Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

Family coping: issues and challenges for cancer nursing

A large body of research now exists suggesting that families are dramatically affected by a diagnosis of cancer, and that they have a wide range of support needs. In particular, evidence suggests that the emotional strains of living with a family member who has cancer are an especially difficult coping challenge, and that such strains have a significant impact on the day-to-day lives of family members. Despite this evidence, there has been little analysis to date on the nature of the families' experience with cancer and what implications the unique features of family relationships and interactions in the context of cancer have for nursing practice. Some of these specific features of the families' experience with cancer are examined in this article. It is suggested that enormous scope exists for improving nurses' contribution to care for families of people with cancer. Specific recommendations for achieving such improvements include a critical review of the constraints that exist on efforts to care for families, and the development of approaches to care that appreciate the interconnectedness of family responses and the considerable needs of family members for emotional and practical support.

Contributing factors to optimal project portfolio selection

A modified Delphi approach has been applied in this study to investigate best practice and to determine the factors that contribute to optimal selection of projects. There are various standards and practices that some may recognise as representing best practice in this area. Many of these have similar characteristics and this study has found no single best practice. The study identified the factors that contribute to the optimal selection of projects as: culture, process, knowledge of the business, knowledge of the work, education, experience, governance, risk awareness, selection of players, preconceptions, and time pressures. All these factors were found to be significant; to be appropriate to public sector organisations, private sector organisations and government owned corporations; and to have a strong linkage to research on strategic decision making. These factors can be consolidated into two underlying factors of organisation culture and leadership.

A family of Alltop functions that are EA-inequivalent to the cubic function

Sequences with optimal correlation properties are much sought after for applications in communication systems. In 1980, Alltop (\emph{IEEE Trans. Inf. Theory} 26(3):350-354, 1980) described a set of sequences based on a cubic function and showed that these sequences were optimal with respect to the known bounds on auto and crosscorrelation. Subsequently these sequences were used to construct mutually unbiased bases (MUBs), a structure of importance in quantum information theory. The key feature of this cubic function is that its difference function is a planar function. Functions with planar difference functions have been called \emph{Alltop functions}. This paper provides a new family of Alltop functions and establishes the use of Alltop functions for construction of sequence sets and MUBs.

A phylogenetic analysis and taxonomic revision of the oribatid mite family Malaconothridae (Acari: Oribatida), with new species of Tyrphonothrus and Malaconothrus from Australia

Hitherto, the Malaconothridae contained Malaconothrus Berlese, 1904 and Trimalaconothrus Berlese, 1916, defined by the possession of one pre-tarsal claw (monodactyly) or by three claws (tridactyly) respectively. However, monodactyly is a convergent apomorphy within the Oribatida and an unreliable character for a classification. Therefore we undertook a phylogenetic analysis of 102 species as the basis for a taxonomic review of the Malaconothridae. We identified two major clades, equivalent to the genera Tyrphonothrus Knülle, 1957 and Malaconothrus. These genera are redefined. Trimala-conothrus becomes the junior subjective synonym of Malaconothrus. Some 42 species of Trimalaconothrus are recom-bined to Malaconothrus and 15 species to Tyrphonothrus. Homonyms created by the recombinations are rectified. The replacement name M. hammerae nom. nov. is proposed for M. angulatus Hammer, 1958, the junior homonym of M. an-gulatus (Willmann, 1931) and the replacement name M. luxtoni nom. nov. is proposed for M. scutatus Luxton, 1987, the junior homonym of M. scutatus Mihelč ič, 1959. Trimalaconothrus iteratus Subías, 2004 is an unnecessary replacement name and is a junior objective synonym of Malaconothrus longirostrum (Hammer 1966). Malaconothrus praeoccupatus Subías, 2004 is a junior objective synonym of M. machadoi Balogh & Mahunka, 1969. Malaconothrus obsessus (Subías, 2004), an unnecessary replacement name for Trimalaconothrus albulus Hammer 1966 sensu Tseng 1982, becomes an available name for what is in fact a previously-undescribed species of Malaconothrus. We describe four new species of Tyrphonothrus: T. gnammaensis sp. nov. from Western Australia, T. gringai sp. nov. and T. maritimus sp. nov. from New South Wales, and T. taylori sp. nov. from Queensland. We describe six new species of Malaconothrus: M. beecroftensis sp. nov., M. darwini sp. nov. M. gundungurra sp. nov. and M. knuellei sp. nov. from New South Wales, M. jowettae sp. nov. from Norfolk Island, and M. talaitae sp. nov. from Victoria.

Genetic response to combined family selection for improved mean harvest weight in giant freshwater prawn (Macrobrachium rosenbergii) in Vietnam

We estimated genetic changes in body and carcass weight traits in a giant freshwater prawn (GFP) (Macrobrachium rosenbergii) population selected for increased body weight at harvest in Vietnam. The data set consisted of 18,387 individual body and 1730 carcass weight records, as well as full pedigree information collected over four generations. Average selection response (per generation) in body weight at harvest (transformed to square root) estimated as the difference between the Selection line and the Control group was 7.4% calculated from least squares mean (LSMs), 7.0% from estimated breeding values (EBVs) and 4.4% calculated from EBVs between two consecutive generations. Favorable correlated selection responses (estimated from LSMs) were found for other body traits including: total length, cephalothorax length, abdominal length, cephalothorax width, and abdominal width (12.1%, 14.5%, 10.4%, 15.5% and 13.3% over three selection generations, respectively). Data in the second generation of selection showed positive correlated responses for carcass weight traits including: abdominal weight, exoskeleton-off weight, and telson-off weight of 8.8%, 8.6% and 8.8%, respectively. We conclude that body weight at harvest responded well to the application of combined (between and within) family selection and correlated responses in carcass weight traits were favorable.

Role salience and support as moderators of demand/conflict relationships in China

This study examined the effects of role demand on both work–family conflict and family–work conflict, and the moderating effects of role salience and support on these relationships. Based on 391 dual-career (managerial and blue-collar employees) couples from a Taiwanese company in China, the results of this survey study showed clear gender differences in the patterns of relationships observed. For men, the most important demands that negatively impacted on work–family conflict were frequency of overtime and frequency of socializing for work purposes (yingchou), and supervisory support buffered the negative impact of frequent overtime. For women however, strong supervisory support and low work role salience were more important for reducing work–family conflict, and there was no significant main effect found for any of the role demand factors. Furthermore, women with high work role salience were more likely to feel the impact of yingchou on work–family conflict. In the family domain, the most influential demand for men was hours spent on household tasks, but for women, it was the frequency of family-related leave. Interestingly, males reported higher family role salience than females and spouse support intensified rather than buffered the positive impact of hours spent on household tasks on family–work conflict for males.

Development and validation of an instrument to measure organizational cultures' support of business process management

The purpose of Business Process Management (BPM) is to increase the efficiency and effectiveness of organizational processes through improvement and innovation. Despite a common understanding that culture is an important element in these efforts, there is a dearth of theoretical and empirical research on culture as a facilitator of successful BPM. We develop the BPM culture construct and propose a validated instrument with which to measure organizational cultures’ support of BPM. The operationalization of the BPM culture concept provides a theoretical foundation for future research and a tool to assist organizations in developing a cultural environment that supports successful BPM.

I’m friends with Louie the Fly, not Mortein : Conceptualising the new brand relationships on social media

Spokes-characters are ‘...animated beings or objects, created to promote a product, service or idea’ (Phillips 1996, p.155). They were first used in the late 1800s when they emerged as registered trademarks, but the use of spokes-characters for marketing communications has since grown, owing to their ability to remind consumers about a product, transfer positive associations to a brand, and give a corporate company a more ‘personal’ face (Callcott and Lee 1995). One example is the Michelin Man, who has served as spokes-character for Michelin tyres since 1898, after starting out in print advertising. Spokes-characters have become important brand representatives, no longer seen as simply entertaining cartoons featured in television and magazine advertisements. Corporations have now extended their use to interactive, social media platforms, where a consumer can be ‘friends’ with a spokes-character via Facebook, read their comments on the latest iPhone release through Twitter, and watch their family histories being documented on YouTube (see Figure 1). The interactions that consumers once had with two-dimensional spokes-characters have undergone significant transformation in the digital space. With spokes-character Facebook pages achieving significant numbers of ‘likes’ and interactions with consumers, one question concerns whether this strategy is creating characters that are more engaging than the brands they represent, and what impact this has on brand outcomes.

Capping them off! Exploring and explaining the patterns in undergraduate capstone subjects in Australian business schools

Universities are increasingly offering capstone subjects as part of curricula to prepare final year undergraduates for employment through consolidating and integrating their knowledge and skills while bridging the gap between academic learning and professional work. This study investigates capstone subjects offered by Australian business schools, drawing on national survey data collected in 2010-2011, complemented by interviews with associate deans teaching and learning instrumental in course and curricula design. Findings indicate the sector-wide use of capstone subjects in business disciplines, diversity in the patterns of offerings, and instances where subjects labelled as capstones do not meet the definition of capstones. We argue that these features are explained by a range of historic and strategic factors, such as the ad hoc development of subjects and a lack of understanding of the features of capstones. The findings of this paper inform the debate on the design, development, value and use of capstone subjects identifying the implications for staff development and knowledge management in higher education.

Culture in global business transformation projects : the discovery of a grounded theory

Presently organisations engage in what is termed as Global Business Transformation Projects [GBTPs], for consolidating, innovating, transforming and restructuring their processes and business strategies while undergoing fundamental change. Culture plays an important role in global business transformation projects as these involve people of different cultural backgrounds and span across countries, industries and disciplinary boundaries. Nevertheless, there is scant empirical research on how culture is conceptualised beyond national and organisational cultures but also on how culture is to be taken into account and dealt with within global business transformation projects. This research is situated in a business context and discovers a theory that aids in describing and dealing with culture. It draws on the lived experiences of thirty-two senior management practitioners, reporting on more than sixty-one global business transformation projects in which they were actively involved. The research method used is a qualitative and interpretive one and applies a grounded theory approach, with rich data generated through interviews. In addition, vignettes were developed to illustrate the derived theoretical models. The findings from this study contribute to knowledge in multiple ways. First, it provides a holistic account of global business transformation projects that describe the construct of culture by the elements of culture types, cultural differences and cultural diversity. A typology of culture types has been developed which enlarges the view of culture beyond national and organisational culture including an industry culture, professional service firm culture and 'theme' culture. The amalgamation of the culture types instantiated in a global business transformation project compromises its project culture. Second, the empirically grounded process for managing culture in global business transformation projects integrates the stages of recognition, understanding and management as well as the enablement providing a roadmap for dealing with culture in global business transformation projects. Third, this study identified contextual variables to global business transformation projects, which provide the means of describing the environment global business transformation projects are situated, influence the construct of culture and inform the process for managing culture. Fourth, the contribution to the research method is the positioning of interview research as a strategy for data generation and the detailed documentation applying grounded theory to discover theory.

ACE research vignette 025 : Is business planning important for entrepreneurial success?

This series of research vignettes is aimed at sharing current and interesting research findings from our team of international Entrepreneurship researchers. This vignette, written by Professor Per Davidsson, takes a closer look at the value of business planning.

On effective accounting information systems in a dynamic business environment : the role of complementing capabilities

The global business environment is witnessing tough times, and this situation has significant implications on how organizations manage their processes and resources. Accounting information system (AIS) plays a critical role in this situation to ensure appropriate processing of financial transactions and availability to relevant information for decision-making. We suggest the need for a dynamic AIS environment for today’s turbulent business environment. This environment is possible with a dynamic AIS, complementary business intelligence systems, and technical human capability. Data collected through a field survey suggests that the dynamic AIS environment contributes to an organization’s accounting functions of processing transactions, providing information for decision making, and ensuring an appropriate control environment. These accounting processes contribute to the firm-level performance of the organization. From these outcomes, one can infer that a dynamic AIS environment contributes to organizational performance in today’s challenging business environment.