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.

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.

Increasing disaster resilience of people and property through fostering collaboration in coastal high hazard zones

As evidenced with the 2011 floods the state of Queensland in Australia is quite vulnerable to this kind of disaster. Climate change will increase the frequency and magnitude of such events and will have a variety of other impacts. To deal with these governments at all levels need to be prepared and work together. Since most of the population of the state is located in the coastal areas and these areas are more vulnerable to the impacts of climate change this paper examines climate change adaptation efforts in coastal Queensland. The paper is part of a more comprehensive project which looks at the critical linkages between land use and transport planning in coastal Queensland, especially in light of increased frequencies of cyclonic activity and other impacts associated with climate change. The aim is improving coordination between local and state government in addressing land use and transport planning in coastal high hazard areas. By increasing the ability of local governments and state agencies to coordinate planning activities, we can help adapt to impacts of climate change. Towards that end, we will look at the ways that these groups currently interact, especially with regard to issues involving uncertainty related to climate change impacts. Through surveys and interviews of Queensland coastal local governments and state level planning agencies on how they coordinate their planning activities at different levels as well as how much they take into account the linkage of transportation and land use we aim to identify the weaknesses of the current planning system in responding to the challenges of climate change adaptation. The project will identify opportunities for improving the ways we plan and coordinate planning, and make recommendations to improve resilience in advance of disasters so as to help speed up recovery when they occur.

Maintenance considerations in applied substation reliability assessment

This paper presents a reliability assessment of a substation, part of the Queensland transmission network in Australia. As part of a maintenance considerations, this study utilises the substation reliability assessment package STAREL to quantitatively compare the reliability improvement achieved by two circuit breaker reinforcement alternatives for Swanbank circuit breaker replacement or refurbishment. Substation reliability is interpreted on the basis of outage frequency and outage duration indices for each individual transmission line terminated in Swanbank 'B' substation. By considering the reliability indices in this paper with the cost associated conducted by POWERLINK Queensland, a Swanbank 'B' reinforcement alternative can be selected that optimises both transmission line security and the costs incurred in achieving it.

Kerberos based security system for session initiation protocol

Session Initiation Protocol (SIP) is developed to provide advanced voice services over IP networks. SIP unites telephony and data world, permitting telephone calls to be transmitted over Intranets and Internet. Increase in network performance and new mechanisms for guaranteed quality of service encourage this consolidation to provide toll cost savings. Security comes up as one of the most important issues when voice communication and critical voice applications are considered. Not only the security methods provided by traditional telephony systems, but also additional methods are required to overcome security risks introduced by the public IP networks. SIP considers security problems of such a consolidation and provides a security framework. There are several security methods defined within SIP specifications and extensions. But, suggested methods can not solve all the security problems of SIP systems with various system requirements. In this thesis, a Kerberos based solution is proposed for SIP security problems, including SIP authentication and privacy. The proposed solution tries to establish flexible and scalable SIP system that will provide desired level of security for voice communications and critical telephony applications.

Coordinated probabilistic optimal decision-making model for multi-area ATC with risk control

In the decision-making of multi-area ATC (Available Transfer Capacity) in electricity market environment, the existing resources of transmission network should be optimally dispatched and coordinately employed on the premise that the secure system operation is maintained and risk associated is controllable. The non-sequential Monte Carlo simulation is used to determine the ATC probability density distribution of specified areas under the influence of several uncertainty factors, based on which, a coordinated probabilistic optimal decision-making model with the maximal risk benefit as its objective is developed for multi-area ATC. The NSGA-II is applied to calculate the ATC of each area, which considers the risk cost caused by relevant uncertainty factors and the synchronous coordination among areas. The essential characteristics of the developed model and the employed algorithm are illustrated by the example of IEEE 118-bus test system. Simulative result shows that, the risk of multi-area ATC decision-making is influenced by the uncertainties in power system operation and the relative importance degrees of different areas.

Chaotic soul - messy heart : the phenomenon of experiencing auditory hallucinations

Globally, it is estimated that 24 million people live with schizophrenia (WHO, 2008), while 1.2 million people have been diagnosed with schizophrenia in Indonesia. Auditory hallucinations are a key symptom of schizophrenia according to the DSM IV-TR (Frances, First, & Pincus, 2002). It is estimated that the prevalence of auditory hallucinations in people with schizophrenia range from 64.3% to 83.4% (Thomas et al., 2007). Until recently, the majority of studies were conducted in Western societies the primary focus of which, has been on the causes and treatments of auditory hallucinations (Walton, 1999) and on the biological and cognitive aspects of the phenomenon (Changas, Garcia-Montes, de Lemus & Olivencia, 2003). While a few studies have explored the lived experience of people with schizophrenia, there is little research about the experience of auditory hallucinations. Therefore, the focus of this study was on an exploration of the experience of auditory hallucinations as described by Indonesian people living with schizophrenia. Based on the available literature, there have been no published qualitative studies relating to the lived experience of auditory hallucinations as described by Indonesian people diagnosed with schizophrenia. Husserlian descriptive phenomenological approach was applied in explicating the phenomenon of auditory hallucinations in this study. In-depth audio-taped interviews were conducted with 13 participants. Analysis of participant transcripts was undertaken using Colaizzi.s (1973) approach. Eight major themes were explicated: Feeling more like a robot than a human being - feeling compelled to respond to auditory hallucinations; voices of contradiction - a point of confusion; a frightening experience, the voices emerged at times of loss and grief; disruption to daily living; tattered relationships and family disarray; finding a personal path to living with auditory hallucinations; seeking relief in Allah through prayer and ritual. Experiencing auditory hallucinations for people diagnosed with schizophrenia is a journey of challenges as each individual struggles to understand their now changed life-world, reconstruct a sense of meaning within their illness experience, and to carve out a pathway to wellness. The challenge for practitioners is to learn from those who have experienced auditory hallucinations, to be with them in their journey of recovery and wellness, and to apply a person-centered approach to care within the context of a multidisciplinary team.

Deep Raman Spectroscopy in the analytical forensic investigation of concealed substances

Deep Raman Spectroscopy is a domain within Raman spectroscopy consisting of techniques that facilitate the depth profiling of diffusely scattering media. Such variants include Time-Resolved Raman Spectroscopy (TRRS) and Spatially-Offset Raman Spectroscopy (SORS). A recent study has also demonstrated the integration of TRRS and SORS in the development of Time-Resolved Spatially-Offset Raman Spectroscopy (TR-SORS). This research demonstrates the application of specific deep Raman spectroscopic techniques to concealed samples commonly encountered in forensic and homeland security at various working distances. Additionally, the concepts behind these techniques are discussed at depth and prospective improvements to the individual techniques are investigated. Qualitative and quantitative analysis of samples based on spectral data acquired from SORS is performed with the aid of multivariate statistical techniques. By the end of this study, an objective comparison is made among the techniques within Deep Raman Spectroscopy based on their capabilities. The efficiency and quality of these techniques are determined based on the results procured which facilitates the understanding of the degree of selectivity for the deeper layer exhibited by the individual techniques relative to each other. TR-SORS was shown to exhibit an enhanced selectivity for the deeper layer relative to TRRS and SORS whilst providing spectral results with good signal-to-noise ratio. Conclusive results indicate that TR-SORS is a prospective deep Raman technique that offers higher selectivity towards deep layers and therefore enhances the non-invasive analysis of concealed substances from close range as well as standoff distances.

Global gene expression in skeletal muscle from well-trained strength and endurance athletes

PURPOSE: We used gene microarray analysis to compare the global expression profile of genes involved in adaptation to training in skeletal muscle from chronically strength-trained (ST), endurance-trained (ET), and untrained control subjects (Con). METHODS: Resting skeletal muscle samples were obtained from the vastus lateralis of 20 subjects (Con n = 7, ET n = 7, ST n = 6; trained [TR] groups >8 yr specific training). Total RNA was extracted from tissue for two color microarray analysis and quantative (Q)-PCR. Trained subjects were characterized by performance measures of peak oxygen uptake V?O 2peak) on a cycle ergometer and maximal concentric and eccentric leg strength on an isokinetic dynamometer. RESULTS: Two hundred and sixty-three genes were differentially expressed in trained subjects (ET + ST) compared with Con (P < 0.05), whereas 21 genes were different between ST and ET (P < 0.05). These results were validated by reverse transcriptase polymerase chain reaction for six differentially regulated genes (EIFSJ, LDHB, LMO4, MDH1, SLC16A7, and UTRN. Manual cluster analyses revealed significant regulation of genes involved in muscle structure and development in TR subjects compared with Con (P < 0.05) and expression correlated with measures of performance (P < 0.05). ET had increased whereas ST had decreased expression of gene clusters related to mitochondrial/oxidative capacity (P ?‰Currency sign 0.05). These mitochondrial gene clusters correlated with V?O2peak (P < 0.05). V?O2peak also correlated with expression of gene clusters that regulate fat and carbohydrate oxidation (P < 0.05). CONCLUSION: We demonstrate that chronic training subtly coregulates numerous genes from important functional groups that may be part of the long-term adaptive process to adapt to repeated training stimuli.

Sensor Data Integrity : Multi-Sensor Perception for Unmanned Ground Vehicles

This document describes large, accurately calibrated and time-synchronised datasets, gathered in controlled environmental conditions, using an unmanned ground vehicle equipped with a wide variety of sensors. These sensors include: multiple laser scanners, a millimetre wave radar scanner, a colour camera and an infra-red camera. Full details of the sensors are given, as well as the calibration parameters needed to locate them with respect to each other and to the platform. This report also specifies the format and content of the data, and the conditions in which the data have been gathered. The data collection was made in two different situations of the vehicle: static and dynamic. The static tests consisted of sensing a fixed ’reference’ terrain, containing simple known objects, from a motionless vehicle. For the dynamic tests, data were acquired from a moving vehicle in various environments, mainly rural, including an open area, a semi-urban zone and a natural area with different types of vegetation. For both categories, data have been gathered in controlled environmental conditions, which included the presence of dust, smoke and rain. Most of the environments involved were static, except for a few specific datasets which involve the presence of a walking pedestrian. Finally, this document presents illustrations of the effects of adverse environmental conditions on sensor data, as a first step towards reliability and integrity in autonomous perceptual systems.

Comparison of accelerometer cut points for predicting activity intensity in youth

The absence of comparative validity studies has prevented researchers from reaching consensus regarding the application of intensity-related accelerometer cut points for children and adolescents. PURPOSE This study aimed to evaluate the classification accuracy of five sets of independently developed ActiGraph cut points using energy expenditure, measured by indirect calorimetry, as a criterion reference standard. METHODS A total of 206 participants between the ages of 5 and 15 yr completed 12 standardized activity trials. Trials consisted of sedentary activities (lying down, writing, computer game), lifestyle activities (sweeping, laundry, throw and catch, aerobics, basketball), and ambulatory activities (comfortable walk, brisk walk, brisk treadmill walk, running). During each trial, participants wore an ActiGraph GT1M, and VO 2 was measured breath-by-breath using the Oxycon Mobile portable metabolic system. Physical activity intensity was estimated using five independently developed cut points: Freedson/Trost (FT), Puyau (PU), Treuth (TR), Mattocks (MT), and Evenson (EV). Classification accuracy was evaluated via weighted κ statistics and area under the receiver operating characteristic curve (ROC-AUC). RESULTS Across all four intensity levels, the EV (κ = 0.68) and FT (κ = 0.66) cut points exhibited significantly better agreement than TR (κ = 0.62), MT (κ = 0.54), and PU (κ = 0.36). The EV and FT cut points exhibited significantly better classification accuracy for moderate-to vigorous-intensity physical activity (ROC-AUC = 0.90) than TR, PU, or MT cut points (ROC-AUC = 0.77-0.85). Only the EV cut points provided acceptable classification accuracy for all four levels of physical activity intensity and performed well among children of all ages. The widely applied sedentary cut point of 100 counts per minute exhibited excellent classification accuracy (ROC-AUC = 0.90). CONCLUSIONS On the basis of these findings, we recommend that researchers use the EV ActiGraph cut points to estimate time spent in sedentary, light-, moderate-, and vigorous-intensity activity in children and adolescents. Copyright © 2011 by the American College of Sports Medicine.

Mission path planning of aerial survey tasks using hybrid game evolutionary algorithm

The work presented in this report is aimed to implement a cost-effective offline mission path planner for aerial inspection tasks of large linear infrastructures. Like most real-world optimisation problems, mission path planning involves a number of objectives which ideally should be minimised simultaneously. Understandably, the objectives of a practical optimisation problem are conflicting each other and the minimisation of one of them necessarily implies the impossibility to minimise the other ones. This leads to the need to find a set of optimal solutions for the problem; once such a set of available options is produced, the mission planning problem is reduced to a decision making problem for the mission specialists, who will choose the solution which best fit the requirements of the mission. The goal of this work is then to develop a Multi-Objective optimisation tool able to provide the mission specialists a set of optimal solutions for the inspection task amongst which the final trajectory will be chosen, given the environment data, the mission requirements and the definition of the objectives to minimise. All the possible optimal solutions of a Multi-Objective optimisation problem are said to form the Pareto-optimal front of the problem. For any of the Pareto-optimal solutions, it is impossible to improve one objective without worsening at least another one. Amongst a set of Pareto-optimal solutions, no solution is absolutely better than another and the final choice must be a trade-off of the objectives of the problem. Multi-Objective Evolutionary Algorithms (MOEAs) are recognised to be a convenient method for exploring the Pareto-optimal front of Multi-Objective optimization problems. Their efficiency is due to their parallelism architecture which allows to find several optimal solutions at each time

The relationship between emotional intelligence and depression in a clinical sample

Background and Objectives: Although depression is a commonly occurring mental illness, research concerning strategies for early detection and prophylaxis has not until now focused on the possible utility of measures of Emotional Intelligence (EI) as a potential predictive factor. The current study aimed to investigate the relationship between EI and a clinical diagnosis of depression in a cohort of adults. Methods: Sixty-two patients (59.70% female) with a DSM-IV-TR diagnosis of a major affective disorder and 39 aged matched controls (56.40% female) completed self-report instruments assessing EI and depression in a cross-sectional study. Results: Significant associations were observed between severity of depression and the EI dimensions of Emotional Management (r = -0.56) and Emotional Control (r = -0.62). The results show a reduced social involvement, an increased prior institutionalization and an increased incidence of "Schizophrenic Psychosis" and "Abnormal Personalities" in the sub-group of repeated admissions. Conclusions: Measures of EI may have predictive value in terms of early identification of those at risk for developing depression. The current study points to the potential value of conducting further studies of a prospective nature.

Burden of depressive disorders by country, sex, age, and year : findings from the Global Burden of Disease Study 2010

Background Depressive disorders were a leading cause of burden in the Global Burden of Disease (GBD) 1990 and 2000 studies. Here, we analyze the burden of depressive disorders in GBD 2010 and present severity proportions, burden by country, region, age, sex, and year, as well as burden of depressive disorders as a risk factor for suicide and ischemic heart disease. Methods and Findings Burden was calculated for major depressive disorder (MDD) and dysthymia. A systematic review of epidemiological data was conducted. The data were pooled using a Bayesian meta-regression. Disability weights from population survey data quantified the severity of health loss from depressive disorders. These weights were used to calculate years lived with disability (YLDs) and disability adjusted life years (DALYs). Separate DALYs were estimated for suicide and ischemic heart disease attributable to depressive disorders.Depressive disorders were the second leading cause of YLDs in 2010. MDD accounted for 8.2% (5.9%-10.8%) of global YLDs and dysthymia for 1.4% (0.9%-2.0%). Depressive disorders were a leading cause of DALYs even though no mortality was attributed to them as the underlying cause. MDD accounted for 2.5% (1.9%-3.2%) of global DALYs and dysthymia for 0.5% (0.3%-0.6%). There was more regional variation in burden for MDD than for dysthymia; with higher estimates in females, and adults of working age. Whilst burden increased by 37.5% between 1990 and 2010, this was due to population growth and ageing. MDD explained 16 million suicide DALYs and almost 4 million ischemic heart disease DALYs. This attributable burden would increase the overall burden of depressive disorders from 3.0% (2.2%-3.8%) to 3.8% (3.0%-4.7%) of global DALYs. Conclusions GBD 2010 identified depressive disorders as a leading cause of burden. MDD was also a contributor of burden allocated to suicide and ischemic heart disease. These findings emphasize the importance of including depressive disorders as a public-health priority and implementing cost-effective interventions to reduce its burden.Please see later in the article for the Editors' Summary.