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.

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.

Hydrothermal technologies for the production of fuels and chemicals from biomass

Biomass and non-food crop residues are seen as relatively low cost and abundant renewable sources capable of making a large contribution to the world’s future energy and chemicals supply. Signifi cant quantities of ethanol are currently produced from biomass via biochemical processes, but thermochemical conversion processes offer greater potential to utilize the entire biomass source to produce a range of products. This chapter will review thermochemical gasifi cation and pyrolysis methods with a focus on hydrothermal liquefaction processes. Hydrothermal liquefaction is the most energetically advantageous thermochemical biomass conversion process. If the target is to produce sustainable liquid fuels and chemicals and reduce the impact of global warming as a result of carbon dioxide, nitrous oxide, and methane emissions (i.e., protect the natural environment), the use of “green” solvents, biocatalysts and heterogeneous catalysts must be the main R&D initiatives. As the biocrude produced from hydrothermal liquefaction is a complex mixture which is relatively viscous, corrosive, and unstable to oxidation (due to the presence of water and oxygenated compounds), additional upgrading processes are required to produce suitable biofuels and chemicals.

ATR-FTIR measurement of biomass components in phosphonium ionic liquids

Qualitative and quantitative measurements of biomass components dissolved in the phosphonium ionic liquids (ILs), trihexyltetradecylphosphonium chloride ([P66614]Cl) and tributylmethylphosphonium methylsulphate ([P4441]MeSO 4), are obtained using attenuated total reflectance-FTIR. Absorption bands related to cellulose, hemicelluloses, and lignin dissolution monitored in situ in biomass-IL mixtures indicate lignin dissolution in both ILs and some holocellulose dissolution in the hydrophilic [P4441]MeSO 4. The kinetics of lignin dissolution reported here indicate that while dissolution in the hydrophobic IL [P66614]Cl appears to follow an accepted mechanism of acid catalyzed -aryl ether cleavage, dissolution in the hydrophilic IL [P4441]MeSO 4 does not appear to follow this mechanism and may not be followed by condensation reactions (initiated by reactive ketones). The measurement of lignin dissolution in phosphonium ILs based on absorbance at 1510 cm 1 has demonstrated utility. When coupled with the gravimetric Klason lignin method, ATR-FTIR study of reaction mixtures can lead to a better understanding of the delignification process. © 2012 Copyright Taylor and Francis Group, LLC.

An invasive grass shows colonization advantages over native grasses under conditions of low resource availability

Increased or fluctuating resources may facilitate opportunities for invasive exotic plants to dominate. This hypothesis does not, however, explain how invasive species succeed in regions characterized by low resource conditions or how these species persist in the lulls between high resource periods. We compare the growth of three co-occurring C4 perennial bunchgrasses under low resource conditions: an exotic grass, Eragrostis curvula (African lovegrass) and two native grasses, Themeda triandra and Eragrostis sororia. We grew each species over 12 weeks under low nutrients and three low water regimes differentiated by timing: continuous, pulsed, and mixed treatments (switched from continuous to pulsed and back to continuous). Over time, we measured germination rates, time to germination (first and second generations), height, root biomass, vegetative biomass, and reproductive biomass. Contrary to our expectations that the pulsed watering regime would favor the invader, water-supply treatments had little significant effect on plant growth. We did find inherent advantages in a suite of early colonization traits that likely favor African lovegrass over the natives including faster germination speed, earlier flowering times, faster growth rates and from 2 weeks onward it was taller. African lovegrass also showed similar growth allocation strategies to the native grasses in terms of biomass levels belowground, but produced more vegetative biomass than kangaroo grass. Overall our results suggest that even under low resource conditions invasive plant species like African lovegrass can grow similarly to native grasses, and for some key colonization traits, like germination rate, perform better than natives.

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.

Effect of preparation method of palygorskite-supported Fe and Ni catalysts on catalytic cracking of biomass tar

In this study, the effect of catalyst preparation and additive precursors on the catalytic decomposition of biomass using palygorskite-supported Fe and Ni catalysts was investigated. The catalysts were characterized by X-ray diffraction (XRD) and transmission electron microscopy (TEM). It is concluded that the most active additive precursor was Fe(NO3)3·9H2O. As for the catalyst preparation method, co-precipitation had superiority over incipient wetness impregnation at low Fe loadings.

CO2 reforming of toluene as model compound of biomass tar on Ni/Palygorskite

Catalytic CO2 reforming of biomass tar on palygorskite-supported nickel catalysts using toluene as a model compound of biomass tar was investigated. The experiments were performed in a bench scale installation a fixed bed reactor. All experiments were carried out at 650, 750, 800 °C and atmospheric pressure. The effect of Ni loading, reaction temperature and concentration of CO2 on H2 yield and carbon deposit was investigated. Ni/Palygorskite (Ni/PG) catalysts with Ni/PG ratios of 0%, 2%, 5% and 8% were tested, the last two show the best performance. H2 yield and carbon deposit diminished with the increase of reaction temperature, Ni loading, and CO2 concentration.

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 comparative study on pyrolysis for liquid oil from different biomass solid wastes

Locally available different bbiomass solid wastes, pine seed, date seed, plum seed, nutshell, hay of catkin, rice husk, jute stick, saw-dust, wheat straw and linseed residue in the particle form have been pyrolyzed in laboratory scale fixed bed reactor. The products obtained are pyrolysis oil, solid char and gas. The oil and char are collected while the gas is flared into atmosphere. The variation of oil yield for different biomass feedstock with reaction parameters like, reactor bed temperature, feed size and running time is presented in a comparative way in the paper. A maximum liquid yield of 55 wt% of dry feedstock is obtained at an optimum temperature of 500 °C for a feed size of 300-600 μm with a running time of 55 min with nutshell as the feedstock while the minimum liquid yield is found to be 30 wt% of feedstock at an optimum temperature of 400 °C for a feed size of 2.36 mm with a running time of 65 min for linseed residue. A detailed study on the variation of product yields with reaction parameters is presented for the latest investigation with pine seed as the feedstock where a maximum liquid yield of 40 wt% of dry feedstock is obtained at an optimum temperature of 500 °C for a feed size of 2.36-2.76 mm with a running time of 120 min. The characterization of the pyrolysis oil is carried out and a comparison of some selected properties of the oil is presented. From the study it is exhibited that the biomass solid wastes have the potential to be converted into liquid oil as a source of renewable energy with some further upgrading of the products.