so that it can capture the attention of the participants. The route of the tour should not be exhausting but convenient for all participants and should include various landscapes. On the other hand, tour guides should provide interesting, relevant and cohesive information. Moreover, a tour guide needs to display charismatic behavior to gain the tour group’s trust and generate positive feelings impressing and immersing participants in the experience and encouraging in them a sense of togetherness. Within the context of the tour, tangible elements such as brochures and maps should be provided, allowing vistors to tailor the experience according to their needs and preferences. Furthermore, interaction between the guide and the tour group, as well as among the participants themselves, should be encouraged. In relation to this, the tour group could be divided into sub-groups according to common features such as age. The guides could also come up with a topic to be jointly discussed and participatory activities such as games could be organized. Finally, participants should have some freedom during the tour; time to explore the setting on their own or a visit to specific places on request.

The originality of the paper lies in the development of the RIF model, illustrating the on-site optimal experience within the context of GTs taking place in the MTR, the setting of the research. The construction of the RIF model was based on an investigation into actual GT participant’s perspectives on GTs.

The current research work presents the application of fuzzy logic modeling for electric discharge coating (EDC) process for predicting the material transfer rate (MTR), which has the capability of producing thick and thin films on the conductive substrate material.

Thirty-two real-time experiments were conducted, and fuzzy rules were framed from the inference made from this experimental data. Validating experiments were carried out to check the feasibility of the developed model in prediction.

A fair agreement has been observed between experimental results and the outcomes of fuzzy model. This was supported by a goodness of fit value of 0.917. The values of adjusted R² and standard error were 0.914 and 19.112, respectively.

Current research deals with the prediction of MTR at various parameter grouping conditions, which majorly influence the response parameters. However, other parameters such as quality of the dielectric fluid, flushing pressure and purity of the electrode and work material and so on that influence the response parameters could be further investigated and stand as a future scope of the current work.

MTR is a response parameter that accounts the actual material transfer to the workpiece during the deposition process. This parameter supports/alters the hardness, adhesion, wear resistance and other mechanical properties of the work material. The current modeling work helps to take an optimum decision without conducting large number of experiments at the industrial scale. Due to the nature of fuzzy logic, this method has a potential advantage in dealing with real-time data for various industrial applications.

Developing a fuzzy model for EDC process is not yet addressed, and to attain the economic objective of the process, optimal deposition conditions must be determined, which help the industries to reduce the operation costs. The current study outcomes substantiate the effectiveness of the fuzzy logic in decision-making and prediction of response parameters.

Investigates the evolution of mass rapid transit (MRT) in relation to the Hong Kong market and analyses the effect of surrounding land values. Outlines the unique features of Hong Kong which make an urban railway system ideal and discusses the changes brought about by MRT. Summarizes the growth of commercial development on Hong Kong island and gives case studies on the Admiralty, Sheung Wan and Taikooshing/Kornhill areas in respect of their development with the advent of MRT. Notes that the shortening of travelling time for workers has increased demand for, and hence the price of, sites immediately adjacent to MRT stations.

The purpose of this study is to determine how to achieve a balance between freedom and control in public space. It analyses the relationship between freedom and control to identify phenomena and offer users and policymakers instructions for achieving that balance. Public space, including privately owned public space, is important to urban living. People have both the right to use public space and the responsibility to protect it. Both freedom and control should exist in public space in an appropriate combination. It is impossible and inappropriate for us to ask for absolute freedom or endure unreasonable control.

A case study of Hong Kong’s Mass Transit Railway (MTR) reveals typical freedom/control relationships. Quantitative descriptions are given based on field observations.

Freedom and control are primary factors affecting the quality of urban life and management of city space. They depend on and conflict with each other. The balance between freedom and control is a balance between diverse spaces. The “freedom space” belonging to both citizens and authorities determines whether freedom and control are balanced. Ethics and strategies constitute control. Only when each authority and user obtains a proper freedom space can freedom and control achieve balance in public space.

Freedom and control differ across cities because they are both affected by culture, history and tradition. As each city has its own characteristics, the freedom and control in each open space are distinctive. Balancing freedom and control requires an understanding of a city’s background and the era. While this paper does not attempt to achieve this understanding, further studies could devote more attention to dimensions of time and location.

The findings provide recommendations for users, policymakers and construction and management companies that will allow the management of harmonious and high-quality open spaces.

Freedom and control are two main factors affecting quality of life. The balance between freedom and control may bring a harmony and stable society environment. It would benefit both the authority and the people a lot.

This study provides a systematic analysis of freedom and control in public space and makes a valuable contribution to quality urban space policy, design and management.

A significant milestone of the quality journey of the MTR Corporation (MTR) was the establishment of the ISO 9000‐based quality management system (QMS) in its core departments. Adopting the ISO 9000 standards, the QMS provided a framework for the Corporation’s quality, safety and environmental management systems, linking and standardizing all work processes from the top management down to the shopfloor. Various initiatives of the MTR’s integrated management system (IMS) such as core business process maps are developed with a view to link all constituent activities of the railway into its core business processes. The Corporation’s quality endeavours were publicly recognized by the ISO 9000 certification in 1992 and by the new version in 2000. This paper shares the MTR’s experience on how its IMS can achieve ISO 9001:2000 certification.