Charity tax exemptions : a stitch in time saves nine

The Industry Commission has recently released a wide ranging draft report on charitable organisations. Part of the Inquiry's terms of reference required the Commission to examine the appropriateness of the taxation treatment of charities. The findings of the draft report when combined with the recommendations of the Federal Parliament's Follow the Yellow Brick Road Report point to a systematic review by the Australian Tax Office (ATO) of its dealings with charitable organisations. Generally prevention rather than cure is the better strategy in taxation issues. This article raises a number of issues charitable organisations might consider as part of their prevention strategy. As the ATO administers all the taxes discussed in this article and as the tests for exemption are similar, charitable organisations should find that "getting it right" for one tax means that their affairs will be in order for most taxes.

The 3D kinematics of the single leg flat and decline squat

Background: Pre-participation screening is commonly used to measure and assess potential intrinsic injury risk. The single leg squat is one such clinical screening measure used to assess lumbopelvic stability and associated intrinsic injury risk. With the addition of a decline board, the single leg decline squat (SLDS) has been shown to reduce ankle dorsiflexion restrictions and allowed greater sagittal plane movement of the hip and knee. On this basis, the SLDS has been employed in the Cricket Australia physiotherapy screening protocols as a measure of lumbopelvic control in the place of the more traditional single leg flat squat (SLFS). Previous research has failed to demonstrate which squatting technique allows for a more comprehensive assessment of lumbopelvic stability. Tenuous links are drawn between kinematics and hip strength measures within the literature for the SLS. Formal evaluation of subjective screening methods has also been suggested within the literature. Purpose: This study had several focal points namely 1) to compare the kinematic differences between the two single leg squatting conditions, primarily the five key kinematic variables fundamental to subjectively assess lumbopelvic stability; 2) determine the effect of ankle dorsiflexion range of motion has on squat kinematics in the two squat techniques; 3) examine the association between key kinematics and subjective physiotherapists’ assessment; and finally 4) explore the association between key kinematics and hip strength. Methods: Nineteen (n=19) subjects performed five SLDS and five SLFS on each leg while being filmed by an 8 camera motion analysis system. Four hip strength measures (internal/external rotation and abd/adduction) and ankle dorsiflexion range of motion were measured using a hand held dynamometer and a goniometer respectively on 16 of these subjects. The same 16 participants were subjectively assessed by an experienced physiotherapist for lumbopelvic stability. Paired samples t-tests were performed on the five predetermined kinematic variables to assess the differences between squat conditions. A Bonferroni correction for multiple comparisons was used which adjusted the significance value to p = 0.005 for the paired t-tests. Linear regressions were used to assess the relationship between kinematics, ankle range of motion and hip strength measures. Bivariate correlations between hip strength measures and kinematics and pelvic obliquity were employed to investigate any possible relationships. Results: 1) Significant kinematic differences between squats were observed in dominant (D) and non-dominant (ND) end of range hip external rotation (ND p = <0.001; D p = 0.004) and hip adduction kinematics (ND p = <0.001; D p = <0.001). With the mean angle, only the non-dominant leg observed significant differences in hip adduction (p = 0.001) and hip external rotation (p = <0.001); 2) Significant linear relationships were observed between clinical measures of ankle dorsiflexion and sagittal plane kinematic namely SLFS dominant ankle (p = 0.006; R2 = .429), SLFS non-dominant knee (p = 0.015; R2 = .352) and SLFS non-dominant ankle (p = 0.027; R2 = .305) kinematics. Only the dominant ankle (p = 0.020; R2 = .331) was found to have a relationship with the decline squat. 3) Strength measures had tenuous associations with the subjective assessments of lumbopelvic stability with no significant relationships being observed. 4) For the non-dominant leg, external rotation strength and abduction strength were found to be significantly correlated with hip rotation kinematics (Newtons r = 0.458 p = 0.049; Normalised for bodyweight: r = 0.469; p = 0.043) and pelvic obliquity (normalised for bodyweight: r = 0.498 p = 0.030) respectively for the SLFS only. No significant relationships were observed in the dominant leg for either squat condition. Some elements of the hip strength screening protocols had linear relationships with kinematics of the lower limb, particularly the sagittal plane movements of the knee and ankle. Strength measures had tenuous associations with the subjective assessments of lumbopelvic stability with no significant relationships being observed; Discussion: The key finding of this study illustrated that kinematic differences can occur at the hip without significant kinematic differences at the knee as a result of the introduction of a decline board. Further observations reinforce the role of limited ankle dorsiflexion range of motion on sagittal plane movement of the hip and knee and in turn multiplanar kinematics of the lower limb. The kinematic differences between conditions have clinical implications for screening protocols that employ frontal plane movement of the knee as a guide for femoral adduction and rotation. Subjects who returned stronger hip strength measurements also appeared to squat deeper as characterised by differences in sagittal plane kinematics of the knee and ankle. Despite the aforementioned findings, the relationship between hip strength and lower limb kinematics remains largely tenuous in the assessment of the lumbopelvic stability using the SLS. The association between kinematics and the subjective measures of lumbopelvic stability also remain tenuous between and within SLS screening protocols. More functional measures of hip strength are needed to further investigate these relationships. Conclusion: The type of SLS (flat or decline) should be taken into account when screening for lumbopelvic stability. Changes to lower limb kinematics, especially around the hip and pelvis, were observed with the introduction of a decline board despite no difference in frontal plane knee movements. Differences in passive ankle dorsiflexion range of motion yielded variations in knee and ankle kinematics during a self-selected single leg squatting task. Clinical implications of removing posterior ankle restraints and using the knee as a guide to illustrate changes at the hip may result in inaccurate screening of lumbopelvic stability. The relationship between sagittal plane lower limb kinematics and hip strength may illustrate that self-selected squat depth may presumably be a useful predictor of the lumbopelvic stability. Further research in this area is required.

Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as 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.

"Money pouring out of its ears" : on the taxation of really profitable nonprofit organisations in Australia

Under current law Australia appears to be a tax haven for certain non-governmental institutions. Millions of ordinary business income may go untaxed and the deductibility for donations is unlimited - both are very generous tax measures in an international context. The basic problems of most Australian nonprofit organisations are not taxation; they are just that: nonprofit. Anybody interested in the non-governmental sector should be willing to face the question: What is an equitable tax treatment? The short-term tactic of ducking the question may not be the best or most beneficial long term strategy.

Socioeconomic differences in takeaway food consumption among adults

Background In Australia and other developed countries, there are consistent and marked socioeconomic inequalities in health. Diet is a major contributing factor to the poorer health of lower socioeconomic groups: the dietary patterns of disadvantaged groups are least consistent with dietary recommendations for the prevention of diet-related chronic diseases compared with their more advantaged counterparts. Part of the reason that lower socioeconomic groups have poorer diets may be their consumption of takeaway foods. These foods typically have nutrient contents that fail to comply with the dietary recommendations for the prevention of chronic disease and associated risk factors. A high level of takeaway food consumption, therefore, may negatively influence overall dietary intakes and, consequently, lead to adverse health outcomes. Despite this, little attention has focused on the association between socioeconomic position (SEP) and takeaway food consumption, with the limited number of studies showing mixed results. Additionally, studies have been limited by only considering a narrow range of takeaway foods and not examining how different socioeconomic groups make choices that are more (or less) consistent with dietary recommendations. While a large number of earlier studies have consistently reported socioeconomically disadvantaged groups consume a lesser amount of fruit and vegetables, there is limited knowledge about the role of takeaway food in socioeconomic variations in fruit and vegetable intake. Furthermore, no known studies have investigated why there are socioeconomic differences in takeaway food consumption. The aims of this study are to: examine takeaway food consumption and the types of takeaway food consumed (healthy and less healthy) by different socioeconomic groups, to determine whether takeaway food consumption patterns explain socioeconomic variations in fruit and vegetable intake, and investigate the role of a range of psychosocial factors in explaining the association between SEP and takeaway food consumption and the choice of takeaway food. Methods This study used two cross-sectional population-based datasets: 1) the 1995 Australian National Nutrition Survey (NNS) which was conducted among a nationally representative sample of adults aged between 25.64 years (N = 7319, 61% response rate); and 2) the Food and Lifestyle Survey (FLS) which was conducted by the candidate and was undertaken among randomly selected adults aged between 25.64 years residing in Brisbane, Australia in 2009 (N = 903, 64% response rate). The FLS extended the NNS in several ways by describing current socioeconomic differences in takeaway food consumption patterns, formally assessing the mediated effect of takeaway food consumption to socioeconomic inequalities in fruit and vegetable intake, and also investigating whether (and which) psychosocial factors contributed to the observed socioeconomic variations in takeaway food consumption patterns. Results Approximately 32% of the NNS participants consumed takeaway food in the previous 24 hours and 38% of the FLS participants reported consuming takeaway food once a week or more. The results from analyses of the NNS and the FLS were somewhat mixed; however, disadvantaged groups were likely to consume a high level of �\less healthy. takeaway food compared with their more advantaged counterparts. The lower fruit and vegetable intake among lower socioeconomic groups was partly mediated by their high consumption of �\less healthy. takeaway food. Lower socioeconomic groups were more likely to have negative meal preparation behaviours and attitudes, and weaker health and nutrition-related beliefs and knowledge. Socioeconomic differences in takeaway food consumption were partly explained by meal preparation behaviours and attitudes, and these factors along with health and nutrition-related beliefs and knowledge appeared to contribute to the socioeconomic variations in choice of takeaway foods. Conclusion This thesis enhances our understanding of socioeconomic differences in dietary behaviours and the potential pathways by describing takeaway food consumption patterns by SEP, explaining the role of takeaway food consumption in socioeconomic inequalities in fruit and vegetable intake, and identifying the potential impact of psychosocial factors on socioeconomic differences in takeaway food consumption and the choice of takeaway food. Some important evidence is also provided for developing policies and effective intervention programs to improve the diet quality of the population, especially among lower socioeconomic groups. This thesis concludes with a discussion of a number of recommendations about future research and strategies to improve the dietary intake of the whole population, and especially among disadvantaged groups.

The 1998 tax reform proposal fringe benefits tax and nonprofit organisations

Fringe Benefits Tax (FBT) is a tax payable by employers on the value of certain fringe benefits that have been provided to their employees or to associates of those employees. It was introduced on 1 July 1986 to improve the equity of the taxation system because non-salary and wage benefits were escaping the taxation base. FBT ensures that tax is paid on those fringe benefits provided in place of, or in addition to, salary or wages of employees.

Context-aware rate-adaptive beaconing for efficient and scalable vehicular safety communication

Vehicular safety applications, such as cooperative collision warning systems, rely on beaconing to provide situational awareness that is needed to predict and therefore to avoid possible collisions. Beaconing is the continual exchange of vehicle motion-state information, such as position, speed, and heading, which enables each vehicle to track its neighboring vehicles in real time. This work presents a context-aware adaptive beaconing scheme that dynamically adapts the beaconing repetition rate based on an estimated channel load and the danger severity of the interactions among vehicles. The safety, efficiency, and scalability of the new scheme is evaluated by simulating vehicle collisions caused by inattentive drivers under various road traffic densities. Simulation results show that the new scheme is more efficient and scalable, and is able to improve safety better than the existing non-adaptive and adaptive rate schemes.

Taxing charities : reform without reason?

The proposal to tax the unrelated business income of charitable organisations was announced in the 2011 budget, but the course of events has overtaken the stated policy rationale. We identify and discuss the policy for the imposition of the new tax and demonstrate that the measure is unnecessary given a recent judgement by the High Court, establishment of a new charity regulator and a better understanding of the applicable tax theory.

Quantitative studies of lower motor neuron degeneration in amyotrophic lateral sclerosis : Evidence for exponential decay of motor unit numbers and greatest rate of loss at the site of onset

Objective: To use our Bayesian method of motor unit number estimation (MUNE) to evaluate lower motor neuron degeneration in ALS. Methods: In subjects with ALS we performed serial MUNE studies. We examined the repeatability of the test and then determined whether the loss of MUs was fitted by an exponential or Weibull distribution. Results: The decline in motor unit (MU) numbers was well-fitted by an exponential decay curve. We calculated the half life of MUs in the abductor digiti minimi (ADM), abductor pollicis brevis (APB) and/or extensor digitorum brevis (EDB) muscles. The mean half life of the MUs of ADM muscle was greater than those of the APB or EDB muscles. The half-life of MUs was less in the ADM muscle of subjects with upper limb than in those with lower limb onset. Conclusions: The rate of loss of lower motor neurons in ALS is exponential, the motor units of the APB decay more quickly than those of the ADM muscle and the rate of loss of motor units is greater at the site of onset of disease. Significance: This shows that the Bayesian MUNE method is useful in following the course and exploring the clinical features of ALS. 2012 International Federation of Clinical Neurophysiology.

The gender wage gap : a comparison of Australia and Canada

Using data from the 1989 Canadian Labour Market Activity Survey and, for Australia, the 1989-90 Income Distribution Survey, the authors investigate the reasons for the significantly lower gender wage gap in Australia than in Canada. Key similarities and differences between these two countries, the authors argue, make them a good basis for a "natural experiment" to investigate the effects of different labor market institutions. In particular, Australia has a stronger union movement and a greater degree of centralization in wage determination than Canada, and most of its workers are covered by legally binding minimum working conditions. The authors conclude that several differences between the countries in labor market structure-notably, a lower rate of return to education, a lower rate of return to labor market experience, and a lower level of wage inequality in Australia than in Canada- are largely responsible for the smaller gender wage gap in Australia.

Consecutive days of cold water immersion: effects on cycling performance and heart rate variability.

We investigated performance and heart rate (HR) variability (HRV) over consecutive days of cycling with post-exercise cold water immersion (CWI) or passive recovery (PAS). In a crossover design, 11 cyclists completed two separate 3-day training blocks (120 min cycling per day, 66 maximal sprints, 9 min time trialling [TT]), followed by 2 days of recovery-based training. The cyclists recovered from each training session by standing in cold water (10 °C) or at room temperature (27 °C) for 5 min. Mean power for sprints, total TT work and HR were assessed during each session. Resting vagal-HRV (natural logarithm of square-root of mean squared differences of successive R-R intervals; ln rMSSD) was assessed after exercise, after the recovery intervention, during sleep and upon waking. CWI allowed better maintenance of mean sprint power (between-trial difference [90 % confidence limits] +12.4 % [5.9; 18.9]), cadence (+2.0 % [0.6; 3.5]), and mean HR during exercise (+1.6 % [0.0; 3.2]) compared with PAS. ln rMSSD immediately following CWI was higher (+144 % [92; 211]) compared with PAS. There was no difference between the trials in TT performance (-0.2 % [-3.5; 3.0]) or waking ln rMSSD (-1.2 % [-5.9; 3.4]). CWI helps to maintain sprint performance during consecutive days of training, whereas its effects on vagal-HRV vary over time and depend on prior exercise intensity.

The effect of post-exercise hydrotherapy on subsequent exercise performance and heart rate variability

We investigated the effect of hydrotherapy on time-trial performance and cardiac parasympathetic reactivation during recovery from intense training. On three occasions, 18 well-trained cyclists completed 60 min high-intensity cycling, followed 20 min later by one of three 10-min recovery interventions: passive rest (PAS), cold water immersion (CWI), or contrast water immersion (CWT). The cyclists then rested quietly for 160 min with R-R intervals and perceptions of recovery recorded every 30 min. Cardiac parasympathetic activity was evaluated using the natural logarithm of the square root of mean squared differences of successive R-R intervals (ln rMSSD). Finally, the cyclists completed a work-based cycling time trial. Effects were examined using magnitude-based inferences. Differences in time-trial performance between the three trials were trivial. Compared with PAS, general fatigue was very likely lower for CWI (difference [90% confidence limits; -12% (-18; -5)]) and CWT [-11% (-19; -2)]. Leg soreness was almost certainly lower following CWI [-22% (-30; -14)] and CWT [-27% (-37; -15)]. The change in mean ln rMSSD following the recovery interventions (ln rMSSD(Post-interv)) was almost certainly higher following CWI [16.0% (10.4; 23.2)] and very likely higher following CWT [12.5% (5.5; 20.0)] compared with PAS, and possibly higher following CWI [3.7% (-0.9; 8.4)] compared with CWT. The correlations between performance, ln rMSSD(Post-interv) and perceptions of recovery were unclear. A moderate correlation was observed between ln rMSSD(Post-interv) and leg soreness [r = -0.50 (-0.66; -0.29)]. Although the effects of CWI and CWT on performance were trivial, the beneficial effects on perceptions of recovery support the use of these recovery strategies.

Tax morale, Eastern Europe and European enlargement

This study tries to remedy the current lack of tax compliance research analyzing tax morale in 10 Eastern European countries that joined the European Union in 2004 or 2007. By exploring tax morale differences between 1999 and 2008 we show that tax morale has decreased in 7 out of 10 Eastern European countries. This lack of sustainability may support the incentive based conditionality hypothesis that European Union has only a limited ability to influence tax morale over time. We observe that events and processes at the country level are crucial to understanding tax morale. Factors such as perceived government quality, trust in the justice system and the government are positively correlated with tax morale in 2008.

Automatic region-of-interest detection and prioritisation for visually optimised coding of low bit rate videos

The increasing popularity of video consumption from mobile devices requires an effective video coding strategy. To overcome diverse communication networks, video services often need to maintain sustainable quality when the available bandwidth is limited. One of the strategy for a visually-optimised video adaptation is by implementing a region-of-interest (ROI) based scalability, whereby important regions can be encoded at a higher quality while maintaining sufficient quality for the rest of the frame. The result is an improved perceived quality at the same bit rate as normal encoding, which is particularly obvious at the range of lower bit rate. However, because of the difficulties of predicting region-of-interest (ROI) accurately, there is a limited research and development of ROI-based video coding for general videos. In this paper, the phase spectrum quaternion of Fourier Transform (PQFT) method is adopted to determine the ROI. To improve the results of ROI detection, the saliency map from the PQFT is augmented with maps created from high level knowledge of factors that are known to attract human attention. Hence, maps that locate faces and emphasise the centre of the screen are used in combination with the saliency map to determine the ROI. The contribution of this paper lies on the automatic ROI detection technique for coding a low bit rate videos which include the ROI prioritisation technique to give different level of encoding qualities for multiple ROIs, and the evaluation of the proposed automatic ROI detection that is shown to have a close performance to human ROI, based on the eye fixation data.

A new legal avenue for pricing GHG emissions? To trade or to tax?

In a September 2010 media release the Prime Minister of Australia presented the terms of reference for the newly established Multi-Party Climate Change Committee. Although the Committee is charged with considering climate change mitigation measures in general, specifically the Committee must consider an appropriate mechanism for the establishment of a carbon price. The purpose of this article is to provide an overview of the mechanisms to be considered by the Climate Change Committee, including the use of emissions trading and carbon levies in other jurisdictions. This article argues that for any effective investigation of a carbon price for Australia to occur, a thorough knowledge of other jurisdictions’ methods for carbon pricing is essential.