The taxation of multinational banking income : is the traditional rationale correct?

This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at meeting client global demand. The second distinguishing feature is the non-traditional organisational structure that is adopted. This structure, also designed to meet client global demand, introduces issues previously not recognised in the traditional taxation system, which is designed for the structure of traditional multinational entities. The unique differences between traditional multinational entities and multinational banks means there may be the need for a distinct international tax regime. It is argued that there are “outmoded economic assumptions” upon which the present tax laws relating to multinational banks are based. An examination of the unique nature of multinational banks leads to the conclusion that the appropriate tax treatment of these banks is different from the appropriate tax treatment of multinational entities generally.

Conceptualising tax expenditures : commentary

The tax expenditures concept has been part of the Australian tax review system since 1973. In view of the fact that tax expenditures are considered part of the tax-transfer system, and that paragraph 9 of the terms of reference for the Review Panel requires a consideration of all relevant tax expenditures, we can be confident that they will be considered once again in the final report of Australia’s Future Tax System Review Panel. However, an examination of previous Government and Parliamentary reviews suggests that few of the resulting recommendations are adopted. Previous recommendations have resulted in the acknowledgement of and concern over tax expenditures, but have led to only one significant advancement: the publication of an annual tax expenditures statement. It is apparent that Brooks in his paper aims to ensure, and makes a compelling case for, the significance and central role tax expenditures should play in the Review Panel deliberations. In doing so, Brooks explores the concept itself as well as the conceptual implications impacting on the more pragmatic aspects of tax expenditure analysis. At the outset, Brooks explains why tax expenditures cannot be evaluated using traditional criteria of equity, neutrality, and simplicity, but rather can only be understood and evaluated using budgetary criteria.

Tax expenditures in Australia : the elevation from ‘disguised’ expenditures to architectural pillars of the 21st century

The current Australian Treasury approach to tax expenditures management and reporting is a culmination of 36 years of Government and Parliamentary reviews and reports. The most notable outcome of these reviews and reports is the publication of the annual tax expenditures statement, which commenced in 1986. Since its inception, the Australian annual tax expenditures statements have themselves been the subject of review. Most recently, the Australian National Audit Office has undertaken a performance audit in the Department of the Treasury and released its report entitled Preparation of the Tax Expenditures Statement. In addition to this 2008 report, a second recent opportunity to consider tax expenditures within the Australian tax regime has arisen. The Australian tax system is currently undergoing a comprehensive and broad review with the terms of reference requiring a consideration of all relevant tax expenditures. While the recommendations of the Australian National Audit Office are not novel, and it is not unusual for a broader review to consider the role of tax expenditures within the Australian tax system, both the recommendations of the Australian National Audit Office and the views of the current Review Panel take on a renewed sense of importance given the proliferation of tax expenditures in Australia. Tax expenditures, in terms of number and pecuniary value, have increased significantly in Australia in recent years. The latest Tax Expenditures Statement lists around 320 tax expenditures with the pecuniary value of those expenditures estimated at $73.69 billion or 7.1% of GDP. The largest category of tax expenditures listed in the 2008 Tax Expenditures Statement, totalling $29.23 billion, relate to concessions aimed at retirement savings.

Then I let you

In this video, a male voice recites a teenage love poem. Words flash on screen in time with the spoken words. Sometimes the two sets of words match, and sometimes they differ. This work examines processes of signification. It emphasizes disruption and disconnection as fundamental and generative operations in making meaning. Extending on post-structural and deconstructionist ideas, this work questions the relationship between written and spoken words. By actively disrupting the sincerity of a teenage love poem, it questions the sites and mechanisms of comprehension, poetry and signification.

Embracing Sharia-Compliant products through regulatory amendment to achieve parity of treatment

This article recognises the potential importance of Islamic finance products in Australia, along with the current regulatory impediments preventing Australia from becoming a leader in the Asia-Pacific Islamic finance market. Taking into account the potential importance of, and impediments to, Islamic finance, this article highlights, through the historical development and contemporary state of Islamic finance, its economic, social and political benefits to Australia. Once a case for embracing Islamic finance is made, the main current regulatory impediments to Australia becoming a key player in the Islamic finance market within the Asia-Pacific region are highlighted. This article then argues that, rather than requiring any separate regulatory regime, the current regulatory impediments may be overcome through amendments to existing laws to ensure parity of treatment in Australia between the Islamic finance market and the conventional finance market. The Australian income tax regime is utilised as a case study demonstrate how parity of treatment could be achieved via amendment by taking two frequent and separate Islamic finance transactions. This article concludes that the economic, social and political benefits potentially warrant Australia embracing Islamic finance and that, with the right regulatory measures, Australia could lay the foundation to become a leader in the Asia-Pacific Islamic finance market.

Discovering novel knowledge using granule mining

This paper presents an extended granule mining based methodology, to effectively describe the relationships between granules not only by traditional support and confidence, but by diversity and condition diversity as well. Diversity measures how diverse of a granule associated with the other granules, it provides a kind of novel knowledge in databases. We also provide an algorithm to implement the proposed methodology. The experiments conducted to characterize a real network traffic data collection show that the proposed concepts and algorithm are promising.

Good Practice Report : Curriculum Renewal

This good practice report, commissioned by the ALTC, provides a summative evaluation of useful outcomes and good practices from ALTC projects and fellowships on curriculum renewal. The report contains: -a summative evaluation of the good practices and key outcomes for teaching and learning from completed ALTC projects and fellowships -a literature review of the good practices and key outcomes for teaching and learning from national and international research -the proposed outcomes and resources for teaching and learning which will be produced by current incomplete ALTC projects and fellowships -identifies areas in which further work or development are appropriate.

Leveraging value within IT-backed collaborative alliances

Organizations today make radical use of the IT resources to sustain or better their existing competitive position. One such initiative is forming alliances on a shared IT backbone with partners of their value chain. We term these alliances the collaborative organizational structures (COS). Regardless of the nature of engagement with IT resources, organizations will require unique competencies to obtain performance-differentiating value from these IT resources. In a collaborative environment, these competencies would be a result of the synergy between the alliances’ unique competences. We call these the inter-firm IT-related capabilities. The resource centric theoretical frameworks suggest a trajectory of competence development and the structure of inter-firm competencies, but does not inform on the nature of these competencies. We employ an interpretive design to suggest three inter-firm IT-related capabilities for IT-backed collaborative alliances. We discuss these capabilities in this research and suggest that their effectiveness be measured directly against the collaborative rent, and indirectly against the firm-level performance of the alliance partners. This forms a model of leveraging and evaluating value within IT-backed collaborative alliances.

Towards an effective IT governance structure for organizations in developing economies

The pervasive use of IT is prominent amongst organizations in developing economies. However, there is growing evidence that these economies fail to capitalize on their IT investment to transform their organizations to be competitive both locally and globally. IT-related benefits are possible with appropriate governance of the IT-related resources, and we need to broaden our understanding on the IT governance mechanics suitable for organizations in the developing economies. In this study, we adopted an initial interpretive design to obtain a deeper understanding of the IT governance (ITG) environment and conceptions of the stakeholders on effective IT governance structures for the developing economies. We found that the presence of an IT Strategic Planning Committee, Multiple level of authority, and a Forum for informal discussions as the crucial components of an ITG structure in developing economies.

Providing a law degree for the real world : perspective of an Australian law school

As a result of a two year curriculum review, QUT’s undergraduate law degree has a focus on first year student transition, integration of law graduate capabilities throughout the degree and work integrated learning. A ‘whole-degree’ approach was adopted to ensure that capabilities were appropriately embedded and scaffolded throughout the degree, that teaching and learning approaches met the needs of students as they transitioned from first year through to final year, and that students in final year were provided with a capstone experience to assist them with transition into the work place. The revised degree commenced implementation in 2009. This paper focuses on the ‘real world’ approach to the degree achieved through the first year program, embedding and scaffolding law graduate capabilities through authentic and valid assessment and work integrated learning to assist graduates with transition into the workplace.

Assessing for work integrated learning experiences : a pre-service teacher perspective

A critical aspect of the debate about work integrated learning in the university context is the blurring of boundaries and responsibilities in terms of student learning. In an Australian pre-service teacher education program this blurring of boundaries is apparent in stakeholder tensions about the nature and role of assessment during the practicum. In the study reported in this paper, students responded positively to the content of assessment tasks but maintained that their efforts to implement the associated planning in the workplace were stymied because of disparate understandings between university and school staff about the purpose of the task.

The Roloffs

Short story published in REX: A Journal of New Writing.

Final call

Travel writing published by Swamp : A Journal of Post-graduate Creative Writing.

Shades of grey

Poem published in Islet