399 resultados para Flat-rate income tax


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To examine socioeconomic differences in the frequency and types of takeaway foods consumed. Cross-sectional postal survey. Participants were asked about their usual consumption of overall takeaway food (< four times a month, or ≥ four times a month) and 22 specific takeaway food items (< once a month, or ≥ once a month): these latter foods were grouped into “healthy” and “less healthy” choices. Socioeconomic position was measured using education and equivalised household income and differences in takeaway food consumption were assessed by calculating prevalence ratios using log binomial regression. Adults aged 25–64 years from Brisbane, Australia were randomly selected from the electoral roll (N = 903, 63.7% response rate). Compared with their more educated counterparts, the least educated were more regular consumers of overall takeaway food, fruit/vegetable juice, and less regular consumers of sushi. For the “less healthy” items, the least educated more regularly consumed potato chips, savoury pies, fried chicken, and non-diet soft drinks; however, the least educated were less likely to consume curry. Household income was not associated with overall takeaway consumption. The lowest income group were more regular consumers of fruit/vegetable juice compared with the highest income group. Among the “less healthy” items, the lowest income group were more regular consumers of fried fish, ice-cream, and milk shakes, while curry was consumed less regularly. The frequency and types of takeaway foods consumed by socioeconomically disadvantaged groups may contribute to inequalities in overweight/obesity and chronic disease.

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A road bridge containing disused flatbed rail wagons as the primary deck superstructure was performance tested in a low volume, high axle load traffic road in Queensland, Australia; some key results are presented in this paper. A fully laden truck of total weight 28.88 % of the serviceability design load prescribed in the Australian bridge code was used; its wheel positions were accurately captured using a high speed camera and synchronised with the real‐time deflections and strains measured at the critical members of the flat rail wagons. The strains remained well below the yield and narrated the existence of composite action between the reinforced concrete slab pavement and the wagon deck. A three dimensional grillage model was developed and calibrated using the test data, which established the structural adequacy of the rail wagons and the positive contribution of the reinforced concrete slab pavement to resist high axle traffic loads on a single lane bridge in the low volume roads network.

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For many people, a relatively large proportion of daily exposure to a multitude of pollutants may occur inside an automobile. A key determinant of exposure is the amount of outdoor air entering the cabin (i.e. air change or flow rate). We have quantified this parameter in six passenger vehicles ranging in age from 18 years to <1 year, at three vehicle speeds and under four different ventilation settings. Average infiltration into the cabin with all operable air entry pathways closed was between 1 and 33.1 air changes per hour (ACH) at a vehicle speed of 60 km/h, and between 2.6 and 47.3 ACH at 110 km/h, with these results representing the most (2005 Volkswagen Golf) and least air-tight (1989 Mazda 121) vehicles, respectively. Average infiltration into stationary vehicles parked outdoors varied between ~0 and 1.4 ACH and was moderately related to wind speed. Measurements were also performed under an air recirculation setting with low fan speed, while airflow rate measurements were conducted under two non-recirculate ventilation settings with low and high fan speeds. The windows were closed in all cases, and over 200 measurements were performed. The results can be applied to estimate pollutant exposure inside vehicles.

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An improved scaling analysis and direct numerical simulations are performed for the unsteady natural convection boundary layer adjacent to a downward facing inclined plate with uniform heat flux. The development of the thermal or viscous boundary layers may be classified into three distinct stages: a start-up stage, a transitional stage and a steady stage, which can be clearly identified in the analytical as well as the numerical results. Previous scaling shows that the existing scaling laws of the boundary layer thickness, velocity and steady state time scale for the natural convection flow on a heated plate of uniform heat flux provide a very poor prediction of the Prandtl number dependency of the flow. However, those scalings perform very well with Rayleigh number and aspect ratio dependency. In this study, a modified Prandtl number scaling is developed using a triple layer integral approach for Pr > 1. It is seen that in comparison to the direct numerical simulations, the modified scaling performs considerably better than the previous scaling.

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Childhood sun exposure has been associated with increased risk of developing melanoma later in life. Sunscreen, children.s preferred method of sun protection, has been shown to reduce skin cancer risk. However, the effectiveness of sunscreen is largely dependent on user compliance, such as the thickness of application. To reach the sun protection factor (SPF) sunscreen must be applied at a thickness of 2mg/cm2. It has been demonstrated that adults tend to apply less than half of the recommended 2mg/cm2. This was the first study to measure the thickness at which children apply sunscreen. We recruited 87 primary school aged children (n=87, median age 8.7, 5-12 years) from seven state schools within one Brisbane education district (32% consent rate). The children were supplied with sunscreen in three dispenser types (pump, squeeze and roll-on) and were asked to use these for one week each. We measured the weight of the sunscreen before and after use, and calculated the children.s body surface area (based on height and weight) and area to which sunscreen was applied (based on children.s self-reported body coverage of application). Combined these measurements resulted in an average thickness of sunscreen application, which was our main outcome measure. We asked parents to complete a self-administered questionnaire which captured information about potential explanatory variables. Children applied sunscreen at a median thickness of 0.48mg/cm2, significantly less than the recommended 2mg/cm2 (p<0.001). When using the roll-on dispenser (median 0.22mg/cm2), children applied significantly less sunscreen thickness, compared to the pump (median 0.75mg.cm2, p<0.001), and squeeze (median 0.57mg/cm2, p<0.001) dispensers. School grade (1-7) was significantly associated with thickness of application (p=0.032), with children in the youngest grades applying the most. Other variables that were significantly associated with the outcome variable included: number of siblings (p=0.001), household annual income (p<0.001), and the number of lifetime sunburns the child had experienced (p=0.007). This work is the first to measure children.s sunscreen application thickness and demonstrates that regardless of their age or the type of dispenser that they use, children do not apply enough sunscreen to reach the advertised SPF. It is envisaged that this study will assist in the formulation of recommendations for future research, practice and policy aimed at improving childhood sun protection to reduce skin cancer incidence in the future.

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Now in its eighth edition, Australian Tax Analysis: Cases, Commentary, Commercial Applications and Questions has a proven track record as a high level work for students of taxation law written by a team of authors with many years of experience. Taking into account the fact that the volume of material needed to be processed by today’s taxation student can be overwhelming, the well-chosen extracts and thought-provoking commentary in Australian Tax Analysis, 8th edition, provide readers with the depth of knowledge, and reasoning and analytical skills that will be required of them as practitioners. As well as the carefully selected case extracts and the helpful commentary, each chapter is supplemented by engaging practice questions, involving problem-solving, commercial decision-making, legal analysis and quantitative application. All these elements combined make Australian Tax Analysis an invaluable aid to the understanding of a subject that can be both technical and complex.

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The Australian Federal Commissioner of Taxation recently released Draft Taxation Ruling TR 2008/D3 with the stated purpose of clarifying ‘what profits derived from the leasing of ships or aircraft fall within the ship and aircraft articles of each of Australia’s tax treaties’. In particular, TR 2008/D3 explains the taxing rights over different types of leasing profits, such as a full basis lease in respect of any transport by a ship operated in international traffic and bareboat leases which are ancillary to the lessor transport operations of ships in international traffic. This article outlines the Commissioner’s views on the application of the standard ships and aircraft articles in the tax treaties to which it is a party as well as considering the major variations on the standard adoption. In doing so, guidance is provided as to the allocation of taxing rights of ship and aircraft leasing profits under Australia’s tax treaties.

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Each year the Australian Federal Treasury releases its Tax Expenditures Statement providing details of concessions, benefits, and incentives delivered through the tax regime to Australian taxpayers. The current Tax Expenditures Statement, released on 25 January 2008, lists approximately 300 tax expenditures and reports on the estimated pecuniary value in terms of revenue foregone, estimated to be a total of $50.12 billion for the 2006-07 financial year. Apart from the annual Tax Expenditures Statement, and despite the recurring fiscal impact, there is very little other scrutiny of Australia’s Federal tax expenditures program. This is despite tax expenditures often being seen as an alternative to direct expenditures with similar impact on the Federal budget. The object of tax expenditures is to provide government assistance and meet government objectives, and, as such, tax expenditures are departures from the revenue raising aspect of the tax regime. Within this context, this article examines the fundamental concept of tax expenditures as contrasted with direct expenditures and considers the role they play in the current tax regime.

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The taxation of multinational banks currently is governed by the general principles of international tax. However, it is arguable that there are characteristics exclusive to multinational banks that may warrant the consideration of a separate taxing regime. This article argues that because of the unique nature of multinational banks, the traditional international tax rules governing jurisdiction to tax and allocation of income do not produce a result which is optimal, as it does not reflect economic reality. That is, the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment. Formulary apportionment is considered as an alternative that reflects economic reality by recognising the unique nature of multinational banks and allocating the income to the location of the economic activity. The unique nature of multinational banking is recognised in the fact that formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Starting from this recognition, the purpose of this article is to demonstrate that formulary apportionment is a theoretically superior (or optimal) model for the taxation of multinational banks. An optimal regime, for the purposes of this article, is considered to be one that distributes the taxing rights in an equitable manner between the relevant jurisdictions, while, simultaneously allowing decisions of the international banks to be tax neutral. In this sense, neutrality is viewed as an economic concept and equity is regarded as a legal concept. A neutral tax system is one in which tax rules do not affect economic choices about commercial activities. Neutrality will ideally be across jurisdictions as well as across traditional and non-traditional industries. The primary focus of this article is jurisdictional neutrality. A system that distributes taxing rights in an equitable manner between the relevant jurisdictions ensures that each country receives its fair share of tax revenue. Given the increase in multinational banking, jurisdictions should be concerned that they are receiving their fair share. Inter-nation equity is concerned with re-determining the proper division of the tax base among countries. Richard and Peggy Musgrave argue that sharing of the tax base by countries of source should be seen as a matter of inter-nation equity requiring international cooperation. The rights of the jurisdiction of residency will also be at issue. To this extent, while it is agreed that inter-nation equity is an essential attribute to an international tax regime, there is no universal agreement as to how to achieve it. The current system attempts to achieve such equity through a combined residency and source regime, with the transfer pricing rules used to apportion income between the relevant jurisdictions. However, this article suggests, that as an alternative to the current regime, equity would be achieved through formulary apportionment. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. Yet these are two separate issues. As such, this article is divided into two core parts. The first part examines the theoretical soundness of the formulary apportionment model concluding that it is theoretically superior to the arm’s length pricing requirement of the traditional transfer pricing regime. The second part examines the practical implications of accepting formulary apportionment as an optimal model with a view to disclosing the issues that arise when a formulary apportionment regime is adopted. Prior to an analysis of the theoretical and practical application of formulary apportionment to multinational banks, the unique nature of these banks is considered. The article concludes that, while there are significant implementation, compliance, and enforcement issues to overcome, the unitary taxation model may be theoretically superior to the current arm’s length model which applies to multinational banks. This conclusion is based on the unitary taxation model providing greater alignment with the unique features of these banks.

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Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2011 brings much needed clarity to this area of law. Utilising many methods to make this often daunting subject achievable, particular features of the 2011 edition include: • seven parts: overview and structure, principles of income, deductions and offsets, timing issues, investment and business entities, tax avoidance and administration, and indirect taxes; • clearly structured chapters within those parts grouped under helpful headings; • flowcharts, diagrams and tables, end of chapter practice questions, and case summaries; • an appendix containing all of the up to date and relevant rates; and • the online self-testing component mentor, which provides questions for students of both business and law. Every major aspect of the Australian tax system is covered, with chapters on topics such as goods and services tax, superannuation, offsets, partnerships, capital gains tax, trusts, company tax and tax administration. All chapters have been thoroughly revised. Principles of Taxation Law 2011 is the perfect tool to guide the reader from their initial exposure to the subject to success in taxation law exams. [from publisher's website]

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Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2012 brings much needed clarity to this area of law. Utilising many methods to make this often daunting subject achievable, particular features of the 2012 edition include: * seven parts: overview and structure, principles of income, deductions and offsets, timing issues, investment and business entities, tax avoidance and administration, and indirect taxes; * clearly structured chapters within those parts grouped under helpful headings; * flowcharts, diagrams and tables, end of chapter practice questions, and case summaries; * an appendix containing all of the up to date and relevant rates; and * the online self-testing component mentor, which provides questions for students of both business and law. Every major aspect of the Australian tax system is covered, with chapters on topics such as goods and services tax, superannuation, offsets, partnerships, capital gains tax, trusts, company tax and tax administration. All chapters have been thoroughly revised. Principles of Taxation Law 2012 is the perfect tool to guide the reader from their initial exposure to the subject to success in taxation law exams.

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This paper proposes a novel approach to video deblocking which performs perceptually adaptive bilateral filtering by considering color, intensity, and motion features in a holistic manner. The method is based on bilateral filter which is an effective smoothing filter that preserves edges. The bilateral filter parameters are adaptive and avoid over-blurring of texture regions and at the same time eliminate blocking artefacts in the smooth region and areas of slow motion content. This is achieved by using a saliency map to control the strength of the filter for each individual point in the image based on its perceptual importance. The experimental results demonstrate that the proposed algorithm is effective in deblocking highly compressed video sequences and to avoid over-blurring of edges and textures in salient regions of image.

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As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.