118 resultados para GST and incapacitated entities


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There has been considerable research conducted over the last 20 years focused on predicting motor vehicle crashes on transportation facilities. The range of statistical models commonly applied includes binomial, Poisson, Poisson-gamma (or negative binomial), zero-inflated Poisson and negative binomial models (ZIP and ZINB), and multinomial probability models. Given the range of possible modeling approaches and the host of assumptions with each modeling approach, making an intelligent choice for modeling motor vehicle crash data is difficult. There is little discussion in the literature comparing different statistical modeling approaches, identifying which statistical models are most appropriate for modeling crash data, and providing a strong justification from basic crash principles. In the recent literature, it has been suggested that the motor vehicle crash process can successfully be modeled by assuming a dual-state data-generating process, which implies that entities (e.g., intersections, road segments, pedestrian crossings, etc.) exist in one of two states—perfectly safe and unsafe. As a result, the ZIP and ZINB are two models that have been applied to account for the preponderance of “excess” zeros frequently observed in crash count data. The objective of this study is to provide defensible guidance on how to appropriate model crash data. We first examine the motor vehicle crash process using theoretical principles and a basic understanding of the crash process. It is shown that the fundamental crash process follows a Bernoulli trial with unequal probability of independent events, also known as Poisson trials. We examine the evolution of statistical models as they apply to the motor vehicle crash process, and indicate how well they statistically approximate the crash process. We also present the theory behind dual-state process count models, and note why they have become popular for modeling crash data. A simulation experiment is then conducted to demonstrate how crash data give rise to “excess” zeros frequently observed in crash data. It is shown that the Poisson and other mixed probabilistic structures are approximations assumed for modeling the motor vehicle crash process. Furthermore, it is demonstrated that under certain (fairly common) circumstances excess zeros are observed—and that these circumstances arise from low exposure and/or inappropriate selection of time/space scales and not an underlying dual state process. In conclusion, carefully selecting the time/space scales for analysis, including an improved set of explanatory variables and/or unobserved heterogeneity effects in count regression models, or applying small-area statistical methods (observations with low exposure) represent the most defensible modeling approaches for datasets with a preponderance of zeros

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While hybrid governance arrangements have been a major element of organisational architecture for some time, the contemporary operating environment has brought to the fore new conditions and expectations for the governance of entities that span conventional public sector departments, private firms and community organisations or groups. These conditions have resulted in a broader array of mixed governance configurations including Public Private Partnerships, alliances, and formal and informal collaborations. In some such arrangements, market based or ‘complete’ contractual relationships have been introduced to replace or supplement existing traditional ‘hierarchical’ and/or newer relational ‘network-oriented’ institutional associations. While there has been a greater reliance on collaborative or relational contracts as an underpinning institutional model, other modes of hierarchy and market may remain in operation. The success of these emergent hybrid forms has been mixed. There are examples of hybrids that have been well adopted, achieving the desired goals of efficiency, effectiveness and financial accountability; while others have experienced implementation problems which have undermined their results. This paper postulates that the cultural and institutional context within which hybrids operate may contribute to the implementation processes employed and the level of success attained. The paper explores hybrid arrangements through three cases of the use of inter-organisational arrangements in three different national contexts. Distilling the various elements of hybrids and the impact of institutional context will provide important insights for those charged with the responsibility for the formation and key infrastructure and public value development.

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This was the question that confronted Wilson J in Jarema Pty Ltd v Michihiko Kato [2004] QSC 451. Facts The plaintiff was the buyer of a commercial property at Bundall. The property comprised a 6 storey office building with a basement car park with 54 car parking spaces. The property was sold for $5 million with the contract being the standard REIQ/QLS form for Commercial Land and Buildings (2nd ed GST reprint). The contract provided for a “due diligence” period. During this period, the buyer’s solicitors discovered that there was no direct access from a public road to the car park entrance. Access to the car park was over a lot of which the Gold Coast City Council was the registered owner under a nomination of trustees, the Council holding the property on trust for car parking and town planning purposes. Due to the absence of a registered easement over the Council’s land, the buyer’s solicitors sought a reduction in the purchase price. The seller would not agree to this. Finally the sale was completed with the buyer reserving its rights to seek compensation.

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Current climate mitigation policies have not fully resolved contentious issues regarding the inclusion of carbon sequestration through changes in forestry and agricultural management practices. Terrestrial carbon sinks could be a low-cost mitigation option that fosters conservation and development, yet issues related to accurately documenting the amount of carbon sequestered undermine confidence that emission offsets through sequestration are equivalent to emission reductions. From an atmospheric perspective, net of CO2 removals through sequestration are equivalent to emission reductions over a given period of time. But carbon will not remain sequestered in biomass or soils indefinitely and investments in sequestration could stifle investments in reducing emissions from other sources. Many international climate agreements cap emissions from some countries or sectors but enable participation of uncapped countries or sectors for forestry and agricultural sequestration. This structure can prompt emission increases in parts of the uncapped entities that weaken the value of emission reductions earned through sequestration. This has been a minor issue under the Clean Development Mechanism of the Kyoto Protocol. Reduced emissions through deforestation and degradation is susceptible to the same problems. The purpose of this article is to review the science, politics, and policy that form the basis of arguments for and against the inclusion forestry and agricultural sequestration as a component of current and future international climate mitigation policies.

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In recent times considerable research attention has been directed to understanding dark networks, especially criminal and terrorist networks. Dark networks are those in which member motivations are self rather than public interested, achievements come at the cost of other individuals, groups or societies and, in addition, their activities are both ‘covert and illegal’ (Raab & Milward, 2003: 415). This ‘darkness’ has implications for the way in which these networks are structured, the strategies adopted and their recruitment methods. Such entities exhibit distinctive operating characteristics including most notably the tension between creating an efficient network structure while retaining the ability to hide from public view while avoiding catastrophic collapse should one member cooperate with authorities (Bouchard 2007). While theoretical emphasis has been on criminal and terrorist networks, recent work has demonstrated that corrupt police networks exhibit some distinctive characteristics. In particular, these entities operate within the shadows of a host organisation - the Police Force and distort the functioning of the ‘Thin Blue Line’ as the interface between the law abiding citizenry and the criminal society. Drawing on data derived from the Queensland Fitzgerald Commission of Enquiry into Police Misconduct and related documents, this paper examines the motivations, structural properties and operational practices of corrupt police networks and compares and contrasts these with other dark networks with ‘bright’ public service networks. The paper confirms the structural differences between dark corrupt police networks and bright networks and suggests. However, structural embeddedness alone is found to be an insufficient theoretical explanation for member involvement in networks and that a set of elements combine to impact decision-making. Although offering important insights into network participation, the paper’s findings are especially pertinent in identifying additional points of intervention for police corruption networks.

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This paper summarises some of the recent studies on various types of learning approaches that have utilised some form of Web 2.0 services in curriculum design to enhance learning. A generic implementation model of this integration will then be presented to illustrate the overall learning implementation process. Recently, the integration of Web 2.0 technologies into learning curriculum has begun to get a wide acceptance among teaching instructors across various higher learning institutions. This is evidenced by numerous studies which indicate the implementation of a range of Web 2.0 technologies into their learning design to improve learning delivery. Moreover, recent studies also have shown that the ability of current students to embrace Web 2.0 technologies is better than students using existing learning technology. Despite various attempts made by teachers in relation to the integration, researchers have noted a lack of integration standard to help in curriculum design. The absence of this standard will restrict the capacity of Web 2.0 adaptation into learning and adding more the complexity to provide meaningful learning. Therefore, this paper will attempt to draw a conceptual integration model which is being generated to reflect how learning activities with some facilitation of Web 2.0 is currently being implemented. The design of this model is based on shared experiences by many scholars as well as feedback gathered from two separate surveys conducted on teachers and a group of 180 students. Furthermore, this paper also recognizes some key components that generally engage in the design of a Web 2.0 teaching and learning which need to be addressed accordingly. Overall, the content of this paper will be organised as follows. The first part of the paper will introduce the importance of Web 2.0 implementation in teaching and learning from the perspective of higher education institutions and those challenges surrounding this area. The second part summarizes related works done in this field and brings forward the concept of designing learning with the incorporation of Web 2.0 technology. The next part presents the results of analysis derived from the two student and teachers surveys on using Web 2.0 during learning activities. This paper concludes by presenting a model that reflects several key entities that may be involved during the learning design.

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Public participate in the planning and design of major public infrastructure and construction (PIC) projects is crucial to their success, as the interests of different stakeholders can be systematically captured and built into the finalised scheme. However, public participation may not always yield a mutually acceptable solution, especially when the interests of stakeholders are diverse and conflicting. Confrontations and disputes can arise unless the concerns or needs of the community are carefully analysed and addressed. The aim of the paper is to propose a systematic method of analysing stakeholder concerns relating to PIC projects by examining the degree of consensus and/or conflict involved. The results of a questionnaire survey and a series of interviews with different entities are provided, which indicate the existence of a significant divergence of views among stakeholder groups and that conflicts arise when there is a mismatch between peoples’ perception concerning money and happiness on the one hand and development and damages on the other. Policy and decision-makers should strive to resolve at least the majority of conflicts that arise throughout the lifecycle of major PIC projects so as to maximise their chance of success.

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The current transfer pricing rules contained in Australia’s taxation regime are designed to counter the underpayment of tax by businesses engaged in international related-party dealings. Currently, these transactions must take place at an arm’s length price, a requirement which is becoming increasingly difficult to demonstrate. This results in an increased risk of an audit by the Australian Taxation Office. If a taxpayer wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (‘APA’). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. This article investigates the use of APAs as a solution to the problem of transfer pricing and considers their impact on stakeholders. It is argued that while APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current regime, they may not be a practical long term solution.

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On 2 December 1998, the Federal Government tabled their policy paper entitled Regulation Impact Statement for the Introduction of a Goods and Services Tax (RIS) in the House of Representatives. The Federal Government predicted that total gross GST compliance costs to Australian businesses in the first year of implementation would be approximately $1,912 million (or $1,195 per firm). Furthermore, it is estimated that the recurrent net compliance costs will be much lower at $131 per firm. Whilst the government made brief references to charitable organisations in their analysis, it stated that the compliance costs faced by nonprofits would, in substance, be no different to the compliance costs faced by businesses or government departments. This paper examines the RIS process in relation to nonprofit organisations in the context of recent taxation legislation affecting nonprofit organisations. It argues that the assumption that nonprofit compliance costs are similar to government and business costs is flawed and makes a case for the RIS process to be reformed to include more appropriate assessments of the impact of legislation on nonprofit enterprises.

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The impact of the GST has on nonprofit organisations has been largely ignored in the compliance cost literature. Most studies to date, both in Australia and overseas, have focused exclusively on measuring the nature and extent of GST compliance costs of businesses in the for-profit sector (particularly the impact on small businesses). This paper examines the impact of The New Tax System, and in particular, the GST on Queensland community sector organisations. The results are extracted from a QCOSS report entitled “Taxing Goodwill: The Impact of GST on Community Services” released in October 2001.

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This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

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Cities have long held a fascination for people – as they grow and develop, there is a desire to know and understand the intricate interplay of elements that makes cities ‘live’. In part, this is a need for even greater efficiency in urban centres, yet the underlying quest is for a sustainable urban form. In order to make sense of the complex entities that we recognise cities to be, they have been compared to buildings, organisms and more recently machines. However the search for better and more elegant urban centres is hardly new, healthier and more efficient settlements were the aim of Modernism’s rational sub-division of functions, which has been translated into horizontal distribution through zoning, or vertical organisation thought highrise developments. However both of these approaches have been found to be unsustainable, as too many resources are required to maintain this kind or urbanisation and social consequences of either horizontal or vertical isolation must also be considered. From being absolute consumers of resources, of energy and of technology, cities need to change, to become sustainable in order to be more resilient and more efficient in supporting culture, society as well as economy. Our urban centres need to be re-imagined, re-conceptualised and re-defined, to match our changing society. One approach is to re-examine the compartmentalised, mono-functional approach of urban Modernism and to begin to investigate cities like ecologies, where every element supports and incorporates another, fulfilling more than just one function. This manner of seeing the city suggests a framework to guide the re-mixing of urban settlements. Beginning to understand the relationships between supporting elements and the nature of the connecting ‘web’ offers an invitation to investigate the often ignored, remnant spaces of cities. This ‘negative space’ is the residual from which space and place are carved out in the Contemporary city, providing the link between elements of urban settlement. Like all successful ecosystems, cities need to evolve and change over time in order to effectively respond to different lifestyles, development in culture and society as well as to meet environmental challenges. This paper seeks to investigate the role that negative space could have in the reorganisation of the re-mixed city. The space ‘in-between’ is analysed as an opportunity for infill development or re-development which provides to the urban settlement the variety that is a pre-requisite for ecosystem resilience. An analysis of the urban form is suggested as an empirical tool to map the opportunities already present in the urban environment and negative space is evaluated as a key element in achieving a positive development able to distribute diverse environmental and social facilities in the city.

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There is a tax amendment bill which will be debated. The Government has promised to outline its plan for the reform of the taxation system sometime this year. The plans appear to go beyond the mere introduction of some sort of goods and services tax to reform of the whole taxation system including fiscal relations with the States. Not for profit organisations will find their taxation environment will change. Governments are reluctant to permit exemptions to a GST style arrangements. GST trade offs such as reduced income tax rates and abolishing indirect taxes are useless to nonprofit organisations, as many are already exempt from such imposts. Administrative changes to tax collections may also have an impact. If the government decides to make an individual PAYE taxpayer return optional in exchange for no or standard deductions, this may have an effect on fundraising. The FBT and salary packaging schemes that not for profit organisations use will be under intense scrutiny. A regionalisation of the ATO along the successful model of the ASC would see discrete areas such as not for profit exemptions being centralised in one regional office for the whole of Australia. For example the Tasmanian ASC Office has the responsibility for much work in respect of corporate charities and not for profit companies.

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There is general agreement in the scientific community that entrepreneurship plays a central role in the growth and development of an economy in rapidly changing environments (Acs & Virgill 2010). In particular, when business activities are regarded as a vehicle for sustainable growth at large, that goes beyond mere economic returns of singular entities, encompassing also social problems and heavily relying on collaborative actions, then we more precisely fall into the domain of ‘social entrepreneurship’(Robinson et al. 2009). In the entrepreneurship literature, prior studies demonstrated the role of intentionality as the best predictor of planned behavior (Ajzen 1991), and assumed that the intention to start a business derives from the perception of desirability and feasibility and from a propensity to act upon an opportunity (Fishbein & Ajzen 1975). Recognizing that starting a business is an intentional act (Krueger et al. 2000) and entrepreneurship is a planned behaviour (Katz & Gartner 1988), models of entrepreneurial intentions have substantial implications for intentionality research in entrepreneurship. The purpose of this paper is to explore the emerging practice of social entrepreneurship by comparing the determinants of entrepreneurial intention in general versus those leading to startups with a social mission. Social entrepreneurial intentions clearly merit to be investigated given that the opportunity identification process is an intentional process not only typical of for profit start-ups, and yet there is a lack of research examining opportunity recognition in social entrepreneurship (Haugh 2005). The key argument is that intentionality in both traditional and social entrepreneurs during the decision-making process of new venture creation is influenced by an individual's perceptions toward opportunities (Fishbein & Ajzen 1975). Besides opportunity recognition, at least two other aspects can substantially influence intentionality: human and social capital (Davidsson, 2003). This paper is set to establish if and to what extent the social intentions of potential entrepreneurs, at the cognitive level, are influenced by opportunities recognition, human capital, and social capital. By applying established theoretical constructs, the paper draws comparisons between ‘for-profit’ and ‘social’ intentionality using two samples of students enrolled in Economy and Business Administration at the University G. d’Annunzio in Pescara, Italy. A questionnaire was submitted to 310 potential entrepreneurs to test the robustness of the model. The collected data were used to measure the theoretical constructs of the paper. Reliability of the multi-item scale for each dimension was measured using Cronbach alpha, and for all the dimensions measures of reliability are above 0.70. We empirically tested the model using structural equation modeling with AMOS. The results allow us to empirically contribute to the argument regarding the influence of human and social cognitive capital on social and non-social entrepreneurial intentions. Moreover, we highlight the importance for further researchers to look deeper into the determinants of traditional and social entrepreneurial intention so that governments can one day define better polices and regulations that promote sustainable businesses with a social imprint, rather than inhibit their formation and growth.

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At common law, a corporation may be liable vicariously for the conduct of its appointed agents, employees or directors. This generally requires the agent or employee to be acting in the course of his or her agency or employment and, in the case of representations, to have actual or implied authority to make the representations. The circumstances in which a corporation may be liable for the conduct of its agents, employees or directors is broadened under the Australian Consumer Law (ACL) to where one of these parties engages in conduct “on behalf of” the corporation. As the decision in Bennett v Elysium Noosa Pty Ltd (in liq) demonstrates, this may extend to liability for the misleading conduct of a salesperson for the joint venture to parties who are not formal members of the joint venture, but where the joint venture activities are within the course of the entity’s “business, affairs or activities”.