...CLAW3201 Case Analysis Introduction In Crown Insurance Services Ltd v Commissioner of Taxation (Crown), the issues raised are pertinent to the residence and source of the company under s6(1) of the Income Tax Assessment Act 1936. As cases are determined on the basis of all relevant facts and circumstances of each case, this analysis will focus on how the court’s decision process determined whether Crown had carried on business in the years 2004-2007 inclusive and the existence of central management and control (CM&C) in Australia. The purpose of this is to assess the valuation of Crown’s taxable income, which ultimately resulted in the objective decision to be set aside in favour of the applicant. Evaluation will be made in regards to how the case compares with previous cases and tax rulings and the likely impacts of the case on future commercial practices. Further, what the case infers about the current state of law in this area will also be discussed, as well as the potential degree of changes in modern judgements of residence and source issues within businesses not incorporated in Australia. Past judgements and tax rulings The facts of the case are similar to that of Malayan Shipping Co Ltd v FCT (1946), where the court held that “the mere trading in Australia by a company not incorporated in Australia will not of itself be sufficient to cause the company to become a resident”. This is true and consistent with the statutory definition of resident of Australia,...
Words: 1429 - Pages: 6
...economy 2.3 Tax incidence in bargaining 2.4 The general equilibrium incidence of environmental taxes 2.5 The tax system incidence on unemployment: A country specific analysis for the OECD economies: 2.6 Tax and subsidy incidence equivalence theories: experimental evidence from competitive markets 2.7 Tax incidence under oligopoly: a comparison of policy approaches 2.8 The incidence of income tax on wages and labour supply 2.9 The incidence of personal income taxation: evidence from the tax reform act of 1986: 2.10 Tax incidence when individuals are time-inconsistent: the case of cigarette excise tax 3. Conclusion References 1. Introduction: Government generally collect taxes to generate revenue and question arise here is that after imposition of taxation, which group will bear the tax burden. After implementation of tax, there would be the division of tax burden between byres and sellers which is known as tax incidence. Tax incidence is linked to the price elasticity of demand and supply. If supply is more elastic than demand then the tax burden falls upon the buyers and when the demand is more elastic than supply then the producers will bear the cost of the tax. Tax incidence is basically the analysis of the effect of taxation on the distribution of economic welfare. Tax incidence expose that which group either consumer or producer is going to pay the price of new tax and it falls mostly on the group...
Words: 2655 - Pages: 11
...Do Oil Revenues Affect Taxation? Christopher Skutnik Oil is an essential commodity to humans, as it powers many goods and services that give us humans a lot of utility. For oil producing countries, the prospects of exporting barrels of oil can be very exciting for fiscal revenues. The effect of oil production on fiscal revenues is largely due to the world oil price. In the last year and a half the price of oil has plummeted from $104/barrel to about $41/barrel today. This sharp decline in the price of oil has certainly hurt fiscal revenues of oil producing countries. It is also very likely that these countries do not enforce taxation. On the other hand, due to the volatile nature of oil prices, it is also rational to assume that oil-producing countries may enforce stringent tax codes. Stringent tax codes may be enforced to relieve budgetary pressures that may be as a result of lower oil prices. The purpose of this paper is to determine whether oil revenues have an effect on taxation. Understanding the effect of oil revenues on taxation is very important in terms of real world application. The information obtained from the analysis between the two variables will enable large producing oil nations to determine the kind of fiscal policy to undertake. It will help nations in planning budgets accordingly, while also helping governments determine whether there needs to be a change in tax rates to meet budgetary ambitions. For example, if...
Words: 1680 - Pages: 7
...Recognized Courses in Accounting/Tax Research and Analysis and Accounting/Business Communications September 3, 2014 The Texas State Board of Public Accountancy requires each candidate to complete a minimum of two semester hours in accounting research and analysis or tax research and analysis from a recognized college or university. The semester hours may be obtained through a discrete course or offered through an integrated approach. If the course content is offered through integration, the college or university must advise the Board which course(s) contain the research and analysis content. Courses identified through integration must dedicate 1 semester hour, or quarter hour equivalent, to research and analysis. Courses used to meet this requirement may not be used to meet the requirement for accounting or business communications described below. Course(s) identified by a university to meet the requirements for research and analysis in accounting or taxation should primarily address the identification, organization, and integration of diverse sources of information such as authoritative literature and pronouncements, to reach a conclusion or make a decision; and should analyze accounting and taxation issues by reviewing information, using empirical data and analytical methods, recognizing data in patterned activities, forecasting, and integrating data. CPAs may be asked to conduct research and analysis when providing attest services, professional accounting...
Words: 3741 - Pages: 15
...Accredited Tertiary Courses Listing 2012 Accredited Tertiary Courses Listing 2012 – as at 26 September 2012 1 2012 Accredited Undergraduate Courses AUSTRALIAN CAPITAL TERRITORY The Australian National University University of Canberra NEW SOUTH WALES Australian Catholic University Australian Institute of Higher Education Avondale College Charles Sturt University Kings Own Institute Macquarie University Southern Cross University Top Education Institute The University of New England The University of New South Wales The University of Newcastle The University of Sydney University of Technology, Sydney University of Western Sydney University of Wollongong Williams Business College NORTHERN TERRITORY Charles Darwin University QUEENSLAND Australian Catholic University Bond University Central Queensland University Christian Heritage College Griffith University James Cook University Queensland University of Technology The University of Queensland The University of Southern Queensland University of the Sunshine Coast SOUTH AUSTRALIA Flinders University Kaplan Business School The University of Adelaide University of South Australia Open Universities (conferred by Uni of SA) TASMANIA University of Tasmania VICTORIA Australian Catholic University Cambridge International College Carrick Higher Education Deakin University Holmes Institute Holmesglen Institute of TAFE La Trobe University Melbourne Institute of Technology Monash University Northern Melbourne Institute of TAFE RMIT...
Words: 16200 - Pages: 65
...CPA Program The Practical Experience Guide EVE CHENG CPA SENIOR ANALYST BHP BILLITON Contents Practical experience requirement How to identify if your role is relevant Where do you fit? What skills areas do you need to demonstrate? Your mentoring relationship How to record your experience in the logbook The skills guide Personal effectiveness skills Leadership skills Business skills Technical skills 3 4 6 7 8 10 11 12 13 14 15 MICHELLE ROACH CPA 2 Practical experience requirement Did you know? Our studies show that members consistently perform better in their segments when they are enrolled in the practical experience requirement The practical experience requirement of the CPA Program gives you the opportunity to use the knowledge and skills gained in your education and apply them in your workplace. Combining your education with mentored practical experience will give you the opportunity to develop and demonstrate highly sought after technical and soft-skills that will benefit your entire career. Starting your practical experience requirement means that you are one step closer to your goal of becoming a CPA. CPA Australia recommends that you start the practical experience requirement and the professional level segments at the same time, if you are employed in a relevant role. What are the requirements? • complete a minimum of three years of relevant full-time or equivalent part-time work experience • demonstrate competence in 16 personal effectiveness...
Words: 7844 - Pages: 32
...THE COMPANY AND ITS OPERATIONS Abbott Laboratories (Pakistan) Limited (The Company) is a public limited company incorporated in Pakistan on July 02, 1948, and its shares are quoted on the Karachi, Lahore and Islamabad stock exchanges. The address of its registered office is opposite Radio Pakistan Transmission Centre, Hyderabad Road, Landhi, Karachi. The Company is principally engaged in the manufacture, import and marketing of research based pharmaceutical, nutritional, diagnostic, diabetic care, molecular devices, hospital and consumer products and in providing toll manufacturing services. Head Office : Abbott Laboratories (Pakistan) Limited, Diagnostics Division, Opposite Radio Pakistan Transmission, Hyderabad Road, Landhi, Karachi. Office: +92-21-5015045-49 (111 222 688) Ext:3500 Dir: +92-21-5100422 Fax : 92-21-5042952 Wyeth Pakistan Ltd. Wyeth Pakistan Limited (the company) is a public limited company incorporated in 1949 in Pakistan. The company is listed on the Karachi and Lahore stock exchanges The address is following;International public company PO Box 167, S-33 Hawkes Bay Rd., SITE, Karachi, 75730, Pakistan ()92 021 256 7411, 92 021 256 4428 fax, http://www.wyethpakistan.com Primary SIC: Pharmaceutical Preparations, Primary NAICS: Pharmaceutical Preparation Manufacturing Description: Manufacturing: Manufacture and marketing of research-based ethical specialities and other pharmaceutical and agro-chemical products, including Tazocin, a highly-effective...
Words: 2334 - Pages: 10
...CHAPTER ONE INTRODUCTION 1.1 Background to the Study Since the 1960s to date, small and medium sized enterprises (SMEs) have been given due recognitions especially in the developed nations for playing very important roles towards fostering accelerated economic growth, development and stability within several economies (Yitzhaki, 2006). They make-up the largest proportion of businesses all over the world and play tremendous roles in employment generation, provision of goods and services, creating a better standard of living, as well as immensely contributing to the gross domestic products (GDPs) of many countries (OECD, 2000).Over the last few decades, the contributions of the SMEs sector, the development of the largest economies in the world have beamed the searchlight on the uniqueness of the SMEs; and this have succeeded in overruling previously held views that SMEs were only ―miniature versions‖ of larger companies (Al-Shaikh 1998; Gaskill et al. 1993). And although Small and Medium Enterprises have been at the center of the policy debate for quite some time in both developed and developing countries, little analytical work has been undertaken in this area.The dearth information that exists among researchers on Small and Medium Enterprises however provides a sense of how important this sector is for sustainable development in emerging economies (Medina, 2001). For instance, recent studies conducted by United Nations Industrial Development Organization (UNIDO) concur that SMEs...
Words: 21615 - Pages: 87
...Country Risk Analysis: John D. Young MGT 448 January 16, 2010 Stephen Thomas Country Risk Analysis When entering any market, analyzing the business risks is an important process. Many sources of risk exist and responsible organization will examine every possible source in preparation for managing a variety of issues. These risk types include political, legal, and regulatory risk, exchange and repatriation of funds risk, competitive risk, taxation and double taxation risk, market risk, distribution and supply chain risk, physical and environmental risk, social and cultural risk, and cyber-risk or technological risk. Political, Legal, and Regulatory Risks Politically, China faces some stability issues. China has a Communist government. In many cases, this regime has led to stability that has helped the country reach the more recent levels of economic improvement, despite some notable discontent among its people (Cai & Li, 2009). However, since reaching a more prosperous economy China has been at odds with itself. Balancing its communistic central government with capitalistic economic centers has been unsuccessful. Additionally, the development of the nation has led to a large disparity between the classes with some rural regions looking as they did decades ago whereas urban centers rival New York and Tokyo in excess (AMBest Co Inc., 2011). This generates a lack of trust in smaller regional centers and towns that threatens to create instability in China (Ke...
Words: 2144 - Pages: 9
...TAXATION PAPERS WORKING PAPER N.33 - 2012 Serena Fatica Thomas Hemmelgarn Gaëtan Nicodème The Debt-Equity Tax Bias: consequences and solutions Taxation and customs union Taxation Papers are written by the staff of the European Commission's Directorate-General for Taxation and Customs Union, or by experts working in association with them. Taxation Papers are intended to increase awareness of the work being done by the staff and to seek comments and suggestions for further analyses. The views expressed in the Taxation Papers are solely those of the authors and do not necessarily reflect the views of the European Commission. Comments and inquiries should be addressed to: TAXUD TAXATION-PAPERS@ec.europa.eu Cover photo made by Milan Pein Despite all our efforts, we have not yet succeeded in identifying the authors and rights holders for some of the images. If you believe that you may be a rights holder, we invite you to contact the Central Audiovisual Library of the European Commission. This paper is available in English only. Europe Direct is a service to help you find answers to your questions about the European Union Freephone number: 00 800 6 7 8 9 10 11 A great deal of additional information on the European Union is available on the Internet. It can be accessed through EUROPA at: http://europa.eu. For information on EU tax policy visit the European Commission's website at: http://ec.europa.eu/taxation_customs/taxation/index_en.htm ...
Words: 7352 - Pages: 30
...2013 2012 ----------- Rupees ‘000 ----------11,507,706 7,972,732 3,534,974 577,636 263,216 230,172 227,029 2,690,979 14,894 2,676,085 540,000 2,136,085 2,136,085 10,503,898 7,691,421 2,812,477 571,002 221,577 119,173 145,899 2,046,624 11,593 2,035,031 598,382 1,436,649 1,436,649 2013 2012 Horizontal Analysis (%) 109.56 103.66 125.69 101.16 118.79 193.14 155.61 131.48 128.47 131.50 90.24 148.69 148.69 2013 2012 Year on Year Ab. Chg (%) 1003808 281311 722497 6634 41639 110999 81130 644355 3301 641054 (58382) 699436 699436 9.56 3.66 25.69 1.16 18.79 93.14 55.61 31.48 28.47 31.50 (9.76) 48.69 48.69 Vertical Analysis (%) 100.00 69.28 30.72 5.02 2.29 2.00 1.97 23.38 0.13 23.25 4.69 18.56 18.56 100.00 73.22 26.78 5.44 2.11 1.13 1.39 19.48 0.11 19.37 5.70 13.68 13.68 Net sales Cost of sales Gross profit Distribution costs Administrative expenses Other expenses Other income Profit from operations Finance cost Profit before taxation Taxation Profit after taxation Other comprehensive income Total comprehensive income Balance Sheet As at June 30, 2012 and 2013 2013 2013 2012 Vertical Analysis Horizontal Analysis ----------- Rupees ‘000 ----------(%) (%) 2013 2012 2013 Change Analysis Ab. Chg (%) Particulars Non-current assets Fixed assets - property, plant and equipment Long-term investment Long-term loans and advances Long-term deposits Current assets Stores, spares and loose tools Stock-in-trade Trade debts - considered good Loans and advances Short-term deposits and prepayments...
Words: 752 - Pages: 4
...CollegeofAgriculture Bachelor of Science in agribusiness COURSE SYLLABUS IN social science 4 first semester, a.y. 2013-2014 I. COURSE CODE: SOC.SCI 4 II. COURSE TITLE: GENERAL ECONOMICS WITH TAXATION AND LAND REFORM III. Course Description: This course provides a comprehensive coverage of all major topics in economics. Attention is given to establish student understands of key economic principles with particular emphasis on the Philippine Economic system, its growth and development. The course covers the foundation of economics, demand and supply analysis, the concept of elasticity, the theory of production and the fundamental concept of micro and macroeconomics with the use of simple graphical and mathematical illustrations. Likewise, the course involves topics on taxation and agrarian reform with discussion on issues and problems related to its implementation. IV. CREDIT UNIT: 3HOURS V. TIME ALLOTMENT: 54 hours/ 3 hours per week VI. GENERAL OBJECTIVE: At the end of the course, the students are expected to know the fundamental principles of economics, and their application to everyday life. SOCIAL SCIENCE 4 – GEN. ECON WITH LAND REFORM AND TAXATION Time Allotment |TOPICS/ CONTENT |SPECIFIC OBJECTIVES |TEACHING STRATEGIES |VALUES INFUSED |INSTRUCTIONAL MATERIALS |LEARNING OUTCOMES |EVALUATION TOOLS | |3 |Reflection of LSPU Vision, Mission, Goals and Objectives •...
Words: 1084 - Pages: 5
...Corporate Finance and Value Creation Memorandum Ocean Carriers November 2015 EXECUTIVE SUMMARY Due to an attractive lease agreement proposed by a larger client, the investment department has conducted an extensive evaluation of the possibility to invest in a new $39 million capesize carrier. This material should be distributed as a basis for the decision regarding the commission of the carrier and includes current assumptions and calculations. The investment department has come to the absolute conclusions to decline the offer to enter into the lease agreement, due to the unprofitability of commissioning a new vessel. This conclusions hold both under U.S. tax law as well as Hong Kong tax law. The net present value of the project is currently -$6,968.828 under U.S. tax law and -$1,228,132 under Hong Kong tax law. The internal rate of returns is 5.5% under U.S. tax law and 8.4% under Hong Kong tax law. The project has been discounted at Oceans Carriers current hurdle rate of 9%. Investment Opportunity Ocean Carriers are currently in negotiations with a well esteemed charterer regarding a three-year charter on a capesize ocean freighter. Our client has made an offer of $ 20,000 per day with an annual escalation of $200...
Words: 1231 - Pages: 5
...(1976) 55-75. 0 North-Holland Publishing Company THE DESIGN OF TAX STRUCTURE: DIRECT VERSUS INDIRECT TAXATION* A.B. ATKINSON University of Essex, Wivenhoe Park, Colchester, England J.E. STIGLITZ Stanford University, Stanford, CA 94305, U.S.A. Revised version received February 1976 1. Introduction The recent literature on optimal taxation may be seen as attempting to clarify the structure of the arguments advanced to support changes in the tax system, tracing the implications of taxes and quantifying (analytically) the trade-offs between the various objectives of tax policy. This literature has examined the optimal structure for particular types of taxation taken in isolation, such as the optimal rates of excise tax and the optimal income tax schedule. Our purpose, on the other hand, is to provide a broader framework and to consider the interaction between different kinds of taxation. To illustrate this, we reexamine the age-old question of direct versus indirect taxation and the relationship of these taxes to the goals of efficiency, vertical equity and horizontal equity. After describing in section 2 the general framework of the analysis, and arguing that any treatment of the choice of tax structures must be centrally concerned with distributional considerations, we begin in section 3 with the extension of the classic Ramsey formula for optimal excise taxation to include vertical equity objectives. This was considered by Diamond and Mirrlees (1971), but the results ...
Words: 9114 - Pages: 37
...Tobacco Taxation 1 Tobacco taxation is a hot topic and all 50 state governments have enacted taxes on cigarettes, and many have raised their taxes several times. Taxes on cigarettes are a way governments can achieve two social objectives; the first objective is to reduce the number of citizens who smoke. The government issuing the cigarette tax hopes that the rise in the cost of a pack of cigarettes will persuade people to quit smoking. The second objective is to raise government revenue. A cigarette tax, like any other tax, increases the amount of revenue governments can spend on social programs. Where there’s smoke, there’s taxes — especially for New Yorkers. In a 2010 budget move officials say will generate $440 million in revenue, the state legislature passed a bill that gave New York the highest cigarette tax in the country. On July 1, 2011 every pack sold in the state cost an extra $1.60, raising the total state tax to $4.35, pushing the average cost of a pack up to $9.20. For New York City residents, the cost of a pack will now come out to close to $11 — a $2 rise from just over a year ago. The $440 million in revenue will benefit health care programs, AIDS drugs subsidies, tobacco cessation programs and $71.6 million will go to the state cancer research center in Buffalo. Supporters also applaud the health benefits, saying it will reduce the number of smokers by tens of thousands of people. Tobacco consumption is the leading cause of preventable death in many...
Words: 1014 - Pages: 5
