Taxation determinations as de facto regulation : private equity exits in Australia

The Australian Taxation Office (AT)) attempted to challenge both the private equity fund reliance on double tax agreements and the assertion that profits were capital in nature in its dispute with private equity group TPG. Failure to resolve the dispute resulted in the ATO issuing two taxation determinations: TD 2010/20 which states that the general anti-avoidance provisions can apply to arrangements designed to alter the intended effect of Australia's international tax agreements net; and TD 2010/21 which states that the profits on the sale of shares in a company group acquired in a leveraged buyout is assessable income. The purpose of this article is to determine the effectiveness of the administrative rulings regime as a regulatory strategy. This article, by using the TPG-Myer scenario and subsequent tax determinations as a case study, collects qualitative data which is then analysed (and triangulated) using tonal and thematic analysis. Contemporaneous commentary of private equity stakeholders, tax professionals, and media observations are analysed and evaluated within a framework of responsive regulation and utilising the current ATO compliance model. Contrary to the stated purpose of the ATO rulings regime to alleviate complexities in Australian taxation law and provide certainty to taxpayers, and despite the de facto law status afforded these rulings, this study found that the majority of private equity stakeholders and their advisors perceived that greater uncertainty was created by the two determinations. Thus, this study found that in the context of private equity fund investors, a responsive regulation measure in the form of taxation determinations was not effective.

Formation of neutral molecules of potential stellar interest by neutralisation of negative ions in a mass spectrometer - The application of experiment and molecular modelling in concert

This paper is a modified version of a lecture which describes the synthesis, structure and reactivity of some neutral molecules of stellar significance. The neutrals are formed in the collision cell of a mass spectrometer following vertical Franck-Condon one electron oxidation of anions of known bond connectivity. Neutrals are characterised by conversion to positive ions and by extensive theoretical studies at the CCSD(T)/aug-cc-pVDZ//B3LYP/6-31G(d) level of theory. Four systems are considered in detail, viz (i) the formation of linear C-4 and its conversion to the rhombus C-4, (ii) linear C-5 and the atom scrambling of this system when energised, (iii) the stable cumulene oxide CCCCCO, and (iv) the elusive species O2C-CO. This paper is not intended to be a review of interstellar chemistry: examples are selected from our own work in this area. (C) 2002 Elsevier Science Inc. All rights reserved.

Predicting positive and negative impacts of cancer among long-term endometrial cancer survivors

OBJECTIVE Although the survival outcomes among women diagnosed with endometrial cancer are very favorable, little is known about the long-term impact of their cancer experience. This study identifies the extent of positive and negative impacts of cancer and factors associated with this, amongst long-term survivors of endometrial cancer. METHODS Australian women diagnosed with endometrial cancer (N=632) were sent questionnaires at the time of diagnosis and 3-5 years later. Hierarchical multiple regression models were used to examine whether a range of variables at diagnosis/treatment predicted subsequent scores on the Impact of Cancer Scale, which examines positive (e.g. health awareness) and negative (e.g. appearance concerns) impacts amongst cancer survivors. RESULTS Overall, women had a higher mean score for the positive than negative impact scales (M=3.5 versus M=2.5, respectively). An intermediate grade of endometrial cancer, a prior diagnosis of cancer and lower levels of education were significant, but weak, predictors of higher scores on the positive impact scale. Higher scores on the negative impact scale were predicted by a higher grade of cancer, poor physical and mental health, a younger age, being single or having lower levels of education. CONCLUSIONS The study demonstrates that factors that predict positive impact in cancer survivors differ to those that predict negative impact, suggesting that interventions to optimize cancer survivors' quality of life will need to be multi-dimensional, and this supports the need for tailored intervention.

Encouragement of physical activity for weight loss may lead to negative psychological outcomes among girls

PURPOSE To examine correlates and consequences of parents' encouragement of girls' physical activity (PA) for weight loss (ENCLOSS). METHODS Data were collected for 181 girls, mothers and fathers when girls were 9, 11, and 13 years old. Mothers and fathers completed a self-report questionnaire of ENCLOSS (e.g., “I have talked to my daughter about how to exercise to lose weight”). Correlates of ENCLOSS that were assessed include girls' Body Mass Index (BMI) z-score and parents' modeling of and logistic support for PA. Dependent variables assessed at age 13 include girls' self-reported and objectively-measured PA, enjoyment of physical activity, and weight concerns. Associations between ENCLOSS, girls' BMI, and parent's support for PA were assessed using spearman rank correlations. To examine links between ENCLOSS and the outcome variables, scores for ENCLOSS were divided into tertiles at each age. Three groups were created including girls who were in the highest tertile at each age (high ENCLOSS), girls who were in the lowest tertile at each age (low ENCLOSS), and girls who varied in their tertile ranking (mid ENCLOSS). Group differences in the outcome variables were assessed using regression analysis (referent group: low ENCLOSS), controlling for girls' BMI and the outcome variable at age 9. RESULTS Girls' with higher BMI had mothers and fathers who reported higher ENCLOSS (r = .61-. 69, p<. 0001). Parents'reports of ENCLOSS were not associated with modeling of or logistic support for PA. Girls in the high ENCLOSS group reported significantly lower enjoyment of PA and higher weight concerns at age 13, independent of covariates. No differences in PA were noted. CONCLUSION Parents who encourage their daughters to be active for weight loss do not model PA or facilitate girls' PA. Persistent encouragement of PA for weight loss may lead to low enjoyment of PA and higher weight concerns among adolescent girls.

Book Review : The Concept of Injustice (Eric Heinze, Routledge, 2013)

Given the level of debate and theorising in Western thought on the topic of justice, it is curious that the concept of injustice has not attracted the same attention. While many schools of thought have sought to address various injustices, most define injustice solely as the opposite of their vision of a just society – it seems they have not been interested in exploring injustice per se. With this as a starting point, Eric Heinze’s The Concept of Injustice addresses this oversight and, by taking injustice itself as an object of analysis, adds a new dimension to these discussions...

Mining and (sustainable) local communities : transforming Ravensthorpe, Western Australia

This chapter examines local community experiences, understandings and changes attending the presence of mining activity, in particular as occurred in the Shire of Ravensthorpe in the South West of Western Australia (WA). It does so by drawing on an extensive ethnographic study spanning the development, opening, and closure of BHP Billiton’s Ravensthorpe Nickel Operation (RNO). Given that the negative consequences of mining activity are most evident and complex at the local level, it is crucial that we understand and address how communities (and the individuals and families who are both part of and are shaped by communities) experience the impacts of mining. Though difficult to measure, social and cultural dimensions of mining at the local scale, as this chapter demonstrates, are central to our understanding of mining as a curse or cure.

Curse or cure? Revisiting state, capital and resources

WA’s experience, as portrayed in this volume, not only highlights the changeable nature of the mining industry, the volatility of global commodity markets and the impact of global capital on people and place, it also draws into question the promise of lasting value derived from resource development as currently practiced. It is in this context that Chapter 18 revisits WA's resource boom and assesses the sustainability of resource-led development in the state, to arrive at an answer to the question of ‘curse or cure?’. Opening up the discourse beyond the dominant developmentalist narrative invites discussion on new perspectives of economic sustainability that include well-being, equity and the protection of people, culture and place.

Book reviews : "Biosecurity interventions: global health and security in question"

International Relations’ engagement with global health governance has proliferated in the last decade. There are a number of excellent works that seek to understand how the relationship between politics and health shapes and informs people’s lives and governments’ policies. However, the overt securitization of health by the IR field has, Biosecurity interventions argues, remained relatively unproblematized...

Promoting posttraumatic growth in police recruits : preliminary results of a randomised controlled resilience intervention trial

Recent research has demonstrated that the same experiences that may elicit symptoms of post-traumatic stress disorder (PTSD) in emergency service personnel can also provide a catalyst for positive personal changes such as posttraumatic growth (PTG). In this research newly recruited police officers (N = 412) participated in a randomised control trial of a program specifically designed to promote mental health. On entry to the academy, new recruits were randomly allocated, by classrooms, to either a treatment as usual condition (i.e., existing psychoeducation program) or to the intervention group. The Promoting Resilient Officers (PRO) program is a resilience building intervention adapted from an earlier resilience building program in collaboration with the police service. The PRO program also includes additional components on trauma and PTG. The current research included the participants who had experienced trauma prior to or during the research period (N = 246). It was hypothesised that participation in the PRO program would increase levels of PTG and lower levels of PTSD when compared to recruits in the control condition. Using multilevel modelling and post-hoc analyses, results indicated there were significantly higher levels of PTG across multiple dimensions when compared to the control group. There was no effect on PTSD symptoms with both conditions showing a floor effect. The research indicated the potential value of developing interventions that elicit reflections on the potential for positive as well as negative outcomes of experiencing traumatic and other highly challenging events.

The activation, appropriation and practices of student-equity policy in Australian higher education

Current national reforms in Australian higher education have prioritised efforts to reduce educational disadvantage within a vernacular expression of neoliberal education policy. Student-equity policy in universities is enmeshed in a set of competitive student recruitment relations. This raises practice-based tensions as universities strive to meet specific institutional targets for low-socio-economic status (SES) and Indigenous student participation, whilst broadening participation more generally within the sector. This paper seeks empirically to trace the activation and appropriation of federal policy through two sites of higher education policy practices: a state government-sponsored equity practitioner body and two differently positioned universities, Dawson and McIllwraith, as they engage with low-SES schools. Working together Dorothy Smith’s insights into the textually mediated activation of local practices, Levinson and colleagues’ concept of the local appropriation of authorised policy, and Bourdieu’s notion of the contested field, we demonstrate that the generation of state level and institutionally specific policies for student-equity practices not only articulates to federal policy, but also appropriates the ruling relations of mandated policy. Further, the scope of these creative local appropriations is organised within a hierarchical academic field through which particular institutional imperatives, as well as the needs of low-SES students, are negotiated. The analysis demonstrates the vernacularisation of policy in the national rearticulation of global discourses, in appropriation at the level of the state body and in the practices of equity workers.

Improving the detection of donations within the RHD negative blood donor panel which weakly express the RHD antigen

This project improved the detection and classification of very weakly expressed RhD variants in the Australian blood donor panel and contributed to the knowledge of anti-D reactivity patterns of RHD alleles that are undescribed. As such, the management of donations possessing these RHD alleles can be improved upon and the overall safety of transfusion medicine pertaining to the Rh blood group system will be increased. Future projects at ARCBS will be able to utilise the procedures developed in this project, thereby decreasing throughput time. The specificity of current testing will be improved and the need for outsourced RHD testing diminished.

Rad51 supports triple negative breast cancer metastasis

In contrast to extensive studies on familial breast cancer, it is currently unclear whether defects in DNA double strand break (DSB) repair genes play a role in sporadic breast cancer development and progression. We performed analysis of immunohistochemistry in an independent cohort of 235 were sporadic breast tumours. This analysis suggested that RAD51 expression is increased during breast cancer progression and metastasis and an oncogenic role for RAD51 when deregulated. Subsequent knockdown of RAD51 repressed cancer cell migration in vitro and reduced primary tumor growth in a syngeneic mouse model in vivo. Loss of RAD51 also inhibited associated metastasis not only in syngeneic mice but human xenografts and changed the metastatic gene expression profile of cancer cells, consistent with inhibition of distant metastasis. This demonstrates for the first time a new function of RAD51 that may underlie the proclivity of patients with RAD51 overexpression to develop distant metastasis. RAD51 is a potential biomarker and attractive drug target for metastatic triple negative breast cancer, with the capability to extend the survival of patients, which is less than 6 months.

Ion-acoustic waves in a complex plasma with negative ions

A wave propagation in a complex dusty plasma with negative ions was considered. The relevant processes such as ionization, electron attachment, diffusion, positive-negative ion recombination, plasma particle collisions, as well as elastic Coulomb and inelastic dust-charging collisions were taken self-consistently. It was found that the equilibrium of the plasma as well as the propagation of ion waves were modified to various degrees by these effects.

Charging and trapping of macroparticles in near-electrode regions of fluorocarbon plasmas with negative ions

Charging and trapping of macroparticles in the near-electrode region of fluorocarbon etching plasmas with negative ions is considered. The equilibrium charge and forces on particles are computed as a function of the local position in the plasma presheath and sheath. The ionic composition of the plasma corresponds to the etching experiments in 2.45 GHz surface-wave sustained and 13.56 MHz inductively coupled C4F8+Ar plasmas. It is shown that despite negligible negative ion currents collected by the particles, the negative fluorine ions affect the charging and trapping of particulates through modification of the sheath/presheath structure.

Ion-acoustic waves in a complex plasma with negative ions

Negative ions and negatively charged micro- to nano-meter sized dust grains are ubiquitous in astrophysical as well as industrial processing plasmas. The negative ions can appear in electro-negative plasmas as a result of elementary processes such as dissociative or non-dissociative electron attachment to neutrals. They are usually rather small in number, and in general do not affect the overall plasma behavior. On the other hand, since the dust grains are almost always highly negative, even in small numbers they can take up a considerable proportion of the total negative charge in the system. The presence of dusts can affect the characteristics of most collective processes of the plasma since the charge balance in both the steady and dynamic states can be significantly altered. Another situation that often occurs is that the electron number density becomes small because of their absorption by the dust grains or the discharge walls. In this case the negative ions in the plasma can play a very important role. Here, a self-consistent theory of linear waves in complex laboratory plasmas containing dust grains and negative ions is presented. A comprehensive model for such plasmas including source and sink effects associated with the presence of dust grains and negative ions is introduced. The stationary state of the plasma as well as the dispersion and damping characteristics of the waves are investigated. All relevant processes, such as ionization, diffusion, electron attachment, negative-positive ion recombination, dust charge relaxation, and dissipation due to electron and ion elastic collisions with neutrals and dust particles, as well as charging collisions with the dusts, are taken into consideration.