The forgotten CGT events: Are asset revaluation reserve distributions by trustees of discretionary trusts capital gains?

It is the present practice that asset revaluation reserve distributions by trustees of discretionary trusts are not taxed in Australia. Are such distributions not meant to be taxed, or have relevant sections in the Income Tax Assessment Acts been overlooked? This article will review how trustees of discretionary trusts perform asset revaluation reserve distributions. It then challenges the current accepted view that they can be distributed tax-free to discretionary beneficiaries by analysing relevant CGT events, which the authors regard as forgotten events. It will be submitted that a discretionary beneficiary in receipt of an asset revaluation reserve distribution may have a capital gain which is required to be included in its assessable income. This liability for tax is regardless of the government's recent introduction of s 109XA to address the practice of asset revaluation reserve distributions bypassing the operation of Div 7A of the ITAA 1936 with such distributions.

O derramamento do Espírito : fortalecimento dos enfraquecidos

Esta tese se insere dentro da leitura bíblica latino-americana trazendo, nessa ótica, a riqueza e o desafio do que significa ler a Bíblia a partir de um contexto de opressão como é o nosso continente. Nos servimos do roteiro das ciências bíblicas e dos métodos exegéticos modernos. É uma pesquisa bibliográfica onde, eventualmente, consideramos o nível experiêncial, por exemplo quando trabalhamos o tema do derramamento do Espírito nos pentecostais chilenos. Esse capítulo, IV, segue o roteiro da hipótese central de nossa tese na medida que firmamos o princípio de que os pentecostais fazem parte do amplo e diverso grupo dos enfraquecidos como produto de um sistema excludente, baseado na exploração social. Numa situação de crise, o anúncio do derramamento do Espírito é um sinal de salvação, de perspectivas futuras, de conservação e prolongação da vida. Esta tese relê o tema do derramamento do Espírito, a partir de Jl 3,1-5. O tema é analisado num contexto social concreto, onde os enfraquecidos recebem o Espírito do Senhor. O eixo que nos permite fazer esta leitura encontra sua referencial nas pessoas setores sociais - mencionadas como beneficiadas diretas da ação do Espírito. São pessoas que representam setores diferentes; jovens, escravos e escravas, formam o grupo que sustenta e faz funcionar o sistema imperial persa grego - baseado na exploração e mão de obra barata. Eles, juntamente com os idosos que não produzem mais, são a base de sustentação da pirâmide social. Como demostraremos no decorrer da tese, nossa hipótese somente é possível se duas conjunturas se cruzam. Para isso, em num primeiro momento, localizamos e demostramos que o livro de Joel deve ser situado no contexto da literatura apocalíptica (nascimento). Em seguida, demonstramos que o livro de Joel, como produto literário final, deve ser localizado no contexto histórico do pós-exílio, isto é, no tempo dos impérios persa e grego. A confirmação destes dois aspectos desenvolvidos nos capítulos I e II, nos permitem, na análise literária, capítulo III, aprofundar, mediante a análise exegética, e confirmar a nossa hipótese central. Com estes três capítulos demostramos que o derramamento do Espírito do Senhor tem como destinatários preferenciais, senão exclusivos, os setores enfraquecidos pela política social, econômica e religiosa dos impérios persa e grego. Com estes três capítulos desenvolvidos, no quarto capítulo analisamos uma experiência concreta, de um setor majoritariamente pobre que tem se apropriado do texto de Jl 3,1-5, e encontrado nele uma alternativa social, política e religiosa para se manter fiel ao Senhor e por quase um século recria e revive a experiência do derramamento do Espírito. Os velhos, os jovens, os escravos e as escravas, formam o setor dos enfraquecidos. É o setor que nada espera, e que nada terá da parte dos impérios e que, como os pentecostais, pela sua situação de enfraquecimento, acredita que somente uma intervenção externa pode mudar o seu futuro, pode trazer de volta a esperança. Essa intervenção externa começa a ser possível pelo derramamento do Espírito e se concretiza na chegada do dia de Javé, que será grande e terrível, onde o sol e a lua se unem para indicar o monte de Sião e a cidade de Jerusalém como lugar de adoração, refúgio e salvação. Esta perspectiva da ação do Espírito é possível somente no período do pós-exílio. Nesse tempo o Espírito adquire uma dimensão ampla e inclusiva agindo sobre diversos setores sociais, independe de serem ou não judeus.(AU)

Religião e Movimento Social: as representações religiosas dos pentecostais do Assentamento Herbert de Souza, Moreno, Pernambuco

Objetiva esta pesquisa descrever e analisar as representações religiosas dos pentecostais do Assentamento Herbert de Souza, localizado no município de Moreno, no Estado de Pernambuco. Percebemos no decorrer da investigação que os assentados pentecostais, todos beneficiados pela ação do Movimento dos Trabalhadores Rurais Sem Terra (MST), atualizam suas representações religiosas de acordo com a demanda de vida que os motivou quando da entrada deles nas terras que pertenceram ao Engenho Pinto. Foi constatado também que o lugar e o tempo no qual aconteceu a inserção de cada pentecostal fez com que eles desenvolvessem elaborações religiosas diferenciadas acerca do Movimento, da terra e do que concebem como prática religiosa. Assim eles tecem redes simbólicas de significado que dão ordem às suas concepções de mundo. Procuramos comparar as representações dos pentecostais que já residiam nas terras do Engenho antes da ocupação com as daqueles que vieram depois, já como militantes do MST, ou simplesmente beneficiados pelo processo de democratização da terra. Criamos três tipos idéias de pentecostais: os pré-ocupação, os pós-ocupação e os pró-ocupação. Consideramos, finalmente, que as representações são elaboradas num momento de crise, em que há um intercâmbio de saberes entre o que afirma o MST e o que sistematiza as doutrinas da igreja à qual os fieis estejam vinculados. A situação de contingência é fundamental para o surgimento de um processo de negociação entre as práticas doutrinárias pentecostais e as exigências do MST.(AU)

A community-based approach to supply chain design

The role of beneficiaries in the humanitarian supply chain is highlighted in the imperative to meet their needs but disputed in terms of their actual decision-making and purchasing power. This paper discusses the use of a beneficiary-focused, community-based approach in the case of a post-crisis housing reconstruction programme. In the community-based approach, beneficiaries become active members of the humanitarian supply chain. Implications of this community-based approach are discussed in the light of supply chain design and aid effectiveness. © 2010 Taylor & Francis.

Designing post-disaster supply chains:learning from housing reconstruction projects

Post-disaster housing reconstruction projects face several challenges. Resources and material supplies are often scarce; several and different types of organizations are involved, while projects must be completed as quickly as possible to foster recovery. Within this context, the chapter aims to increase the understanding of relief supply chain design in reconstruction. In addition, the chapter is introducing a community based and beneficiary perspective to relief supply chains by evaluating the implications of local components for supply chain design in reconstruction. This is achieved through the means of secondary data analysis based on the evaluation reports of two major housing reconstruction projects that took place in Europe the last decade. A comparative analysis of the organizational designs of these projects highlights the ways in which users can be involved. The performance of reconstruction supply chains seems to depend to a large extent on the way beneficiaries are integrated in supply chain design impacting positively on the effectiveness of reconstruction supply chains.

Tsunami disaster recovery experience:a case study on micro, small and medium scale enterprises in Southern Sri Lanka

Post-disaster recovery of Micro, Small and Medium-Scale Enterprises (SMEs) remains an issue of interest for policy and practice given the wide scale occurrences of natural disasters around the globe and their significant impacts on local economies and SMEs. Asian Tsunami of December 2004 affected many SMEs in southern Sri Lanka. The study was developed to identify the main issues encountered by the Tsunami affected SMEs in Southern Sri Lanka in the process of their post-tsunami recovery. The study: a) identifies tsunami damage and loss in micro and SMEs in the Galle district; b) ascertains the type of benefits received from various parties by the affected micro and SMEs; c) evaluates the problems and difficulties faced by the beneficiary organizations in the benefit distribution process; and d) recommends strategies and policies for the tsunami-affected micro and SMEs for them to become self-sustaining within a reasonable time frame. Fifty randomly selected tsunami-affected micro and SMEs were surveyed for this study. Interviews were conducted in person with the business owners in order to identify the damages, recovery, rehabilitation, re-establishment and difficulties faced in the benefit distribution process. The analysis identifies that the benefits were given the wrong priorities and that they were not sufficient for the recovery process. In addition, the many governance-related problems that arose while distributing benefits are discussed. Overall, the business recovery rate was approximately 65%, and approximately 88% of business organizations were sole proprietorships. Therefore, the policies of the tsunami relief agencies should adequately address the needs of sole proprietorship business requirements. Consideration should also be given to strengthen the capacity and skills of the entrepreneurs by improving operational, technological, management and marketing skills and capabilities.

The Long-Term impact of Business Support? - Exploring the Role of Evaluation Timing using Micro Data

The original contribution of this work is threefold. Firstly, this thesis develops a critical perspective on current evaluation practice of business support, with focus on the timing of evaluation. The general time frame applied for business support policy evaluation is limited to one to two, seldom three years post intervention. This is despite calls for long-term impact studies by various authors, concerned about time lags before effects are fully realised. This desire for long-term evaluation opposes the requirements by policy-makers and funders, seeking quick results. Also, current ‘best practice’ frameworks do not refer to timing or its implications, and data availability affects the ability to undertake long-term evaluation. Secondly, this thesis provides methodological value for follow-up and similar studies by using data linking of scheme-beneficiary data with official performance datasets. Thus data availability problems are avoided through the use of secondary data. Thirdly, this thesis builds the evidence, through the application of a longitudinal impact study of small business support in England, covering seven years of post intervention data. This illustrates the variability of results for different evaluation periods, and the value in using multiple years of data for a robust understanding of support impact. For survival, impact of assistance is found to be immediate, but limited. Concerning growth, significant impact centres on a two to three year period post intervention for the linear selection and quantile regression models – positive for employment and turnover, negative for productivity. Attribution of impact may present a problem for subsequent periods. The results clearly support the argument for the use of longitudinal data and analysis, and a greater appreciation by evaluators of the factor time. This analysis recommends a time frame of four to five years post intervention for soft business support evaluation.

The long-term impact of business support? - Exploring the role of evaluation timing using micro data

The original contribution of this work is threefold. Firstly, this thesis develops a critical perspective on current evaluation practice of business support, with focus on the timing of evaluation. The general time frame applied for business support policy evaluation is limited to one to two, seldom three years post intervention. This is despite calls for long-term impact studies by various authors, concerned about time lags before effects are fully realised. This desire for long-term evaluation opposes the requirements by policy-makers and funders, seeking quick results. Also, current ‘best practice’ frameworks do not refer to timing or its implications, and data availability affects the ability to undertake long-term evaluation. Secondly, this thesis provides methodological value for follow-up and similar studies by using data linking of scheme-beneficiary data with official performance datasets. Thus data availability problems are avoided through the use of secondary data. Thirdly, this thesis builds the evidence, through the application of a longitudinal impact study of small business support in England, covering seven years of post intervention data. This illustrates the variability of results for different evaluation periods, and the value in using multiple years of data for a robust understanding of support impact. For survival, impact of assistance is found to be immediate, but limited. Concerning growth, significant impact centres on a two to three year period post intervention for the linear selection and quantile regression models – positive for employment and turnover, negative for productivity. Attribution of impact may present a problem for subsequent periods. The results clearly support the argument for the use of longitudinal data and analysis, and a greater appreciation by evaluators of the factor time. This analysis recommends a time frame of four to five years post intervention for soft business support evaluation.

The Political Economy of Financially Successful Independent Hip-Hop Artists

From 2000 to 2010, America’s music industry’s annual revenue went from $4 billion to $2 billion. Much of this is attributed to the internet’s ability to provide consumers with easy access to free music, and hip hop has been especially impacted by this trend. Utilizing document analysis and personal interviews, this study found that the success of independent artists has influenced the business strategies of major record companies. In response to a dramatic decrease in record sales, major labels have made more of an effort to sign their artists to 360 deals, which allow the labels to profit from every aspect of an artist’s brand or identity. While some independent artists are the main beneficiary of the profits generated from their music and personal brand, they also reify the commodity-form capitalist system by attempting to turn their music and brand into a fetishized commodity and by turning their audience into a fetishized commodity.

Atenção à criança no período neonatal: chamada neonatal, Rio Grande do Norte, 2010

The neonatal period, which includes the first 27 da ys postpartum, is a vulnerability phase in child health, making it necessary for a greater mon itoring by health professional through actions that add value to the binomial mother/child and comprehensive care to the newborn. To this end, this study aimed to evaluate the care actions the neonato from the strategies recommended by the Ministry of Health. This is a cr oss-sectional study carried out from the database of the national survey of population base entitled "Call Neonatal: evaluation of prenatal care and to children younger than one year old in the North and Northeast regions". It used as the sample unit the mothers and children yo unger than 1-year-old, costal residents of Rio Grande do Norte, Natal, Brazil, who attended th e vaccination campaign on June 12, 2010 in nine municipality’s priority for the Pact to Red uce Infant and Neonatal Mortality. To compose the study variables were selected issues/ac tions regarding the neonatal period and socio-demographic factors, followed by a descriptiv e and inferential analysis. A sample of 837 mother/child pairs was obtained, being 57.6% in capital and 42.4% in the whole from the interiors, which was weighted to represent the muni cipalities of the State. It was predominated by mothers aged between 20-29 years, complete high school, not entitled to income transfer program and male children (51.2%). The frequency of the actions of the hospital ranged from 35% to 96% and those performed at the Basic Health Unit (BHU) from 57% to 91.2%. Most actions had an association with hospitals and publi c nature of the state capital (p<0.05). The results for most of the actions are recommended in the care programs and policies for children, and reveal the regional inequities in hea lth and the need for the involvement of services and professionals in search of comprehensi ve care for enabling better care through humanized practices during this increased vulnerabi lity period.

Avaliação das condicionalidades em saúde do Programa Bolsa Família

The programs of conditional cash transfer are widespread in developing countries in Latin America with emphasis on Brazil as a new paradigm in social p olicies for poverty eradication . Consist of transferring monetary funds from the government directly to poor families by fulfilling the condition alities on education and health . In health, even wi th variations between countries , conditionality targeting public pregnant women and children with a view to improving health indic ators maternoinfantil as growth , infant mortality and prenatal care. The objectives of this study are to compare the transfer progr am conditional Brazilian income , the Family and similar programs in Latin A merica in relation to it s effects on growth in children , and to evaluate the effect of Bolsa Família in the prevalence of use of services ( conditionalities ) of prenatal care in Brazilian health services whose teams joined the Programa de Acesso e Melhoria da Qualidade da Atenção Básica (PMAQ - AB) . For the first objective a systematic review , we selec ted ten articles between 1007 ( one thousand and seven ) found in the databases Embase , PubMed, Scopus , Scielo and Lilacs databases was performed . Articles are ob servational epidemiological studies of transverse descriptive and analytical types of cohort and case - co ntrol. For the second objective, for it is a prevalence study , a statistical analysis using Poisson regression with robust variance was performed to i nvestigate how the prevalence of compliance with conditionalities on health was influenced b y various explanatory variables . Ratios , crude and adjusted prevalence , with their respective confidence i ntervals of 95 % were estimated . The family joined the sch olarship program was considered as the main expo sure variable . Confounding variables were: maternal age , race / color, paid employment , marital status and region of residence . In d ata analysis software R 3.0.1 (RDevelopment Core Team 2013 ) was used . Rega rding the comparison of the Bolsa Família with other programs in Latin America , the review found similar results regarding the positive effect of income transfer in the nutritional status o f beneficiary children programs , and these effects are more evident in children under two years old and belonging to familie s of lower socioeconomic status . For the prevalence of conditionalities entres different groups of users of the Bolsa Família and nonusers results showed no statistically significant difference betwe en respondents (with children under two years ) registered and not registered in PBF on issues relating to: me et at least six prenatal visits , meet and participate in health education activities . It follows from side to increase minimum income for families in extreme poverty showed positive impact on children's health in Brazil and Latin America. The o ther is not confirmed in Brazil , an increase in conditionality expressed in use of primary care by the user s of the Bolsa Família services.

A influência da relevância social no viés de grupo

Behaviors found in every culture, general human tendencies, are knew in Evolutionary Psychology as evolved psychological mechanisms. Those behaviors date back the Environment of Evolutionary Adaptedness, and a well know example of such behavior is the group bias (or intergroup bias). This bias consists of recognizing members of your own group and favor them, while disregarding or even harming outsiders. This behavior was and still is extensively studies, among the most important conclusions about this phenomenon is the Minimal Groups Paradigm, in which it was discovered that the group bias could trigger even when the groupings were done in following very arbitrary criteria. In the current study, our goal was to test if the participants, when playing an economic game, would behave in a similar fashion under a minimal group situation and real groups, with social meaning. With this in mind we made two experimental conditions, a Low Social Meaning one (LSM) where the groups were represented by letters (H, B, O and Y) in which participants would be ramdomly assorted to each group; and the High Social Meaning condition (HSM) in which religion was used as a group marker, containing the two most dominating religious groups in Brazil, catholic and evangelic, another group containing all the other affiliations e the fourth and last group representing atheists and agnostics. The ratio of donations in-group/out-group was roughly the same across both conditions. However, the amount of wafers donated to ingroup was significantly bigger in the HSM condition. By verifying which aspects of the individual best predicted the observed group bias, we discovered that the in-group Entitativity perception as well as the Group Identification were the most relevant variables, however, only in the HSM condition. Simultaneously, by verifying the generosity, biased or not, we observed that the agreeableness personality factor was the only variable able to predict it, and only in the LSM condition. We conclude that our generosity, or the lack of it, is for most part defined by our personality, the Agreeableness factor in particular. But this very generosity can be biased by the social meaning of the involved groups and that, if the social meaning is big enough, even people who, thanks to their personality, normally wouldn’t show generosity, are able to do so when the receiver is an in-group member.

Increased water charges improve efficiency and equity in an irrigation system

Conventional wisdom in many agricultural systems across the world is that farmers cannot, will not, or should not pay the full costs associated with surface water delivery. Across Organisation for Economic Co-operation and Development (OECD) countries, only a handful can claim complete recovery of operation, maintenance, and capital costs; across Central and South Asia, fees are lower still, with farmers in Nepal, India, and Kazakhstan paying fractions of a U.S. penny for a cubic meter of water. In Pakistan, fees amount to roughly USD 1-2 per acre per season. However, farmers in Pakistan spend orders of magnitude more for diesel fuel to pump groundwater each season, suggesting a latent willingness to spend for water that, under the right conditions, could potentially be directed toward water-use fees for surface water supply. Although overall performance could be expected to improve with greater cost recovery, asymmetric access to water in canal irrigation systems leaves the question open as to whether those benefits would be equitably shared among all farmers in the system. We develop an agent-based model (ABM) of a small irrigation command to examine efficiency and equity outcomes across a range of different cost structures for the maintenance of the system, levels of market development, and assessed water charges. We find that, robust to a range of different cost and structural conditions, increased water charges lead to gains in both efficiency and concomitant improvements in equity as investments in canal infrastructure and system maintenance improve the conveyance of water resources further down watercourses. This suggests that, under conditions in which (1) farmers are currently spending money to pump groundwater to compensate for a failing surface water system, and (2) there is the possibility that through initial investment to provide perceptibly better water supply, genuine win-win solutions can be attained through higher water-use fees to beneficiary farmers.

Can I still qualify for Medicaid nursing facility eligibility if my income is more than the allowed $2,130 per month? September 19, 2013

A Miller Trust is an irrevocable trust established on or before August 10, 1993, for the benefit of an individual and is used to help pay the cost of nursing facility care. The person residing in the nursing facility is designated as the beneficiary, and after the beneficiary’s death, all remaining amounts, up to the amount of Medicaid paid for the beneficiary, are paid to the State, the residuary beneficiary. Once a trust is established, a bank account for monies associated with the trust can be opened. Only certain funds, including the beneficiary’s earned and unearned income, can be deposited into the Miller Trust account. A trustee, usually a spouse or family member, is the person who administers the trust and pays out money.

Dos prejuízos no regime de participation exemption: a relação entre estabelecimento estável e filial

Mestrado em Fiscalidade