Taxation determinations as de facto regulation : private equity exits in Australia

The Australian Taxation Office (AT)) attempted to challenge both the private equity fund reliance on double tax agreements and the assertion that profits were capital in nature in its dispute with private equity group TPG. Failure to resolve the dispute resulted in the ATO issuing two taxation determinations: TD 2010/20 which states that the general anti-avoidance provisions can apply to arrangements designed to alter the intended effect of Australia's international tax agreements net; and TD 2010/21 which states that the profits on the sale of shares in a company group acquired in a leveraged buyout is assessable income. The purpose of this article is to determine the effectiveness of the administrative rulings regime as a regulatory strategy. This article, by using the TPG-Myer scenario and subsequent tax determinations as a case study, collects qualitative data which is then analysed (and triangulated) using tonal and thematic analysis. Contemporaneous commentary of private equity stakeholders, tax professionals, and media observations are analysed and evaluated within a framework of responsive regulation and utilising the current ATO compliance model. Contrary to the stated purpose of the ATO rulings regime to alleviate complexities in Australian taxation law and provide certainty to taxpayers, and despite the de facto law status afforded these rulings, this study found that the majority of private equity stakeholders and their advisors perceived that greater uncertainty was created by the two determinations. Thus, this study found that in the context of private equity fund investors, a responsive regulation measure in the form of taxation determinations was not effective.

National and state-level politics on social media : Twitter, Australian political discussions, and the online commentariat

This paper examines the use of Twitter for long-term discussions around Australian politics, at national and state levels, tracking two hashtags during 2012: #auspol, denoting national political topics, and #wapol, which provides a case study of state politics (representing Western Australia). The long-term data collection provides the opportunity to analyse how the Twitter audience responds to Australian politics: which themes attract the most attention and which accounts act as focal points for these discussions. The paper highlights differences in the coverage of state and national politics. For #auspol, a small number of accounts are responsible for the majority of tweets, with politicians invoked but not directly contributing to the discussion. In contrast, #wapol stimulates a much lower level of tweeting. This example also demonstrates that, in addition to citizen accounts, traditional participants within political debate, such as politicians and journalists, are among the active contributors to state-oriented discussions on Twitter.

A mass spectrometry study of XCO+, X = Si, Ge : Is SiCO+ a main group carbonyl? Comments on the bonding in ground state SiCO and the Si,C,O (+) potential energy surface

The cation\[Si,C,O](+) has been generated by 1) the electron ionisation (EI) of tetramethoxysilane and 2) chemical ionisation (CI) of a mixture of silane and carbon monoxide. Collisional activation (CA) experiments performed for mass-selected \[Si,C,O](+), generated by using both methods, indicate that the structure is not inserted OSiC+; however, a definitive structural assignment as Si+-CO, Si+-OC or some cyclic variant is impossible based on these results alone. Neutralisation-reionisation (+NR+) experiments for EI-generated \[Si,C,O](+) reveal a small peak corresponding to SiC+, but no detectable SiO+ signal, and thus establishes the existence of the Si+-CO isomer. CCSD(T)//B3LYP calculations employing a triple-zeta basis set have been used to explore the doublet and quartet potential-energy surfaces of the cation, as well as some important neutral states The results suggest that both Si+-CO and Si+ - OC isomers are feasible; however, the global minimum is (2)Pi SiCO+. Isomeric (2)Pi SiOC+ is 12.1 kcal mol(-1) less stable than (2)Pi SiCO+, and all quartet isomers are much higher in energy. The corresponding neutrals Si-CO and Si-OC are also feasible, but the lowest energy Si - OC isomer ((3)A") is bound by only 1.5 kcal mol(-1). We attribute most, if nor all, of the recovery signal in the +NR' experiment to SiCO+ survivor ions. The nature of the bonding in the lowest energy isomers of Si+ -(CO,OC) is interpreted with the aid of natural bond order analyses, and the ground stale bonding of SiCO+ is discussed in relation to classical analogues such as metal carbonyls and ketenes.

State of the art reviews : measurement of physical activity in children and adolescents

To date, a wide range of methods has been used to measure physical activity in children and adolescents. These include self-report methods such as questionnaires, activity logs, and diaries as well as objective measures of physical activity such as direct observation, doubly labeled water, heart rate monitoring, accelerometers, and pedometers. The purpose of this review is to overview the methods currently being used to measure physical activity in children and adolescents. For each measurement approach, new developments and/or innovations are identified and discussed. Particular attention is given to the use of accelerometers and the calibration of accelerometer output to units of energy expenditure to developing children.

Pressure state response-based method for evaluating social benefits from smart grid development

In this paper, the inherent mechanism of social benefits associated with smart grid development is examined based on the pressure state response (PSR) model from resource economics. The emerging types of technology brought up by smart grid development are regarded as pressures. The improvements of the performance and efficiency of power system operation, such as the enhanced capability of accommodating renewable energy generation, are regarded as states. The effects of smart grid development on society are regarded as responses. Then, a novel method for evaluating social benefits from smart grid development is presented. Finally, the social benefits from smart grid development in a province in northwest China are carried out by using the developed evaluation system, and reasonable evaluation results are attained.

An examination of tax deductible donations made by individual Australian taxpayers in 2011–12

This study uses information based on published ATO material and represents the extent of tax-deductible donations made and claimed by Australian individual taxpayers (i.e. not including corporate entities or trusts) to DGRs, at Item D9 Gifts or Donations, in their income tax returns for the 2011-12 income year. The total amount claimed as tax-deductible donations in 2011-12 was $2.24 billion (compared to $2.21 billion in 2010-11), representing 6.85% of all personal taxpayer deductions. Since 1978-79, the actual total tax-deductible donations claimed by Australian individual taxpayers has outpaced inflation-adjusted total tax-deductible donations, measured against the Consumer Price Index. The average tax-deductible donation claimed in 2011-12 increased to $494.25, but the absolute number and percentage of taxpayers claiming donations dropped (to 4.54 million or 35.62%). Analysis is given of individual taxpayers' donation claiming by Gender, State of Residence, Postcode, Income Band, Industry of employment, and Occupation.

Curse or cure? Revisiting state, capital and resources

WA’s experience, as portrayed in this volume, not only highlights the changeable nature of the mining industry, the volatility of global commodity markets and the impact of global capital on people and place, it also draws into question the promise of lasting value derived from resource development as currently practiced. It is in this context that Chapter 18 revisits WA's resource boom and assesses the sustainability of resource-led development in the state, to arrive at an answer to the question of ‘curse or cure?’. Opening up the discourse beyond the dominant developmentalist narrative invites discussion on new perspectives of economic sustainability that include well-being, equity and the protection of people, culture and place.

Nowhere to hide: informal disease surveillance networks tracing state behaviour

Since the revisions to the International Health Regulations (IHR) in 2005, much attention has turned to how states, particularly developing states, will address core capacity requirements attached to the revised IHR. Primarily, how will states strengthen their capacity to identify and verify public health emergencies of international concern (PHEIC)? Another important but under-examined aspect of the revised IHR is the empowerment of the World Health Organization (WHO) to act upon non-governmental reports of disease outbreaks. The revised IHR potentially marks a new chapter in the powers of ‘disease intelligence’ and how the WHO may press states to verify an outbreak event. This article seeks to understand whether internet surveillance response programs (ISRPs) are effective in ‘naming and shaming’ states into reporting disease outbreaks.

Multiband photoluminescence from carbon nanoflakes synthesized by hot filament CVD: towards solid-state white light sources

Carbon nanoflakes (CNFLs) are synthesized on silicon substrates deposited with carbon islands in a methane environment using hot filament chemical vapor deposition. The structure and composition of the CNFLs are studied using field emission scanning electron microscopy, high-resolution transmission electron microscopy, micro-Raman spectroscopy, and X-ray photoelectron spectroscopy. The results indicate that the CNFLs are composed of multilayer graphitic sheets and the area and thickness of CNFs increase with the growth time. The photoluminescence (PL) of CNFLs excited by a 325 nm He-Cd laser exhibits three strong bands centered at 408, 526, and 699 nm, which are related to the chemical radicals terminated on the CNFLs and the associated interband transitions. The PL results indicate that the CNFLs are promising as an advanced nano-carbon material capable of generating white light emission. These outcomes are significant to control the electronic structure of CNFLs and contribute to the development of next-generation solid-state white light emission devices. © 2014 the Partner Organisations.

Structure, bonding state and in-vitro study of Ca–P–Ti film deposited on Ti6Al4V by RF magnetron sputtering

Experimental investigation of functionally graded calcium phosphate-based bio-active films on Ti-6A1-4V orthopaedic alloy prepared in an RF magnetron sputtering plasma reactor is reported. The technique involves concurrent sputtering of Hydroxyapatite (HA) and Ti targets, which results in remarkably enhanced adhesion of the film to the substrate and stability of the interface. The films have been characterized using X-ray diffraction (XRD) and X-ray photoelectron spectroscopy (XPS). The XPS data show that the films are composed of O, Ca, P and Ti, and reveal the formation of O=P groups and hybridization of O-Ca-P. The XRD pattern shows that the Ca-P thin films are of crystalline calcium oxide phosphate (4CaO·P2O5) with preferred orientation varying with processing parameters. High-resolution optical emission spectra show that the emission of CaO is dominant. The CaO, PO and CaPO species are strongly influenced by deposition conditions. The introduction of Ti element during deposition provides a stable interface between bio-inert substrates Ti-6A1-4V and bioactive HA coating. In-vitro cell culturing tests suggest excellent biocompatibility of the Ca-P-Ti films.

Volatile properties of CNG and Diesel bus emissions produced during steady state and transient driving modes

An analysis of the emissions from 14 CNG and 5 Diesel buses was conducted during April & May, 2006. Studies were conducted at both steady state and transient driving modes on a vehicle dynamometer utilising a CVS dilution system. This article will focus on the volatile properties of particles from 4 CNG and 4 Diesel vehicles from within this group with a priority given to the previously un-investigated CNG emissions produced at transient loads. Particle number concentration data was collected by three CPC’s (TSI 3022, 3010 & 3782WCPC) having D50 cut-offs set to 5nm, 10nm & 20nm respectively. Size distribution data was collected using a TSI 3080 SMPS with a 3025 CPC during the steady state driving modes. During transient cycles mono-disperse “slices” of between 5nm & 25nm were measured. The volatility of these particles was determined by placing a thermodenuder before the 3022 and the SMPS and measuring the reduction in particle number concentration as the temperature in the thermodenuder was increased. This was then normalised against the total particle count given by the 3010 CPC to provide high resolution information on the reduction in particle concentration with respect to temperature.

Nanoparticle emissions from a fleet of CNG buses in transient and steady state operation

Particle emission measurements from a fleet of 14 CNG and 5 Diesel buses were measured both for transient and steady state mode s on a chassis dynamometer with a CVS dilution system. Several transient DT80 cycles and 4 steady sate modes (0, 25, 50 100% of maximum load) were measured for each bus tested. Particle number concentration data was collected by three CPC’s (TSI 3022, 3010 3782WCPC) having D50 cut-offs set to 5, 10 and 20nm respectively. The size distributions were measured with a TSI 3080 SMPS with a 3025 CPC during the steady state modes. Particle mass emissions were measured with a TSI Dustrak. Particle mass emissions for Diesel buses were upto 2 orders of magnitude higher than for CNG buses. Particle number emissions during steady state modes for Diesel busses were 2 to 5 times higher than for CNG busses for all of the tested loads. On the other hand for the DT80 transient cycle particle number emissions were up to 3 times higher for the CNG buses. More detailed analysis of the transient cycles revealed that the reason for this was due to high particle number emissions from CNG busses during the acceleration parts of the cycles. Particles emitted by the CNG busses during acceleration were in the nucleation mode with the majority being smaller than 10nm. Volatility measurements have also shown that they were highly volatile.

Steady state and transient dynamometer vehicle emission measurements using a DiSC

Analysis of the particulate size and number concentration emissions from a fleet of inner city medium duty CNG buses was conducted using the newly available Diffusion Size Classifier in comparison with more traditional SMPS's and CPC's. Studies were conducted at both steady state and transient driving modes on a vehicle dynamometer utilising a CVS dilution system. Comparative analysis of the results showed that the DiSC provided equivalent information during steady state conditions and was able to provide additional information during transient conditions, namely, the modal diameter of the particle size distribution.

Steady state genuine multipartite entanglement in harmonic oscillator ensembles with a common environment

Steady state entanglement in ensembles of harmonic oscillators with a common squeezed reservoir is studied. Under certain conditions the ensemble features genuine multipartite entanglement in the steady state. Several analytic results regarding the bipartite and multipartite entanglement properties of the system are derived. We also discuss a possible experimental implementation which may exhibit steady state genuine multipartite entanglement.