How to write a strategy paper
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Thursday, September 3, 2020
Epic of Beowulf Essay - Honor and Dishonor :: Epic Beowulf essays
Beowulf:â Balance of Valuesâ â â â â Representing honor and quality, control of the wine-lobby goes under the control of the victor, under the customary laws of the Danes and Geats. As Beowulf triumphs over the devil, Grendel, he pushes off the disgrace and disrespect which would have happened to him, and full control of the wine-lobby, just as regional matchless quality, are unmistakably his. Just later in the sonnet does Beowulf start to lose the power that had been solely his area. Indeed, even in death, be that as it may, Beowulf is deified by the individuals from his clan, and by the essayist, as he went into sublime history His burial service fire, and landmark on the coast, took the stand concerning his significance. It appears that the evasion of disgrace and shame in one's childhood builds up a long lasting example in Geat Society, regardless of whether minor disappointments are enrolled further down the road or not. When an extraordinary warrior, Beowulf stays one. His kin blossom with his honorable character and triumphs; his rivals tremble at his name, in stunningness and regard. Further, between ancestral liberality and receptiveness, for instance, during scenes of thankfuness for the triumph over Grendel, are likewise characteristics which sparkle forward all through this adventure, further propelling the reason that this Geat warrior-ruler and his kin exemplify the entirety of the attributes thought respectable and decent according to his tribesmen. The conspicuous premium put on the respect of triumph, and the disgrace of annihilation is exhibited over and over in savage encounters which intersperse this emotional story. The storyteller appears to continue concentrating on similar demonstrations of valor, shifting the portrayals just marginally, as one entry softens into the following. On numerous events, ladies encompass the victor; wine, fortune or tribute are traded and valiant acts are commended in routine. In any case, devastation of one's notoriety is conceivable, too, as the artist brings up in the shocking scene managing Haetheyn who incidentally slaughtered his own brother.
Saturday, August 22, 2020
Measuring Patient Dependency in Clinical Settings
Estimating Patient Dependency in Clinical Settings Title: Should understanding reliance be utilized to set medical attendant staffing levels when all is said in done emergency clinic wards? Presentation: In this segment, we play out a writing audit to talk about patient reliance in clinical settings, and look at how we can quantify understanding reliance levels. We additionally talk about whether quiet reliance levels ought to and could frame the models for setting medical attendant staffing levels in the emergency clinic. We will likewise break down the other various techniques and standards that can assist with deciding medical attendant staffing levels inside the clinical setting. Tolerant reliance levels shows the necessities of medical caretakers and the degree to which patients will require attendants for their constant consideration. Attendant patient proportions are frequently used to talk about the medical caretaker staffing levels and these figures show in the case of staffing levels must be expanded or diminished. We would point our conversation of patient reliance requiring increment in staffing levels and the patient attendant proportion as markers of medical attendant s taffing both inside general clinic wards and at basic consideration and crisis units. Evidential Information Quiet reliance may simply frame a significant piece of nursing staff and outstanding task at hand of an individual attendant. Hurst (2005) led a significant investigation on the nature and estimation of reliance sharpness quality (DAQ) request side nursing workforce-arranging strategies, which are set with regards to nursing workforce arranging and advancement. Broad DAQ information was acquired from UK nursing workforce in 347 wards, which included 64 high caliber, and 62 low quality emergency clinic wards. The investigation gives uncommon thought to outstanding task at hand and quality settings. New bits of knowledge have been created with this examination and Hurst underscores that low quality consideration is increasingly normal in bigger wards that have fluctuating and temperamental remaining task at hand and medical caretaker â⬠persistent proportion. Littler outstanding tasks at hand having reliable and high remaining burden of nursing staff brings about resolute medical ca retaker staffing so staff levels and performed obligations continue as before. Studies certainly recommend that nursing movement and staffing contrasts do frame a significant piece of characterizing and adding to the nature of the wards with higher staffing levels and increasingly steady work for medical caretakers at top notch wards and lower setting up levels and sporadic administrations with low attendant patient proportion in low quality wards. From this proof, it is conceivable to give suggestions to nursing the board and practice and test into progressively precise relations of reliance keenness quality in DAQ measures. In an investigation utilizing appraisal of patient medical caretaker reliance frameworks for deciding attendant patient proportion in the ICU and HDU, Adomat et al (2004) call attention to that a tremendous scope of patient order frameworks or devices are utilized in basic consideration units to advise workforce arranging, and nursing remaining task at hand in spite of the fact that the use of these techniques may not generally be applicable, finished or fitting. The frameworks or instruments utilized for tolerant order and arrangement were grown exclusively with the end goal of increasingly effective appropriation of patient across medical clinic areas, albeit now similar frameworks are utilized for workforce arranging, dissemination of outstanding task at hand, deciding attendant patient proportion in basic consideration settings. Anyway these progressions can raise various issues identified with workforce arranging, staffing levels and nursing the board when all is said in done. A domat and Hewison assess the three primary appraisal frameworks utilized in basic consideration units to adequately decide the fundamental medical caretaker tolerant proportion that can offer the best quality support in the wards. The utilization of these apparatuses is to upgrade the nature of care by keeping medical attendant patient proportion at its ideal. The creators propose that choices identifying with remaining task at hand arranging and deciding the medical caretaker persistent proportion are reliant on a comprehension of the birthplaces and motivation behind the classificatory devices that classifies patients and measures their reliance on care administrations. Quiet reliance and grouping frameworks just as patient reliance scoring frameworks for seriousness of sickness are measures demonstrating mortality and dismalness in spite of the fact that Adomat brings up that these reliance measure may not be genuine markers or determinants of the medical attendant patient propor tion that help in estimating nursing input. The expenses of giving a nursing administration inside basic consideration utilizes nursing power measures to give a system for nursing the executives and patient consideration and furthermore decides the specific job of patient reliance in nurture staffing levels. In any case, parts of the nursing job and how it decides principles of care have not been completely decided (Adomat and Hewison, 2004). They bring up that cautious thought of patient reliance and arrangement frameworks might be important to design, sort out and give a financially savvy basic consideration administration. In a comparable report, Adomat and Hicks (2003) assesses the nursing remaining task at hand in serious consideration a there is a developing deficiency of medical caretakers in these consideration units. The issue distinguished in this deficiency lies in the technique for ascertaining the medical caretaker/persistent proportion utilizing the Nurse Workload Patient Category scoring and classificatory framework use in most concentrated consideration units. The medical caretaker understanding proportion is controlled by utilizing the patient class or reliance scales and the general supposition that will be that the more basically sick a patient is, the more consideration and nursing time will be required for the patient. Numerous basically sick patients set on an elevated level of mechanical consideration, for example, a taking care of or ventilator tube and in concentrated units may anyway require less immediate individual nursing care than patients who are self ventilating or have bee n considered to have lower levels of reliance. In this manner understanding reliance might be tended to by implies other than direct nursing care and fake consideration and emotionally supportive networks may b utilized as opposed to nursing staff. These and different components show that patent reliance may not be a totally important measure for deciding medical caretaker ââ¬patient proportion or attendant staffing levels and many partner factors must be thought of. This examination by Adomat and Hicks utilize a video recorder to report nurture action in 48 persistent moves inside two serious consideration units and assisted with deciding the precision of the Nursing Workload Patient Category scoring framework to quantify nurture outstanding task at hand. The information got from the video of medical caretaker movement was then related with the Patient classification scale score that was assigned to the patient by the attendant in control. The aftereffects of this examination dem onstrated that the nursing abilities required in these consideration units were of low aptitude type in spite of the necessities of care being unpredictable when all is said in done. It was discovered that medical caretakers invested less energy with patients who were classified as needing serious consideration than those out of luck and in high reliance go in all units. The discoveries demonstrate that current medical attendant patient proportion arrangements are improper as medical caretakers invest less and less energy with basically sick patients. The creators uncover the imperfections of characterization or scaling frameworks that will in general relate care with basic sickness. They recommend that extreme reexamination of nursing levels and aptitudes blend should make it conceivable to build arrangements and levels of escalated care giving the correct quantities of staff at the fitting units where patients need them most proposing progressively adaptable and elective ways to d eal with the utilization of medical attendant patient proportions. In a comparable report talking about connection between remaining task at hand, ability blend and staff oversight, Tibby et al (2004) proposes a frameworks approach and recommends that medical clinic unfriendly occasions or AE are more probable when problematic working conditions happen. Appropriate working conditions are consequently completely important to guarantee the smooth working of the clinical setting. Tibby and partners examined the unfavorable occasions in a pediatric emergency unit a frameworks approach and observational examination to research the relationship between the event of these antagonistic occasions and inert hazard factors including transient outstanding burden, management issues, aptitudes blend, nurture staffing and the cooperations between built up clinically related hazard factors (Tibby et a, 2004). The information was gathered structure 730 nursing shifts and the examination was finished with calculated relapse displaying. The pace of unfriendly occasion s was 6 for each hundred patient days and the variables related with expanded AE including day move, persistent reliance, number of involved beds, and synchronous administration related issues in spite of the fact that these were impressively diminished with upgraded administrative capacity of the medical caretakers. Diminished number of unfriendly occasions have been seen as identified with the nearness of a senior medical attendant in control, high extent of movements took care of by rostered, prepared, lasting staff and the nearness of junior specialists. Quiet remaining task at hand factors, for example, bed inhabitance and the degree to which the patient needs assistance and nursing administrative levels and level of staffing, for example, nearness of a senior medical caretaker have been seen as related. This examination reveals insight into the elements expanding or diminishing unfavorable occasions and aides in distinguishing the issues firmly identified with the need of dire cting and advancing medical caretaker staffing levels. As we have just recommended through an investigation by Adomat and Hicks, patients in high reliance units may require increasingly visit nursing care and higher medical attendant patient proportions than basic consideration units where patients might be bolstered by counterfeit strategies. As per an examination by Garfield et al (2000) high reliance units are expanding in the emergency clinics and getting increasingly significant as a component of a hospitalââ¬â¢s offices. Despite the fact that the ideal staffing proportion for patients is obscure for such units, the Department of Health and Intensive Care Society suggest a degree of one medical caretaker for each two patients. Garfield et al recorded Therapeutic Intervention Scoring System scores and Nurse Depen
Friday, August 21, 2020
The Value of Having Sample Argumentative Essay Samples
The Value of Having Sample Argumentative Essay SamplesAll schools of law and other academic institutions should be using a variety of different argumentative essay samples when teaching students to write persuasive essays. Students who are well informed about what goes into a winning essay will be more likely to do it themselves, and those who can't or won't do it themselves will be less likely to be successful in their future careers. This is the value of having an assortment of different essay samples available to students, all of which have been tried and proven.The most effective essay you will ever write will be a persuasive essay. For the most part, students will think of a persuasive essay as one in which the writer puts forward an argument that a reader should take to support a particular conclusion. Of course, no argument should be necessarily accepted as fact by an objective reader. An argumentative essay will present the arguments in question and give readers reasons why t hey should accept the argument, or reject it out of hand.Many students who write essays do not realize the magnitude of effort that goes into each essay. A strong argumentative essay requires much more than just the ability to present information. The entire essay must be an argument in and of itself. All the facts must support the point being made in the essay. If the essay does not have an actual argument behind it, the reader will dismiss it as being nothing more than a piece of academic fluff.The time and effort required to write an essay for a course at any level is considerable. It can take years of study to become an efficient essay writer. Without support from sample argumentative essay samples, it is impossible for students to know where to begin writing a persuasive essay. The only way for them to find their feet in the writing world is by spending the required time and trying to understand where they are going wrong.Essays require more attention to detail than any other t ype of work. Students need to be able to place every comma, every comma following a semi-colon, every punctuation mark within the text correctly. They also need to understand the difference between academic and non-academic use of language. These issues are handled by the use of sample argumentative essay samples.Students who are asked to write an essay for a course will have to take the material and work with it on a regular basis. They cannot simply forget about the material and expect to get away with it if the material was poorly written. It will be a constant source of confusion for students as they attempt to incorporate a lot of new information without becoming lost.Student think tanks can become a treasure trove of information for students of all ages. Students who decide to use the results of past research in their own argumentative essays will have much more knowledge to draw from than students who do not. Students will be able to find information that is similar to what t hey already know in order to make a compelling argument for their selected conclusions.Students have access to many resources to help them learn to write an essay with a purpose, such as websites that offer sample arguments, articles with a similar topic, and books that discuss how students should handle arguments and why they should work with arguments. These resources are important, but the ones mentioned above are much more valuable. Argumentative essay samples are the best thing that a student has at their disposal when they want to improve the way they write arguments.
Friday, June 12, 2020
Dartmouth Grad
Dartmouth Grad November 3, 2013 Brad Ausmus, a Dartmouth grad and former star MLB catcher, has been named the new Manager of the Detroit Tigers. Ausmus is also notable for being a Jewish athlete who declined to play a MLB game because it fell on Yom Kippur. Our Founder, Bevs cousin Sandy Koufax (pictured), is well known for having taken this stance in a game of the World Series many years ago. Its always nice to see an Ivy League athlete succeeding on the professional level. For many years (18 in fact), Brad Ausmus, a Dartmouth grad, did just that as a catcher in Major League Baseball. Today, he was named the new Manager of the Detroit Tigers, a team with a lot of promise to win next years World Series. Drafted in the 1987 MLB Draft by the New York Yankees, Ausmus alternated attending Dartmouth with his minor league career. As such, he did not play baseball for the Big Green, though he did spend quite a bit of time around the baseball players at Dartmouth. Over the course of his career, Ausmus earned three Gold Glove Awards and he made the All-Star Team in 1999. Ausmus, who majored in government at Dartmouth and never earned a grade lower than a B, became the first Ivy League grad in 2005 to play in a game of the World Series since another Dartmouth grad did it in 1916. Its more than rare for an Ivy Leaguer to play in Major League Baseball. Frankly, its rare for college graduates to play in Major League Baseball as a 2009 survey found that only 26 players and managers at the time were grads of four year schools. Does that surprise you in any way? Anyhow, we want to salute Brad Ausmus for this great new job. He may not have managerial experience but hes a Dartmouth grad, he had a very successful playing career, andhe is a very proud Jewish athlete. Thats right, Brad Ausmus, who has also been previously designated by OutSports as the best looking athlete in sports is also Jewish. He takes great pride when Jewish boys come up to him and let him know that he inspires them not only for being a great baseball player but for being a great Jewish baseball player. It should also be noted that Ausmus even sat out a game because it fell on the holiest day of the Jewish calendar Yom Kippur. As you may know, our Founder Bevs cousin, Sandy Koufax, widely regarded as the greatest pitcher in the history of the game of baseball, was well respected for taking this stand many years ago in a game of the World Series.
Sunday, May 17, 2020
Catcher in the Rye the Quest for Love - 2431 Words
Catcher In the Rye: The Quest For Love In many novels in J.D. Salingers library of books, there is a recurring theme of the loss of innocence of children, the falling and the confusions of childhood, and many other ideas that apply to the ideas of adolescence and the life of the average teenager growing up. Many of his themes occur in a short period of time in a childs life that affects him/her in a very profound and significannot way. The idea of love is also a major theme that arises in many of his characters and that indicates the character of the individual. He uses love in the context of being a device that is used to protect and to care for people who need protecting and caring. In the novel, Catcher in the Rye, by J. D.â⬠¦show more contentâ⬠¦That is why he seeks to find adolescents, to catch them from falling into the kind of fake maturity that they are destined for. He seeks children, free of impurities. At Phoebes school, ....I saw something that drove me crazy. Somebodyd written Fuck You on the wall. It drove me damn near crazy. I thought how Phoebe and all the other kids would see it, and how theyd wonder what the hell it meant, and then finally some dirt kid would tell them-all cockeyed, naturally-what it meant, and how theyd all think about it and maybe even worry about it for a couple of days (Salinger 201). He realizes then, that innocence is a very hard part of ones soul to save. This eventually leads him to his final realizations. Holden has a few aspects and thoughts that help him to appease him slightly of the thirst for love. In childhood he had what he is now seeking- non- phoniness, truth, innocence. He can find it now only in Phoebe and in his dead brother Allies baseball mitt, in a red hunting cap and the tender little nuns (Heiserman and Miller 26). Phoebe is a hope that Holden holds in his heart. Her childish innocence gives him a true and pure outlook that lets him feel secure in her presence. Also, the memories of his long dead brother, Allie, remain in his mind, giving him comfort in the thoughts of the totally innocentShow MoreRelated Cacther In The Rye Essay1147 Words à |à 5 Pagespopular and influential writers. His only novel, The Catcher in the Rye, drew such great attention during the fifties and sixties that those years have been called the age of Holden Caulfield (Contemporary Literary Critiscm, Vol. 12). Salinger is a master of contemporary dialect and idiomatic expression. He created in Holden Caulfield a character who became the prototype of alienated adolescence for an entire generation of Americans. The Catcher in the Rye has been banned even recently from a few librariesRead More Catcher in the Rye Essay: Holden - The Misfit Hero2101 Words à |à 9 PagesThe Misfit Hero of The Cat cher In The Rye à à à à The Catcher In The Rye by J.D. Salinger was published in 1951. A recurring theme in J.D. Salingers stories concerns people who dont fit in with the traditional American Culture. Salingers misfit heroes, unlike the rest of society, are caught in the struggle between a superficial world and a conscious morality (1 Wildermuth). In his attempt to create a new and realistic portrayal of the times, Salinger first, effectively creates Holden CaulfieldRead MoreJ.D. Salinger is Holden Caulfield1666 Words à |à 7 Pageswriting abilities. ââ¬Å"Despite his slim body of work and reclusive lifestyle, ââ¬ËSalingerââ¬â¢ was one of the more influential twentieth century American writers.â⬠states Biography.com, ââ¬Å"His landmark novel, Catcher in the Rye, set a new course for literature in post World War II America.â⬠The Catcher in the Rye told a story of Holden Caulfield and his struggle to find something pure in a world filled with ââ¬Å"phoniesâ⬠(Biography). It is arguable that some of Holdenââ¬â¢s experiences could be comparitively autobiographicalRead MoreSummary Of The Great Gatsby By F. Salinger904 Words à |à 4 PagesWorld War II, was born on January 1, 1919 in New York City. Little is known about his early life except for his education. He attended schools on the upper west side of Manhattan, which would later be the setting of his most famous novel, The Catcher in the Rye. After flunking out of several prep schools, including McBurneyââ¬â¢s, his parents sent him to Valley Forge Military Academy. At Valley Forge he maintained average grades and was involved in several clubs and organizations, many of which had toRead MoreThe Catcher in the Rye Essay1442 Words à |à 6 PagesThis paper proposes to delineate the characteristics of Holden Caulfield, the adolescent protag onist hero of J.D. Salingerââ¬â¢s The Catcher in the Rye and illuminate the reasons as to why this prototype of brooding adolescence, displaying a rather uber-cool style of disaffection, disenchantment and disillusionment became an indispensable figure of interest, in literary circles as well as popular culture. The paper seeks to take issue with the wider dimensions attached to the ââ¬Ëincapacitation and debilitationââ¬â¢Read MoreEssay on Comparison Great Gatsby and Catcher in the Rye1331 Words à |à 6 PagesThe Great Gatsby, Gatsby is a man who can be compared to Holden Caulfield from J.D Salingerââ¬â¢s Catcher in the Rye. Jay Gatsby and Holden Caulfield are both caught up in their unattainable dreams and first love and as a result struggle with an obsession of their past. It is a natural tendency for all men and women to dream but sometimes these dreams may be unattainable. In J.D Salingerââ¬â¢s Catcher in the Rye, Holden Caulfield has a desire to preserve the innocence of children and save them from adulthoodRead More The Catcher Essay2456 Words à |à 10 Pagesadolescent struggling with growing up in the novel The Catcher in the Rye, is not aware of these mediums. To him the two worlds seem to be as different as heaven and hell with no purgatory in between. Holden has no positive adult role models, his only concern is preserving innocence and the only people he truly cares about and respects are children. Holden Caulfield fears the transition from child to adult in J. D. Salingerââ¬â¢s novel The Catcher in the Rye because childhood is so inviting and adulthood isRead MoreThe Great Gatsby By F. Scott Fitzgerald2365 Words à |à 10 Pagesprovides insights into the delusions and deterioration of this dream through showing how the strive for nob le goals and great achievements deteriorated into a quest for riches and how distant the dream is from reality. The American Dream has been in the spirit of America since its founding days. In the beginning, the dream simply was the quest for breaking free from class restrictions and acquiring prosperity and stability on a new land. The Founding Fathers declared that people inherently have theRead MoreChris Mccandless s Into The Wild1570 Words à |à 7 PagesCaulfield are two boys who both disagree with their current societies and decide to escape to discover their identities. In Into the Wild by Jon Krakauer, Chris McCandless never seems to regret his decision to leave, while Holden Caulfield in The Catcher in the Rye begins appreciating his life more and shortly returns home to his family. After leaving the comfort and security of their homes, Chris McCandless feels finally liberated from society, whereas Holden Caulfield realizes that he is too young andRead More Janie in Their Eyes Were Watching God and Holden Caulfield in The Catcher in the Rye1019 Words à |à 5 Pageseach one of these men contribute to Janieââ¬â¢s quest in different ways. In the beginning, the pear tree symbolizes Janieââ¬â¢s yearning to find within herself the sort of harmony and simplicity that nature embodies. However, that idealized view changes when Janie is forced to marry Logan Killicks, a wealthy and well-respected man whom Janieââ¬â¢s Nanny set her up with. Because Janie does not know anything about love, she believes that even if she does not love Logan yet, she will find it when they marry.
Wednesday, May 6, 2020
A Of The Sun Is A Play Written By Lorriane Hansberry
A Raisin in the Sun is a play written by Lorriane Hansberry. The play was highly influenced by events that happen during her childhood. Lorriane family moved into a white neighborhood and was threated countless of times to move out. It was so serious that they family had to go to the Supreme Court so they could overturn the decision and allow the Hansberry to live in a white neighborhood, this case made it that no white residents could push Africans Americans out of their neighborhoods. What is the meaning of the title? Does it have a deeper meaning? Lorriane Hansberry was actually influenced by the poem Langston Hughes wrote, A Dream Deferred. She used a line in his poem, for the title of her book, although there is not one raisin in the play you can see many dreams being deferred. Langston poem ask us a question on what happens to our dreams when they do not become reality. Walter had a dream on providing for his family rather than having to work everyday for the whites, rather he would like to own his own business. While his dream could have been fulfilled, Willie ran off with all of their money. The younger families have a dream on overcoming racism and owning their own house. They want to get out of poverty and with the insurance check they received they were able to fulfill one of the dreams. It does not have a deeper meaning than that. Identify the settingââ¬â¢s historical significance. The book was written in the 1950s and it portrays the modern times as age of
Capital gains Tax Historical Trends and Forecasting
Question: Discuss about the Capital gains Tax for Historical Trends and Forecasting. Answer: Introduction: Permanent establishment as defined under Subsection 6 (1) of the Income Tax Assessment Act 1936 states that a person, state of an authority, commonwealth or through which an individual carries on any business without limiting the generality of the foregoing. This includes a place where the person is carrying on a business through an agent or a place where the person is using or installing substantial equipment or substantial machinery. From the current study, it is evident that Alex Ran and Ryan Tan a resident of Singapore having its business in the same country looking forward to expand their business operations in Australia (Woellner et al., 2016). The study highlights that the brothers have also held a shares in ASX listed companies is Australia and intends to use the service of stockbroker, which they found online to sell the shares in order to raise capital for their enterprise. The ruling of the Permanent Establishment provides that it does not takes into the consideration a place where the person is involved in the business dealings through using the service of a bonfire commission agent or broker. The rulings provides that brokers who in relation to those dealings acts in the ordinary course of his or her business who does not receive any remuneration or otherwise than at the customary rate in relation to those dealings of that kind, not being a place where an individual otherwise carries on a business. It is noteworthy to denote that the rulings provided under Subsection 6 (1) of the Income Tax Assessment Act 1936 states that Alan Tan and Ryan Tan is looking to raise the capital through using a broker who will be negotiating and concluding the terms of contracts on behalf of the brothers (Snape De Souza, 2016). Hence, the use of various brokers by Alan Tan and Ryan Tan will not result in Permanent Establishment in Australia. Determination of tax implications for Melbourne and Cambrai operations: According to the concept of Australian Taxation Laws if an individual acquires a vacant land either for private use or for business purpose it is normally considered as capital assets and are subjected to capital gains tax. In the current study, Alan Tan and Ryan Tan bought the properties with the intention to subdivide the land into ten blocks. The abandoned land was subdivided further into two small blocks in order to raise money by selling the blocks and the remaining eight blocks for constructing townhouse. Hence, the income raised from the selling of the subdivided land should be considered as capital gains and any profit is generally treated as capital gains, which is subjected to capital gains. As stated under the ITAA 1936 subdivision of land does not necessary result in the CGT event unless an individual retains the ownership of the subdivided block of land. This in turn represents that an individual does not make capital gains or a capital loss during the time of subdivision. However, under the current case study of Alan and Ryan the initial intention was to make a capital gain from the sale of two subdivided block of land and this would constitute Permanent Establishment. On the other hand, the remaining eight blocks were used for townhouse which implies that the constructed properties were used for residential purpose and were also engaged in the profit-making activity of property renovation and is liable for CGT tax (Kania, 2013). Considering the tax implications regarding the context of the definition of Permanent Establishment it is evident that Subsection 6 (1) definition implied on acquisition and subdivision of land in context with the ITAA 1936. Determining the residency of brothers and tax implications: Australian resident are usually taxed on their income from all sources whereas a temporary resident of Australia along with the overseas resident they are usually taxed on their income sourced in Australia. In the current case study, it is evident that the anticipated time of stay for the brothers was eight months. According to the 183 days Statutory test an individual would be considered as an Australian resident if an individual has originally been in Australia continuously or intermittently for more than one half of the income year (David, 2013). The commissioner of tax is satisfied that that the individuals original place of dwelling was outside Australia and the individual does not intend to take up the permanent resident in Australia. As stated in the given case of FC of T v Jenkins 82 ATC 4068, where an office of bank was transferred from Australia to work in bank of New Hebrides office for a three-year term. However, depending upon the Applegate the time that he spent working in New Hebrides was the tax payers permanent place of abode rather than Australia. Hence, under the current study both the brothers spend more than one half of the Australian income year living in Australia which would be substantially regarded as more than the statutory period of 183 days (Zelinsky, 2016). Hence, they would be considered as a resident of Australia since the duration and continuity of their presence was greater than the one-half of the income year. Application of CGT rules with necessary calculations: Application of CGT rules on Sale of Shares: Shares in a company or units are treated in the same way compare to any other CGT assets. It is assumed that the shares are acquired by the brothers after 20 September 1985 and Capital Gains Tax is applicable on gains derived from the sale of shares or units on the occurrence of CGT event (Clark, 2014). Thus, under the current study it is observed that the brothers were engaged in the sale of shares with the help of broker and gains derived from such sale of shares or units are liable to be taxed under the CGT event. The shares were redeemed by switching them from one fund to another and received assessable payments as it involved involuntary change in ownership. Demolitions and construction of town houses and planned disposal of townhouse and beef business: As stated under the income tax assessment act 1936 if an individual is demolishing a house the cost base does not gets reduced because any losses suffered and can be increased by the cost of demolition. In the current study, it is observed that the vacant land was demolished to build up townhouse which was later sold off to raise money and the remaining blocks of townhouse was used for residential purpose (Althaus et al., 2012). Thus, when a property changes its form to being a business into a trading stocks would lead to the application of CGT and any profit made from such sale of such block of land would constitute Capital gains tax. On the other hand, improvement made on Cambrai property with the intention to re-establish in the form of commercial herd would represent a business venture and any profits derived from the business would be taxed as normal income. Cost Calculation of Fitzroy Project:- Particulars Amount Cost of Fitzroy Block $12,50,000 Brokerage Fees $16,000 Demolition Cost $37,000 Interest Cost per year $35,000 Cost of 10 Blocks $13,38,000 Cost of 2 Undeveloped Blocks $2,67,600 Cost of 6 Blocks $8,02,800 Add: Construction Cost $24,00,000 Total Cost of 6 Town Houses $32,02,800 Cost of Each Townhouse $5,33,800 Income tax implications on the disposal of townhouse: A house is usually exempted from tax unless an individual has an investment property which is build or renovated for disposal. Ryan and Alex bought the abandoned land with the intention to renovate for profit and using it as running a business, this attracts income tax implications with capital gains tax and goods and service tax (De Goede et al., 2016). Special CGT rules are applicable since both Ryan and Alex are foreign residential who ceases to be an Australian resident for taxation purpose. Analysis of Cambrai Operations: The Cambrai operations will be considered as business since the property was originally acquired with the intention of re-establishing it for commercial herd. This ultimately signifies that any profits derived from the business would be considered for income tax (Hegemann et al., 2015). However, on the event of suffering loss from carrying on the business of commercial herd such losses are subjected to be offset on gains made from commercial herd only. Non-resident Company Company Company Company Company Company Particulars 2015-16 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 Assessable Ordinary Income 0 0 $15,000 $2,50,000 $12,50,000 2000000 2150000 Less: Deductible Expenses Repairs 850000 850000 850000 850000 Depreciation on Capital Improvements 125000 250000 375000 500000 500000 500000 Interest Expenses 60000 60000 60000 60000 60000 60000 Net Ordinary Assessable Income 0 -1035000 -1145000 -1035000 -160000 1440000 1590000 Assessable Statutory Income: Sale Proceeding of Shares 1750000 Less: Cost of Shares -625000 Less: Brokerage -17500 Capital Gain Tax on Shares 1107500 Less: 50% Exemption 553750 Net Capital Gain Tax on Shares 553750 Sale Proceeding of Undeveloped Blocks 650000 Less: Cost of Undeveloped Blocks 267600 Net Capital Gain Tax on Undeveloped Blocks 382400 Sale Proceeding of 2 Townhouses 1600000 1600000 1600000 Less: Cost of 3 Townhouses 1067600 1067600 1067600 Capital Gain on 3 Townhouses 532400 532400 532400 Less: 50% Exemption 0 266200 266200 Net Capital Gain Tax on Townhouses 532400 266200 266200 TOTAL TAXABLE INCOME 553750 -1035000 -762600 -502600 106200 1706200 1590000 Tax on Taxable Income 230872.5 0 0 0 31860 511860 477000 Deductibility of interest incurred on contingency funding options: As stated under section 8-1of the income tax assessment act 1997 interest incurred on the contingency funding are the monies which is raised by Ryan and Alex through are deductible. The rulings specifically state that the payments are deductible under the positive limbs of section 8-1 of the Income Tax Assessment Act 1997 as an expense of generating income as opposed to the application of income generated (Mehrotra et al., 2013). Analysis of structure: From the study it is evident that the two brothers are not planning to consolidate both the units however it is better advised that a partnership form of control would add significant advantage with complete control over one property. It is further recommended that the interest of the property should be vested equally in each others control and trusteeship form of property management would constitute as an advantageous step forward in managing the ownership of land. To further justify the interest of beneficiaries an equal distribution of ownership would form an appropriate mode of holding equal rights on each property. Reference List: Althaus, C., Bridgman, P., Davis, G. (2012).The Australian policy handbook. 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OPTIONS FOR REFORMING AUSTRALIA'S GOODS AND SERVICES TAX. Woellner, R., Barkoczy, S., Murphy, S., Evans, C., Pinto, D. (2016).Australian Taxation Law 2016. Oxford University Press. Yong, S. E., Ma, M. (2015). A comparative study of the Goods and Services Tax (GST) implications on real property transactions in Australia and New Zealand. Zelinsky, E. A. (2016). Defining Residence for Income Tax Purposes: Domicile as Gap-Filler, Citizenship as Proxy and Gap-Filler.Michigan Journal of International Law,37.
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