bluuebunny/crossref_metadata_2025_split huggingface dataset:
The Progress of the Japanese National Consumption Tax
Authors: Beyer Vicki , Ishimura Koji 
Published: June 2021

On 1 April 1989, a broad-based natioal consumption tax went into effect in Japan. The tax was unpopular, but is gradually being accepted. In the four years since its inception, he tax has undergone a few minor adjustments to facilitate its smooth operaion, but unlike consumption taxes in many jurisdictions, has yet to see a rate rise. This is partly because of public reluctance toward the tax. This article surveys the history of Japan’s national consumption tax, analyses the structure of the tax and its reception by taxpayers, and comments on its future.
Peabody v FCT and Part IVA
Authors: Cassidy Julie 
Published: June 2021

The courts were only recently given their first opportunity to consider the substantive operation of Part IVA of the Income Tax Assessment Act 1936 (Cth) in the trilogy of Peabody v FCT. Given the potential scope of Part IVA, an understanding of the Courts’ appraisal of the legislation’s breadth is crucial for all taxation practioners. Whilst aspects of the High Court’s judgment particularly its view as to the Commissioner’s discretion under s 177F, may cause taxpayers concern, other aspects of the judgment affirm the existence of significant limits upon Part IVA’s scope. When coupled with Hill J’s acceptance that transactions entered into for commercial reasons are not caught by Part IVA, it is submitted that Peabody provides an appropriate balance between preventing tax avoidance and not discouraging business and family transactions.
International Tax Education
Authors: Prebble John 
Published: June 2021

Government and commercial organisations that have to do with income tax devote a good deal of time and money to the continuing education of their staff. Professor Prebble’s article offers a philosophical basis and a theoretical framework for such education, and suggests an approach to curriculum planning and programme design for the education of people who work in the area of international taxation. The article advocates the adoption in curriculum planning of the kaizen approach that has been developed from W Edwards Deming’s seminal work on management theory and offers syllabuses of topics and skills that could be included in continuing education curricula.
Book Review
Authors: Bentley Duncan 
Published: June 2021

[Extract]Adrian Ogley, Principles of Value Added Tax, 1998, Interfisc Publishing, , ISBN 0-9520442-1-8, 239 pages. As Australia moves to introduce the GST from 1 July 2000, it is easy to get lost in the minutiae of the GST rules and forget the bigger picture. Most Australian advisers have yet to come to grips with the big picture planning for GST that will soon become an essential part of their daily work. The focus is on understanding the detail of the legislation and its application. This book provides a European insight into the principles of planning in a consumption tax regime.
Japan’s Income Tax System - Lessons for Australia
Authors: Dabner Justin 
Published: June 2021

The Japanese income tax system was redesigned following World War II. As such it has features of the systems of both Europe and the United States, although in many respects it is quite unique. Whilst it arguably contributed to Japan’s meteoric rise to the status of an economic superpower, little analysis of the Japanese income tax system from an Australian perspective has been attempted. This paper explores certain unique features of the Japanese income tax system with a view to identifying whether they are worthy of adoption in Australia.
Taxation of Employee Stock Option Plans : International Principles
Authors: Khincha H Padamchand 
Published: June 2021

As taxation policy seeks to recognise substance over form, it is important to view ESOPs as a whole at the international level, in the same way as they are generally given special treatment at the national level. The problem will become more acute as the labour market becomes more mobile. Increasingly, ESOPs are used to reward senior executives. As long as they fall within the favourable or particular treatment given to ESOPs in most jurisdictions, there is scope for significant double or non-taxation.
The Meaning of Income : the Implications of Stone v FCT
Authors: Dr Braedon Clark 
Published: June 2021

In the recent case of Stone v FCT, the Australian Federal Court had difficulty in determining whether grant payments made to an elite athlete should be characterised as income. Both levels of the Court determined the character of the payment based on a whether or not Ms Stone was carrying on a business or merely pursuing a hobby. This article argues that the distinction between a business and hobby should not blur the interpretation of what constitutes income according to ordinary concepts. The suggested threshold of when voluntary payments received by an athlete will attain the character of income should be when the individual commences commercially exploiting their personal attributes for money.
The Interpretation of Taxation Legislation by the Courts - A Reflection on the Views of Justice Graham Hill
Authors: Tretola John 
Published: June 2021

This article looks at the changing approach that both the Australian High Court and the House of Lords have taken over the last 70 or so years in interpreting taxation legislation. This changing approach reflects underlying changes in community attitudes. Particular consideration is given to the High Court’s changing interpretation of the general anti‐avoidance provision (formerly s 260 and now Part IVA of the Income Tax Assessment Act 1936). The article focuses on the observations of Justice Graham Hill and his Honour’s views as to the correct approach for a court to take in interpreting taxation legislation. His Honour made it clear that a court should adopt a purposive approach by applying the ordinary meanings of the words used, to give effect to the legislative purpose behind the legislation. This approach requires looking to the context of the legislation in its widest sense to give effect to the objects of the legislation. However, such an approach should not be used to advance any personal theories of justice. Justice Hill was widely regarded as having been the leading Australian tax judge for more than a decade before his untimely death in 2005.
There are Too Many Witchdoctors in Our Tax Courts : Is There a Better Way?
Authors: Dabner Justin 
Published: June 2021

The traditional methodology employed by the judiciary in tax cases leads to narrow definitional debates separate from a consideration of policy and principle. With each new case we expect a resolution of fundamental issues and some clarity. But this is rarely achieved and the uncertainty and ambiguity associated with our tax laws compounds. We need to depart from the traditional methodology and embrace an approach in which the judiciary expressly acknowledges policy considerations when deciding hard tax cases. Thus our legal witchdoctors need to embrace a new methodology. Such an approach can be demonstrated by reference to recent general anti-avoidance cases.
Policy and Fiscal Effects of Swiss Bank Secrecy
Authors: Chaikin David 
Published: June 2021

Bank secrecy has provided a significant competitive advantage to Switzerland in its development as an international financial centre. The ‘Rolls Royce’ image of Swiss bank secrecy is not merely determined by its legal components, but also by its underlying philosophy, and the perceived discretion, honesty and efficiency of the Swiss banking system. Although bank secrecy in Switzerland has been diluted by the enactment of new financial crimes, it continues to be unassailable in the case of fiscal offences. Switzerland has sought to protect its reputation by prohibiting bankers from actively assisting in flight capital and tax evasion, but this has had little effect on Switzerland’s position as the world’s leader in the management of offshore private wealth.
Still a Problem Child : Central Management and Control after RITA
Authors: Dirkis Michael 
Published: June 2021

The central management and control test for determining residency of a company has been problematic. The uncertainties in the test were addressed by Taxation Ruling TR 2004/15. The author believes the Ruling has done little to clarify the operation of the test. Legislative reform is recommended to ensure that the central management and control test does operate more effectively
When Is An Acquisition By A ‘Trust’ For GST Purposes?
Authors: Edmundson Peter 
Published: June 2021

The Australian GST regime treats trusts as entities separate from trustees. This article deals with the important but deceptively complex matter of when an acquisition is by a trust and when it is by a trustee. There are no cases on the issue and it is submitted that the Commissioner’s comments do not provide satisfactory guidance. For this reason an attempt is made to develop some guiding principles that are both practical and minimise the conceptual dissonance between the GST regime and the law of trusts.
The 1999 Review of Business Taxation: Should We Fast Track Small Business Tax Reform?
Authors: Kenny Paul 
Published: June 2021

This article examines the policy design processes associated with the 1999 Review of Business Taxation. Given the breadth of the Review’s recommendations, this article focuses on two of its enacted proposals, the non-commercial loss (NCL) rules and the Simplified Tax System (STS). Whilst this legislation closely followed the Review’s recommendations, the NCL and STS rules have been subject to much criticism by commentators, professional and government bodies. The STS proved to be very unpopular and was eventually scrapped on 30 June 2007. The NCL rules, though, have remained intact, notwithstanding the considerable angst of small business. This article analyses the Review’s problem identification processes. Its proposed solutions are investigated in the light of the experience with the enacted reforms. The article highlights the shortcomings of the Review’s problem identification and policy design processes. Taxation enquiries should adopt a more gradual, transparent and consultative approach in identifying and researching problems and in drafting taxation reform solutions. In particular there is a great need to carefully develop objectives for specific tax reforms and to build socio-economic modelling capabilities to forecast the fiscal adequacy, economic, equity and simplicity impacts, as well as to assess policy outcomes.
Tax Planning, Avoidance and Evasion in Australia 1970-2010: The Regulatory Responses and Taxpayer Compliance
Authors: Xynas Lidia 
Published: June 2021

This article examines tax avoidance strategies used by Australian taxpayers over the last four decades and analyses the regulatory responses by the government, noting a move away from the ‘command-and-control’ approach of the 1980s towards one of ‘responsive regulation’ and ‘meta risk management’. It is argued that despite inherent complexity issues, this regulatory approach has nevertheless contributed to the fostering of trust and a perception of fairness in the Australian tax system.
Taxation Of Gains From Banking and Insurance Businesses In New Zealand
Authors: Manyam Joel 
Published: June 2021

There has been major contest over the taxation of business income. Questions are twofold: the factual one of defining the boundaries of the business activity. Second, that of determining whether a particular gain comes within the ambit of ‘business’. Recent NZ cases have sought to apply the guiding principle - that it is not the size of the gain but the source of it that determines the taxation consequences. Logically, this principle should apply to specialist businesses such as those dealing with banking and insurance. However, the NZ Commissioner has, until 10 years ago, argued that it is the size rather than the source of the gain that is the determining criterion. And since the questions of what is the scope of the particular business activity and whether the particular gain has arisen in the course of such activity are purely factual ones, they are to be guided by the facts of each case. This article concludes that the decisions are indeed based on their particular facts. Further, it investigates how important it is for the taxpayer to ponder the strategy that is to underpin the particular business. The evidence of such strategy being in place and having the practical effect of guiding the decision making of the taxpayer company’s business activities are highly significant in determining the taxation consequences of such decision making. The consistency with which such corporate strategy or policy is formulated and implemented tends to determine their taxation consequences.
A leitura como prática intersemiótica: tópicos semantizadores e construção de sentidos
Authors: Oldoni Cristiano , Freitas Ernani Cesar de 
Published: June 2021

Os gêneros discursivos, essencialmente mestiços na contemporaneidade digital, têm acompanhado os desafios propostos para as práticas de interação, de comunicação e de apreensão de sentidos: um mundo de intensas multissemioses exige que os sujeitos desenvolvam competências específicas, que permitam verdadeiros encontros por meio de linguagens em associação e da leitura em rede. Por conta de tal panorama, propomos como objetivo deste estudo analisar a forma como engendramentos e associações semióticas articulam-se na construção de sentidos, promovendo a leitura multimodal da cena enunciativa de textos de gêneros digitais, em plataformas virtuais. Com a finalidade de melhor explorar esse processo, selecionamos como corpus uma postagem da rede social Instagram e procedemos com sua análise por meio do mapeamento de seus tópicos semantizadores. Esta pesquisa bibliográfica e documental, de abordagem qualitativa, aponta para a percepção da necessidade de sistematização das práticas de leitura em plataformas digitais, ancoradas em suportes virtuais.
Palavras-chave: Gêneros digitais; Plataformas virtuais; Multimodalidade discursiva; Leitura; Sentido.
The Interconnected Ancestral Network of Hip Arthroplasty Device Approval
Authors: Premkumar Ajay , Zhu Andrew , Ying Xiaohan , Pean Christian A. , Sheth Neil P. , Cross Michael B. , Gonzalez Della Valle Alejandro 
Published: June 2021

Background:
In the United States, the most overwhelming medical devices, including hip arthroplasty devices, are cleared for human use by demonstration of “substantial equivalence” to a predicate, previously approved marketed device. This study examined the predicate approval lineages of modern hip arthroplasty devices.

Methods:
The FDA 510(k) and premarket approval databases were searched to identify all approved hip arthroplasty devices since the database's inception in May 28, 1976. Ancestral predicate lineages were created using approval documentation, and FDA recall data were used to identify recalled devices.

Results:
Evaluating 2,118 hip arthroplasty devices approved from 1976 to 2020, we found that the number of descendant devices for each approved device varied from 0 to 242. Many descendant devices served as predicates for other devices, leading to frequent indirect connections of equivalency across a wide range of implants. Two hundred forty-six (11.6%) devices were recalled for various reasons, with 34 (1.6%) related to implant design. Evaluating the predicate lineage of 51 hip arthroplasty devices approved between May 1, 2019, and May 1, 2020, 32 of 51 (62.7%) devices were linked, directly or indirectly, to predicates which were recalled for design issues.

Conclusions:
The lineage of hip arthroplasty device predicates reflects a complex ancestral web of equivalency across a wide range of implants, although their material and design properties may be different. Several currently approved devices were approved on substantial equivalence claims to products that were subsequently recalled from the market for implant design issues. These findings present several policy considerations for regulators, physicians, and the medical device industry.
Characterization of Native Goat’s Production Systems in Eastern of the Democratic Republic of Congo
Authors: Birindwa Ahadi Bwihangane 
Published: June 2021

Phenotypic characterization of goats is an important step in the breeding sector, recognition and selection of breeds. This study assessed the various biometric morphological characteristics of goats in different farming systems in Eastern of Democratic Republic of Congo. A total of 90.6% of farmers practice goat’s free range. Imperata cylindrica, banana leaves and avocado nuts with the respective percentages of 100; 70.4 and 64.5 are the most common feeds for goats. Goats reared in sheds have an average body size at the withers (55,5 cm), a large weight (24 kg) and a large body length (80.1 cm) and livestock systems significantly influenced the total goats body length (p-value 0.03404 at 5%). The weight of adult goats is increasing in proportion to the length of the head (0.38), ears (0.01), tail (0.19), body (0.22), and chest circumference (0.66). Adult male animals have a bright higher average body size (26 kg) than females (21,8Kg). Almost 97% of investigated goats had tails and horns.
Processing and Properties of Oil Palm Fronds Composite Boards from Elaeis guineensis
Authors: Wahab Razak , Sukhairi Mat Rasat Mohd , Mohd Fauzi Norashikin , Saiful Sulaiman Mohamad , W. Samsi Hashim , Mokhtar Nasihah , Syazmini Mohd Ghani Ros , Haziq Razak Muhammad 
Published: June 2021

Oil palm fronds are one of the biomass residues originating from oil palm plantations. It has great potential to be used as an alternative material for the composite boards industry to reduce dependency on wood-based raw materials. The fronds are obtainable all the year round and in big quantity. The oil palm fronds had been processed as compressed oil palm fronds to form such a potential composite board in this topic. A composite board from compressed oil palm fronds was produced by removing the fronds’ leaflets and epidermis. The sample was sliced longitudinally into thin layers and compressed into an identical thickness at about 2 to 3 mm. Pieces of the sample were dry using the air-dried method. They were then mixed with phenol and urea-formaldehyde of resins in the range of 12-15% and compressed again with another layer forming a composite board. Standard outlined by the International Organization for Standardization (ISO) tested for their physical and strength properties of composite board. Found that the physical and strength aspects’ properties show that the composite board possessed characteristics at par or equivalent. The composite board from compressed oil palm fronds has good prospects to be used as an alternative to wood. Thus, this characteristics can overcome the shortage in materials supply in the wood-based industry.
Impact of Child Labour on Children’s Academic Activities in Krachi East District
Authors: Issaka Jacob , Adams Francis Hull , Gyimah Ethel , Kissi Barbara Amoako 
Published: June 2021

Child labour is one of the contemporary issues that has attracted the attention of many researchers. Most school children all over the world are engaged in child labour. This research investigates the effects of child labour on children academic activities in the Krachi East District in Ghana. The research adopted the mixed method. The purposive and snow ball sampling technique were used to select one hundred and sixty (160) victims of child labour. The questionnaire was the main instrument used for data collection. The questionnaire was edited by experts in child labour and this helped to achieve validity. Data were analysed using tables and figures. It was realized that 68.7% of the children were engaged in agricultural activities and the major reasons for their plight include large household size, parental illiteracy and poverty. Child labour leads to low academic performance. The study recommends that government should support children from poor homes.
Impact of Twice Weekly Hematinics on Hematological Parameters in Pregnancy
Authors: Musa G. D. , Daru P. H. , Damulak O. D. , Lucius I. , Anzaku S. A. 
Published: June 2021

Background: Anemia is prevalent in our setting for myriads of reasons hence iron supplementation has become a routine in the antenatal clinics; other regimens are practiced in other climes.
Aims: This study aimed at comparing the efficiency of the twice-weekly as against the daily iron supplementation on hematologic indices in healthy pregnant women.
Study design: This was a longitudinal prospective study
Place and duration of study: this study was carried out at antenatal clinic at the Jos university teaching hospital Jos plateau state of Nigeria over a period of 14 weeks.
Methodology: A total of 120 pregnant women were assigned by simple random sampling to receive either daily or twice weekly iron supplementation. Their blood samples were assessed by determining hemoglobin concentration, mean corpuscular volume and serum ferritin as baseline at booking visit from 16-24 weeks of gestation and follow up at 4, 8 and 14 weeks. All data
generated was analyzed using EPI info computer software version 3.5.2. The level of statistical significance was set at P<0.05.
Results: The twice weekly supplementation showed similar effects with the daily regimen with regards to the trends in Hb and serum ferritin. More women (77.1%) on twice weekly regimen had Hb>10g/dl at the 14 week visit compared with daily regime and this was statistically significant P=0.031.
Conclusion: These findings suggest that both regimens have about the same effect on hematological parameters during pregnancy. Therefore, in non-anemic pregnant women twice weekly iron supplementation may be used.
Acrylonitrile–Butadiene–Styrene (ABS) Polymers
Authors: Li Dejin , Wang Shi 
Published: June 2021

AbstractAcrylonitrile–butadiene–styrene (ABS) polymers are composed of elastomers dispersed as a grafted particulate phase in a thermoplastic matrix of styrene and acrylonitrile (SAN) copolymer. The presence of SAN grafted onto the elastomeric component, usually polybutadiene or a butadiene copolymer, compatabilizes the rubber with the SAN component. The property advantages provided by this graft terpolymer include excellent toughness, good dimensional stability, good processability, and chemical resistance. The system is structurally complex. This allows considerable versatility in the tailoring of properties to meet specific product requirements. Consequently, research and development in ABS systems is active. Numerous grades of ABS are available, including new alloys and specialty grades for high heat, flaming‐retardant, or static dissipative product requirements. Good chemical resistance combined with the relatively low water absorptivity (<1%) results in high resistance to staining agents. Antioxidants substantially improve oxidative stability. Applications involving extended outdoor exposure require the use of stabilizing additives, pigments, and protective coatings. In manufacturing, grafting is achieved by the free‐radical copolymerization of styrene and acrylonitrile monomers. The commercial processes for manufacturing ABS are discussed. ABS can be processed by compression and injection molding, extrusion, calendering, and blow molding. Postprocessing operations include cold forming, painting, and adhesive bonding. ABS is one the two major plastic materials used in 3D printing, an emerging additive‐manufacturing technology that is developing rapidly in the past couple of decades. As a “bridge” polymer between commodity plastics and higher performance engineering thermoplastics, ABS has become the largest selling engineering thermoplastic.