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.

The switch

In this video, text types across the screen one line at a time set to an emotive stock music soundtrack. The text combines two teen film plot descriptions into one story. This work engages with the language of Hollywood narratives. By emphasizing the potentially abstract and convoluted qualities of linguistic communication, it challenges our capacity to assimilate information into conventional narratives. It draws specific attention to the conventions of Hollywood plot development, and questions the mechanisms by which they construct and communicate meaning.

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.

Adaptive subcarrier allocation in multiuser OFDM system using forced cost based decisions

Subcarrier allocation scheme for Orthogonal Frequency Division Multiplexing(OFDM) based multiuser system is proposed. Most previous algorithms use greedy approach as a subcarrier allocation scheme until a conflict occurs or as an initial first round allocation with improvement steps carried out in next rounds. Our algorithm uses information obtained by the forced costs of a system that incur by a current allocation to make assignment decisions. This algorithm does not rely on greedy approach and therefore can also be considered as a substitute for first layer Greedy algorithms. Simulation results show that for two user case this algorithm gives better or equal allocation 80-90 percent of the time when compared with the greedy allocation.

Resource allocation in multiuser cooperative OFDM system using forced cost based decisions

A sub optimal resource allocation algorithm for Orthogonal Frequency Division Multiplexing (OFDM) based cooperative scheme is proposed. The system consists of multiple relays. Subcarrier space is divided into blocks and relays participating in cooperation are allocated specific blocks to be used with a user. To ensure unique subcarrier assignment system is constrained such that same block cannot be used by more than one user. Users are given fair block assignments while no restriction for maximum number of blocks a relay can employ is given. Forced cost based decisions [1] are used for block allocation. Simulation results show that this scheme outperforms a non cooperating scheme with sequential allocation with respect to power usage.

A new technique for optimal allocation and sizing of capacitors and setting of LTC

An iterative based strategy is proposed for finding the optimal rating and location of fixed and switched capacitors in distribution networks. The substation Load Tap Changer tap is also set during this procedure. A Modified Discrete Particle Swarm Optimization is employed in the proposed strategy. The objective function is composed of the distribution line loss cost and the capacitors investment cost. The line loss is calculated using estimation of the load duration curve to multiple levels. The constraints are the bus voltage and the feeder current which should be maintained within their standard range. For validation of the proposed method, two case studies are tested. The first case study is the semi-urban 37-bus distribution system which is connected at bus 2 of the Roy Billinton Test System which is located in the secondary side of a 33/11 kV distribution substation. The second case is a 33 kV distribution network based on the modification of the 18-bus IEEE distribution system. The results are compared with prior publications to illustrate the accuracy of the proposed strategy.

Dynamic lifecycle strategies for target date retirement funds

Target date retirement funds have gained favor with retirement plan investors in recent years. Typically, these funds initially have a high allocation to stocks but move towards less volatile assets, such as bonds and cash, as the target retirement date approaches. Empirical research has generally found that a switch to low-risk assets prior to retirement can reduce the risk of confronting the most extreme negative outcomes. This article questions the rationale for lifecycle switching based solely on age or target retirement date as is the prevalent practice among target date funds. The authors argue that a dynamic switching strategy, which takes into consideration achieved investment returns, will produce superior returns for most investors compared to conventional lifecycle switching. In this article, the authors put forward a dynamic lifecycle switching strategy that is conditional on the attainment of the plan member's wealth accumulation objective at every stage of switching.

Hepatitis C and policy implementation : ethics as a dialogic process for resource allocation

Hepatitis C, which was first identified in 1988, has become an important issue for public health as epidemiological and clinical evidence has emerged. These disciplines have highlighted the extent of infection and its medical consequences. Now, governments at both the state and federal levels are sifting through this evidence and are attempting to create structures to deal with the problem of hepatitis C. These structures have generally taken the form of expert committees and working parties organised from established medical, scientific and public health bodies...

Improved earthwork allocation planning for fuel consumption and emissions reduction in linear infrastructure construction – case study data

This document provides data for the case study presented in our recent earthwork planning papers. Some results are also provided in a graphical format using Excel.

Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

A class B switch-mode assisted linear amplifier

A switch-mode assisted linear amplifier (SMALA) combining a linear (Class B) and a switch-mode (Class D) amplifier is presented. The usual single hysteretic controlled half-bridge current dumping stage is replaced by two parallel buck converter stages, in a parallel voltage controlled topology. These operate independently: one buck converter sources current to assist the upper Class B output device, and a complementary converter sinks current to assist the lower device. This topology lends itself to a novel control approach of a dead-band at low power levels where neither class D amplifier assists, allowing the class B amplifier to supply the load without interference, ensuring high fidelity. A 20 W implementation demonstrates 85% efficiency, with distortion below 0.08% measured across the full audio bandwidth at 15 W. The class D amplifier begins assisting at 2 W, and below this value, the distortion was below 0.03%. Complete circuitry is given, showing the simplicity of the additional class D amplifier and its corresponding control circuitry.

Hysteretic multilevel NPC converter control for a Switch Mode Assisted Linear Amplifier

A Switch-Mode Assisted Linear Amplifier (SMALA) combines the high quality of a linear amplifier required for audio applications with the high efficiency of a switch-mode amplifier. The careful choice of current sense point and switch placement allows a simple non-isolated hysteresis current controller for the switch-mode section. This paper explains the extension of the hysteresis current controller for the control of a three level Neutral Point Clamped (NPC) converter, with simulations as proof of concept. The NPC topology allows the use of lower voltage switches and lower switching frequencies to implement high power audio amplifiers using the SMALA topology.

A method of switch selection for an electric vehicle drive

The key to reducing cost of electric vehicles is integration. All too often systems such as the motor, motor controller, batteries and vehicle chassis/body are considered as separate problems. The truth is that a lot of trade-offs can be made between these systems, causing an overall improvement in many areas including total cost. Motor controller and battery cost have a relatively simple relationship; the less energy lost in the motor controller the less energy that has to be carried in the batteries, hence the lower the battery cost. A motor controller’s cost is primarily influenced by the cost of the switches. This paper will therefore present a method of assessing the optimal switch selection on the premise that the optimal switch is the one that produces the lowest system cost, where system cost is the cost of batteries + switches.

Asset allocation policy, returns and expenses of superannuation funds : recent evidence based on default options

We examine the asset allocation, returns, and expenses of superannuation funds whose assets are mainly invested in default investment options between 2004 and 2012. A majority of these funds fail to earn returns commensurate with their strategic asset allocation policy. It appears that much of the variation of returns between the funds might be a result of their engaging in significant active management of assets. Our results indicate that returns from active management are negatively related to expenses. We also find strong evidence of economies of scale existing in these superannuation funds across different size categories.