The allocation of taxing rights of ship and aircraft leasing profits under Australia's tax treaties

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.

Strategic Management Practices in the Construction Industry : a Dynamic Capabilities View

This book is an empirical study of strategic management practices in the construction industry. It examines the dynamic capabilities paradigm within the context of the Indonesian construction industry. The characteristics of asset-capability combinations were found to be significant determinants of the competitive advantage of the Indonesian construction enterprises, and that such advantage sequentially contributes to organizational performance. In doing so, this study fills an important gap in the empirical literature and reinforces the dynamic capabilities framework’s recognition as a rigorous theory of strategic management. As the dynamic capabilities framework can work in the context of Indonesia, it suggests that the framework has potential applicability in other emerging and developing countries

Static and dynamic strain sensing using a polymer : carbon nanotube film strain sensor

The search for new multipoint, multidirectional strain sensing devices has received a new impetus since the discovery of carbon nanotubes. The excellent electrical, mechanical, and electromechanical properties of carbon nanotubes make them ideal candidates as primary materials in the design of this new generation of sensing devices. Carbon nanotube based strain sensors proposed so far include those based on individual carbon nanotubes for integration in nano or micro elecromechanical systems (NEMS/MEMS) [1], or carbon nanotube films consisting of spatially connected carbon nanotubes [2], carbon nanotube - polymer composites [3,4] for macroscale strain sensing. Carbon nanotube films have good strain sensing response and offer the possibility of multidirectional and multipoint strain sensing, but have poor performance due to weak interaction between carbon nanotubes. In addition, the carbon nanotube film sensor is extremely fragile and difficult to handle and install. We report here the static and dynamic strain sensing characteristics as well as temperature effects of a sandwich carbon nanotube - polymer sensor fabricated by infiltrating carbon nanotube films with polymer.

Unlocking risk allocation and equitable conversion : reform of the passing of risk in the sale of land

The principles relating to the passing of risk under a contract for the sale of real property would seem to have been long settled. The rule under the general law is that the risk of loss of the subject matter under a contract for the sale of real property passes to the buyer upon the creation of a valid and binding contract. This article considers the origin of that rule, how it developed with the growth of equity, and advances the view that it is anomalous in a modern context of property dealings. In doing so, the article adverts to the variety of statutory mechanisms used to subvert the rule, few of which are of practical value. It concludes that the rule is outmoded in many respects and suggests a number of reforms which might be implemented nationally to bring consistency and simplicity to the issue of damage or destruction of improvements which are the subject of a land contract.

Interplay effects during enhanced dynamic wedge deliveries

In this study the interplay effects for Enhanced Dynamic Wedge (EDW) treatments are experimentally investigated. Single and multiple field EDW plans for different wedge angles were delivered to a phantom and detector on a moving platform, with various periods, amplitudes for parallel and perpendicular motions. A four field 4D CT planned lung EDW treatment was delivered to a dummy tumor over four fractions. For the single field parallel case the amplitude and the period of motion both affect the interplay resulting in the appearance of a step function and penumbral cut off with the discrepancy worst where collimator-tumor speed is similar. For perpendicular motion the amplitude of tumor motion is the only dominant factor. For large wedge angle the dose discrepancy is more pronounced compared to the small wedge angle for the same field size and amplitude-period values. For a small field size i.e. 5 × 5 cm2 the loss of wedged distribution was observed for both 60º and 15º wedge angles for of parallel and perpendicular motions. Film results from 4D CT planned delivery displayed a mix of over and under dosages over 4 fractions, with the gamma pass rate of 40% for the averaged film image at 3%/1 mm DTA (Distance to Agreement). Amplitude and period of the tumor motion both affect the interplay for single and multi-field EDW treatments and for a limited (4 or 5) fraction delivery there is a possibility of non-averaging of the EDW interplay.

Condition deterioration prediction of bridge elements using Dynamic Bayesian Networks (DBNs)

The ability of bridge deterioration models to predict future condition provides significant advantages in improving the effectiveness of maintenance decisions. This paper proposes a novel model using Dynamic Bayesian Networks (DBNs) for predicting the condition of bridge elements. The proposed model improves prediction results by being able to handle, deterioration dependencies among different bridge elements, the lack of full inspection histories, and joint considerations of both maintenance actions and environmental effects. With Bayesian updating capability, different types of data and information can be utilised as inputs. Expert knowledge can be used to deal with insufficient data as a starting point. The proposed model established a flexible basis for bridge systems deterioration modelling so that other models and Bayesian approaches can be further developed in one platform. A steel bridge main girder was chosen to validate the proposed model.

Semantic service discovery in the service ecosystem

Electronic services are a leitmotif in ‘hot’ topics like Software as a Service, Service Oriented Architecture (SOA), Service oriented Computing, Cloud Computing, application markets and smart devices. We propose to consider these in what has been termed the Service Ecosystem (SES). The SES encompasses all levels of electronic services and their interaction, with human consumption and initiation on its periphery in much the same way the ‘Web’ describes a plethora of technologies that eventuate to connect information and expose it to humans. Presently, the SES is heterogeneous, fragmented and confined to semi-closed systems. A key issue hampering the emergence of an integrated SES is Service Discovery (SD). A SES will be dynamic with areas of structured and unstructured information within which service providers and ‘lay’ human consumers interact; until now the two are disjointed, e.g., SOA-enabled organisations, industries and domains are choreographed by domain experts or ‘hard-wired’ to smart device application markets and web applications. In a SES, services are accessible, comparable and exchangeable to human consumers closing the gap to the providers. This requires a new SD with which humans can discover services transparently and effectively without special knowledge or training. We propose two modes of discovery, directed search following an agenda and explorative search, which speculatively expands knowledge of an area of interest by means of categories. Inspired by conceptual space theory from cognitive science, we propose to implement the modes of discovery using concepts to map a lay consumer’s service need to terminologically sophisticated descriptions of services. To this end, we reframe SD as an information retrieval task on the information attached to services, such as, descriptions, reviews, documentation and web sites - the Service Information Shadow. The Semantic Space model transforms the shadow's unstructured semantic information into a geometric, concept-like representation. We introduce an improved and extended Semantic Space including categorization calling it the Semantic Service Discovery model. We evaluate our model with a highly relevant, service related corpus simulating a Service Information Shadow including manually constructed complex service agendas, as well as manual groupings of services. We compare our model against state-of-the-art information retrieval systems and clustering algorithms. By means of an extensive series of empirical evaluations, we establish optimal parameter settings for the semantic space model. The evaluations demonstrate the model’s effectiveness for SD in terms of retrieval precision over state-of-the-art information retrieval models (directed search) and the meaningful, automatic categorization of service related information, which shows potential to form the basis of a useful, cognitively motivated map of the SES for exploratory search.

Monte Carlo simulations of dynamic radiotherapy treatments

The effects of tumour motion during radiation therapy delivery have been widely investigated. Motion effects have become increasingly important with the introduction of dynamic radiotherapy delivery modalities such as enhanced dynamic wedges (EDWs) and intensity modulated radiation therapy (IMRT) where a dynamically collimated radiation beam is delivered to the moving target, resulting in dose blurring and interplay effects which are a consequence of the combined tumor and beam motion. Prior to this work, reported studies on the EDW based interplay effects have been restricted to the use of experimental methods for assessing single-field non-fractionated treatments. In this work, the interplay effects have been investigated for EDW treatments. Single and multiple field treatments have been studied using experimental and Monte Carlo (MC) methods. Initially this work experimentally studies interplay effects for single-field non-fractionated EDW treatments, using radiation dosimetry systems placed on a sinusoidaly moving platform. A number of wedge angles (60º, 45º and 15º), field sizes (20 × 20, 10 × 10 and 5 × 5 cm2), amplitudes (10-40 mm in step of 10 mm) and periods (2 s, 3 s, 4.5 s and 6 s) of tumor motion are analysed (using gamma analysis) for parallel and perpendicular motions (where the tumor and jaw motions are either parallel or perpendicular to each other). For parallel motion it was found that both the amplitude and period of tumor motion affect the interplay, this becomes more prominent where the collimator tumor speeds become identical. For perpendicular motion the amplitude of tumor motion is the dominant factor where as varying the period of tumor motion has no observable effect on the dose distribution. The wedge angle results suggest that the use of a large wedge angle generates greater dose variation for both parallel and perpendicular motions. The use of small field size with a large tumor motion results in the loss of wedged dose distribution for both parallel and perpendicular motion. From these single field measurements a motion amplitude and period have been identified which show the poorest agreement between the target motion and dynamic delivery and these are used as the „worst case motion parameters.. The experimental work is then extended to multiple-field fractionated treatments. Here a number of pre-existing, multiple–field, wedged lung plans are delivered to the radiation dosimetry systems, employing the worst case motion parameters. Moreover a four field EDW lung plan (using a 4D CT data set) is delivered to the IMRT quality control phantom with dummy tumor insert over four fractions using the worst case parameters i.e. 40 mm amplitude and 6 s period values. The analysis of the film doses using gamma analysis at 3%-3mm indicate the non averaging of the interplay effects for this particular study with a gamma pass rate of 49%. To enable Monte Carlo modelling of the problem, the DYNJAWS component module (CM) of the BEAMnrc user code is validated and automated. DYNJAWS has been recently introduced to model the dynamic wedges. DYNJAWS is therefore commissioned for 6 MV and 10 MV photon energies. It is shown that this CM can accurately model the EDWs for a number of wedge angles and field sizes. The dynamic and step and shoot modes of the CM are compared for their accuracy in modelling the EDW. It is shown that dynamic mode is more accurate. An automation of the DYNJAWS specific input file has been carried out. This file specifies the probability of selection of a subfield and the respective jaw coordinates. This automation simplifies the generation of the BEAMnrc input files for DYNJAWS. The DYNJAWS commissioned model is then used to study multiple field EDW treatments using MC methods. The 4D CT data of an IMRT phantom with the dummy tumor is used to produce a set of Monte Carlo simulation phantoms, onto which the delivery of single field and multiple field EDW treatments is simulated. A number of static and motion multiple field EDW plans have been simulated. The comparison of dose volume histograms (DVHs) and gamma volume histograms (GVHs) for four field EDW treatments (where the collimator and patient motion is in the same direction) using small (15º) and large wedge angles (60º) indicates a greater mismatch between the static and motion cases for the large wedge angle. Finally, to use gel dosimetry as a validation tool, a new technique called the „zero-scan method. is developed for reading the gel dosimeters with x-ray computed tomography (CT). It has been shown that multiple scans of a gel dosimeter (in this case 360 scans) can be used to reconstruct a zero scan image. This zero scan image has a similar precision to an image obtained by averaging the CT images, without the additional dose delivered by the CT scans. In this investigation the interplay effects have been studied for single and multiple field fractionated EDW treatments using experimental and Monte Carlo methods. For using the Monte Carlo methods the DYNJAWS component module of the BEAMnrc code has been validated and automated and further used to study the interplay for multiple field EDW treatments. Zero-scan method, a new gel dosimetry readout technique has been developed for reading the gel images using x-ray CT without losing the precision and accuracy.

Dynamic covalent chemistry on surfaces employing highly reactive cyclopentadienyl moieties

Silicon substrates coated with a bromide-terminated silane are transformed into highly reactive, cyclopentadiene covered analogues. These surfaces undergo rapid cycloaddition reactions with various dienophile-capped polymers. Mild heating of the substrates causes the retro-Diels-Alder reaction to occur, thus reforming the reactive cyclopentadiene surface, generating an efficiently switchable surface.

Leveraging innovation for sustainable construction, proceedings of the CIB Task Group 58: Clients and Construction Innovation Workshop

This publication consists of a volume of papers presented at the workshop of the CIB Task Group 58: Clients and Construction Innovation, held on May 18- 19, 2009 at the University of Alberta in Edmonton, Canada. The workshop theme, “Leveraging Innovation for Sustainable Construction”, reflects a growing concern among clients for perspectives, approaches, and tools that will secure the practice of construction economically, socially, and environmentally. This collection encompasses some of the most incisive assessments of the challenges facing the construction industry today from a range of researchers and industry practitioners who are leading the way for tomorrow’s innovations. It provides a useful documentation of the ongoing conversation regarding innovation and sustainability issues and a foundation of knowledge for future research and development. The papers contained in this volume explore the workshop’s overarching theme of how to leverage innovation to increase the sustainability of the construction process and product. Participants sought to generate discussion on the topics of innovation and sustainability within the construction field, to share international examples of innovation from the research community and from industry, and to establish a point of reference for ongoing enquiry. In particular, our contributors have noted the value of learning through practice in order to orient research based on real-world industry experience. Chapters two and three present complementary models of sustainable research programs through the three parts collaboration of government, industry, and academia. Chapters four and five explore new tools and forms of technological innovation as they are deployed to improve construction project management and set the direction for advances in research. Chapters six, seven, and eight closely study practical examples of innovation in large-scale construction projects, showing with concrete results the impact of applying creative methods and best practices to the field. Innovation and sustainability in construction are truly global efforts; these papers illustrate how we can draw on international examples and cooperative organizations to address these important issues for long-term benefit of the industry.

Recognising the capacities of dynamic reconfiguration for the QoS assurance of running systems in concurrent and parallel environments

Recognizing the impact of reconfiguration on the QoS of running systems is especially necessary for choosing an appropriate approach to dealing with dynamic evolution of mission-critical or non-stop business systems. The rationale is that the impaired QoS caused by inappropriate use of dynamic approaches is unacceptable for such running systems. To predict in advance the impact, the challenge is two-fold. First, a unified benchmark is necessary to expose QoS problems of existing dynamic approaches. Second, an abstract representation is necessary to provide a basis for modeling and comparing the QoS of existing and new dynamic reconfiguration approaches. Our previous work [8] has successfully evaluated the QoS assurance capabilities of existing dynamic approaches and provided guidance of appropriate use of particular approaches. This paper reinvestigates our evaluations, extending them into concurrent and parallel environments by abstracting hardware and software conditions to design an evaluation context. We report the new evaluation results and conclude with updated impact analysis and guidance.