978 resultados para Tax planning


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In this paper, a hardware-based path planning architecture for unmanned aerial vehicle (UAV) adaptation is proposed. The architecture aims to provide UAVs with higher autonomy using an application specific evolutionary algorithm (EA) implemented entirely on a field programmable gate array (FPGA) chip. The physical attributes of an FPGA chip, being compact in size and low in power consumption, compliments it to be an ideal platform for UAV applications. The design, which is implemented entirely in hardware, consists of EA modules, population storage resources, and three-dimensional terrain information necessary to the path planning process, subject to constraints accounted for separately via UAV, environment and mission profiles. The architecture has been successfully synthesised for a target Xilinx Virtex-4 FPGA platform with 32% logic slices utilisation. Results obtained from case studies for a small UAV helicopter with environment derived from LIDAR (Light Detection and Ranging) data verify the effectiveness of the proposed FPGA-based path planner, and demonstrate convergence at rates above the typical 10 Hz update frequency of an autopilot system.

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At one level the urban landscapes of South Florida and South East Queensland look quite similar. However at another level the context of planning and planning control and regulation is quite different. To understand the contextual differences between South Florida and South East Queensland, four themes will be used, some of which were based on Cullingworth and Booth. The four themes include: demography, governance, the law and regulatory philosophy. After having evaluated South Florida and South East Queensland across these four themes, we propose a framework for examining whether these differences have shaped planning outcomes and in particular, the built form.

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The Australian government, and opposition, are committed to facilitating high-speed broadband provision. In April 2009 the (then) Labor government announced a proposal to facilitate provision by mandating “…the use of fibre optic infrastructure … in greenfield estates ….” Separately, the installation of (usually overhead) cables commenced in select brownfield areas throughout Australia. In the lead up to the 2010 federal election, the broadband policy focus of the (then) federal opposition was to enabling private investment rather than direct investment by government itself. High-speed broadband is essential for Australia’s economic future. Whether implementation is undertaken by government, government owned corporations or private investors, will impact on the processes to be followed. Who does what, also will determine the rights available to land owners. The next stage, of necessity, will involve the establishment of procedures to require the retrofitting of existing urban environments. This clearly will have major property, property rights and valuation impacts. As Horan (2000) observed “…preserving... unique characteristics … of…regions requires a compromise between economic ambitions and social, cultural, and environmental values”. The uncertainty following the federal election, and the influence of independants with individual agendas; presents unique challenges for broadband implementation. This paper seeks to identify the processes to be followed by various potential broadband investors as they work to establish a ubiquitous network. It overviews current legislative regimes and examines concerns raised by stakeholders in various government reviews. It concludes by plotting a clear way forward to the future, with particular regard to property rights and usage.

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Now in its eighth edition, Australian Tax Analysis: Cases, Commentary, Commercial Applications and Questions has a proven track record as a high level work for students of taxation law written by a team of authors with many years of experience. Taking into account the fact that the volume of material needed to be processed by today’s taxation student can be overwhelming, the well-chosen extracts and thought-provoking commentary in Australian Tax Analysis, 8th edition, provide readers with the depth of knowledge, and reasoning and analytical skills that will be required of them as practitioners. As well as the carefully selected case extracts and the helpful commentary, each chapter is supplemented by engaging practice questions, involving problem-solving, commercial decision-making, legal analysis and quantitative application. All these elements combined make Australian Tax Analysis an invaluable aid to the understanding of a subject that can be both technical and complex.

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The Australian income tax regime is generally regarded as a mechanism by which the Federal Government raises revenue, with much of the revenue raised used to support public spending programs. A prime example of this type of spending program is health care. However, a government may also decide that the private sector should provide a greater share of the nation's health care. To achieve such a policy it can bring about change through positive regulation, or it can use the taxation regime, via tax expenditures, not to raise revenue but to steer or influence individuals in its desired direction. When used for this purpose, tax expenditures steer taxpayers towards or away from certain behaviour by either imposing costs on, or providing benefits to them. Within the context of the health sector, the Australian Federal Government deploys social steering via the tax system, with the Medicare Levy Surcharge and the 30 percent Private Health Insurance Rebate intended to steer taxpayer behaviour towards the Government’s policy goal of increasing the amount of health provision through the private sector. These steering mechanisms are complemented by the ‘Lifetime Health Cover Initiative’. This article, through the lens of behavioural economics, considers the ways in which these assorted mechanisms might have been expected to operate and whether they encourage individuals to purchase private health insurance.

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It is argued that concerns arise about the integrity and fairness of the taxation regime where charitable organizations, which avail themselves of the tax exemption status while undertaking commercial activities, compete directly with the for-profit sector. The appropriateness of the tax concessions granted to charitable organizations is considered in respect of income derived from commercial activities. It is principally argued that the traditional line of reasoning for imposing limitations on tax concessions focuses on an incorrect underlying inquiry. Traditionally, it is argued that limitations should be imposed because of unfair competition, lack of competitive neutrality, or an arbitrary decision relating to a lack of deserving. However, it is argued that a more appropriate question from which to base any limitations is one which considers the value attached to the integrity of the taxation regime as a whole, and the tax base specifically compared to the public good of charities. When the correct underlying question is asked, sound taxation policy ensues, as a less arbitrary approach may be adopted to limit the scope of tax concessions available to charitable organizations.

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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.

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Each year the Australian Federal Treasury releases its Tax Expenditures Statement providing details of concessions, benefits, and incentives delivered through the tax regime to Australian taxpayers. The current Tax Expenditures Statement, released on 25 January 2008, lists approximately 300 tax expenditures and reports on the estimated pecuniary value in terms of revenue foregone, estimated to be a total of $50.12 billion for the 2006-07 financial year. Apart from the annual Tax Expenditures Statement, and despite the recurring fiscal impact, there is very little other scrutiny of Australia’s Federal tax expenditures program. This is despite tax expenditures often being seen as an alternative to direct expenditures with similar impact on the Federal budget. The object of tax expenditures is to provide government assistance and meet government objectives, and, as such, tax expenditures are departures from the revenue raising aspect of the tax regime. Within this context, this article examines the fundamental concept of tax expenditures as contrasted with direct expenditures and considers the role they play in the current tax regime.

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Performance based planning is a form of planning regulation that is not well understood and the theoretical advantages of this type of planning are rarely achieved in practice. Normatively, this type of regulation relies on performance standards that are quantifiable and technically based which are designed to manage the effects of development, where performance standards provide certainty in respect of the level of performance and the means of achievement is flexible. Few empirical studies have attempted to examine how performance based planning has been conceptualised and implemented in practice. Existing literature is predominately anecdotal and consultant based (Baker et al. 2006) and has not sought to quantitatively examine how land use has been managed or determine how context influences implementation. The Integrated Planning Act 1997 (IPA) operated as Queensland’s principal planning legislation between March 1998 and December 2009. The IPA prevented Local Governments from prohibiting development or use and the term zone was absent from the legislation. While the IPA did not use the term performance based planning, the system is widely considered to be performance based in practice (e.g. Baker et al. 2006; Steele 2009a, 2009b). However, the degree to which the IPA and the planning system in Queensland is performance based is debated (e.g. Yearbury 1998; England 2004). Four research questions guided the research framework using Queensland as the case study. The questions sought to: determine if there is a common understanding of performance based planning; identify how performance based planning was expressed under the IPA; understand how performance based planning was implemented in plans; and explore the experiences of participants in the planning system. The research developed a performance adoption spectrum. The spectrum describes how performance based planning is implemented, ranging between pure and hybrid interpretations. An ex-post evaluation of seventeen IPA plans sought to determine plan performativity within the conceptual spectrum. Land use was examined from the procedural dimension of performance (Assessment Tables) and the substantive dimension of performance (Codes). A documentary analysis and forty one interviews supplemented the research. The analytical framework considered how context influenced performance based planning, including whether: the location of the local government affected land use management techniques; temporal variation in implementation exists; plan-making guidelines affected implementation; different perceptions of the concept exist; this type of planning applies to a range of spatial scales. Outcomes were viewed as the medium for determining the acceptability of development in Queensland, a significant departure from pure approaches found in the United States. Interviews highlighted the absence of plan-making direction in the IPA, which contributed to the confusion about the intended direction of the planning system and the myth that the IPA would guarantee a performance based system. A hybridised form of performance based planning evolved in Queensland which was dependent on prescriptive land use zones and specification of land use type, with some local governments going to extreme lengths to discourage certain activities in a predetermined manner. Context had varying degrees of influence on plan-making methods. Decision-making was found to be inconsistent and the system created a range of unforeseen consequences including difficulties associated with land valuation, increased development speculation, and the role of planners in court was found to be less critical than in the previous planning system.

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At St Thomas' Hospital, we have developed a computer program on a Titan graphics supercomputer to plan the stereotactic implantation of iodine-125 seeds for the palliative treatment of recurrent malignant gliomas. Use of the Gill-Thomas-Cosman relocatable frame allows planning and surgery to be carried out at different hospitals on different days. Stereotactic computed tomography (CT) and positron emission tomography (PET) scans are performed and the images transferred to the planning computer. The head, tumour and frame fiducials are outlined on the relevant images, and a three-dimensional model generated. Structures which could interfere with the surgery or radiotherapy, such as major vessels, shunt tubing etc., can also be outlined and included in the display. Catheter target and entry points are set using a three-dimensional cursor controlled by a set of dials attached to the computer. The program calculates and displays the radiation dose distribution within the target volume for various catheter and seed arrangements. The CT co-ordinates of the fiducial rods are used to convert catheter co-ordinates from CT space to frame space and to calculate the catheter insertion angles and depths. The surgically implanted catheters are after-loaded the next day and the seeds left in place for between 4 and 6 days, giving a nominal dose of 50 Gy to the edge of the target volume. 25 patients have been treated so far.

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Exploiting wind-energy is one possible way to ex- tend flight duration for Unmanned Arial Vehicles. Wind-energy can also be used to minimise energy consumption for a planned path. In this paper, we consider uncertain time-varying wind fields and plan a path through them. A Gaussian distribution is used to determine uncertainty in the Time-varying wind fields. We use Markov Decision Process to plan a path based upon the uncertainty of Gaussian distribution. Simulation results that compare the direct line of flight between start and target point and our planned path for energy consumption and time of travel are presented. The result is a robust path using the most visited cell while sampling the Gaussian distribution of the wind field in each cell.

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The tax expenditures concept has been part of the Australian tax review system since 1973. In view of the fact that tax expenditures are considered part of the tax-transfer system, and that paragraph 9 of the terms of reference for the Review Panel requires a consideration of all relevant tax expenditures, we can be confident that they will be considered once again in the final report of Australia’s Future Tax System Review Panel. However, an examination of previous Government and Parliamentary reviews suggests that few of the resulting recommendations are adopted. Previous recommendations have resulted in the acknowledgement of and concern over tax expenditures, but have led to only one significant advancement: the publication of an annual tax expenditures statement. It is apparent that Brooks in his paper aims to ensure, and makes a compelling case for, the significance and central role tax expenditures should play in the Review Panel deliberations. In doing so, Brooks explores the concept itself as well as the conceptual implications impacting on the more pragmatic aspects of tax expenditure analysis. At the outset, Brooks explains why tax expenditures cannot be evaluated using traditional criteria of equity, neutrality, and simplicity, but rather can only be understood and evaluated using budgetary criteria.

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The changing R&D Tax Concession has been touted as the biggest reform to business innovation policy in over a decade. But, is it a changing tax for changing times? This paper addresses this question and further asks ‘what’s tax got to do with it?’. To answer this question, the paper argues that rather than substantive tax reform, the proposed measures simply alter the criteria and means by which companies become eligible for a Federal Government subsidy for qualifying R&D activity. It further argues that when considered as part of the broader innovation agenda, the R&D Tax Concession should be evaluated as a government spending program in the same way as any direct spending on innovation. When this is done, the tax regime is arguably only the administrative policy instrument by which the subsidy is delivered. However, it is proposed that this may not be best practice to distribute those funds fairly, efficiently, and without distortion, while at the same time maintaining adequate government control and accountability. Finally, in answering the question of ‘what’s tax got to do with it?’ the paper concludes that the answer is ‘very little’.

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The current Australian Treasury approach to tax expenditures management and reporting is a culmination of 36 years of Government and Parliamentary reviews and reports. The most notable outcome of these reviews and reports is the publication of the annual tax expenditures statement, which commenced in 1986. Since its inception, the Australian annual tax expenditures statements have themselves been the subject of review. Most recently, the Australian National Audit Office has undertaken a performance audit in the Department of the Treasury and released its report entitled Preparation of the Tax Expenditures Statement. In addition to this 2008 report, a second recent opportunity to consider tax expenditures within the Australian tax regime has arisen. The Australian tax system is currently undergoing a comprehensive and broad review with the terms of reference requiring a consideration of all relevant tax expenditures. While the recommendations of the Australian National Audit Office are not novel, and it is not unusual for a broader review to consider the role of tax expenditures within the Australian tax system, both the recommendations of the Australian National Audit Office and the views of the current Review Panel take on a renewed sense of importance given the proliferation of tax expenditures in Australia. Tax expenditures, in terms of number and pecuniary value, have increased significantly in Australia in recent years. The latest Tax Expenditures Statement lists around 320 tax expenditures with the pecuniary value of those expenditures estimated at $73.69 billion or 7.1% of GDP. The largest category of tax expenditures listed in the 2008 Tax Expenditures Statement, totalling $29.23 billion, relate to concessions aimed at retirement savings.