Geared equity investments : a case study of tax arbitrage down under

Geared Equity Investment (GEI) contracts are an over-the-counter financial derivative product offered by Macquarie Bank, Ltd. to individual investors in Australia and New Zealand as a managed-risk investment in local shares carrying significant tax shield benefits. Upon issuance, a geared equity contract has three stakeholders: (1) the investor; (2) the issuer; and (3) the national tax authority. We assess the value of these contracts to each stakeholder and their support for tax arbitrage. We find that the national tax authority provides a significant subsidy to GEI contracts via tax shield benefits. These benefits support investor tax arbitrage in certain cases and issuer tax arbitrage in all cases examined.

Effectiveness of Liechtenstein entities to prevent the application of Australian income tax attribution regimes

Analyses the most common structures of Liechtenstein. The Anstalt, Stiftung, Trust, Business Trust and Company are described and the taxation consequences for an Australian investor considered. The analysis covers the CFC, FIF, transferor trust, deemed entitlement and anti-avoidance rules in Australian income tax law.

Characterisation of foreign entities for tax purposes

The thesis explores the characterisation of foreign legal entities from the perspective of Australia's taxation regime. It also examines entity characterisation methodologies in the US, the UK and Germany. It proposes how juristic existence conferred on foreign forms of association should be dealt with in an Australian tax context.

Taxation of branches of international banks : towards a multilateral tax treaty

Examines the taxation of branches of international banks under the OECD Model Tax Treaty. Argues that globalisation has made the current international tax system obsolete and suggests that a multilateral tax treaty system is a twenty-first century solution.

Income tax treatment of financial instruments : theory and practice

Examines the theoretical and practical aspects of the treatment of financial instruments under a realisation-based income tax. Argues that, within such a context, a system of expected-return taxation in preferable. The argument is developed through a review of the academic literature and selected legislative regimes.

Pain relief for the removal of femoral sheath in interventional cardiology adult patients (Review)

Pain relief for removal of femoral sheath after cardiac procedures
Procedures for the non-surgical management of coronary heart disease include balloon angioplasty and intracoronary stenting. At the start of each procedure an introducer sheath is inserted through the skin (percutaneously) into an artery, frequently a femoral artery in the groin. This allows the different catheters used for the procedure to be exchanged easily without causing trauma to the skin. At the end of the procedure the sheath is removed and, if the puncture site isn't "sealed" using a device closure, firm pressure is required over the site for 30 minutes or more to control any bleeding and reduce vascular complications. Removing the sheath and the firm pressure required to control bleeding can cause pain, although this is generally mild. Some centres routinely give pain relief before removal such as intravenous morphine, or an injection of a local anaesthetic in the soft tissue around the sheath (called a subcutaneous injection). Adequate pain control during sheath removal is also associated with a reduced incidence of a vasovagal reaction, a potentially serious complication involving a sudden drop of blood pressure and a slowed heart rate. Four studies were reviewed in total. Three trials involving 498 participants compared subcutaneous lignocaine, a short acting local anaesthetic, with a control group (participants received either no pain relief or an inactive substance known as a placebo). Two trials involving 399 people compared intravenous opioids (fentanyl or morphine) and an anxiolytic (midazolam) with a control group. One trial involving 60 people compared subcutaneous levobupivacaine, a long acting local anaesthetic, with a control group. Intravenous pain regimens and subcutaneous levobupivacaine appear to reduce the pain experienced during femoral sheath removal. However, the size of the reduction was small. A significant reduction in pain was not experienced by participants who received subcutaneous lignocaine or who were in the control group. There was insufficient data to determine a correlation between pain relief administration and either adverse events or complications. Some patients may benefit from routine pain relief using levobupivacaine or intravenous pain regimens. Identifying who may potentially benefit from pain relief requires clinical judgement and consideration of patient preference. The mild level of pain generally experienced during this procedure should not influence the decision as some people can experience moderate levels of pain.

Aid, debt relief and new sources of finance for meeting the millennium development goals

This article focuses on aid, debt relief and new sources of finance for meeting the Millennium Development Goals (MDGs). It was said that MDGs provide a clear set of objectives for mobilizing the international development community, especially in the area of development finance. The call for increased aid as well as for more debt relief in the creation of new sources of development finance has increased since the United Nations Financing for Development Summit and the subsequent report of the panel chaired by then President Ernesto Zedillo of Mexico on development finance. The goal of reducing the proportion of people living in extreme poverty by 2015 cannot be achieved in Sub-Saharan Africa (SSA). Such optimistic forecast suggests that MDG income poverty target will not be achieved in SSA until 2147.