Release of draft legislation to “wind back” the 2010 tax consolidation changes and amend TOFA interactions - 19 April 2012

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Government introduces Bill on proposed changes to Part IVA

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Important changes to the operation of the general anti-avoidance rule under Part IVA of the Income Tax Assessment Act 1936 ("Part IVA") were introduced into Federal Parliament yesterday. Those changes, if legislated in their current form, will in some cases have a significant impact on how taxpayers and the Australian Taxation Office ("ATO") approach the potential application of Part IVA going forward.

The amendments are the culmination of significant debate concerning the ongoing effectiveness of Part IVA as a bulwark against tax avoidance and propose to alter the analysis for determining whether a taxpayer has obtained a tax benefit; one of the three key criteria which needs to be satisfied in the application of the general anti-avoidance rule under Part IVA.

Read our full Alert on the paper.

The Assistant Treasurer, David Bradbury, has today announced the release of exposure draft legislation and explanatory memorandum in relation to the previously announced amendments to the general anti-avoidance provisions in Part IVA of the Income Tax Assessment Act 1936. The proposed amendments are stated as addressing "technical deficiencies in the way in which Part IVA determines whether or not a tax advantage has been obtained in connection with an arrangement". The amendments are not intended to disturb the operation of Part IVA in any other respect.

The start date of the proposed amendments has been revised, and the measures will now apply to schemes entered into or commenced to be carried out on or after today, i.e. 16 November 2012.

Broadly, the amendments apply to: allow Part IVA to operate as an integrated wholeensure that when a conclusion that a tax benefit has been obtained depends upon a hypothetical reconstruction of what would have happened absent the scheme (as distinct from a straight forward application of the statutory postulate that the scheme, in its entirety, did not happen), the hypothesis focuses on other ways in which the taxpayer might reasonably be expected to have achieved the same non-tax effects as it achieved from, and in connection with, the scheme; andensure that, in considering alternatives to the scheme, no consideration is given to the taxation implications of those alternatives.Submissions on the draft legislation can be made until Wednesday 19 December 2012.On 19 July 2012, the Australian Taxation Office (ATO) released its Compliance Program for 2012-13 which outlines the compliance activities it will be taking over the coming year.

It also describes the market segments and compliance issues that the ATO will focus on for each segment, including individuals, micro enterprises, small-to-medium enterprises and large businesses. This information is essential for taxpayers as it enables them to adopt a more strategic approach to manage tax risk by assessing their exposure to the focus areas identified in the Compliance Program.

This year's Compliance Program sees a continuation of a number of themes that have emerged in recent years. Some of the recurring themes include a focus on: international cooperation with other countries to tackle cross-border tax avoidance and evasion.profit-shifting through the use of related party transactionsensuring companies have good corporate governance and tax risk management, and a continued commitment to Project Wickenby Read our full Alert on the paper. Register to our upcoming events on this topic.More and more countries, such as the UK and India, are considering the enactment of a General Anti-Avoidance Rule (GAAR). This Alert summarises the main features for the GAARs of 17 countries, illustrating the diversity of anti-avoidance regimes currently existing around the world (see table at the end.)

This Alert summarises the main features for the GAARs of 17 countries, illustrating the diversity of anti-avoidance regimes currently existing around the world (see table at the end.) It also describes some broad design elements that move toward a balanced approach, the potential negative impacts if a po oor design is implemented, as well as competing policy interests. This Alert does not, however, advocate the introduction of a GAAR. Whether a GAAR should be enacted must be determined with reference to the individual circumstances of each country.

Read our full Alert on the paper.

In late March 2012, the ATO commenced issuing letters to taxpayers advising it had commenced an intelligence gathering project to investigate the level of exempt foreign income being declared by Australian companies under section 23AJ of the Income Tax Assessment Act 1936. The letter advises that no action is required of the taxpayer at this time.

However, taxpayers ought to be aware that the ATO has indicated that it has already commenced the process of obtaining information from those countries listed below under the relevant article of the double tax agreement or tax information exchange agreement.

The project is part of the ATO's broader Tax Haven strategy which, until now, had not focused closely on the large business sector.

Companies targeted under the project include Australian headquartered companies and some Australian subsidiaries of US headquartered companies with operations in any of the jurisdictions listed below. We understand the ATO has already sought information from the following countries. Countries with Double Tax Agreements (DTAs)Countries with Tax Information Exchange Agreements (TIEAs)* Australia does not currently have a TIEA with Panama.

The ATO objectives of the project include: testing the effectiveness of their TIEAs, many of which have only recently come into effectunderstanding the reasons for the decline in amounts of attributable income with a particular focus on assessing the actual operations of the offshore businessreviewing the large increase in section 23AJ non-assessable non-exempt income and determining whether these dividends satisfy the requirements of the provision.Taxpayers may wish to review their tax affairs to determine whether this project is likely to raise risks which require strategic management both domestically and internationally. This may include obtaining an understanding of the ATO's exchange of information procedures and developing appropriate strategies to manage their global tax risk. This process may include reviewing your tax position in order to determine the extent of any risks that might arise.

Should you require any further information, including a sanitised copy of the letters issued to taxpayers, please contact your usual PwC advisor or one of the tax controversy specialists listed on the right.

Read our full Alert on the paper.

New changes to the Duties Act 1997 (NSW) - 13 April 2012

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Our national Stamp Duty practice is one of the largest in Australia and comprises a network of specialists located in four States whom have experience across a wide range of industries. Accordingly, we are able to assist with stamp duty issues on any type of transaction within any State or Territory of Australia.

Our national team can assist you with: Identifying stamp duty exposures and developing strategies to mitigate or minimise those exposuresProviding due diligence (whether vendor or purchaser) and structuring services on mergers and acquisitionsSubmissions to the Revenue Offices, including to secure exemptions/relief from stamp duty and / or to meet statutory filing requirements and payment deadlinesStamp duty services integrated with PwC's full range of advisory, tax and legal servicesObtaining access to key industry bodiesThe Australian Stamp Duty team is also part of a global network which means we can assist on international transactions by liaising with and providing access to stamp duty specialists from other PwC Global member firms.

The most common types of transactions where stamp duty issues arise are: Mergers and AcquisitionsCorporate re-organisationsLiquidations and restructuringDue diligenceHowever, stamp duty issues could arise when you: Acquire or transfer assetsEstablish, amend or terminate trusts, partnerships and joint venturesDeal with shares in companies, interests in partnerships, units in trusts and joint venture arrangementsSecure financeMerge or amalgamate entities, whether or not under foreign lawThese issues could arise even where none of the parties are Australian residents or incorporated in Australia. For more information on when stamp duty applies and the relevant rates, see above links.

Impending changes to Australian Industry Participation Plan requirements to impact the Enhanced Project By-law Scheme - 12 April 2012

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With an unrivalled knowledge of customs, excise and trade law, we work with organisations ranging from SMEs to major multinationals. Our focus is to minimise duty costs, supply chain improvements, assist with dispute settlements, liaise with the various authorities and trade policy agencies, and respond to compliance needs with creative strategies and solutions in order to reduce compliance costs.

Working with you, our team will deliver positive results for your business, which include: minimising your customs duty costs by our shared planning skills & innovative solutions, such as our Customs Duty Analyser tool. enhancing your trading performance by optimising the supply chain and representing your best interests with the Australian and International Customs authorities and trade policy agenciesresponding to your compliance needs with creative strategies and solutions to reduce your compliance costs advising on all aspects of excise including classification, refunds/remissions, fuel tax credits, warehousing, internal controls, reporting and complianceSecuring customs duty exemptions through various duty concession mechanisms, such as the Enhanced Project By-Law Scheme and Tariff ConcessionsAdvantageous tariff classifications to lower duty ratesReducing customs duty costs by employing WTO-based customs valuation rules to enable planning strategies and price unbundlingEfficient and optimised import/export processingCompliance “health checks” in order to mitigate the risks that can accrue as a result of non-compliance Implementation of procedures, drafting of manuals and assessment of internal controlsTechnical assistance and strategic advice in managing auditsSecure advance rulings In-house customs, excise and trade training and awareness workshopsAssist companies to take full advantage of customs duty savings and enhance trade facilitation under preferential trading arrangementsMonitoring emerging FTAs so that future planning and benefits can be taken into accountTrade intelligence reporting covering WTO, WCO, ASEAN, FTAs and country specific customs and trade issues globallyIndustry protection- submissions and Advice on Anti Dumping and Countervailing MeasuresCross border advice on trade impediments, such as intellectual property protection (trademarks and copyright) non-tariff barriers and discriminatory taxesAustralian Industry Participation Planning and strategy

NCAA 14 Dynasty mode levels up with coach skills, recruiting changes

by Mike Suszek on May 29th 2013 11:45AM

NCAA Football 14 will receive some changes this year to Dynasty mode, the series' career mode in which players lead a school's football team to victory. Of the changes, the addition of coach skills stand out, which grant your team's leader and play-caller more nuance in the form of 18 RPG-like abilities that can be upgraded as your dynasty progresses. The abilities range from "Road Warrior," which helps your quarterback succeed on the road against teams, to "Clutch," which encourages your team to play better in high-pressure situations.

NCAA 14 will also see a more streamlined athlete recruitment process. Whereas NCAA 13 included a phone call system, the feature's been stripped out entirely in favor of a points system called "Power Recruiting." Players will receive 5,000 points per week and can allocate points how they see fit towards scouting, recruitment and offering scholarship.

Like minutes on a cell phone plan, points roll over every week, so players can put off their athlete recruitment process as well and not falter too much. The offseason recruitment phase, in which players receive 10,000 points to play with, has also been rolled into a single stage, making for a faster, likely more stressful experience.

This post was made using the Auto Blogging Software from WebMagnates.org This line will not appear when posts are made after activating the software to full version.

Pregnant mothers can support the development of fetal Gut changes

THURSDAY, Aug. 2 HealthDay News)--obtain a change in the composition of intestinal microbes that normally would cause health problems such as weight and inflammation may actually be beneficial for the pregnant, according to the researchers.

In conducting the research, published in the Aug. 3 edition of the journal cell, scientists tested stool samples taken from 91 women in pregnancy. It appeared that the composition of intestinal microbes women changing in time, from the first quarter of their pregnancy at the third trimester.

"This is the first in-depth characterization of intestinal microbiota associated with pregnancy," study senior author, Ruth Ley, Cornell University, said in a news release. log "The findings suggest that our body have coevolved with the microbiota and can actually use them as a tool to help you change the metabolism of the mother--to promote the development of the fetus."

In the course of their pregnancy, intestinal microbes women became less "normal" and less varied. Researchers also found that the number of bacteria beneficial bacteria levels associated with rejected as the disease has increased. There was also evidence that inflammation increased during the pregnancies of women.

"Changes in intestinal microbes do not relate to diet, so we think that the immune system or the hormones play a role," Ley noted.

The researchers then passed the transfer of pregnant women healthy mouse intestinal bacteria. They found mice that received transfer of the bacteria from the third trimester got fatter and had higher levels of inflammation markers in blood sugar metabolism, and worse than the mice that received the first trimester of the micro-organism.

"By the third trimester, the microbiota may entail changes in metabolism," Lei said. "In the context of pregnancy, these changes in the mother are healthy metabolic because they promote the energy storage in fat tissue support and assistance of the fetus. Beyond the pregnancy, however, these changes may lead to the development of type 2 diabetes and other health problems. "

--Mary Elizabeth Dallas Copyright © 2012 HealthDay. All rights reserved. Source: cell, news release, Aug. 2, 2012

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Pregnant mothers can support the development of fetal Gut changes

THURSDAY, Aug. 2 HealthDay News)--obtain a change in the composition of intestinal microbes that normally would cause health problems such as weight and inflammation may actually be beneficial for the pregnant, according to the researchers.

In conducting the research, published in the Aug. 3 edition of the journal cell, scientists tested stool samples taken from 91 women in pregnancy. It appeared that the composition of intestinal microbes women changing in time, from the first quarter of their pregnancy at the third trimester.

"This is the first in-depth characterization of intestinal microbiota associated with pregnancy," study senior author, Ruth Ley, Cornell University, said in a news release. log "The findings suggest that our body have coevolved with the microbiota and can actually use them as a tool to help you change the metabolism of the mother--to promote the development of the fetus."

In the course of their pregnancy, intestinal microbes women became less "normal" and less varied. Researchers also found that the number of bacteria beneficial bacteria levels associated with rejected as the disease has increased. There was also evidence that inflammation increased during the pregnancies of women.

"Changes in intestinal microbes do not relate to diet, so we think that the immune system or the hormones play a role," Ley noted.

The researchers then passed the transfer of pregnant women healthy mouse intestinal bacteria. They found mice that received transfer of the bacteria from the third trimester got fatter and had higher levels of inflammation markers in blood sugar metabolism, and worse than the mice that received the first trimester of the micro-organism.

"By the third trimester, the microbiota may entail changes in metabolism," Lei said. "In the context of pregnancy, these changes in the mother are healthy metabolic because they promote the energy storage in fat tissue support and assistance of the fetus. Beyond the pregnancy, however, these changes may lead to the development of type 2 diabetes and other health problems. "

--Mary Elizabeth Dallas Copyright © 2012 HealthDay. All rights reserved. Source: cell, news release, Aug. 2, 2012

View the original article here

Migraine: They are triggered by weather changes?

Some people who have headaches seem to be more sensitive to changes in time. Weather related triggers include:

Bright cold temperaturesHigh SunlightHot or humidityDry airWindy or weatherBarometric stormy pressure changes

For some people, weather changes can cause imbalance in brain chemicals, including serotonin, which can take a headache. Weather triggers can also worsen a headache caused by other triggers.

If you feel your migraines are triggered by time, you may be understandably frustrated. After all, you can't change the time. However, you can learn what changes weather forecast initiate a migraine and take measures to reduce the effects:

Keep a diary of migraine headaches, migraine, list each when it happened, how long it lasted, and what might have caused. This can help determine if you have triggers specific forecasts.Monitor changes to climate and to avoid the trigger if possible. For example, staying indoors during the very cold and windy weather if these factors seem to trigger your headache.Take the migraine medicine at the first sign of a migraine.Make healthy lifestyle — eating healthy foods, exercise regularly, get enough sleep and keeping your stress under control. These factors may help to reduce the number and severity of your migraines.Next question references environmental and physical factors. National Foundation of headaches. http://www.headaches.org/education/Tools_for_Sufferers/Headache_-_Frequently_Asked_Questions/Environmental_and_Physical_Factors. The 21 February, 2012. Friedman DI, et al., migraines and the environment. Headaches. 2009; 49: 941. Migraine headaches. American Academy of Neurology. http://www.aan.com/Professionals/Practice/Guidelines/migraine/Migraine_Guide_Patients.pdf. Accessed February 29, 2012. Hoffman J, et al., weather sensitivity in migraine sufferers. Journal of Neurology. 2011; 258: 596. Migraine. National Foundation of headaches. http://www.headaches.org/education/Headache_Topic_Sheets/migraine. Accessed 1 March 2012.

View the original article here

Migraine: They are triggered by weather changes?

Some people who have headaches seem to be more sensitive to changes in time. Weather related triggers include:

Bright cold temperaturesHigh SunlightHot or humidityDry airWindy or weatherBarometric stormy pressure changes

For some people, weather changes can cause imbalance in brain chemicals, including serotonin, which can take a headache. Weather triggers can also worsen a headache caused by other triggers.

If you feel your migraines are triggered by time, you may be understandably frustrated. After all, you can't change the time. However, you can learn what changes weather forecast initiate a migraine and take measures to reduce the effects:

Keep a diary of migraine headaches, migraine, list each when it happened, how long it lasted, and what might have caused. This can help determine if you have triggers specific forecasts.Monitor changes to climate and to avoid the trigger if possible. For example, staying indoors during the very cold and windy weather if these factors seem to trigger your headache.Take the migraine medicine at the first sign of a migraine.Make healthy lifestyle — eating healthy foods, exercise regularly, get enough sleep and keeping your stress under control. These factors may help to reduce the number and severity of your migraines.Next question references environmental and physical factors. National Foundation of headaches. http://www.headaches.org/education/Tools_for_Sufferers/Headache_-_Frequently_Asked_Questions/Environmental_and_Physical_Factors. The 21 February, 2012. Friedman DI, et al., migraines and the environment. Headaches. 2009; 49: 941. Migraine headaches. American Academy of Neurology. http://www.aan.com/Professionals/Practice/Guidelines/migraine/Migraine_Guide_Patients.pdf. Accessed February 29, 2012. Hoffman J, et al., weather sensitivity in migraine sufferers. Journal of Neurology. 2011; 258: 596. Migraine. National Foundation of headaches. http://www.headaches.org/education/Headache_Topic_Sheets/migraine. Accessed 1 March 2012.

View the original article here

Migraine: They are triggered by weather changes?

Some people who have headaches seem to be more sensitive to changes in time. Weather related triggers include:
Bright cold temperaturesHigh SunlightHot or humidityDry airWindy or weatherBarometric stormy pressure changes For some people, weather changes can cause imbalance in brain chemicals, including serotonin, which can take a headache. Weather triggers can also worsen a headache caused by other triggers.Click Here!
If you feel your migraines are triggered by time, you may be understandably frustrated. After all, you can't change the time. However, you can learn what changes weather forecast initiate a migraine and take measures to reduce the effects:
Keep a diary of migraine headaches, migraine, list each when it happened, how long it lasted, and what might have caused. This can help determine if you have triggers specific forecasts.Monitor changes to climate and to avoid the trigger if possible. For example, staying indoors during the very cold and windy weather if these factors seem to trigger your headache.Take the migraine medicine at the first sign of a migraine.Make healthy lifestyle — eating healthy foods, exercise regularly, get enough sleep and keeping your stress under control. These factors may help to reduce the number and severity of your migraines.Next question references environmental and physical factors. National Foundation of headaches. http://www.headaches.org/education/Tools_for_Sufferers/Headache_-_Frequently_Asked_Questions/Environmental_and_Physical_Factors. The 21 February, 2012. Friedman DI, et al., migraines and the environment. Headaches. 2009; 49: 941. Migraine headaches. American Academy of Neurology. http://www.aan.com/Professionals/Practice/Guidelines/migraine/Migraine_Guide_Patients.pdf. Accessed February 29, 2012. Hoffman J, et al., weather sensitivity in migraine sufferers. Journal of Neurology. 2011; 258: 596. Migraine. National Foundation of headaches. http://www.headaches.org/education/Headache_Topic_Sheets/migraine. Accessed 1 March 2012.

Migraine: They are triggered by weather changes?

Some people who have headaches seem to be more sensitive to changes in time. Weather related triggers include:
Bright cold temperaturesHigh SunlightHot or humidityDry airWindy or weatherBarometric stormy pressure changes For some people, weather changes can cause imbalance in brain chemicals, including serotonin, which can take a headache. Weather triggers can also worsen a headache caused by other triggers.Click Here!
If you feel your migraines are triggered by time, you may be understandably frustrated. After all, you can't change the time. However, you can learn what changes weather forecast initiate a migraine and take measures to reduce the effects:
Keep a diary of migraine headaches, migraine, list each when it happened, how long it lasted, and what might have caused. This can help determine if you have triggers specific forecasts.Monitor changes to climate and to avoid the trigger if possible. For example, staying indoors during the very cold and windy weather if these factors seem to trigger your headache.Take the migraine medicine at the first sign of a migraine.Make healthy lifestyle — eating healthy foods, exercise regularly, get enough sleep and keeping your stress under control. These factors may help to reduce the number and severity of your migraines.Next question references environmental and physical factors. National Foundation of headaches. http://www.headaches.org/education/Tools_for_Sufferers/Headache_-_Frequently_Asked_Questions/Environmental_and_Physical_Factors. The 21 February, 2012. Friedman DI, et al., migraines and the environment. Headaches. 2009; 49: 941. Migraine headaches. American Academy of Neurology. http://www.aan.com/Professionals/Practice/Guidelines/migraine/Migraine_Guide_Patients.pdf. Accessed February 29, 2012. Hoffman J, et al., weather sensitivity in migraine sufferers. Journal of Neurology. 2011; 258: 596. Migraine. National Foundation of headaches. http://www.headaches.org/education/Headache_Topic_Sheets/migraine. Accessed 1 March 2012.

Migraine: They are triggered by weather changes?

Some people who have headaches seem to be more sensitive to changes in time. Weather related triggers include:
Bright cold temperaturesHigh SunlightHot or humidityDry airWindy or weatherBarometric stormy pressure changes For some people, weather changes can cause imbalance in brain chemicals, including serotonin, which can take a headache. Weather triggers can also worsen a headache caused by other triggers.Click Here!
If you feel your migraines are triggered by time, you may be understandably frustrated. After all, you can't change the time. However, you can learn what changes weather forecast initiate a migraine and take measures to reduce the effects:
Keep a diary of migraine headaches, migraine, list each when it happened, how long it lasted, and what might have caused. This can help determine if you have triggers specific forecasts.Monitor changes to climate and to avoid the trigger if possible. For example, staying indoors during the very cold and windy weather if these factors seem to trigger your headache.Take the migraine medicine at the first sign of a migraine.Make healthy lifestyle — eating healthy foods, exercise regularly, get enough sleep and keeping your stress under control. These factors may help to reduce the number and severity of your migraines.Next question references environmental and physical factors. National Foundation of headaches. http://www.headaches.org/education/Tools_for_Sufferers/Headache_-_Frequently_Asked_Questions/Environmental_and_Physical_Factors. The 21 February, 2012. Friedman DI, et al., migraines and the environment. Headaches. 2009; 49: 941. Migraine headaches. American Academy of Neurology. http://www.aan.com/Professionals/Practice/Guidelines/migraine/Migraine_Guide_Patients.pdf. Accessed February 29, 2012. Hoffman J, et al., weather sensitivity in migraine sufferers. Journal of Neurology. 2011; 258: 596. Migraine. National Foundation of headaches. http://www.headaches.org/education/Headache_Topic_Sheets/migraine. Accessed 1 March 2012.

What two significant changes have occurred in Alice springs within the last 10 years and what factors have caused them?

Is two a factor of 10? Yes, two (2) is a factor of ten (10). In reverse, ten is a multiple of 2.

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