The article examines the interaction of domestic anti-abuse rules with Article 9 of the Organization for Economic Cooperation and Development (OECD) Model Convention. To be considered non-abusive, a transaction must do more than satisfy domestic anti-abuse provisions. It must also pass the test under the treaty rule that incorporates paragraphs 1.36-1.41 of the OECD Transfer Pricing Guidelines. If tax authorities may not re-characterize transactions under domestic law, they may do so under a treaty, which may broaden the power of tax authorities to re-characterize transactions.

Though the curriculum reform movement that began in 1989 has had a significant impact on calculus pedagogy and content (Windham, 2008), the question remains to what extent reform-based calculus textbooks reflect these reforms. This paper explores this question by analyzing the mathematical content and pedagogical approach of the chapter on functions in Hughes-Hallett et al.’s (2018) reform-based college textbook Calculus: Single and Multivariable (CS&M). To conduct this analysis, the paper first synthesizes Hwang et al.’s (2021) framework for analyzing mathematics textbooks along with Sood and Jitendra’s (2007) framework for comparing traditional and reform-based mathematics textbooks. The paper then applies the synthesized frameworks to identify elements of reform from the big ideas, contextual features, mediated scaffolding, problem solving activities, and STEM integration found in the CS&M chapter. The results suggest that, although the chapter  integrates many reform-based principles, there may be scope for further integration. Such efforts, however, may be constrained by influential stakeholders.

This article proposes transfer pricing strategies to help multinationals alleviate the problem of grey markets by introducing the tax dimension to pricing decisions of companies. This article not only explores strategies that involve direct transfer price adjustments through the comparable uncontrolled price (CUP) method but also examines alternative strategies using indirect adjustments to a transfer price through the resale price and cost plus methods when the effects of both price arbitrage and tax arbitrage are considered.

The paper proposes a pedagogical approach to teaching and learning calculus differentiation formulas that synthesizes the principles of variation theory (VT) and <i>bianshi </i>in a problem-based learning (PBL) format. Unlike traditional approaches that view formulas procedurally, the paper adapts Steinbring’s (1989) distinction between “concept” and “symbol,” abstracting differentiation calculus formulas as “concept” (i.e., the meaning of the formula) and “symbol” (i.e., procedural knowledge about how to apply the formula). The paper then aligns this distinction with VT and <i>bianshi</i> pedagogies. While VT emphasizes more static elements of conceptual knowledge (e.g., highlighting the contrast between conceptual and non-conceptual features of the object of learning), <i>bianshi</i> broadens the concept of variation, offering more dynamic principles of variation through procedural variation (e.g., via the process of problem solving) (Gu et al., 2004). Combining VT and <i>bianshi</i> into a single pedagogical application yields an eight-step approach to teaching and learning calculus differentiation formulas.

Although there may be difficulties, especially during challenging economic times, in applying profit-based regulations when an income tax dimension is considered, if a trade dimension is introduced, in some circumstances profit-based methods, such as the comparable profits method (CPM) or transactional net marginal method (TNMM), may be preferred transfer pricing methods for multinationals. The article provides a comprehensive overview of the profit-based methods CPM and TNMM, where advantages and disadvantages of these methods are considered, and differences between these two methods are pointed out. The article also introduces a conceptual framework for transfer price coordination in the context of income tax and customs laws and examines issues pertaining to harmonization of income tax and customs laws.