Judicial and legislative considerations in the taxation of compensation receipts : an international comparison

In 1995, the Federal Commissioner of Taxation released Taxation Ruling TR 95/35 in an attempt to comprehensively address the appropriate capital gains tax treatment of a receipt of compensation, awarded either by the courts or via a settlement. The ruling was in response to the numerous, somewhat contradictory, court decisions of the early 1990s. Despite the release of TR 95/35, there still appears to be a lack of consensus as to the appropriate treatment of such awards. It has been suggested that the only way a taxpayer can, with any certainty, determine their liability is to obtain a private binding ruling, a far from satisfactory situation. In an attempt to clarify what the capital gains tax consequences of a compensation receipt should be, this article examines the Australian position and explores the comparative jurisprudence of the United Kingdom and Canada to ascertain whether the Australian attitude is consistent with these international jurisdictions. This article concludes that while the jurisdictions, through differing approaches, achieve a similar result, there is still a need to address the uncertainties that remain.

Local Hollywood: global film production and the Gold Coast

Hollywood films and television programs are watched by a global audience. While many of these productions are still made in southern California, the last twenty years have seen new production centres emerge in the US, Canada and other locations worldwide. Global Hollywood has been made possible by this growing number of Local Hollywoods: locations equipped with the requisite facilities, resources and labour, as well as the political will and tax incentives, to attract and retain high-budget, Hollywood-standard projects. This new book gives an unprecedented insight into how the Gold Coast became the first outpost of Hollywood in Australia. When a combination of forces drove Hollywood studios and producers to work outside California, the Gold Coast's unique blend of government tax support, innovative entrepreneurs and diverse natural settings made it a perfect choice to host Hollywood productions. 'Local Hollywood' makes an essential contribution to the field of film and media studies, as well as giving film buffs a behind-the-scenes tour of the film industry.

Cultural diversity, cultural networks and trade : international cultural policy debate

This article sketches some of the ways in which the language and concepts of cultural diversity are being taken up internationally. The debate has been driven in part by concerns about the treatment of cultural goods, services and knowledge in trade agreements. But it also involves larger questions about the role of the state, the role of non-state actors in domestic policy formation, and the shape and function of international policy communities comprising both state and non-state actors. The extent of the discussion of cultural diversity internationally is described through new formal and informal cultural networks and work towards an international instrument for cultural diversity to lay our ground rules for international trade, cultural exchange and policy principles to guide governmental responsibilities. The article concludes with analysis of some of these new networks, and investigates why Canada has been so prominent in these international efforts.

International transfer pricing : the Australian approach and lessons for Canada

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.

Experiences of a walking intervention in a University community : Qualitative perspectives

Background: This study explored the experiences of university employees that participated in a walking intervention that encouraged individuals to walk more throughout their workday. The 10-week program was comprised of 5 phases (i.e. baseline, anticipating barriers, short planned walks, longer planned walks and maintenance) and utilized a pedometer diary and an online website for logging steps. The pedometer diary included “action plans” for addressing barriers and planning walking and the online dashboard provided graphical outputs that allowed participants to visualize whether they were reaching or exceeding their step targets. Methods: A subsample of 12 academic and administrative employees from the study completed open ended questionnaires at the end of the study. The questions focused on capturing the major themes of benefits/mediators and problems/moderators of the program and were assessed using phenomenological approaches. Results: Participants found a raised consciousness of physical inactivity throughout the work day. They also found it useful to have a graphical display of physical activity patterns, but found time constraints and lack of managerial support to be the primary barriers/moderators of the program. Those most likely to withdraw from the program experienced technical difficulties with objective monitors and the online website. Conclusions: Findings highlight the value in being involved in a group forum and provide insights into the challenges of supporting such programs within the workplace.

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.

Knowledge-Intensive Business Processes: Proceedings of the 1st International Workshop on Knowledge-intensive Business Processes [CEUR Workshop Proceedings, Volume 861]

Nowadays, Workflow Management Systems (WfMSs) and, more generally, Process Management Systems (PMPs) are process-aware Information Systems (PAISs), are widely used to support many human organizational activities, ranging from well-understood, relatively stable and structures processes (supply chain management, postal delivery tracking, etc.) to processes that are more complicated, less structured and may exhibit a high degree of variation (health-care, emergency management, etc.). Every aspect of a business process involves a certain amount of knowledge which may be complex depending on the domain of interest. The adequate representation of this knowledge is determined by the modeling language used. Some processes behave in a way that is well understood, predictable and repeatable: the tasks are clearly delineated and the control flow is straightforward. Recent discussions, however, illustrate the increasing demand for solutions for knowledge-intensive processes, where these characteristics are less applicable. The actors involved in the conduct of a knowledge-intensive process have to deal with a high degree of uncertainty. Tasks may be hard to perform and the order in which they need to be performed may be highly variable. Modeling knowledge-intensive processes can be complex as it may be hard to capture at design-time what knowledge is available at run-time. In realistic environments, for example, actors lack important knowledge at execution time or this knowledge can become obsolete as the process progresses. Even if each actor (at some point) has perfect knowledge of the world, it may not be certain of its beliefs at later points in time, since tasks by other actors may change the world without those changes being perceived. Typically, a knowledge-intensive process cannot be adequately modeled by classical, state of the art process/workflow modeling approaches. In some respect there is a lack of maturity when it comes to capturing the semantic aspects involved, both in terms of reasoning about them. The main focus of the 1st International Workshop on Knowledge-intensive Business processes (KiBP 2012) was investigating how techniques from different fields, such as Artificial Intelligence (AI), Knowledge Representation (KR), Business Process Management (BPM), Service Oriented Computing (SOC), etc., can be combined with the aim of improving the modeling and the enactment phases of a knowledge-intensive process. The 1st International Workshop on Knowledge-intensive Business process (KiBP 2012) was held as part of the program of the 2012 Knowledge Representation & Reasoning International Conference (KR 2012) in Rome, Italy, in June 2012. The workshop was hosted by the Dipartimento di Ingegneria Informatica, Automatica e Gestionale Antonio Ruberti of Sapienza Universita di Roma, with financial support of the University, through grant 2010-C26A107CN9 TESTMED, and the EU Commission through the projects FP7-25888 Greener Buildings and FP7-257899 Smart Vortex. This volume contains the 5 papers accepted and presented at the workshop. Each paper was reviewed by three members of the internationally renowned Program Committee. In addition, a further paper was invted for inclusion in the workshop proceedings and for presentation at the workshop. There were two keynote talks, one by Marlon Dumas (Institute of Computer Science, University of Tartu, Estonia) on "Integrated Data and Process Management: Finally?" and the other by Yves Lesperance (Department of Computer Science and Engineering, York University, Canada) on "A Logic-Based Approach to Business Processes Customization" completed the scientific program. We would like to thank all the Program Committee members for the valuable work in selecting the papers, Andrea Marrella for his valuable work as publication and publicity chair of the workshop, and Carola Aiello and the consulting agency Consulta Umbria for the organization of this successful event.

Towards persistent localization and mapping with a continuous appearance-based topology

Appearance-based localization can provide loop closure detection at vast scales regardless of accumulated metric error. However, the computation time and memory requirements of current appearance-based methods scale not only with the size of the environment but also with the operation time of the platform. Additionally, repeated visits to locations will develop multiple competing representations, which will reduce recall performance over time. These properties impose severe restrictions on long-term autonomy for mobile robots, as loop closure performance will inevitably degrade with increased operation time. In this paper we present a graphical extension to CAT-SLAM, a particle filter-based algorithm for appearance-based localization and mapping, to provide constant computation and memory requirements over time and minimal degradation of recall performance during repeated visits to locations. We demonstrate loop closure detection in a large urban environment with capped computation time and memory requirements and performance exceeding previous appearance-based methods by a factor of 2. We discuss the limitations of the algorithm with respect to environment size, appearance change over time and applications in topological planning and navigation for long-term robot operation.

Digital Storytelling within a Service-Learning Partnership: Technology as Product and Process for University Students and Culturally and Linguistically Diverse High School Youth

This chapter describes a university/high school partnership focused on digital storytelling. It also explains the multi-stage process used to establish this successful partnership and project. The authors discuss the central role that technology played in developing this university/high school partnership, a collaboration that extended the impact of a digital storytelling project to reach high school students, university students, educators, high school administrators, and the local community. Valuing a reflective process that can lead to the creation of a powerful final product, the authors describe the impact of digital storytelling on multiple stakeholders, including the 13 university students and 33 culturally and linguistically diverse high school youth who participated during the fall of 2009. In addition, the chapter includes reflections from university and high school student participants expressed during focus groups conducted throughout the project. While most participants had a positive experience with the project, complications with the technology component often caused frustrations and additional challenges. Goals for sharing this project are to critically evaluate digital storytelling, describe lessons learned, and recommend good practices for others working within a similar context or with parallel goals.