The Digital Nexus

Over half a century ago, in The Gutenberg Galaxy (1962), Marshall McLuhan noted that the overlap of traditional print and new electronic media like radio and television produced widespread upheaval in personal and public life: Even without collision, such co-existence of technologies and awareness brings trauma and tension to every living person. Our most ordinary and conventional attitudes seem suddenly twisted into gargoyles and grotesques. Familiar institutions and associations seem at times menacing and malignant. These multiple transformations, which are the normal consequence of introducing new media into any society whatever, need special study. The trauma and tension in the daily lives of citizens as described here by McLuhan was only intensified by the arrival of digital media and the Web in the following decades. The rapidly evolving digital realm held a powerful promise for creative and constructive good—a promise so alluring that much of the inquiry into this new environment focused on its potential rather than its profound impact on every sphere of civic, commercial, and private life. The totalizing scope of the combined effects of computerization and the worldwide network are the subject of the essays in The Digital Nexus, a volume that responds to McLuhan’s request for a “special study” of the tsunami-like transformation of the communication landscape. These critical excursions provide analysis of and insight into the way new media technologies change the workings of social engagement for personal expression, social interaction, and political engagement. The contributors investigate the terms and conditions under which our digital society is unfolding and provide compelling arguments for the need to develop an accurate grasp of the architecture of the Web and the challenges that ubiquitous connectivity undoubtedly delivers to both public and private life. Contributions by Ian Angus, Maria Bakardjieva, Daryl Campbell, Sharone Daniel, Andrew Feenberg, Raphael Foshay, Carolyn Guertin, David J. Gunkel, Bob Hanke, Leslie Lindballe, Mark McCutcheon, Roman Onufrijchuk, Josipa G. Petrunić, Peter J. Smith, Lorna Stefanick, Karen Wall.

"By definition, this generation -- those born between the early sixties and late seventies -- has no "hard edges". It is a generation based on formative experiences and pivotal events rather than specific birthdates and cohort size. Essentially, you are a Nexus if you first felt the effects of the computer chip and global media at some point during your formative years. This means you could have encountered a PC for the first time in university or mastered Pong (the first video game) at the age of seven. You could be Nexus if you watched live CNN coverage of the Gulf War at high school, saw the space shuttle Challenger blow up in high school, or were the first kid in your neighbourhood with cable TV and a remote control." (p.17,18).

International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.

"This is a book that I am going to have to own, and will work to find contexts in which to recommend. It cuts obliquely through so many important domains of evidence and scholarship that it cannot but be a valuable stimulus" -Hamish Macleod, University of Edinburgh Digital connectivity is a phenomenon of the 21st century and while many have debated its impact on society, few have researched relationship between the changes taking place and the actual impact on learning. Rethinking Learning in an Age of Digital Fluency examines what kind of impact an increasingly connected environment is having on learning and what kind of culture it is creating within learning settings. Engagement with digital media and navigating through digital spaces with ease is something that many young people appear to do well, although the tangible benefits of this are unclear. This book, therefore, will present an overview of current research and practice in the area of digital tethering, whilst examining how it could be used to harness new learning and engagement practices that are fit for the modern age. Questions that the book also addresses include: Is being digital tethered a new learning nexus? Are social networking sites spaces for co-production of knowledge and spaces of inclusive learning? Are students who are digitally tethered creating new learning maps and pedagogies? Does digital tethering enable students to use digital media to create new learning spaces? This fascinating and at times controversial text engages with numerous aspects of digital learning amongst undergraduate students including mobile learning, individual and collaborative learning, viral networking, self-publication and identity dissemination. It will be of enormous interest to researchers and students in education and educational psychology.

The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework. Focusing in turn on the legal framework, specific proposals for adapting tax concepts for the digital economy, types of transactions and administrative issues such as those around data protection and digital currencies, the expert contributors discuss such challenges to taxation as the following: the pervasiveness of intangible assets; new value creation models; the ascendance of the sharing economy and digital services; virtual currencies; the importance of user participation for digital platforms; cloud computing; the impact of Big Data on tax enforcement; virtual business presence; and the influence of robotization. Throughout, the authors describe and analyse proposals made by the Organisation for Economic Co-operation and Development (OECD), the European Union (EU) and individual countries and their likely impact going forward. They also attend to the limits imposed on reform possibilities by public international law, EU law and constitutional law. It is generally acknowledged that there is a need to monitor how the digital transformation may be impacting value creation. This book is a key milestone toward developing a durable, long-term solution to the tax challenges posed by the digitalization of the economy. With its thorough scrutiny of proposals for digital services tax and virtual permanent establishments, insightful analysis of digital services and detailed description of the impact of big data on tax administration and taxpayer protection, it will quickly prove indispensable for tax practitioners and the international tax community more generally.

Climate change is unfolding amid the greatest information and communication revolution in human history. From e-commerce and social media to smart manufacturing and precision farming, digital technologies have become prevalent in all aspects of economic and social life. Digital technologies also have the potential to shape climate change action. Green digital transformation can help countries adapt e¬ffectively to the impacts of climate change and create greener growth pathways. Doing this means combining a focus on digital transformation and inclusion with a strategic and sustainable use of digital technologies to address climate change. Green Digital Transformation: How to Sustainably Close the Digital Divide and Harness Digital Tools for Climate Action illuminates the channels through which digital technologies intersect with climate change, and it proposes a path to low-emissions applications of digital technologies to help countries mitigate and adapt to climate change.

Activists use digital as well as mainstream media tools to attract supporters, advertise their campaigns, and raise awareness of issues in the broader community. Activism and Digital Culture in Australia examines the use of digital tools and culture by Australian and international activist organisations to facilitate public engagement, participation and deliberation in issues and advance social change. In particular the book engages media studies, cultural studies, social theory and various ethical and political philosophical perspectives to examine the use of digital multi-platform tools by activist organisations and advocates for social change to a) disseminate information and raise public awareness; b) invoke, inform and shape public debate through the provision of information and invocation of affect; and c) garner public support (including funding) for issues and for associated social change. Engaging both qualitative and quantitative approaches, these case studies will demonstrate the richness of digital culture for activism and advocacy, examining the use by activist organisations of such digital media tools as apps, blogging, Facebook, RSS, Twitter, and YouTube. The shows that digital culture offers productive mechanisms and spaces for the reshaping of society itself to take more of a participatory role in progressing social change.