Cat writing paper
College Essay Requirements
Thursday, September 3, 2020
MBA Admissions Essays :: MBA College Admissions Essays
MBA Admissions Essays à Consider the choices you have made in your life. Depict the accompanying: PAST: What decisions have you made that driven you to your present position? PRESENT: Why is a Wharton MBA important now in your life? FUTURE: What is your ideal situation upon graduation from the Wharton School? à I like alternatives, I like security, and I like force. With these needs, I knew at an early age that I would enter business and consequently I went to a school that has practical experience in the subject. In my first situation out of school, I was employed by Dunhill Equities as a cool guest. Following a little while of being hung up on by furious possibilities, I concluded that this vocation way would not lead me to progress. I at that point moved inside the firm to a situation as deals aide. While this was in no way, shape or form my fantasy work, I took in a gigantic sum about business, and I increased valuable presentation to the universe of account. Sadly, the organization hit a time of insecurity, and following ten months I moved with my manager to Coleman and Company. After thirteen months, that organization additionally started to fall flat, and I started to look for another way to progression. With two negative marks against me, I hit a grand slam and was employed by Sanfo rd Bernstein into a difficult activity with boundless open door for development. à After right around three years at Bernstein, I am by and by looking for professional success. My instruction and work experience have given me a brilliant prologue to business, and they have started my enthusiasm for account. Mulling over my establishment and my inclinations, graduate business college is the following consistent advance. Now in my life, I believe a Wharton MBA to be essential since I have to increase a more extensive comprehension of account and to hone my diagnostic abilities so as to be fruitful in corporate money. Wharton's MBA program will permit me to gather in fund, fortify my worldwide business viewpoint, and furnish me with the chance to concentrate with and gain from individuals with fluctuated foundations. The school's area in the money related capital of the world and in one of the most assorted urban communities on the planet likewise suits me consummately. à Beside propelling my vocation, I might likewise want to grow by and by. In school I didn't join numerous clubs or associations, and I didn't take an interest in sports.
Saturday, August 22, 2020
How Do I Get Help With My Research Paper?
How Do I Get Help With My Research Paper?Many students are worried about writing a thesis for their college courses and wonder how to get help. There are many ways that they can look at, but how do you know which one is right for you? Here are some ideas to get you started on your search for help.Start by searching online - There are many websites that are dedicated to helping students in this situation, and if your school is offering a student writing service, they might be able to help you out. You can also seek help from a local writing tutor or a graduate student. Some students may prefer to self-edit their papers, and the writing tutorials available online allow them to do just that.Find out who your teacher is - Many students are unsure how to start their research paper, but you should find out how your professor is grading it before you start looking for help. If he or she is giving you credit that does not fit with the grade you are expecting, it is best to change courses and work with someone who will help you gain a more accurate reflection of the work you have done. Your professor can help you learn how to go about writing your own thesis, but keep in mind that you need to have a solid grasp of the subject matter in order to prepare yourself for writing an appropriate research paper.Look for academic writing workshops - If you have a question that is difficult to answer, or you need some assistance with editing your paper, consider consulting with a workshop that provides technical writing assistance. Many college instructors offer such workshops for a small fee. This is not the only way to get help with your research paper, but it is a cost effective option that many students like to use. You may want to consider turning in your paper to someone who offers this type of service as well, so that they have it on hand when you need it.Look for self-help books - Another place that many students turn to when they need help is to find a good book that will give them advice on writing papers. Many of these books focus on topics that are similar to what you are working on, and they often offer writing tips that can make writing a research paper easier. Some of these books are available in libraries, and other people will even mail copies to students who ask for them.Contact a tutoring service - Some schools offer editing services that can help students learn how to revise their papers properly. Some students feel that they cannot improve upon their work, while others feel that they can do more. You should contact the editor to see if they can assist you in this area, as they might be able to set up a schedule that works for you.Get help from another professor - Many professors offer advice to students who need help writing their own research paper. The professors might be able to help you determine how you should begin your research paper, and they might even offer tips on how to revise your research before it is due. As you might expe ct, this is not a free service, but it can be useful.Once you have figured out which steps to take, it's time to get your paper in the mail. If you use self-help materials, it is also best to use a professional copy editor to proofread your paper before sending it to the professor. It is best to hire someone who has an in-depth knowledge of research papers, and someone who knows what it is like to write a research paper.
Friday, August 21, 2020
The Problem of Pornography Essay -- Argumentative Essay, Censorship 201
à In the United States somebody must be eighteen years of age before they can purchase sex entertainment, yet in light of the fact that they must be eighteen to get it doesn't mean they need to be eighteen to take a gander at it. Wherever around the Internet one may discover erotic entertainment where anybody, including kids, may take a gander at it. Sex entertainment isn't something to be glad for and isn't something that our kids ought to have the option to see arbitrarily on the Internet or in a store at a youthful age. à â â â â â â â â â â In Susan Brownmillers article, Lets Put Porn Back in the Closet, she contends that sex entertainment speaks to scorn of ladies, that pornographys goal is to mortify, corrupt, and dehumanize the female body with the end goal of sensual incitement and joy, which I totally concur with. (Brownmiller 53.) Women that regard themselves or other ladies could never model for a sex entertainment. Individuals ought to never take a gander at a lady as though they are only an article in a magazine or film. Ladies ought to be regarded thus should their protection. à â â â â â â â â â â When I was growing up, erotic entertainment was not something peopl...
Monday, June 8, 2020
7 Tips on How to Write a Reasonable Research Critique
7 Tips on How to Write a Reasonable Research Critique The major ââ¬Ëkey elementsââ¬â¢ when writing a reasonable research critique are the study and criticism that are ultimately performed as well as the writing results. Some very simple tips in the sense of ââ¬Ëmagic rulesââ¬â¢ are presented below. Tip #1. The collection of literature is typically gradual. For every book or article that we use, we follow the procedure below. First we perform a diagonal reading to determine the relationship of the text with our subject and the degree of the significance of the text. The evaluation of a text can also be done indirectly from the number of petitions, the size of literature, and the relation to the subject of research in the summary or results. Then we incorporate in our literature, some keywords for grouping related texts. Then they shall be read as references (i.e. fragments). Tip #2. Books are interesting in the early stages, as background reading. The articles show much more interest, because they present research results and because in order to write a research paper you should first read many others. Additionally, conferences articles are interesting when they are very recently written (e.g. 2-3 years maximum). Otherwise, there will probably be plenty of corresponding articles in academic journals by the same authors, which usually are more complete and organized. Tip #3. Articles or book chapters must be selected as the first group of interest together and be evaluated as a whole. In other words, several work teams internationally can be engaged in the same or similar subject, so you must decide what approaches are most interesting for your own work. Tip #4. Keep a brief note stuck on the article so as to remember the criticism you did. This is called horizontal or comparative reading. A good benchmark of research papers in a cognitive domain can be an interesting review article (review paper) especially if it is accompanied by repeatedly deeper criticism; comparison and experimental (or theoretical) results. Tip #5. Eventually, some articles or book chapters which you choose to analyze in depth are left (vertical reading). Such articles should be read carefully and you must try to reproduce their entire theoretical and experimental data. Take special care of them; not be boxed in intentional or unintentional oversights of the authors. There are always less well written articles. Also, you can try to get help from the authors (by e-mail). Besides, many times in the authors website you can find internal research reports, containing the results of articles in an expanded form. Tip #6. Generally, above all these tips, the composition of an article can at least in principle be achieved by ââ¬Ëloansââ¬â¢ from other articles. ââ¬ËLoansââ¬â¢ may be reported on the structure, the experimental methodology, text parts etc. The necessary thing is the full reference to the source from which you got the ââ¬Ëloanââ¬â¢. Tip #7. Finally, it is clarified that critic thought is inextricably linked to the object of analysis. If you need more professional research paper help online, visit our writing service and get a custom written paper online.
Sunday, May 17, 2020
Jimmy Hoffa, Legendary Teamsters Boss
Jimmy Hoffa was the controversial boss of the Teamsters Union when he became nationally famous for sparring with John and Robert Kennedy during televised Senate hearings in the late 1950s. He was always rumored to have substantial organized crime connections, and eventually served a sentence in federal prison. When Hoffa first became famous, he projected an aura of a tough guy who was fighting for the little guy. And he did get better deals for the truck drivers who belonged to the Teamsters. But rumors about his links to the mob always overshadowed whatever legitimate accomplishments he had as a labor leader. One day in 1975, a few years after his release from prison, Hoffa went out to lunch and disappeared. At the time it was widely believed he was planning a return to active involvement in the Teamsters, and it was widely assumed that he was the victim of a gangland execution. The search for Jimmy Hoffa became a national sensation and searches for his body have periodically popped up in the news ever since. The mystery about his whereabouts spawned countless conspiracy theories, bad jokes, and enduring urban legends. Early Life James Riddle Hoffa was born in Brazil, Indiana, on February 14, 1913. His father, who labored in the coal industry, died of a related respiratory disease when Hoffa was a child. His mother and Hoffas three siblings lived in relative poverty, and as a teenager Hoffa left school to take a job as a freight worker for the Kroger grocery store chain. In Hoffas early union days he showed a talent for exploiting an opponents weakness. While still a teenager, Hoffa called a strike just as trucks carrying strawberries arrived at a grocery warehouse. Knowing the strawberries wouldnt keep for long, the store had no choice but to negotiate on Hoffas terms. Rise to Prominence The group Hoffa represented, known locally as the Strawberry Boys, joined a Teamsters local, which later merged with other Teamsters groups. Under Hoffas leadership, the local grew from a few dozen members to more than 5,000. In 1932, Hoffa moved to Detroit, along with some friends who worked with him at Krogers, to take a position with Teamsters locals in Detroit. In the labor unrest during the Great Depression, union organizers were targeted for violence by company goons. Hoffa was attacked and beaten, by his count, 24 times. Hoffa picked up a reputation as someone who wouldnt be intimidated. In the early 1940sà Hoffa began to establish links with organized crime. In one incident, he enlisted Detroit gangsters toà run off a rival union from the Congress of Industrial Organizations. Hoffas connections with mobsters made sense. The mob protected Hoffa, and the implicit threat of violence meant his words carried serious weight. In return, Hoffas power in the union locals let mobsters intimidate local business owners. If they didnt pay tribute, the truckers who made deliveries could go out on strike and bring business to a standstill. Connections with mobsters became even more important as the Teamsters amassed a vast amount of money from dues and payments into pension funds. That cash could finance mob ventures, such as the building of casino hotels in Las Vegas. The Teamsters, with Hoffas help, became a piggy bank for organized crime families. Sparring With the Kennedys Hoffas power within the Teamsters grew in the early 1950s. He became the unions top negotiator in 20 states, where he famously fought for the rights of the truck drivers he represented. The rank and file workers came to love Hoffa, often clamoring to shake his hand at union conventions. In speeches delivered in a gravelly voice, Hoffa projected a tough guy persona. In 1957, a powerful U.S. Senate committee investigating labor racketeering began to hold hearings focused on the Teamsters. Jimmy Hoffa came up against the Kennedy brothers, Senator John F. Kennedy of Massachusetts, and his younger brother Robert F. Kennedy, a counsel to the committee. In dramatic hearings, Hoffa tangled with the senators, parrying their questions with streetwise quips.à And nobody could missà the particular dislike Robert Kennedy and Jimmy Hoffa had for each other. When Robert Kennedy became attorney general in his brothers administration, one of his priorities was to put Jimmy Hoffa behind bars. A federal case against Hoffa finally did convict him in 1964. After a series of appeals, Hoffa began serving a federal prison sentence in March 1967.à Pardon and Attempted Comeback In December 1971, President Richard Nixon commuted Hoffas sentence and he was released from prison. The Nixon administration included a provision with the commutation that he not become involved with union activity until 1980. By 1975, Hoffa wasà rumored to be exerting influence within the Teamsters while officially having no involvement. He told associates, and even a few journalists, that he was going to get even with those in the union and the mob who had betrayed him and helped send him to prison. On July 30, 1975, Hoffaà told family members he was going to meet someone for lunch at a restaurant in suburban Detroit. He never returned from his lunch date, and he was never seen or heard from again. His disappearance quickly became a major news story across America. The FBI and local authorities chased down countless tips, but actual clues were scant. Hoffa had vanished, and was widely assumed to have been the victim of a mob hit. Disappearance As a peculiar coda to such a tumultuous life, Hoffa became eternally famous. Every few years another theory of his murder would emerge. And periodically the FBI would receive a tip from mob informant and send crews to dig up backyards or remote fields. One supposed tip from a mobster grew into a classic urban legend: Hoffas body was rumored to be buried under the end zone of Giants Stadium, which had been built in the New Jersey Meadowlands at roughly the time Hoffa had disappeared. Comedians told jokes playing on Hoffas disappearance for years. According to a New York Giants fan site, sportscaster Marv Albert, while broadcasting a Giants game, said a team was kicking toward the Hoffa end of the stadium. For the record, the stadium was demolished in 2010, and no trace of Jimmy Hoffa was discovered under the end zones.
Wednesday, May 6, 2020
Standardized tests in Illinois Essay - 978 Words
nbsp;nbsp;nbsp;nbsp;nbsp;Standardized tests are administered to allow reliable and valid comparisons to be made among students taking the test. Two major types of standardized tests are currently in use; norm-referenced and criterion-referenced. A norm-referenced test is a test that has been given to representative samples of students such that norms of performance are established. Each student taking the test receives a score that can be compared to the norm or normal or sample of students. The scores are then reported in percentiles. The main purpose of these tests is to rank students along a distribution of performance. Because of this tests are likely to have items that are very difficult for the grade level so students can beâ⬠¦show more contentâ⬠¦It also serves as a way for colleges to determine if a student is qualified to be admitted to the school. This test is a multiple-choice test that covers four areas: Math, Reading, English, and Science. nbsp;nbsp;nbsp;nbsp;nbsp;These tests use reasoning, analysis, problem solving, and what your previous knowledge of the subject is. It measures the kinds of tasks that college students are expected to learn (http://www.act.org, 2004). nbsp;nbsp;nbsp;nbsp;nbsp;The math part of the section contains 60 multiple-choice questions within a 60 minute section. The English part has 75 multiple-choice questions within a 45 minute section. So time is a factor. The reading part has 40 multiple-choice questions within a 35 minute sections and science has 40 multiple-choice questions within a 35 minute section. nbsp;nbsp;nbsp;nbsp;nbsp;ââ¬Å"Taking the Scholastic Aptitude Test (SAT) and the American College Test (ACT) is perhaps the single most important event in a college-bound studentââ¬â¢s junior-senior yearâ⬠(McManus, amp; Luger, 1991). Each collegeââ¬â¢s requirements are different in allowing students to be admitted. You might have a high grade point average but score fairly low on your ACT but still be admitted. In vice-versa you might have a high ACT score but a low grade point average and still be admitted, also. nbsp;nbsp;nbsp;nbsp;nbsp;The SAT are standardized tests, formally called the Scholastic Aptitude Tests and are used by most collegesShow MoreRelatedEssay On Stop Common Core1108 Words à |à 5 PagesStop Common Core Illinois is a non-partisan community of Illinois citizens united by our concerns about Common Core in Illinois. We are the typical people you can see whenever you open your garage doors to take your car out every morning. 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AYP or ââ¬Å"adequate yearly progressâ⬠is a measurement of how students perform in proficiency tests, is a very important factor in NCLB. If a school fails to record AYP for their students then the school is going to suffer from monetary and organizational sanctions. OrRead MoreCommon Core And Standardized Assessments Essay1506 Words à |à 7 PagesCommon Core Standardized Assessments Assignment Template Use this template to complete the Common Core State Standards assignment. Type your responses in between the brackets [Like this!] Reflecting on Your Research: Summarize the current state of the Common Core (and associated national standards) in the United States using the assigned readings. [The Common Core standards are currently implemented in 43 states and the District of Columbia. All of the states who use Common Core can be an
Australian Taxation Oxford University Press ââ¬Myassignmenthelp.Com
Question: Discuss About The Australian Taxation Oxford University Press? Answer: Introduction The determination of tax residency for a taxpayer is very critical on account of the differential treatment that is extended to a particular taxpayer based on the underlying tax residency. This essentially is not limited to the sources of income that are taken into consideration but also the tax rate that are applied. The ATO offers differential tax rates and concessions for resident and non-resident taxpayers. In the wake of this differential treatment, it becomes pivotal to outline the tax residency and then apply the same based on the given facts of the taxpayer. Relevant Rule The nodal statute for tax residency status determination is subsection 6(1), ITAA 1936. This section tends to highlight the various conditions which in turn determine the tax residency of an individual for the financial year under consideration. Further, a tax ruling TR 98/17 is also found to be useful as it lists down the various tests that are available to individual taxpayers. For any individual, in order to get the tax residency, the only criterion is that one of those tests needs to be satisfied (ATO, 1998). As per TR 98/17 along with the subsection 6(1), ITAA 1936, the following tests for ascertaining individual residency status are available (Barkoczy, 2017). Domicile test In order to oblige with this test, there are two main conditions that need to be fulfilled. The first condition pertains to the respective taxpayer being an Australian domicile holder in accordance with the applicable statute i.e. Domicile Act 1982. Another condition that needs to be fulfilled is that the permanent abode of the individual taxpayer must be situated in Australia for the year under consideration. Failure to comply with either of the conditions would lead to non-fulfilment of this test and non-confirming of the Australian tax residency. Based on the underlying conditions, it becomes apparent that this is useful in determining tax residency of Australian domicile holders who tend to stay abroad for extended length of period on account of myriad reasons (Sadiq et.al., 2016). Resides test The word reside finds no mention in the statute law and hence reliance on various court cases and tax rulings commentary is the only source to determine the underlying parameters considered for this test. The key factors in this regards are outlined as follows (Nethercott, Richardson and Devos, 2016). The first factor takes into account the reason for which the taxpayer enters into Australia. In this regard, the higher the significance, the higher the chances of the taxpayer being termed as Australian resident. The significant reasons could be employment (more than six months preferably a year) along with education. In accordance with the IRC v Lysaght [1928] AC 234 case, another key parameter to be considered is the visit frequency to country or origin along with the underlying reason and the duration of such visits. The strength of personal and professional ties that the individual taxpayer has in Australia and country of origin needs to be compared as it is indicative of the commitment of an individual towards Australia. Also, the nature of social life that the taxpayer tends to reside in Australia and the similarity of the same to the life in the country of origin is also a significant factor. Along with the above factors, if required then the nationality of the taxpayer is also taken into consideration for tax residency determination. Superannuation test This above test is very specific and applied only for those taxpayers who are government employees and have to serve abroad due to foreign consignments or deputation on duty for these employees. The tax residency of these employees is dependent on their participation in the specific superannuation funds by way of regular contributions. If the obligation in relation to the dedicated superannuation fund is complied with, then irrespective of other conditions such as the duration of stay, visit of Australia, presence of family would not be considered and the underlying taxpayer would be classified as Australian tax resident (Woellner, 2014). 183 day test This given test is applied for determining the tax residency of foreign residents. In order to comply with the given test, the respective taxpayer needs to fulfil the conditions that have been outlined below (CCH, 2013). The respective taxpayer should have spent 183 days at a minimum in Australia being physically present in the financial year for which the tax residency is under consideration. It is not essential that this stay should be at one go or continuous and hence can be done on intermittent basis. Also, it is essential that there must be intention on the part of the taxpayer to settle on a permanent basis in Australia in the long term. This intention may be expressed through actions in this regard or an explicit statement regarding the future intent. Failure on the part of the taxpayer to comply with either of the two conditions outlined above would imply that the concerned taxpayer would not be categorised as a tax resident of Australia (Deutsch et. al., 2016). The relevant facts are summarised as indicated below. The country of origin for Minh is Malaysia. A work visa was granted to Minh in June 2016 and he migrated to Australia with family with the intention of starting a business. A family home is purchased in Melbourne where he starts living with his wife and children. However, Minh continues to have strong business interests in Malaysia and hence needs to stay there for quite some time. Meanwhile his family continue to stay in Australia and the children are enrolled in local school. In the wake of the above facts, the tax residency of Minh (the taxpayer) needs to be determined for 2016/17. The domicile test would not be applicable for Minh as he does not possess a domicile of Australia since he has just migrated to Australia on a work visa. Also, the superannuation test is not applicable in case of Minh as he is not a government employee who is serving abroad. Further, 183 day test would be applicable for Minh considering that that he is not an Australia resident. However, based on the information provided, it is apparent that Minh has spent only 120 days in Australia in the year FY2017 and thus fails to satisfy the minimum stay period condition of 183 days. Further, the intention to settle in Australia is also lacking on part of Minh. Hence, this test is failed. The last test that is applicable is resides test. However, even though his reason for migration is significant in terms of employment and subsequent business but he has not established any business in Australia. Further, for more than half the year, he continues to be in his country of origin maintaining very strong professional ties (stronger than Australia). Also, he maintains a flat in Kuala Lumpur and has cultural and social ties as well. Thus, considering the above, it would be fair to infer that this test is also failed. The main concern is to determine the impact of residency of Minh on the tax treatment extended to the investment income and assessibility of business income that is being earned from Malaysia. The tax residency is vital primarily because the assessable income determination is driven by the same. In accordance to s. 6-5(2) ITAA 1997, in case the given taxpayer is not a tax resident of Australia, then only the income arising from Australia would be taxable in Australia (Barkoczy, 2017). The foreign income if any for such a taxpayer would not be assessable in Australia. On the other hand, as per s. 6-5(3) ITAA 1997, in case the given taxpayer in an Australian tax resident, then the income from all the sources (i.e. domestic and foreign) would be taken into consideration for computation of assessable income and determining of the tax liability (Nethercott, Richardson and Devos, 2016). As has been highlighted above, Minh for the year 2016-17 is a foreign tax resident. Thus, in accordance with the relevant statute, no foreign income would contribute to assessable income. As a result, the business income along with investment income that is procured from Malaysia would be considered as foreign income and hence would not be subject to any taxation in Australia. No tax would be levied on the income that Minh derives from Malaysia in the form of investment and business income as these are categorised as foreign income and the same is not assessable for foreign tax residents such as Minh. For deriving assessable income, there are various means that have been prescribed in the tax law prevalent in Australia. In wake of the same, it is imperative that the various provisions regarding the same are outlined and then applied to the given case. Further, the amount of tax liability amounting from the application of different rules would also tend to vary which has also been outlined. Besides, the most likely scenario in relation to application of statute would be identified taking into consideration the available facts along with relevant case law and tax rulings. The key concern in this given case is to ascertain the three alternative ways in which the sales proceeds arising from the three townhouse sales can be recognised with regards to tax purpose. One of the key sections pertaining to assessable income is s. 6(5) ITAA 1997. It highlights that the income derived from ordinary concepts are referred to as ordinary income. Based on case laws and tax rulings, a plethora of sources have been identified in this regards. One of these is business income which along with employment income contributes to assessable income. However, it is essential to segregate business activity and hobby by considering the various measures identified in the commentary of the Evans v.F.C. of T(1989) 20 ATR 922case (Gilders et. al., 2016). While any regular business or employment activities for earning money is assessed under s. 6(5), any isolated transactions which has been enacted by the taxpayer in order to earn money is assessed under s. 15(15) ITAA 1997. The only main criterion for this section is that from the outset, there must be an intention to earn profit which has been the key driver prompting the taxpayer to undertake the activity (Sadiq et. al., 2016). Another contributor to assessable income is in the form of statutory income. As the name suggests, for this particular income, there are dedicated statute which need to be referred to. One of the key contributors to statutory income is in the form of capital gains. These typically would realise when there is sale of any capital asset. Assuming that this sale does not constitute the business of the underlying taxpayer, the proceeds would be capital in nature and hence tax free (CCH, 2013). However, considering the asset cost base and the sale price of the asset, it is possible that the capital gains may have been derived by the taxpayer under s. 104-8 ITAA 1997. In case of these capital gains, these would contribute to the income of the taxpayer which would be subjected to capital gains tax (Barkoczy, 2017). In the light of the given facts where Pennys profession is not stated, it could be assumed that she is a contractor who deals in real estate properties. As a result, she borrowed money and conducted business operations by constructing four identical homes and selling three of these identical houses while retaining the fourth for her private use. Thus, the proceeds that would be derived from sale of three houses would be termed as assessable income under s 6(5) and taxable income would be derived post adjustment for deductible expenses. In this case, it is assumed that Penny is not in the profession of contracting or dealing with real estate properties. As a result, the profits that the taxpayer Penny derives on account of an isolated transaction would be termed as assessable income under s.15(15). The presence of profit motive behind sub-dividing is apparent. Also, the using of marketing services for deriving the optimum selling price further indicates the intent to maximise profit which is what prompted the construction of four houses at the first place. In this case, it is assumed that intention to profit was not present for Penny and hence the taxpayer has merely realised a capital asset which was purchased earlier. In such a scenario, the proceeds from the sale of the house would be termed as capital proceeds which would not be taxed. However, capital gains would be computed on the same and CGT would be paid on the net capital gains available after any deduction and concessions that may be applicable. Hence, the given transaction can be recognised through the use of s. 6(5) (Assessable income), s. 15(15) (Isolated transaction profits) or s. 108(10) (Capital gains). The assessable income under alternative approaches needs to be determined. Alternative Approach 1: Assessable income (s. 6(5)) Total proceeds derived from the sale of the three houses = $ 3 million Cost of construction for four houses = $ 1million Assuming proportionate division of expenses, construction cost for three houses = (3/4) *1 = $ 0.75 million Further cost of the vacant land = $ 1 million Assuming equal land area division for all the four houses, land cost for three houses = (3/4) *1 = $ 0.75 million Hence, deductions would be available for the above expenses and then taxable income would be computed (Gilders et. al., 2017). Alternative Approach 2: Assessable income (s. 15(5)) Total proceeds derived from the sale of the three houses = $ 3 million Cost of construction for four houses = $ 1million Assuming proportionate division of expenses, construction cost for three houses = (3/4) *1 = $ 0.75 million Further cost of the vacant land = $ 1 million Assuming equal land area division for all the four houses, land cost for three houses = (3/4) *1 = $ 0.75 million Hence, profits = 3-1.5 = $ 1.5 million The above amount would be considered as assessable income under this approach (Woellner, 2014). Alternative Approach 2: Assessable income (s. 108(10) Cost base of the property = Cost of land + Cost of construction = $1 million + $ 1 million = $2 million However, the above is for the whole property which consists of four houses, hence the cost base needs to be adjusted accordingly = (3/4)*2 = $ 1.5 million Proceeds from the sale of the three houses = $ 3 million Hence, capital gains = 3-1.5 = $ 1.5 million Assuming that the sale happened within 12 months of purchase of land, hence the discount method is not applicable and hence CGT would be applicable on the complete capital gains of $ 1.5 million derived above (CCH, 2013). It is noteworthy that the marketing cost for sale of house has been considered to be zero for this computation. It would be inappropriate to assume that Penny is a builder or contractor and therefore the derived proceeds should not be considered as assessable income under s. 6(5). In relation to capital gains, it would have to be assumed that the activity of Penny particularly in relation to sub-division was not related to profit making. Clearly, this is not the case since she borrowed money as she clearly had the hope that she can sell these houses for a higher amount and hence make profits from land subdivision. Thus, while the purchase of land was essentially not driven by profit, it is very apparent that construction of the four identical house and relevant subdivision coupled with marketing are driven by profit motive (Barkocy, 2017). Hence, it would be appropriate to realise the profits from this isolated transaction as assessable income under s 15(15). Conclusion On the basis of the above discussion, it is apparent that the given sale of subdivided houses would be regarded under the aegis of s. 15-15 ITAA 1997. This is because the sub-dividing activity seems to be driven from profit motive which is confirmed through the use of marketing services for higher price extraction. Hence, the assessable income would essentially comprise of the profits that the taxpayer tends to derive on the sale of the three houses. References ATO (1998), Rulings: TR98/17, ATO Website, [online] available at https://www.ato.gov.au/law/view/document?Docid=TXR/TR9817/NAT/ATO/00001 [Accessed September 25, 2017] Barkoczy,S. (2017), Foundation of Taxation Law 2017, 9thed.,North Ryde: CCH Publications CCH (2013), Australian Master Tax Guide 2013, 51st ed., Sydney: Wolters Kluwer Deutsch, R., Freizer, M., Fullerton, I., Hanley, P., and Snape, T. (2016), Australian tax handbook 8th ed., Pymont: Thomson Reuters, Gilders, F., Taylor, J., Walpole, M., Burton, M. and Ciro, T. (2016), Understanding taxation law 2016, 9th ed., Sydney: LexisNexis/Butterworths. Nethercott, L., Richardson, G. and Devos, K. (2016), Australian Taxation Study Manual 2016, 4th ed., Sydney: Oxford University Press Sadiq, K, Coleman, C, Hanegbi, R, Jogarajan, S, Krever, R, Obst, W, and Ting, A (2016) ,Principles of Taxation Law 2016, 8th ed., Pymont:Thomson Reuters Woellner, R (2014), Australian taxation law 2014, 7th ed., North Ryde: CCH Australia
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