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.

Judicial and Legislative Considerations in the Taxation of Compensation Receipts: An International Comparison

In 1995 the Federal Commissioner of Taxation released Taxation Ruling TR 95/35 - an attempt to comprehensively address the appropriate capital gains tax treatment of a receipt of compensation awarded either by the courts or via a settlement - still a lack of consensus regarding the appropriate treatment of such awards - a private binding ruling presently the only way a taxpayer can determine their liability with any certainty - the Australian position compared to that of the United Kingdom and Canada.

Retirement income policy and the taxation of superannuation in Australia

Superannuation is a form of savings for retirement. The savings are invested and earn income, but the proceeds are generally not available until the beneficiary reaches retirement age} The federal government's retirement income policy has three components, two of which relate to superannuation: the age pension, which provides income support to men aged 65 and over and to women aged 62 and over.2 The pension is means tested and does not depend on previous labour force participation or individual contributions; a compulsory superannuation scheme (under the Superannuation Guarantee Charge (Administration) Act 1992 (SGA Act)), which requires contributions to be made by employers on behalf of all employees, whether full-time, part-time or casual;3 and encouragement, through the taxation system, of voluntary contributions to approved superannuation funds.4 In May 2002, the government released a report, the "Intergenerational Report", 5 which identifies issues associated with Australia's ageing population and considers the fiscal implications of those changes. The Report noted that a steadily ageing population is likely to place significant pressure on government finances. It also noted that one of the key priorities for ensuring fiscal sustainability should be "maintaining a retirement income policy that encourages private saving for retirement and reduces the future demand for the Age Pension". 6 The main way the government has sought to encourage that private saving is through the tax system, primarily by the use of tax concessions. Over the past 20 years, however, the taxation of superannuation has grown in an extremely ad hoc manner and is now inequitable, inefficient and overly complex. This article suggests that the taxation of superannuation in Australia is in urgent need of a complete review. The article further asserts that, if an appropriate framework can be devised, changes could be introduced as budgetary pressures allow.

Moving personal tax online: the Australian Taxation Office's E-Tax initiative

In exploiting the capabilities of online technologies, governments have developed policies and launched projects to conduct transactions and deliver their services through the Internet. The motivations for this include cost cutting, efficiency improvements, service enhancements, and leadership in business transformation. However, these diverse goals are not necessarily consistent, especially in the early stages of implementation. The e-government initiative discussed in this case study (E-Tax) provided an additional service to individual Australian taxpayers by enabling them to file their tax returns online. This case study provides an analysis of the E-Tax implementation in the first three years of its operation. Data on E-Tax use compared to other filing methods show that the package worked well technically, was favorably received by users, and was consistent with policy on e-government. However, adoption levels in the early stages did not meet government targets. The analysis suggests that impediments to a greater level of E-Tax use included entrenched patterns of filing, the nature of the taxation system, and political sensitivities. The E-Tax case demonstrates how complex e-government projects can be and the need to take contextual factors into account in planning and evaluating e-government implementation.

Mortgages and bonds: the asset management practices of Australian life insurers to 1960

Recent studies of the experience of the British life insurance industry indicate that a period of transition, and the development of more diversified investment strategies, began in the interwar period. Australian life insurers lagged behind their British counterparts in the introduction of such strategies. This paper investigates why this was the case. It argues that in the Australian market there was both a lack of opportunity and incentive to broaden asset portfolios. However, this did not mean that asset management practices did not advance. Australian life offices became progressively more sophisticated in their approach to portfolio management during this period. Developments in the interwar period provided a grounding for post-war expansion into the equity market.

Losing innocence : finding the line between emotional bonds and boundaries in protective service work

This paper builds on existing literature on the notion of emotional labour by investigating work in a child protective service environment. Notable characteristics of formal organisations, such as child protective services, are that they operate within a legal framework and that workers' professional duties have great influence on clients. This paper examines the intricacies of the worker-client relationship and the emotional dynamics of the service interactions by interviewing a group of workers in a public hospital in Victoria, Australia. This research extricates the complexities in the client-worker relationship by examining a range of work characteristics including their roles as professional caregivers, the emotional bonds and boundaries in the workers-client relationship, the intensity and magnitude of felt and displayed emotions, as well as the self-management of emotions and clients' emotions. This study adds to existing knowledge on the emotional expressions, experiences and regulation of emotions of the professional work lives in a child protective service work environment.
This paper is divided into the following sections. The first section details protective service work within the larger framework of human service work, and how the worker-client interface is different from other front-line service work. This is followed the need to examine the emotional dynamics of work in a child protective service organisation. Next, a study of these emotional dynamics in a child protective service organisation is reported. The paper concludes with a consideration of the wider implications for the sociology of protective service work, and how affective issues differ other service work roles.

An exploration of the components of relational bonds to an arts festival brand

This research investigates the nature of the bonds that consumers form with a brand that provides highly uncertain outcomes, and is only available intermittently. The research model draws upon elements of Keller’s (2001) conceptualisation of brand resonance, and extends McAlexander, Kim, and Roberts’ (2003), and Muniz and O’Guinn’s (2001) brand community construct, testing these in an atypical service environment. Qualitative research suggested the need for a broader view of the bond formed in these circumstances, specifically one comprising measures of anticipation of usage, social attraction, commitment, loyalty, and trust. This paper reports on analysis undertaken to develop such a construct, which has been labelled “brand affinity”. Tests for discriminant validity suggest that the brand affinity construct is a distinct construct that can be used to measure consumer attitudes toward a highly uncertain, intermittently available product.

Tourism, congestion, taxation, and strategic interaction

This paper examines the strategic interaction between firms and governments in two Small Island Tourism Economies (SITEs). In a situation where congestion can threaten the viability of tourism industries in SITEs, we highlight the role of two factors that determine the distribution of tourists across SITEs: whether the tourism market is vertically or horizontally differentiated, and the extent to which tourists care about congestion. Under these circumstances, counterintuitive results are possible: congestion in a SITE may rise in response to tourists caring more about congestion in the SITE. Moreover, maximising tourism tax revenue emerges as a dominant strategy for governments.

Isn't sport taxing? The taxation of sports professionals post-Agassi

In Agassi v Robinson (Her Majestyʹs Inspector of Taxes), a majority of the House of Lords found that payments under two sponsorship contracts between a company owned and controlled by Mr Andre Agassi, (Agassi Enterprises Inc) and Nike Inc and Head Sport AG were assessable under UK tax law. This was so despite (i) none of the parties to the contracts was resident, nor domiciled, in the United Kingdom and (ii) none of the payer companies conducted business, directly or indirectly, through branches/agencies in the United Kingdom. The article considers whether the Australian Taxation Office could similarly assess non‐resident sports‐persons, like Mr Agassi, personally, and/or entities they control, on payments made under sponsorship agreements with a company such as Nike Inc. While the preferable view is that such payments are not sourced in Australia, Australian source rules are so ill defined that there is some basis for asserting such payments are sourced in Australia.

Room-temperature insertion of elemental tellurium into the Cspł-Br and -I bonds of α-bromo-and α-iodopinacolone

Pinacolyltellurium(IV) dihalides, (t-BuCOCH₂)₂TeX₂ (X ) Br (1b), I (1c)) and Ar(t-BuCOCH₂)TeCl₂ (Ar == 1-C₁₀H₇ (Np) (2a), 2,4,6-Me₃C₆H₂ (Mes) (3a)), are readily prepared at room temperature by the oxidative insertion of elemental tellurium into the C_sp³-Br or -I bond of the α-halopinacolone and by the reaction of ArTeCl₃ with the pinacolone t-BuCOCH₃. The bromides Np(t-BuCOCH₂)TeBr₂ (2b) and Mes(t-BuCOCH₂)TeBr₂ (3b) can be prepared by the addition of bromine to the telluride Ar(t-BuCOCH₂)-Te or of α-bromopinacolone to ArTeBr. Variable-temperature ¹H and ¹³C NMR of the separate signals for the o-Me groups in 3a,b indicate a very high barrier to rotation about the Te-C(aryl) bond. Crystal diffraction data for 1c, 2a-c, and 3b show that intramolecular 1,4-Te …O(C) secondary bonding interactions (SBIs) are retained even in the presence of bulky aryl groups and intermolecular Te …X SBIs are subject to electronic population and steric congestion around the Te(IV) center in the solid state.