The church of the first three centuries: or, Notices of the lives and opinions of the early fathers, with special reference to the doctrine of the Trinity;

Bibliographical footnotes.

Antígona: nome de código: a peça em um ato de Mário Sacramento

Sob a influência da Antígona sofocliana, Mário de Sacramento escreveu uma peça homónima publicada, isoladamente, em 1959, no vol. XIX, nº 186 da “Revista Vértice”, e incluída, no ano seguinte, na tetralogia intitulada Teatro Anatómico. Nesta peça em um ato, a tragédia homónima de Sófocles configura-se um recurso metateatral de carácter crítico-reflexivo, em que o diálogo intertextual com o ancestral texto trágico promove uma leitura dramática do destino infortunado dos sobreviventes de uma família francesa, vítima da ocupação alemão, na Segunda Guerra Mundial, que, como os últimos Labdácidas, confrontam o sofrimento de situações-limite, ditadas por conflitos insolúveis da condição humana. Neste «ensaio dramático de Mário de Sacramento, a protagonista é uma mulher francesa, Ivonne, que no tempo do Maquis, escolhe, como nome de código, “Antígona”. Pretende-se, neste estudo, apresentar uma análise da influência exercida pela Antígona sofocliana neste «ensaio dramático», ao nível da caracterização das dramatis personae e do desenvolvimento da ação, que se sustenta numa reflexão crítica sobre as motivações da filha de Édipo e o sentido trágico das suas ações.

12 Notices du Doupeng xianhua 豆棚閒話 (ca. 1668, par Aina jushi 艾衲居士) (12 chapitres, complet)

International audience

O ato de agradecimento nas interações comerciais : contributo para o seu estudo

O presente estudo, no âmbito da Pragmática Linguística, resulta de uma investigação, que observa a realização dos atos ilocutórios expressivos de agradecimento nas interações comerciais. O objetivo é tentar compreender os processos linguísticos subjacentes à realização dos referidos atos ilocutórios, nomeadamente através do recenseamento dos diferentes tipos de agradecimento, da descrição dos atos de fala predominantes e das funções semântico-pragmáticas do agradecimento. Um dos aspetos mais importantes será o recensear dos tipos de agradecimento mais usados nas interações comerciais. Para tal, parte-se da observação detalhada de um corpus recolhido no âmbito específico de interações comerciais que ocorreram entre 10 de fevereiro de 2014 a 30 de setembro de 2014. Os resultados obtidos convergem no sentido de que o agradecimento é um ato expressivo reativo que pode ser verbal ou não verbal, com a finalidade de estabelecer a relação custo-benefício entre locutor e ouvinte, tendo em conta e respeitando os vários contextos socioculturais. De facto, o ato de agradecer, tal como os restantes atos ilocutórios expressivos, depende da forma como é expressado, dos gestos que o acompanham e das emoções que lhe são inerentes.

Planning for smart urban ecosystems : information technology applications for capacity building in environmental decision making

Since the industrial revolution, our world has experienced rapid and unplanned industrialization and urbanization. As a result, we have had to cope with serious environmental challenges. In this context, an explanation of how smart urban ecosystems can emerge, gains a crucial importance. Capacity building and community involvement have always been key issues in achieving sustainable development and enhancing urban ecosystems. By considering these, this paper looks at new approaches to increase public awareness of environmental decision making. This paper will discuss the role of Information and Communication Technologies (ICT), particularly Webbased Geographic Information Systems (Web-based GIS) as spatial decision support systems to aid public participatory environmental decision making. The paper also explores the potential and constraints of these webbased tools for collaborative decision making.

An examination of tax-deductible donations made by individual Australian taxpayers in 2007-08

Each year, The Australian Centre for Philanthropy and Nonprofit Studies (CPNS) at Queensland University of Technology (QUT) collects and analyses statistics on the amount and extent of tax-deductible donations made and claimed by Australians in their individual income tax returns to deductible gift recipients (DGRs). The information presented below is based on the amount and type of tax-deductible donations made and claimed by Australian individual taxpayers to DGRs for the period 1 July 2006 to 30 June 2007. This information has been extracted mainly from the Australian Taxation Office's (ATO) publication Taxation Statistics 2006-07. The 2006-07 report is the latest report that has been made publicly available. It represents information in tax returns for the 2006-07 year processed by the ATO as at 31 October 2008. This study uses information based on published ATO material and represents only the extent of tax-deductible donations made and claimed by Australian taxpayers to DGRs at Item D9 Gifts or Donations in their individual income tax returns for the 2006-07 income year. The data does not include corporate taxpayers. Expenses such as raffles, sponsorships, fundraising purchases (e.g., sweets, tea towels, special events) or volunteering are generally not deductible as „gifts‟. The Giving Australia Report used a more liberal definition of gift to arrive at an estimated total of giving at $11 billion for 2005 (excluding Tsunami giving of $300 million). The $11 billion total comprised $5.7 billion from adult Australians, $2 billion from charity gambling or special events and $3.3 billion from business sources.

The Changing world and service problems in bankruptcy

In an age where financial transactions are conducted worldwide and mobility of citizens throughout the world is common, lawyers seeking to serve Bankruptcy Notices and Creditor’s Petitions encounter many problems. To assist lawyers in overcoming some of the service problems that are arising as a result of this changing world, a number of recent cases are considered that highlight a number of issues, including American Express Australia Limited v Michaels [2010] FMCA 103, Deputy Commissioner of Taxation v Barnes (2008) 70 ATR 776; [2008] FMCA 7, Battenberg v Restom & Ors (2005) 223 ALR 692; upheld by the Full Federal Court in Battenberg v Restrom and Ors (2006) 149 FCR 128 at 133; [2006] FCAFC 20 and Envee Energy Pty Ltd (In Liquidation) v Stockford [2007] FMCA 1426. While the fact situation of every bankruptcy case will differ, recent decisions may assist lawyers in dealing effectively with bankruptcy matters in these times of transition. Lawyers can facilitate completion of the litigious process within the relevant legislative framework in order to satisfy their responsibility to clients and to the Court by considering this case law.

Regulation of train service by coasting control in metro railway system

To maximise the capacity of the rail lineand provide a reliable service for pas-sengers throughout the day, regulation of train service to maintain steady service headway is es-sential. In most current metro systems, train usually starts coasting at a fixed distance from the departed station to achieve service regulation. However, this approach is only effective with re-spect to a nominal operational condition of train schedule but not necessarily the current service demand. Moreover, it is not simply to identify the necessary starting point for coasting under the run time constraints of current service conditions since train movement is attributed by a large number of factors, most of which are non-linear and inter-dependent. This paper presents an ap-plication of classical measures to search for the appropriate coasting point to meet a specified inter-station run time and they can be integrated in the on-board Automatic Train Operation (ATO) system and have the potential for on-line implementation in making a set of coasting command decisions.

Catch me if you can : the effective service of bankruptcy documents in a changing world

This article discusses some recent judicial decisions to assist legal practitioners to overcome some of the problems encountered when serving Bankruptcy Notices and Creditor’s Petitions. Some of the issues covered in the discussion are: What the valid last-known address of the debtor can be, whether a Bankruptcy Notice can be validly served by email on a debtor who is located outside Australia, whether service of a Bankruptcy Notice is valid when the debtor is outside Australia when service on the debtor occurs in Australia, whether the creditor’s failure to obtain leave for service of a Bankruptcy Notice can be excused, what can be done regarding personal service of a Creditor’s Petition when a debtor is outside Australia and whether the Court can set aside a sequestration order. The article goes on to place the issues in the context of broader bankruptcy policies noting that effective service of bankruptcy documents is challenging in a world where mobility of debtors is global and new modes of communication ever changing.

An examination of tax-deductible donations made by individual Australian taxpayers in 2008-09, ACPNS Working Paper 54

Each year, The Australian Centre for Philanthropy and Nonprofit Studies (CPNS) at Queensland University of Technology (QUT) collects and analyses statistics on the amount and extent of tax-deductible donations made and claimed by Australians in their individual income tax returns to deductible gift recipients (DGRs). The information presented below is based on the amount and type of tax-deductible donations made and claimed by Australian individual taxpayers to DGRs for the period 1 July 2008 to 30 June 2009. This information has been extracted mainly from the Australian Taxation Office's (ATO) publication Taxation Statistics 2008-09. The 2008-09 report is the latest report that has been made publicly available. It represents information in tax returns for the 2008-09 year processed by the ATO as at 31 October 2010.

Charity law, advocacy and the aid/watch decision : compatibility of charitable purposes and political objects — the view from Australia

Introduction In 1952 the Nathan report stated that: Some of the most valuable activities of voluntary societies consist, however, in the fact that they may be able to stand aside from and criticize State action or inaction, in the interests of the inarticulate man in the street. Some 60 years later it remained the case that if a voluntary society wanted to gain or retain charitable status then, contrary to the Nathan report, the one thing it could not do was set itself up with the purpose of criticizing State action or inaction. This legal position was adopted by the authorities in Australia with the Australian Taxation Office (ATO) noting in Taxation Ruling TR2005/21: 102. An institution or fund is not charitable if its purpose is advocating a political party or cause, attempting to change the law or government policy, or propagating or promoting a particular point of view. So, why, if it is such a valuable activity, have governments steadfastly refused to allow charities to have as their purpose the freedom to advocate in this way and how has this situation been affected by the recent High Court of Australia decision in Aid/Watch v Commissioner of Taxation? This article proposes to address such questions. Beginning with some background history, it explains that, initially, the current constraints did not apply. Then it looks at the nature of these constraints: how does the law define what constitutes the type of political activity that a charity must not undertake? What is the rationale for prohibition? How has the judiciary contributed to the development of the law in this area in recent years? This will lead into a consideration of the Aid/Watch case and the implications arising from the recent final decision. The article concludes by reflecting on what has changed and why the view on this contentious matter now looks different from Australia.

Advance pricing arrangements : an Australian Tax Office success or a legislative failure?

Australia’s domestic income tax legislation and double tax agreements contain transfer pricing rules which are designed to counter the underpayment of tax by businesses engaged in international dealings between related parties. The current legislation and agreements require that related party transactions take place at a value which reflects an arm’s length price, that is, a price which would be charged between unrelated parties. For a host of reasons, it is increasingly difficult for multinational entities to demonstrate that they are transferring goods and services at a price which is reflective of the behaviour of independent parties, thereby making it difficult to demonstrate compliance with the relevant legislation. Further, where an Australian business undertakes cross-border related party transactions there is the risk of an audit by the Australian Tax Office (ATO). If a business wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (APA). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. The ATO views the APA process as an important part of its international tax strategy and believes that there are complementary benefits provided to both the taxpayer and the ATO. The ATO promotes the APA process on the basis of creating greater certainty for all parties while reducing compliance costs and the risk of audit and penalty. While the ATO regards the APA system as a success, it may be argued that the implementation of such a system is simply a practical solution to an ongoing problem of an inherent failure in both the legislation and ATO interpretation and application of this legislation to provide certainty to the taxpayer. This paper investigates the use of APAs as a solution to the problem of transfer pricing and considers whether they are the success the ATO claims. It is argued that there is no doubt that APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current transfer pricing regime. It does not, however, provide a long term solution. Rather, the long term solution may be in the form of legislative amendment.

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.

Charity tax exemptions : a stitch in time saves nine

The Industry Commission has recently released a wide ranging draft report on charitable organisations. Part of the Inquiry's terms of reference required the Commission to examine the appropriateness of the taxation treatment of charities. The findings of the draft report when combined with the recommendations of the Federal Parliament's Follow the Yellow Brick Road Report point to a systematic review by the Australian Tax Office (ATO) of its dealings with charitable organisations. Generally prevention rather than cure is the better strategy in taxation issues. This article raises a number of issues charitable organisations might consider as part of their prevention strategy. As the ATO administers all the taxes discussed in this article and as the tests for exemption are similar, charitable organisations should find that "getting it right" for one tax means that their affairs will be in order for most taxes.

A taxing definition — a comment on the industry commission's draft proposals for defining community social welfare organisations

The draft report of the Industry Commission's charitable organisations inquiry introduces a new term for nonprofit organisations delivering human services. The new term is "community social welfare organisation" or "CSWO". The report recommends that tax deductibility of donations be extended such organisations. It then hints at making the definition of CSWO a standard criteria for state taxation exemptions. This paper examines the definition of the new term community social welfare organisation and charts its possible consequences if adopted by the federal government. The promise of tax deductibility status to previously shunned organisations is largely illusory. The Commission's aim of simplification through clarification of the definition is flawed and will not reduce the administration costs for the Australian Tax Office (ATO) or organisations.