Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment.

Nonprofit organisations and value added (GST) taxation

The subject of this paper is the changes in the taxation of non-profit organisations which seem to be more or less inherent in the value added taxes. The Australian federal Coalition's proposed goods and services tax will be part of the discussion.

"Money pouring out of its ears" : on the taxation of really profitable nonprofit organisations in Australia

Under current law Australia appears to be a tax haven for certain non-governmental institutions. Millions of ordinary business income may go untaxed and the deductibility for donations is unlimited - both are very generous tax measures in an international context. The basic problems of most Australian nonprofit organisations are not taxation; they are just that: nonprofit. Anybody interested in the non-governmental sector should be willing to face the question: What is an equitable tax treatment? The short-term tactic of ducking the question may not be the best or most beneficial long term strategy.

Case study of Queensland state taxation

1. Like the Commonwealth Tax regime, state taxation legislation has now ballooned in size from the good old days when life and tax were relatively simple issues. 2. This case study of Queensland state taxation will examine the following taxes affecting churches and charities in this state: (a) Stamp Duty (b) Land Tax; and (c) Local Authority Rates 3. Each type of tax will be considered in turn. A brief legislative history of the statutory instruments governing these taxes will be given with a closer examination of the present schemes. Relevant judicial pronouncements will be considered and some open discussion of real life examples. 4. It is submitted that the regular donors to our worthy charities and the dedicated weekly churchgoers would have absolutely no idea: (a) that indirectly the value of their donations and weekly offerings are increasingly being eroded by the imposts of Government not only in terms of the amounts of those imposts but the enormous administrative burden of coping with the legislation; (b) of the complexity of the taxation legislation affecting their churches and charities; or (c) that their churches and charities are even paying taxes.

A select and annotated bibliography of nonprofit taxation

It seems likely that the Industry Commission Inquiry on Charitable Organisations will include a reference to examine the state of taxation and charities. There will no doubt be discussions on the taxation benefits enjoyed by charities. These benefits include not only the exemption from being liable for income tax and enjoying the status of being a "deductible body" for the purpose of gifts, but also fringe benefits tax, sales tax, land tax, stamp duty, financial institutions duty, local government rates and charges as well as electricity, gas, telephone and motor vehicle concessions.

Effect on charitable bodies of taxation alternations

It appears that the Industry Commission terms of reference will include a review of (among other things) the appropriateness of the present taxation treatment of charitable organisations. It is uncertain exactly which taxation treatments might be reviewed. However, at a federal government level, a review of the current taxation treatment of charitable organisations could refer to a review of the following taxation measures...

Effects of lime content and amelioration period in double lime application on the strength of lime treated expansive sub-grade soils

The addition of lime into soils has been widely used to stabilize the expansive sub-grade soils when the road pavements are constructed on them. It is common practice to apply a half of the required lime amount and allow a certain time period for lime to react with soils (Amelioration period) before applying the rest of lime and compacting the sub-grade. The optimum amelioration period is essential to minimize the construction delay and to gain the higher strength. In this study, two different expansive soils procured from two different locations in the state of Queensland in Australia were first mixed with different lime contents. A soil mixed with a particular lime content was compacted at different amelioration periods (e.g.: 0, 6, 12, 18, 24 hrs) to obtain soil samples to measure the Unconfined Compressive Strength (UCS). The results suggested that for a given amelioration period, UCS increased with the increase in lime content. The optimum amelioration period could be within 14~17 hours for most of the lime contents in tested soils. This could suggest that the current 24-48 hour amelioration period specified by the Queensland Department of Transport and Main roads could be reduced.

Synthesis and characterisation of layered double hydroxides and their application for water purification

Layered doubly hydroxides (LDHs) also known as hydrotalcites or anionic clays are a group of clay minerals that have shown promise for the removal of toxic anions from water through both anion exchange and a process known as the reformation effect. This project has involved the preparation and characterisation of LDH materials as well as the investigation of their ability to remove selected anions from aqueous solutions by the reformation effect. The LDH materials were successfully prepared from magnesium, aluminium, zinc and chromium chloride salts using the co-precipitation method. Samples were characterised using powder X-ray diffraction (XRD) and thermogravimetry (TG) to confirm the presence of LDHs. Powder XRD revealed a characteristic LDH structure for all LDH samples. Thermal Analysis showed decomposition usual occurred through a three or four step process as expected for LDHs. Preliminary investigations of the removal of sulfate, nitrate and fluoride by an Mg/Al LDH were carried out, and the products were characterised using XRD and TG which showed that an LDH material similar to the original hydrotalcite was formed after reformation. A Zn/Al LDH was investigated as a potential sorbent material for the removal of iodine and iodide from water. It was found that the LDH was a suitable adsorbent which is able to remove almost all of the iodine present in the test solutions. Again, the products were characterised by XRD, TG and evolved gas mass spectrometry (EGMS) in an attempt to better understand the iodine removal process. Powder XRD showed successful reformation of the LDH structure and TG/EGMS showed that only a small amount of iodine species were lost during thermal decomposition. Finally, the mineral stichtite a Mg/Cr LDH was successfully synthesised and investigated using XRD, TG and EGMS. Unfortunately, due to lack of time it was not possible to identify any new uses for the mineral stichtite in the current project.

The inherent international tax regime and its constraints on Australia's sovereignty

Neither an international tax, nor an international taxing body exists. Rather, there are domestic taxing rules adopted by jurisdictions which, coupled with double tax treaties, apply to cross-border transactions and international taxation issues. International bodies such as the OECD and UN, which provide guidance on tax issues, often steer and supplement these domestic adoptions but have no binding international taxing powers. These pragmatic realities, together with the specific use of the word ‘regime’ within the tax community, lead many to argue that an international tax regime does not exist. However, an international tax regime should be defined no differently to any other area of international law and when we step outside the confines of tax law to consider the definition of a ‘regime’ within international relations it is possible to demonstrate that such a regime is very real. The first part of this article, by defining an international tax regime in a broader and more traditional context, also outlining both the tax policy and principles which frame that regime, reveals its existence. Once it is accepted that an international tax regime exists, it is possible to consider its adoption by jurisdictions and subsequent constraints it places on them. Using the proposed changes to transfer pricing laws as the impetus for assessing Australia’s adoption of the international tax regime, the constraints on sovereignty are assessed through a taxonomy of the level adoption. This reveals the subsequent constraints which flow from the broad acceptance of an international tax regime through to the specific adoption of technical detail. By undertaking this analysis, the second part of this article demonstrates that Australia has inherently adopted an international tax regime, with a move towards explicit adoption and a clear embedding of its principles within the domestic tax legislation.

Exo1 plays a major role in DNA end resection in humans and influences double-strand break repair and damage signaling decisions

The resection of DNA double-strand breaks (DSBs) to generate ssDNA tails is a pivotal event in the cellular response to these breaks. In the two-step model of resection, primarily elucidated in yeast, initial resection by Mre11-CtIP is followed by extensive resection by two distinct pathways involving Exo1 or BLM/WRN-Dna2. However, resection pathways and their exact contributions in humans in vivo are not as clearly worked out as in yeast. Here, we examined the contribution of Exo1 to DNA end resection in humans in vivo in response to ionizing radiation (IR) and its relationship with other resection pathways (Mre11-CtIP or BLM/WRN). We find that Exo1 plays a predominant role in resection in human cells along with an alternate pathway dependent on WRN. While Mre11 and CtIP stimulate resection in human cells, they are not absolutely required for this process and Exo1 can function in resection even in the absence of Mre11-CtIP. Interestingly, the recruitment of Exo1 to DNA breaks appears to be inhibited by the NHEJ protein Ku80, and the higher level of resection that occurs upon siRNA-mediated depletion of Ku80 is dependent on Exo1. In addition, Exo1 may be regulated by 53BP1 and Brca1, and the restoration of resection in BRCA1-deficient cells upon depletion of 53BP1 is dependent on Exo1. Finally, we find that Exo1-mediated resection facilitates a transition from ATM- to ATR-mediated cell cycle checkpoint signaling. Our results identify Exo1 as a key mediator of DNA end resection and DSB repair and damage signaling decisions in human cells.

Double blind : women as creative practice-led researchers

While the productive relationship between praxis and feminist research has been well established, the situation is more complicated for female artist/researchers in the fraught field of creative practice-led research. Firstly, their research is being conducted in the context of ongoing debate, as Andrea Phillips has summarized, over whether practice-led research has been embraced in order to potentially produce emancipatory knowledge, or whether it is simply the rationalization and quantification of creative processes. Secondly, there is a pervasive paradox whereby, rather than feeling empowered by the process of critical and reflective self-analysis, many women are inhibited by enduring insecurities about the value of their work and/or their ownership of it. The reasons for this appear to be twofold: they are disheartened by the ongoing disproportion of successful women artists, and they are intimidated by the fundamentally masculine discourse surrounding research in the university. Many of these anxieties appear to have been exacerbated by the research quality assessment process, the Excellence in Research for Australia Initiative (ERA). This collaborative paper draws on the authors' experiences as both artist-researchers and educators to contextualize this paradox and also discuss what forms of praxis intervention may be useful in the preparation for, and supervision of, creative practice-led research by women.

Layered double hydroxides as iodine sorbents

This study investigates the potential of a Zn/Al layered double hydroxides (LHDs) as an adsorbent for the removal of iodine species from potable water (Theiss et al., 2011b). In this paper the resultant materials were characterised using powder x-ray diffraction (XRD) and thermogravimetry (TG) coupled with evolved gas mass spectrometry (EGMS) (Frost, et al, 2005, Rives, et al, 2001).

Thermogravimetric analysis of selected layered double hydroxides

Thermogravimetric analysis (TG) and powder X-ray diffraction (PXRD) were used to study some selected Mg/Al and Zn/Al layered double hydroxides (LDHs) prepared by co-precipitation. A Mg/Al hydrotalcite was investigated before and after reformation in fluoride and nitrate solutions. Little change in the TG or PXRD patterns was observed. It was proposed that successful intercalation of nitrate anions has occurred. However, the absence of any change in the d(003) interlayer spacing suggests that fluoride anions were not intercalated between the LDH layers. Any fluoride anions that were removed from solution are most likely adsorbed onto the outer surfaces of the hydrotalcite. As fluoride removal was not quantified it is not possible to confirm that this has happened without further experimentation. Carbonate is probably intercalated into the interlayer of these hydrotalcites, as well as fluoride or nitrate. The carbonate most likely originates from either incomplete decarbonation during thermal activation or adsorption from the atmosphere or dissolved in the deionised water. Small and large scale co-precipitation syntheses of a Zn/Al LDH were also investigated to determine if there was any change in the product. While the small scale experiment produced a good quality LDH of reasonable purity; the large scale synthesis resulted in several additional phases. Imprecise measurement and difficulty in handling the large quantities of reagents appeared to be sufficient to alter the reaction conditions causing a mixture of phases to be formed.