Tax Residency Status Period Commencing

Question: Describe about the Tax Residency Status for Period Commencing. Answer: Issue The relevant issue in the case is to opine on the tax residency status of Joan for the period commencing from January 2014 until her return to Australia in July 2016. Further, the implications of the tax residency status on the respective tax obligations also need to be highlighted. Relevant Law The subject of tax residency is dealt with in Section 6(1), ITAA 1936 which narrates the various test for the residency determination of individuals which have been elaborately explained in the tax ruling TR 98/17 (ATO, 1998). The tax residency determination is significant as in accordance with Section 6-5(2), ITAA 1997, for Australian tax residents, income from all sources (irrespective of the fact that it may be generated domestically or from abroad) would be considered for taxable income computation (Barkoczy, 2016). The relevant legislation and relevant ruling suggests that namely four tests may be applicable for tax residency determination as outlined below (Nethercott, Richardson Devos, 2016). Domicile Test Normal Test of Residency 183 day test Superannuation Test The relevant test from the above are discussed above. Domicile Test The domicile test is used for the tax residency determination of Australian residents. The essential conditions that the given taxpayer needs to comply within the given assessment year are highlighted below (Woellner, 2014). The taxpayer must be a holder of Australian domicile in a manner sanctioned under the Domicile Act 1982. Additionally, the permanent abode of the given taxpayer must be located within Australia at the time of assessment. The determination of domicile possession is a straight forward task with no ambiguity, however high subjectivity may be involved with regards to permanent abode location. In this regard, the critical factors to be taken into consideration for location determination are summarised below (ATO, 1991). The difference between the length of actual stay abroad compared to the intended stay duration abroad. The intent on taxpayers part to return to Australia after accomplishment of a defined task. The act of abandoning the residence in Australia. The act of establishing residence in a foreign country The continuity of the stay abroad along with the underlying duration. Further, as indicated by the verdict extended in the F.C. of T. v. Applegate (1979) 9 ATR 899 case, in the event the expected duration of stay is expected to be greater than 2 years, then for the period of stay abroad, the tax authorities tend to consider that the taxpayer has a permanent residence abroad even though there may be intention on taxpayers part to return to Australia at the completion of the obligation (Coleman et. al., 2016). Resides Test or Normal Test of Residency This test is primarily deployed for tax residency determination of foreign residents. This is primarily used for those individuals whose country of origin is not Australia but come to Australia for a variety of reasons. The underlying residency of these individuals is determined by considering the following factors (Barkoczy, 2016). Extent of significance for which taxpayer has come to Australia Extent of ties in various spheres such as professional and personal which taxpayer maintains in Australia Nature of social arrangement that the person has in place when in Australia. The stay duration in Australia and the visit frequency to country of origin during the assessment period. Fact and Application The relevant facts related to the given situation are outlined below. Joan is an Australian resident and works for an Australian company based out of Melbourne as the chief accountant. In January 2014, Joan is entrusted with the task of establishing a factory for the employer in Vietnam for which, she goes to Vietnam with her husband. However her son continued stay in the Melbourne located family home. The couple has intention to return to Australia post the establishment of factory which would take three to four years. Joans husband gets employment in Vietnam and also an apartment is leased for four years. Joan returned to Australia in January 2016 after which she went to a Europe trip for six months before returning to Australia in July, 2016. For the whole period i.e. from January 2014 to July 2016, the Australian domicile of Joan was intact as intention to return in Australia was always intact. Tax residency status FY2014 While the domicile condition is met being an Australian resident, but since Joans expected stay in Vietnam is expected to be longer than 2 years, hence it is fair to expect that there has been a shift in the permanent abode from Australia to Vietnam as apparent from IT 2650. Hence, for FY2014, Joan would be considered a foreign tax resident. Additional proof to this is provided by the fact that both have started socialising in Vietnam indicating the intent to stay in Vietnam for long. Tax residency status FY2015 While the domicile condition is met being an Australian resident, but since Joans expected stay in Vietnam is expected to be longer than 2 years, hence it is fair to expect that there has been a shift in the permanent abode from Australia to Vietnam as apparent from IT 2650. Also, Joans husband has found an employment in Vietnam only. Further, during the year Joan did not visit even once to Australia. Hence, for FY2015, Joan would be considered a foreign tax resident. Tax residency status FY2016 While the intended stay duration was 3 to 4 years, Joan finished her professional obligation earlier and returned in January 2016. Besides, considering the presence of son, job for Australian company and house in Melbourne, significant ties are maintained in Australia. The Europe trip of six months is done with the intent of a casual traveller since Joan keeps moving from one city to the other and hence this purpose is not significant. Thus, in line with the domicile test and the resides test, it would be fair to conclude that Joan for this year would be an Australian tax resident. Income tax implications For the period from January 1, 2014 to June 30, 2015, the employment income is derived from Vietnam and hence would not be taxable in Australia as per Section 6-5(3). However, as per Section 6-5(2), for FY2016, the employment income would be taxable in Australia. References ATO 1991, IT 2650, Australian Taxation Office, Available online from https://www.ato.gov.au/law/view/document?Docid=ITR/IT2650/NAT/ATO/00001 (Accessed on October 4, 2016) ATO 1998, TR 98/17, Australian Taxation Office, Available online from https://www.ato.gov.au/law/view/document?Docid=TXR/TR9817/NAT/ATO/00001 (Accessed on October 4, 2016) Barkoczy,S 2016,Foundation of Taxation Law 2015,8th eds., CCH Publications, North Ryde Coleman C, Hart G, Jogarajan S, Krever R McLaren J, Sadiq K 2016, 9th eds., Principles of Taxation Law, Thompson Reuters, Sydney Nethercott, L, Richardson, G Devos, K 2016, Australian Taxation Study Manual 2016, 4th ed., Oxford University Press, Sydney Woellner, R 2014, Australian taxation law 2014, 8th eds., CCH Australia, North Ryde

Analysis of Jims story of Po little Lizabeth in Huck Finn

Analysis of Jims story of Po little Lizabeth in Huck Finn How the passage conveys a theme:Through vivid imagery, situational irony, and a powerful emotional sequence, Twain gives the reader a memorable scene, one which conveys a powerful theme. Essentially, we see Jim, apparently a loving father, not even knowing his own daughter; he doesn't realize she is deaf and thus sends her "a-sprawlin'" across the room when she doesn't obey his command of shutting the door. It is situational irony; a person supposed to know this little girl the best doesn't at all. More importantly, Twain crafts the scene in a way that makes the reader slow down when he reads it; this is powerful as it allows the reader to focus on the vivid imagery of the scene. We see Jim busting out crying, grabbing his little daughter in his arms, regretting his actions and repenting for his sins. This imagery focuses on a major themeJim, a slave, has feelings too.Anti-Stratfordian Mark Twain, wrote "Is Shakespear...Thus, in Jim's narrative, Huck begins to see that even though he is a slave, Jim has strong familial ties and powerful emotions, and this is possibly a turning point in the novel regarding Huck and Jim's relationship. Twain accomplishes all of this in a simple, yet very emotionally powerful narrative.Message it sends to Twain's reader of 1884:Although slavery had been abolished by 1884, racism still existed. By portraying Jim with feelings (he was extremely sad and regretted slapping his daughter), Twain suggests that African-Americans are completely equal to whites. This is an eye opening passage, and Twain utilizes a sad narrative to show the reader of 1884 that blacks are equal to whitesnot just that they should be by law, but that they really are, and he uses Jim's emotion to show this.Message it creates for...

The eNotes Blog Home, Hearth, and Holidays Writers Homes and HolidayReflections

Home, Hearth, and Holidays Writers Homes and HolidayReflections At Christmas, all roads lead home.†Ã‚  ~ Marjorie Holmes, one of the sixteen founders of  Alpha Kappa Alpha  Sorority, Incorporated, at  Howard University  in Washington, DC. It was the first sorority founded by African American women.   Christmas, of   course, is a time of homecoming.   Here are some reflections of writers and images of their personal homes on this season of family and familiarity: Charles Dickens summer home:  The author wrote part of his novel David Copperfield and the BBC reports he also is believed  to have planned Bleak House there. I have always thought of Christmas time, when it has come round, as a good time; a kind, forgiving, charitable time; the only time I know of, in the long calendar of the year, when men and women seem by one consent to open their shut-up hearts freely, and to think of people below them as if they really were fellow passengers to the grave, and not another race of creatures bound on other journeys. ~ from   A Christmas Carol E.M. Forsters home:   According to  London: City of Words, Forster lodged in this hotel from 1902 to 1904. While here he wrote part of his Italian novels,  Where Angels Fear to Tread  and  A Room With A View, which were published in 1905 and 1908 respectively. I do like Christmas on the whole. In its clumsy way, it does approach Peace and Goodwill. But it is clumsier every year. Washington Irving purchased his   home, Sunnyside, in 1835. It remained in his family until 1945. Christmas is the season for kindling the fire of hospitality in the hall, the genial flame of charity in the heart. Henry Wadsworth  Longfellows home:  Ã‚  Peleg and Elizabeth Wadsworth  raised ten children in the house before retiring to the family farm in Hiram, Maine, in 1807 I heard the bells on Christmas Day Their old, familiar carols play, And wild and sweet The words repeat Of peace on earth, good-will to men! If you havent heard John Gorkas musical interpretation of this poem, give it a listen: E.B. Whites home (Charolettes Web), Brooklin, Maine: To perceive Christmas through its wrapping becomes more difficult with every year. Theodore Geisel (Dr. Seuss) home, built in 1922, La Jolla, California: Maybe Christmas,† he thought, â€Å"doesn’t come from a store. Maybe Christmas†¦ perhaps†¦ means a little bit more.† ~ from  How the Grinch Stole Christmas   Charles Schultzs home: Napa, California Christmas is doing a little something extra for someone.†

London ships of historic interest partnership Essay - 1

London ships of historic interest partnership - Essay Example From the fact that Britain is a maritime country, the income of most of the citizens is derived from maritime activity. The London’s ships partnership has a major obligation of increasing the maritime activity and the number of visitors coming to the country. This has to be done through enacting various strategies and ways. The partnership should make the whole world aware of the existence of the historic ships and the uniqueness in them. This paper will explore how the partnership can increase the global awareness of the uniqueness and existence of the historic ships in London, means and ways to tap into the market and PEST analysis in relation to the same. The paper is to explore the best marketing mix in international and global marketing especially during overseas expansion. The main objective is to identify the most appropriate international market place to target to ensure tourists are aware of the brand and will view the member vessels as must see attractions when they visit London. The subsidiary objectives are as stipulated below: Tourism is a major player in the economy of Britain with tourist coming from both local and international markets. This has boosted the economy of the country and efforts to increase the tourist volume are being put in place each and every day. The London ships of historic interest partnership being a major player has also implemented actions to increase awareness among the residents and foreigners of the tourism facilities available. This has boosted the tourism industry in a major way. International tourists are well informed of existence of the maritime tourism and are well aware of the kind of tourism facilities they are to view and interact with when they pay a visit to the city of London. There are various factors both internal and external that have contributed to the success of the organization in response to marine tourism. The coming

Indian folk dance Essay Example | Topics and Well Written Essays - 750 words

Indian folk dance - Essay Example Folk dances are the essential elements of almost every important event of Indian social life and celebration. Despite their extreme simplicity, all folk dances tend to convey certain messages to the community they belong to with regard to their history or survival. As mentioned in the introduction, one of the important features of all Indian folk dances is their simplicity. Dancers normally wear colorful costumes having creative designs and symbols. They also wear extensive jewels which obviously enhance the performance and overall appeal. Though not classical in nature, Indian folk dances are evidently creative works that comprise certain artistic steps and postures. These steps are usually accompanied by rhythmic composition of some primitive musical instruments. Unlike classical dances, folk dances are cherished by common people to express their joy on different occasions. To be more specific, folk dances maintain a social perspective rather than the mere manifestation of individual emotions. Bhangra: Bhangra is a lively folk dance originated from Punjab and is highly associated with harvest celebrations of the state. Therefore, normally it is performed on April 13, the day of Baishaki. The dance is accompanied by Punjabi Boliyaan lyrics and drum beats. The drummer plays a vital role in enhancing the tempo of dancers’ movements. The costume of Bhangra dancers reflects the typical Punjabi outfit. In addition to the traditional turban on head, they wear colorful waistcoat and ‘ghunghroos’ on ankles; and Bhangra, fondly called ‘Shaan of Punjab’ was introduced to Vancouver during the 1st international Sports and Cultural Festival (Dances of India). Although Bhangra songs have been a major influence on the Indian film industry Bollywood for decades, obviously Bhangra has got mixed with western classical music. As Huq (121) points out, a bhangra/hip hop crossover has been visible in the UK produced rap for the recent years. According to the writer, the bhangra beats and Punjabi lyrics have been a major influence on western world of music since 1980s. In other words, Bhangra has been highly influenced by the various dance periods mainly because of its vulnerability to amalgamate with other cultures and art forms. For instance, as Roy (22) argues, contemporary bhangra fails to reflect its primitive folk origin or other classificatory boundaries. Obviously bhangra has become a popular art despite its Indian origin as a primitive folk dance. Padayani: this is one of the important traditional folk dances said to have promoted by some temples of Southern Kerala in India. The most fascinating feature of this art is the ‘Kolam†™, the huge mask which is the imitation of some divine and semi divine characters including Bhairavi, Kali, Kalan, Yakshi etc. The masks or chest-covers the performers wear are extremely huge so that no one can identify the persons. Although researchers are deeply at odds, the origin of Padayani traces back to several centuries. As reported in The Hindu, some are of the opinion that Padayani originated

Economic Development of East Asia

Economic Development of East Asia The East Asia Miracle: Lessons for the developing countries The East Asia region has been drawing global attention as fruits of its growth and development over the past thirty years continuously awe many. The most successful developing countries over the last half century apparently have come form this region. ­Ã‚  [1]  It has a remarkable record of high and sustained economic growth as 23 economies in it grew faster that those in other parts of the world.  [2]  However, when the Asian Financial Crisis hit this region in 1997 some structural and institutional weaknesses have cast doubt on the East Asian Miracle. Hasty recovery and resiliency which the region revealed in fighting off and prevailing over most of the negative drawbacks brought by the crisis was enough to sustain the belief in the miracle. Although East Asian economies applied varying strategies in their economic development, a salient and strong factor common to all is the presence and the role of the government in their development. East Asian countries have assume d a role of a developmental state in which the government played an important hands-on role in the process of industrialization and economic development.  [3]   Thus, understanding the economic development and experiences of East Asia may offer helpful lessons that other developing countries trapped in stagnation may want to consider. According to Thorbecke and Wan (2004) there are two critical factors and corresponding phases of development that occurred in East Asia. First, countries need to reach first a take-off point which emphasizes on promotion of education, to build up on human capital and the promotion of the agricultural sector in order to eventually finance investments on physical infrastructure. The second phase, development calls for industrialization that brings structural and technological upgrading.  [4]   First lesson implied in the first phase of development is that economic development cannot be hurried. There are certain processes that need to be readied before countries reach the take-off point. At the beginning of the development process a country is predominantly agrarian and the economy is relatively closed.  [5]  East Asian governments understood that the major mechanism for obtaining the resources needed to escape the poverty trap and for industrialization was through and inter-sectoral transfer out of agriculture. The major role of the agricultural sector was to generate the necessary capital to finance the outset of the industrialization process.  [6]  The main lesson to be drawn from the experience was summarized by Thorbecke and Morrison cited in the Revisiting East and (South East) Asias development model (2004): A lesson learned from those countries which were most successful in achieving both growth and equity throughout their development history (e.g. Taiwan and South Korea) is that a continuing gross flow of resources should be provided to agriculture in the form of such elements as irrigation, inputs, research and credit, combined with appropriate institutions and price policies to increase this sectors productivity and potential capacity of contributing an even larger flow to the rest of the economy In addition, the East Asian countries invested heavily on universal education with a long-term goal in mind. They spread of education in the rural areas provided farmers and their children the skills they need to operate in non-farming activities after the take-off.  [7]  They sponsored education of technical skills in the college level. This strategy resulted in a very competitive labor force able to man their industries.  [8]   In the second phase, East Asian economies recognized that the international economy is highly interdependent and that a development process of interdependence is much more favorable than individual growth.  [9]  Interaction among countries lets in trade, investment and technology transfer. East Asian economies took advantage of the positive spill over effects the interactions brought with it. It should be noted however that Thorbecke and Wan perceived of openness as a necessary yet insufficient condition for successful development. Catching up though is impossible without openness.  [10]   In an increasingly interdependent world, competition is much potent. To ensure high economic growth rate major structural changes like industrialization should undertaken. Structural changes needed by less developed countries require acquisition of technology. This is a step familiar to East Asian economies. They took advantage of the technology and knowledge transfer by making their countries attractive to foreign direct investments; they became subcontractors of high-tech firms and studied how they can localize the ideas and eventually create their own. Case in point is Taiwan which invested in industrial parks and attracted many foreign firms.  [11]  They acquired technology and idea transfer from joint ventures and foreign direct investments. Policies also played a great role in the development of East Asian economies. Although there are certain differences in the initial conditions for development and growth, economic development and growth pattern that East Asian economies that are common to them also is linked to growth factors and the policy system they adopted.  [12]   East Asian economies have growth led by investments, exports and enforcing of sound policies to support their industries. Moreover, the governments in East Asian countries are very much involved and unhesitatingly intervene in the market-oriented economies.  [13]  The role of the government is to maintain macroeconomic stability, overcome possible coordination failure and act as an intermediary in promoting growth initiations.  [14]  The economic system was based on wide ranging cooperative relationship between government and the local and transnational firms based in their country.  [15]   The industrial policies enforced seek to encourage the development of industries through various government measures such as tax incentives, Research and Development subsidies, credit allocation and protection against foreign imports.  [16]  In addition, the export-oriented industries did not develop without these particular measures of the government to accelerate investment in such industries; provision of infrastructure, universal education.  [17]  The role of the government was mainly to set up institutional policy foundations required for growth and overcoming coordination failures that can stop a the economy from flourishing.  [18]   The Asian Financial Crisis unearthed and exposed certain weaknesses of the East Asian economic model. Weak and inefficient financial systems, lack of corporate transparency and accountability, and widespread corruption became apparent after the crisis broke out.  [19]  This occurrence explicitly calls for constant improvement on institutions in the country which serves as the pillar of economic development. This is a lesson not only for developing countries but for the East Asian economies as well. The East Asia economic development model is applicable to the Philippines to a certain extent. The former policies and steps undertaken needed to be modified to suit the condition of the Philippines. The Philippines can consider setting its neighbors and the East Asia Miracle as benchmark of development and a goal to be achieved. The Philippines always has to remember that East Asian economies started modestly and took advantage and cultivated the initial conditions and resource endowments to their advantage. A step back to reexamine where the Philippines went wrong, why it seems to be experiencing a prolonged period at the take-off stage, would be a humble at the same time brave gesture on the part of the countries leaders. Although it may be too late to shift the focus back on agriculture because of changing conditions, it is still important that the government invest in infrastructure (i.e. farm-to-market roads) and R D as many in the country still rely on agriculture for a living ._ If it is possible that the government nurture the current industries it has and the agricultural sector at the same may be beneficial for the country. The Philippines have a lot of catching up to do, the East Asian miracle may also come true for the Philippines if it would only reconsider some of the policies being implemented and strengthen its institutions that would foster economic development. Sources: Chang, H. The Economic Theory of the Developmental State. 182-199. East Asia Analytical Unit. The Philippines: Beyond the Crisis . Manila: Department of Foreign  Affairs, 1998. Page, John. The East Asian Miracle: Four Lessons for Development Policy. NBER  Macroeconomics Annual, 1994: 219-269. Park, Jong. The East Asian Model of Economic development and developing countries.  Journal of Developing Societies, 2002: 330-335. Sakurai, Makoto. The Sustainable Development of East Asia and accompanying issues.  Economic and Social Research Institute, 2003. Thorbecke, E, and H Wan. Revisiting East and (South East) Asias development model. Cornell Conference on Seventy five years of Development. New York, 2004. 1-38. Wade. Lessons from East Asias Development Experience. 2005.

catcher in the rye :: essays research papers

Holden’s True Love Children: spirited, loveable, cute, and something that a society could not live without. But when ones life is so rotated around children like JD Salinger’s Catcher in the Rye character, Holden, one loses all conscious and can only find happiness when with children or thinking about them. Holden can only find genuine love in children, for they have not learned the dreadful prerequisite of life, â€Å"phonieness.† He hates the artificiality that adults eventually acquire because all his good memories remain in his youth and his life with young children his age. This characteristic of Holden is shown throughout the book, particularly with his love for Phoebe, his helping the innocent children who are unable to help themselves, and his love for Jane at their age of serenity and ignorance! Holden shows his love for Phoebe by continuously thinking about her and requiring for her company. The only gift we have ever seen given by Holden was his record purchase for Phoebe. â€Å"Besides, I wanted to find a record store that was open on Sunday. There was this record I wanted to get for Phoebe, called ‘Little Shirely Beans.’ It was a very hard record to get (114).† This is one example of Holden’s thought and love for Phoebe. We can believe that he only views Phoebe as one who deserves gifts in all the people that he knows. A great example of his love for Phoebe is how he risks showing himself at his own home just to see his sister. â€Å"Anyway, I went into D.B’s room quiet as hell, and turned on the lamp on the desk. Old Phoebe didn’t even wake up†¦ My mother, she has ears like a goddam bloodhound (159).† Holden takes this risk, a risk that could cost him much more then a week of hell. His love for his sister’s com pany is obvious by this and there is no denying that he would have never taken this risk if he found himself having a phony and older sister. What separates Phoebe from all of the rest of the phony people is by how â€Å"straight-up† she is. She gets to the point and she doesn’t try to squiggle out of the situation. This is proven when she says, â€Å"’How come you’re not home Wednesday?’ ‘What?’†¦ ‘How come you’re not home Wednesday?’ She asked me, ‘You didn’t get kicked out or anything, did you?