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.

Progressive adult antimetropia

Antimetropia, a sub-classification of anisometropia, is a rare refractive condition in which one eye is myopic and the fellow eye is hyperopic. This case report describes the ocular characteristics and atypical refractive progression in an adult male with a moderate degree of non-amblyopic antimetropia over a 20-year period. The potential mechanisms underlying unilateral axial elongation, anisometropia and myopia progression in adulthood are discussed.

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

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.

The Role of the G20 in Taxation Regulation

This chapter explores the status of the current programs designed to address global tax avoidance, critiques the role that the G20 plays in the reform agenda, and considers the part that Australia will play in the process.

Progressive dysgraphia in a case of posterior cortical atrophy

Dysgraphia (agraphia) is a common feature of posterior cortical atrophy (PCA). However, detailed analyses of these spelling and writing impairments are infrequently conducted. LM is a 59-year-old woman with dysgraphia associated with PCA. She presented with a two-year history of decline in her writing and dressmaking skills. A 3D T1-weighted MRI scan confirmed selective bi-parietal atrophy, with relative sparing of the hippocampi and other cortical regions. Analyses of LM's preserved and impaired spelling abilities indicated mild physical letter distortions and a significant spelling deficit characterised by letter substitutions, insertions, omissions, and transpositions that was systematically sensitive to word length while insensitive to real word versus nonword category, word frequency, regularity, imagery, grammatical class and ambiguity. Our findings suggest a primary graphemic buffer disorder underlies LM's spelling errors, possibly originating from disruption to the operation of a fronto-parietal network implicated in verbal working memory.

Principles of taxation law 2015 [8th 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

The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

Unitary Taxation of the Finance Sector

Multinational financial institutions (MNFIs) play a significant role in financing the activities of their clients in developing nations. Consistent with the ‘follow-the-customer’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. However, not only are MNFIs persistent users of tax havens, but also, more than other industries, have the opportunity to reduce tax through transfer pricing measures. This paper establishes a case for an industry-specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. In doing so, it considers the practicalities of implementing this by examining both definitional issues and possible formulas for MNFIs. This paper argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined, as well as the factors that should be included in an allocation formula, and the appropriate weighting. This paper concludes that unitary taxation with formulary apportionment is a viable industry-specific alternative for MNFIs.

Quantifying progressive anterior overgrowth in the thoracic vertebrae of adolescent idiopathic scoliosis patients

Study design Anterior and posterior vertebral body heights were measured from sequential MRI scans of adolescent idiopathic scoliosis (AIS) patients and healthy controls. Objective To measure changes in vertebral body height over time during scoliosis progression to assess how vertebral body height discrepancies change during growth. Summary of background data Relative anterior overgrowth has been proposed as a potential driver for AIS initiation and progression. This theory proposes that the anterior column grows faster, and the posterior column slower, in AIS patients when compared to healthy controls. There is disagreement in the literature as to whether the anterior vertebral body heights are proportionally greater than posterior vertebral body heights in AIS patients when compared to healthy controls. To some extent, these discrepancies may be attributed to methodological differences. Methods MRI scans of the major curve of 21 AIS patients (mean age 12.5 ± 1.4 years, mean Cobb 32.2 ± 12.8º) and between T4 and T12 of 21 healthy adolescents (mean age 12.1 ± 0.5 years) were captured for this study. Of the 21 AIS patients, 14 had a second scan on average 10.8 ± 4.7 months after the first. Anterior and posterior vertebral body heights were measured from the true sagittal plane of each vertebra such that anterior overgrowth could be quantified. Results The difference between anterior and posterior vertebral body height in healthy, non-scoliotic children was significantly greater than in AIS patients with mild to moderate scoliosis. However there was no significant relationship between the overall anterior-posterior vertebral body height difference in AIS and either severity of the curve or its progression over time. Conclusions Whilst AIS patients have a proportionally longer anterior column than non-scoliotic controls, the degree of anterior overgrowth was not related to the rate of progression or the severity of the scoliotic curve.

How to design educational settings to promote collaborative inquiry: Pedagogical infrastructures for technology-enhanced progressive inquiry

Strategies of scientific, question-driven inquiry are stated to be important cultural practices that should be educated in schools and universities. The present study focuses on investigating multiple efforts to implement a model of Progressive Inquiry and related Web-based tools in primary, secondary and university level education, to develop guidelines for educators in promoting students collaborative inquiry practices with technology. The research consists of four studies. In Study I, the aims were to investigate how a human tutor contributed to the university students collaborative inquiry process through virtual forums, and how the influence of the tutoring activities is demonstrated in the students inquiry discourse. Study II examined an effort to implement technology-enhanced progressive inquiry as a distance working project in a middle school context. Study III examined multiple teachers' methods of organizing progressive inquiry projects in primary and secondary classrooms through a generic analysis framework. In Study IV, a design-based research effort consisting of four consecutive university courses, applying progressive inquiry pedagogy, was retrospectively re-analyzed in order to develop the generic design framework. The results indicate that appropriate teacher support for students collaborative inquiry efforts appears to include interplay between spontaneity and structure. Careful consideration should be given to content mastery, critical working strategies or essential knowledge practices that the inquiry approach is intended to promote. In particular, those elements in students activities should be structured and directed, which are central to the aim of Progressive Inquiry, but which the students do not recognize or demonstrate spontaneously, and which are usually not taken into account in existing pedagogical methods or educational conventions. Such elements are, e.g., productive co-construction activities; sustained engagement in improving produced ideas and explanations; critical reflection of the adopted inquiry practices, and sophisticated use of modern technology for knowledge work. Concerning the scaling-up of inquiry pedagogy, it was concluded that one individual teacher can also apply the principles of Progressive Inquiry in his or her own teaching in many innovative ways, even under various institutional constraints. The developed Pedagogical Infrastructure Framework enabled recognizing and examining some central features and their interplay in the designs of examined inquiry units. The framework may help to recognize and critically evaluate the invisible learning-cultural conventions in various educational settings and can mediate discussions about how to overcome or change them.

Critical criminological understandings of adult pornography and woman abuse: New progressive directions in research and theory

There is a small, but growing, social scientific literature on the racist and violent nature of contemporary adult pornography. However, considerably more empirical and theoretical work needs to be done to advance a critical criminological understanding of how such hurtful sexual media contribute to various forms of woman abuse in intimate relationships. The main objective of this article is to briefly review the relevant literature and to suggest a few new progressive empirical and theoretical directions.

First convention of the World Union for Progressive Judaism; Herrenhaus, Berlin Organizations

Verso: "In the chair: Claude Montefiore others on the platform Lily Montegu, Israel Mattuck, Leo Baeck"