The taxation of international maritime leasing profits : has the commissioners ship come in?

In light of McDermott Industries (AUST) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties to which Australia is a party, in particular the application of the business profits provisions of those treaties, and the deemed existence of a permanent establishment where substantial equipment, owned by a fiscal non-resident, is used within Australian waters.

Evolutions of an Online Generation: Education, Industry and IMC

This paper traces the evolutions of a new generation of students who are predominantly the ‘online generation’; explores the emerging impact of this generation on industry; identifies the changing role of education from traditional classroom to an online environment; and explores the contribution related to integrated marketing communications (IMC). Educational requirements from a business perspective must incorporate global business demands; virtual learning environments progress the online generation towards a post-modern learning state. The central proposition of this paper is that the emergence of IMC in evolving industry practices is influenced by student generations who are producing a new paradigm of alignment between education and industry. This is purely a conceptual exploration using limited examples to provide some context and illustrate the questions raised for consideration.