Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

An examination of recent taxation amendments, corporate law reforms and Queensland legislative reforms affecting nonprofit organisations

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.

Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment.

Nonprofit organisations and value added (GST) taxation

The subject of this paper is the changes in the taxation of non-profit organisations which seem to be more or less inherent in the value added taxes. The Australian federal Coalition's proposed goods and services tax will be part of the discussion.

"Money pouring out of its ears" : on the taxation of really profitable nonprofit organisations in Australia

Under current law Australia appears to be a tax haven for certain non-governmental institutions. Millions of ordinary business income may go untaxed and the deductibility for donations is unlimited - both are very generous tax measures in an international context. The basic problems of most Australian nonprofit organisations are not taxation; they are just that: nonprofit. Anybody interested in the non-governmental sector should be willing to face the question: What is an equitable tax treatment? The short-term tactic of ducking the question may not be the best or most beneficial long term strategy.

Case study of Queensland state taxation

1. Like the Commonwealth Tax regime, state taxation legislation has now ballooned in size from the good old days when life and tax were relatively simple issues. 2. This case study of Queensland state taxation will examine the following taxes affecting churches and charities in this state: (a) Stamp Duty (b) Land Tax; and (c) Local Authority Rates 3. Each type of tax will be considered in turn. A brief legislative history of the statutory instruments governing these taxes will be given with a closer examination of the present schemes. Relevant judicial pronouncements will be considered and some open discussion of real life examples. 4. It is submitted that the regular donors to our worthy charities and the dedicated weekly churchgoers would have absolutely no idea: (a) that indirectly the value of their donations and weekly offerings are increasingly being eroded by the imposts of Government not only in terms of the amounts of those imposts but the enormous administrative burden of coping with the legislation; (b) of the complexity of the taxation legislation affecting their churches and charities; or (c) that their churches and charities are even paying taxes.

A select and annotated bibliography of nonprofit taxation

It seems likely that the Industry Commission Inquiry on Charitable Organisations will include a reference to examine the state of taxation and charities. There will no doubt be discussions on the taxation benefits enjoyed by charities. These benefits include not only the exemption from being liable for income tax and enjoying the status of being a "deductible body" for the purpose of gifts, but also fringe benefits tax, sales tax, land tax, stamp duty, financial institutions duty, local government rates and charges as well as electricity, gas, telephone and motor vehicle concessions.

Effect on charitable bodies of taxation alternations

It appears that the Industry Commission terms of reference will include a review of (among other things) the appropriateness of the present taxation treatment of charitable organisations. It is uncertain exactly which taxation treatments might be reviewed. However, at a federal government level, a review of the current taxation treatment of charitable organisations could refer to a review of the following taxation measures...

Principles of Taxation Law 2013

Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2013 brings much needed clarity to this area of law. Utilising many methods to make this often daunting subject achievable, particular features of the 2013 edition include: • seven parts: overview and structure, principles of income, deductions and offsets, timing issues, investment and business entities, tax avoidance and administration, and indirect taxes; • clearly structured chapters within those parts grouped under helpful headings; • flowcharts, diagrams and tables, end of chapter practice questions, and case summaries; • an appendix containing all of the up to date and relevant rates; and • the online self-testing component mentor, which provides questions for students of both business and law. Every major aspect of the Australian tax system is covered, with chapters on topics such as goods and services tax, superannuation, offsets, partnerships, capital gains tax, trusts, company tax and tax administration. All chapters have been thoroughly revised. Principles of Taxation Law 2013 is the perfect tool to guide the reader from their initial exposure to the subject to success in taxation law exams.

Australia - taxation of trusts – the problem of aligning concepts of income

The Australian government is currently considering options for the rewrite and reform of the current provisions which apply to the taxation of trust income. This article provides a discussion of the current regime and the proposed reforms. It is suggested that a major revamp of taxation of trust income in Australia is problematic and a simpler approach may be to leave the law as is, with modification where necessary to address key issues as and when they arise.

Principles of Taxation Law 2014 [7th Edition]

"Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2014 brings much needed clarity to this area of law. Utilising many methods to make this often daunting subject achievable, particular features of the 2014 edition include: seven parts: overview and structure, principles of income, deductions and offsets, timing issues, investment and business entities, tax avoidance and administration, and indirect taxes; clearly structured chapters within those parts grouped under helpful headings;flowcharts, diagrams and tables, end of chapter practice questions, and case summaries; an appendix containing all of the up to date and relevant rates; and the online self-testing component mentor, which provides questions for students of both business and law. Every major aspect of the Australian tax system is covered, with chapters on topics such as goods and services tax, superannuation, offsets, partnerships, capital gains tax, trusts, company tax and tax administration.All chapters have been thoroughly revised"-- Publishers website

#Pontiff-Ex : the Twitter community’s reaction to the Papal resignation

In this paper, we provide an account-centric analysis of the tweeting activity of, and public response to, Pope Benedict XVI via the @pontifex Twitter account(s). We focus our investigation on the particular phase around Pope Benedict XVI’s resignation to generate insights into the use of Twitter in response to a celebrity crisis event. Through a combined qualitative and quantitative methodological approach we generate an overview of the follower-base and tweeting activity of the @pontifex account. We identify a very one-directional communication pattern (many @mentions by followers yet zero @replies from the papal account itself), which prompts us to enquire further into what the public resonance of the @pontifex account is. We also examine reactions to the resurrection of the papal Twitter account by Pope Benedict XVI’s successor. In this way, we provide a comprehensive analysis of the public response to the immediate events around the crisis event of Pope Benedict XVI’s resignation and its aftermath via the network of users involved in the @pontifex account.