Common types of academic writing
Tuesday, August 25, 2020
Economic Class free essay sample
Keeping a decent social standard is some of the time hard to continue, making it difficult to change. Creator Gregory Mantsios ââ¬Å"Class in Americaâ⬠in 2003, has a wide range of thoughts in transit financial class is. Social standings and therefore life chances are generally decided during childbirth. People who have gone from clothes to newfound wealth have large amounts of the broad communications, insights on class portability demonstrate these jumps to be incredibly uncommon (Mantsios711). Most financial achievement is a direct result of the riches that these people get during childbirth. More than 66 percent of the purchaser units with wages of $100,000 or more have acquired resources (Mantsios711). In the accounts that are perused by and large there is more riches due to being naturally introduced to it than gaining it by difficult work. The vast majority don't decide to be placed into a monetary class; rather it occurs all alone. In the event that somebody grows up knowing just low pay or having next to no as a youngster, they appear to convey that on with them as they get more seasoned. It is difficult to go from something youââ¬â¢re used to for your entire life to something so extraordinary. Destitution is a troublesome boundary to survive, regardless of where somebody is from or where they presently live. Creator Diana George ââ¬Å"Changing the Faces of Poverty: Nonprofits and the Problem of Representationâ⬠. 001 composes, ââ¬Å"You donââ¬â¢t need to leave your own nation to discover third-world neediness. â⬠(George623). Most gatherings that are requesting cash to help the destitute kids are for the most part in an alternate nation. As individuals see Children, Inc. demonstrating photographs of kids that cause individuals to feel powerlessness for. Individuals need to help tackle the yearning issues by sending cash yet once in a while feel uncomfortable with doing it since we are anxious about the possibility that that the cash isn't continually going for what these individuals think it is. Living space for Humanity helps people here in the Unit ed States to recover financially and attempt to beat an obstruction of no food or spots to live. Living space for Humanity intends to take out neediness lodging from the globe (George 625). Being in little urban communities is likewise once in a while an obstruction to defeat on the grounds that there are not the same number of occupations or access to employments. There are run down houses that individuals without employments, think that its elusive the financing to do upkeep on them. Neediness censures a large number of individuals all through the world to live in woeful and barbaric conditions. These individuals are caught in a pattern of destitution, living in places offering little security from the downpour, wind and cold (George 626). Living in run down houses causes a wide range of ailments and can cause passing also. It is hard observing youngsters living in this circumstance just as more seasoned individuals. Discovering better lodging is something the vast majority make progress toward. It is simply progressively troublesome when not living in a superior neighborhood with better lodging. Writer Peter Singer ââ¬Å"The Singer Solution to World Povertyâ⬠, composes, an American family with a salary of $50,000 spends around $30,000 every year on necessities, as per the Conference Board, a philanthropic financial exploration association, (Singer 879). Along these lines, for a family acquiring $50,000 every year, gifts to help the worldââ¬â¢s poor ought to be as close as conceivable to $20,000 (Singer 879). When living in run down territories, and networks with having no way to improve, makes it extremely difficult to change. For certain individuals seeing others doing things they couldn't want anything more than to do and realize they can't, causes a few people to feel sad and gives them musings of always being unable to change. Roughly 12 percent of American populace that is, about one of each eight individuals in this nation live underneath the official neediness line (determined in 2001 at $9,214 for an individual and $17,960 for a group of four). Among the poor are more than 2. million destitute, including about 1 million destitute kids (Mantsios 701). Last time anyone checked, about 33 million Americans the country over lived in tenacious destitution (Mantsios 703). Having extracurricular exercises make it hard for more unfortunate individuals than increasingly well off. A few people go to tuition based schools, where they have numerous choices for the sake of entertainment and ex ercises after school. Having alternatives like taking distinctive language classes in the wake of, resting ceaselessly camps, some with children of diplomats and offspring of specialists. Going on family travels consistently, a few times each year is more than likely. They know early that they will most unquestionably get into an awesome school with or without grants with desire to be president. With respect to other people, go to a little to medium government funded school where most alternatives are practically nothing. Setting off to a YMCA day camp is the most outdoors experience a great deal of more unfortunate individuals get the chance to understanding. They are offspring of dedicated people in factoryââ¬â¢s and school workers. This is the means by which a few of them get the chance to do sports also. They have desire to be presidents just as teachers. Racial and sexual orientation issues prevent individuals from going farther in life than they might want also. Racial and sex mastery are different powers that hold individuals down (Mantsios 712). Ladies experience the impacts of sexism whether they are generously compensated proficient or inadequately paid representatives. As ladies, they face segregation and male mastery, just as heckles and generalizing (Mantsios 712). Likewise, a rich dark man faces racial mistreatment, is exposed to racial slurs, and is precluded openings in light of the fact that from securing his shading (Mantsios 712). The experience of ladies and minorities are separated along class lines. Despite the fact that they are subordinate positions opposite white men, the specific issues that stand up to ladies and minorities possibly very unique relying upon their situation in the class structure (Mansios 712-713). Class - persecuted men, regardless of whether they are white or dark, have benefits managed them as men in a misogynist society. Essentially, class-mistreated whites, regardless of whether they are men or ladies, advantage from white benefit in a supremacist society. In todayââ¬â¢s society, individuals would imagine this would not be an issue any longer, yet it appears to at present be issues with it. Mistreatment is combined, and the individuals who are poor, dark, and female are regularly dependent upon the entirety of the powers of class, race and sexual orientation segregation at the same time (Mantsios 713). It appears that in the event that you are a dark lady that you would be in a lower class than a white female. Being female and of ethnic race you would be considered in the lower class and that makes numerous issues for somebody succeed. Being in a general public that does passes by classes has made numerous issues for a few classes prevail in a place that is needed. Americans judge such a large number of individuals, and it shows that it very well may be a significant obstruction for somebody to move beyond. Nobody likes for others to know their circumstances, individuals attempt to conceal things from others with the goal that nobody know whether they are in the lower class. Attempting to fit in is something that most Americans permit themselves to do. Everybody needs to be considered in a similar classification of class. For what reason do individuals judge so a lot and for what reason do they direct and do destructive sentiments toward individuals that are in a lower class than themselves? It is exactly how mankind is and more than likely will consistently be. It has been like this for a long time and will keep on doing as such. A few people are brought up in various degrees of human instinct, and it develops with every person as they become grown-ups, yet looking down on somebody and putting down them, all since they are not as rich as them, or have the same number of material things as they do necessities to grind to a halt. That makes an excessive number of individuals quit attempting to conquer hindrances in their manner to improve a life for themselves and their families. Escaping a groove is a hard thing to achieve. This is a significant hindrance to survive. Works Cited George, Diana. Changing the Face of Poverty: Nonprofits and the Problem of Representation. 2001. The Norton Field Guide to Writing with Readings. Ed. Richard Bullock and Maureen Daly Goggin. second ed. New York: Norton, 2010. 622-33. Print. Mantsios, Gregory. Class in America-2003. 2004. The Norton Field Guide to Writing with Readings. Ed. Richard Bullock and Maureen Daly Goggin. second ed. New York: Norton, 2010. 697-717. Print. Vocalist, Peter. The Singer Solution to World Poverty. 2009. The Norton Field Guide to Writing with Readings. Ed. Richard Bullock and Maureen Daly Goggin. second ed. New York: Norton, 2010. 873-80. Print.
Saturday, August 22, 2020
Dawn Social Justice Group Essay Example For Students
Day break Social Justice Group Essay Day break The social equity bunch DAWN (incapacitated womans arrange Ontario) is a region wide association of lady with a wide range of inabilities. They are a women's activist association which bolsters lady in their battle to control their own lives. Sunrise Ontario is constrained by ladies with inabilities. The individuals incorporate lady with incapacities and non-incapacitated lady. Additionally included are lesbians, indiscriminate lady, native lady, Franco-Ontarian lady, and lady from numerous other ethnic, racial, social, and strict foundations. Lady all things considered, from adolescents to seniors, are dynamic individuals from DAWN. They accept that incapacitated lady reserve the privilege to coordinate their own lives. They additionally accept that lady with handicaps: reserve the privilege to get to the administrations and supports accessible to all lady; have needs which are not quite the same as those of men with inabilities; know best what their needs are; reserve an option to opportunity of decision in all parts of their live; and can be glad for their incapacities and have the decision to self-personality. As a gathering DAWN at Ontario: keep current on issues confronting ladies with incapacities; give job mode to young ladies with handicaps; create assets for young ladies with inabilities; help start and bolster DAWN bunches across Ontario; represent the privileges of lady with inabilities to ensure they can partake in womans gatherings, exercises, occasions and administrations; work with different womans and handicaps gatherings; produce assets about social insurance for lady with inabilities; campaign for the legislature on issues influencing lady with inabilities. Issues, for example, business, preparing, training, transportation, lodging, human services, and others. On June 17, 1985 17 lady with incapacities from across Canada assembled to examine issues of concern. From this gathering, DAWN of Canada was shaped. Crippled lady sorted out the nation over, staying in contact via mail and telephone, lastly they got subsidizing from the secretary of state for some uncommon tasks. Debilitated lady have been driving forward from that point forward to develop DAWN on a nearby and national level. In 1992 DAWN Ontario was framed. From that point forward they have put out numerous pamphlets and so forth for data all through Ontario. They additionally have worked with different gatherings, for example, Employment Equity Coalition; the Coalition Against Depo Provera; and the Coalition Against Extra Billing in Ontario. First light is an extraordinary Social Justice bunch that emphasis on helping the impaired. They help a wide range of individuals, and do it because of the great or their heart. These individuals don't do it for cash or force yet they do it for the individuals that they assist they with doing this all alone and the prize for them is the outcomes they see through helping others. They must be an incredible model for us, and give us how 17 individuals can transform into an extraordinary association that help a great many individuals each .
Saturday, August 8, 2020
College Essay News and Tips CEAs Link Roundup - College Essay Advisors Admissions Essay Experts
College Essay News and Tips CEAs Link Roundup - College Essay Advisors Admissions Essay Experts College Essay News and Tips: CEAs Link Roundup College Essay News and Tips: CEAs Link Roundup Okay, you probably already know this, but the college application process isnât all fun and games all the time, so in this edition of the ever-informative CEA Link Round Up, weâd like to shed some light on some of the heftier conversations people are having about higher education admissions. The competition for college admissions has reached a fever pitch, and its only getting crazier. Whether acceptance rates drop deeper into the single-digits or colleges add video sections to their online applications, the application process has become a high-stakes obstacle course. Recently, though, the national conversation has shifted its focus away from 21st century admissions challenges and onto the long-lasting inequalities that make it easier for some students to reach the finish line, so we have selected three thought-provoking articles that address the issue of inequality from a variety of angles. Earlier this week we shared a few college essays about money that Ron Lieber had hand selected to feature in the New York Timesâ Your Money column. Here, he explains why the challenging topic is so fitting for the college essay. While the NYT addresses money, the Chicago Tribune examines geography and how where you go to high school actually affects your admissions chances. And finally, NPR tackles the big one, race, in this interview with Jip Jump, former president of the National Association of College Admissions Counseling (and winner of the CEA 2015 Amazing Name Award). Yes, itâs important for us to examine the dynamics and causes of inequality in our lives (and maybe in our college essays), but itâs also important to find humor and inspiration in the world around us. Thank goodness itâs commencement season and that Robert Deniro and Maya Rudolph (and Beyonce) exist. Want essay help on demand? Watch our video series! Read our guide to the 2015-16 Common App Essay. Read more about The College Essay Advisors Process. About Thea HogarthView all posts by Thea Hogarth »
Saturday, May 23, 2020
Tuesday, May 12, 2020
The Black Panthers As Reverse Racism - 971 Words
When approaching which event to select for the requirement, it seemed it could not have been better timing for The Black Panthers: Vanguard Of The Revolution documentary to air. It had been in the same week, debates and circling campus and social media regarding the halftime show with the performance by Beyonce with dancers that resembles the female members of the Black Panther Party. The performance was also a reference towards the fact that it was Black History Month along the recent #Black Lives Matter movement which is still in progress concerning police brutality and systematic racism. By looking at the performance, I did not think anything more of it than being a performance; however on social media, many did not appreciate the performance and labelling the inclusion of the black panthers as reverse racism. People presented the point that the black panther party could be equated to the Ku Klux Klan, due to my own ignorance, I felt compelled to agree. Being multiracial and growi ng up in mainly white spaces, I was not exactly educated on the political party or their accomplishments, I was informed that it was an anti white party. Luckily, the RiverRun Film Festival that would provide me with the impression necessary about the party, so with that came a feeling of excitement.Although there were not many multiracial people in the room, I was not offended or uncomfortable since my motive was to attain knowledge rather than a sense of belonging. The interviews and factualShow MoreRelatedShirley Chisholm : The First African American Woman1278 Words à |à 6 Pagesworst, Chisholmââ¬â¢s parent sent her and her sisters back home to Barbados to stay with their grandmother. Chisholm received a more rigorous education in Barbados than the public schools in Brooklyn, focusing intensely on reading and writing. Having black teachers allowed Chisholm to view people of color as competent and professionally successful, which she may not have experienced in Brooklyn. Chisholm gained a strong sense of self and pride while living in Barbados, mainly from her grandmother andRead MoreThe Rhetorical Analysis Of Mary Crow Dog And Graduation By Maya Angelou1640 Words à |à 7 Pagestheir effectiveness as a rhetor. Crow Dog gives the argument that ââ¬Å"racism breeds racism in reverseâ⬠(79); when we do not look at people as people, it gives us an excuse to treat them badly. The author explains that they are like animals and savages; the Indians being the animals, and the nuns and priests being the savages. Her argument is effective because it still applies in society today. The rhetorââ¬â¢s essay is kairotic because racism has always been a pressing issue and when Crow Dog went to St. FrancisRead More Cults Essay1229 Words à |à 5 Pagescommonly known cults are Reverend Jim Jones and the People Temple, Heavens Gate, and Charles Manson and the Family. In the early 20th century, Allistar Crowly, AKA ââ¬Å"The Black Popeâ⬠, started modern Satanism. It is said that Anton Lavey brought Satanism to the United States. Anton believed that he was the reincarnation of the ââ¬Å"Black Popeâ⬠. He set his church up in San Francisco in 1966. Within one year Antonââ¬â¢s cult grew to more than 200,000 members (Miller, 1991, p. 28-29). Anton then went to HollywoodRead MoreSocial And Cultural Diversity : Beyond Racism3572 Words à |à 15 PagesRunning head: SOCIAL AND CULTURAL DIVERSITY ? BEYOND RACISM 1 SOCIAL AND CULTURAL DIVERSITY ? BEYOND RACISM 11 Social and Cultural Diversity ? Beyond Racism Thomas J. McCarthy Grand Canyon University: PCN-509 August 31, 2016 Social and Cultural Diversity ? Beyond Racism The title Beyond Racism was chosen because that is where I wish the world will be some day. Where everyone doesn?t see differences of one?s melanin or culture or status in life, but sees the likenessRead More The Origin of the Civil Rights Movement Essay1820 Words à |à 8 Pagesadvancement of African Americans. As W.E.B. Du Bois provided the diving board that would allow blacks to dive into the pool of equality, he is found at the origin of the Civil Rights Movement. The Pan-Africanism movement, the rage following the Red Summer, and the Great Migration continued the efforts of W.E.B. Du Bois. The bold and striking words and actions of Marcus Garvey showed whites that blacks would not be called an inferior race any longer. Following World War II, many bounds toward racialRead MoreDoomed : Repeat The Past2605 Words à |à 11 PagesAndrea Acosta Mrs. Hart Creative Writing 16 September 2014 Doomed to Repeat the Past - Racism is the belief that all members of each race possess characteristics or abilities specific to that race, especially so as to distinguish it as inferior or superior to another race or races. It is the systematic oppression of people who did not set up the system of oppression (i.e. white people vs. every other POC). This system is not just institutionalized but embedded into every fabric of society fromRead MoreThe Fall of the Liberal Consensus Essay1919 Words à |à 8 Pagesthe civil rights movement took form in the Lowndes County Freedom Organization, otherwise known as the Black Panther Party. Stokely Carmichael marks the feelings of part of America in reaction to the rise of fragmented civil rights groups such as the Black Panthers when he writes, as for white America, perhaps it can stop crying out against ââ¬Ëblack supremacy, ââ¬Ëblack nationalism, ââ¬Ëracism in reverse, and begin facing reality. While we now have an understanding of how the fragmentation of the liberalRead MoreNonviolent Resistance And Nonviolent Action2197 Words à |à 9 Pagessuccess in raising awareness and getting people to adopt their narratives and commit to fighting disparities, as evident by the Civil Rights Act and Brown vs. Board of Education, where enough activism allowed for a change in the course of explicit racism in the US. Next, the methods of Nonviolent Noncooperation utilize the majority to weaken governments and systems and dismantle their authority and power. These methods involve economic boycotts, such as consumer boycotts and rent refusals, strikesRead MoreFor decades, African Americans have been on a racial discrimination and extremely deadly roller2100 Words à |à 9 Pagesroller coaster ride for justice and equality. In this new day and age, racial tendencies and prejudice has improved since the 1700-1800s,however, they are slowly going back to certain old ways with voting laws and restaurants having the option to serve blacks or not. It all began with the start of slavery around 1619. The start of the New World, the settlers needed resources England and other countries had, which started the Triangle Trade. The New England settlers manufactured and shipped rum to WestRead MoreOpposing Forces Civil Rights Movement2317 Words à |à 10 Pagesfor civil rights had been started long ago, when t he black man was freed from the bonds of slavery. Over a hundred years later, the problem of blacks being treated as second-class citizens still persisted. What could be done to correct the present situation? Some, both blacks and whites, believed that non-violence was the only means to achieve civil rights, as Dr. Martin Luther King, Jr. preached. Others like Huey Newton of the Black Panthers believed that violence was the only way. (W. H. Chafe:
Wednesday, May 6, 2020
Salvador Dali Free Essays
Vanishesâ⬠sees UN Ecuador whiz poor el artists Salvador Feline Action Dali. Cosecà © Salvador Dali y est. Ecuador porous De com pià ±ata. We will write a custom essay sample on Salvador Dali or any similar topic only for you Order Now Us USA el still De surrealist, per us Trojan sees realists. Poor example, en ââ¬Å"The Image Vanishes,â⬠Mira realists, per hack UN concept De surrealist. Edemaà ¤s, you jocose Dali porous me gusts el rate De Dali. Me gusts us Trojan y rate porous us still surrealist sees Ã'Ënice y creative. Tamakià ©n me gusts us rate porous De us ideas y el significant deterà ¤s De cad painter. Ho, SE upped encounter e]employ De us rate en SST. Petersburg, Florida; Berlin Germany; Paris, France; Catalina, Spawn. Salvador Feline Action Dali is a Spanish artist that is considered the personification of surrealism. Dali was born in 1904 in Catalina, Spain. He spent the early part of his life with his rich parentââ¬â¢s and attended the Academy of Fine Arts in Madrid. Then, he moved away to Join the Surrealist movement in 1934. He spent most of his live doing this in Madrid, Spain; Paris, France; and New York. The style that he used was surrealism, but he painted his portraits and other paintings realistically. Surrealism is the type of style that is not realistic and expresses the power of imagination. ââ¬Å"The Image Vanishesâ⬠is a painting made by the artist, Salvador Feline Action Dali. I chose Salvador Dali and this painting because of how he paints. He uses the surrealistic style, but his work is realistic. For example, en ââ¬Å"The Image Vanishes,â⬠it looks realistic, but it uses a surrealistic concept. In addition, I chose Dali because I like the art of Dali. I like his work and art because of his surrealistic style is unique and creative. Also, I like his art because of his ideas and the significance behind each painting. Today, examples of his art can be found in SST. Petersburg, Florida; Berlin Germany; Paris, France; Catalina, Spawn. How to cite Salvador Dali, Papers
Saturday, May 2, 2020
Tax Law Residents and Foreign Residents
Question: Define the Tax Law for the Residents and Foreign Residents in Australia. Answer: Part 1 Fred, in the given situation will not be taxed in a manner same as the manner in which a resident would be taxed. Individuals in Australia are to be considered as resident for purposes of tax if they are residents of Australia under common law (ordinary meaning test or the common law); or if the domicile is that of Australia, unless to the satisfaction the place of permanent abode is established as not being in Australia (the test of domicile); or if the person is in Australia either intermittently or continuously for more than half of the income year, unless it is to the satisfaction of the Commissioner that it is not in Australia that the usual place of abode is and it is clear that there is no intention of taking up residence here (the 183 days test); or is the Commonwealth superannuation schemes member (Section 6, Australian Income Tax Assessment Act 1936) (Australian income tax assessment act 1936-1974, 1975). The main concept behind this is that the residence of the taxpayer is where the home is of that tax payer (Clinton, 2016). Whether the home of the tax payer is in Australia is a question of fact and if the same is found to be true than there is no requirement of moving any further. In the case of Levene v IRC (Levene v IRC [1928]) Viscount LC defined the term reside a established the meaning as defined under the Oxford English Dictionary meaning the permanent dwelling or for a considerable period of time, to have an individuals usual abode or ones settlement, to live at or in a certain place. The determination of the fact that a man has his usual abode or is settled there is not difficult, and if the same is established he would not become less of a citizen if he has left the country for pleasure or business (Ato.gov.au, 2016). The ATO issued the Taxing Ruling TR 98/17 to interpret the ordinary meaning of a resident (Wills 1997). The relevant factors are identified that whether a person who is entering the country is under the ordinary meaning a resident. The persons behaviors character and quality and the period for which they are present physically are a factor (Ato.gov.au, 2016). The character and quality of a person are indicated through secondary factors. Intention is the first main factor or the persons presences purpose. The ruling differentiates between a persons coming to Australia for employment purposes, travelling and education, albeit while doing work that is casual. The persons location of family is the second factor whether the person maintains outside his place of abode, business ties that he has in Australia and the contract of employments existence, particularly purchase and occupation of a house which may establish his home in the country. The living and social arrangements is the fourth factor which is an indicative of residence which include the childrens education, joining of club, leasing of a house. Any resident under the Taxation Ruling TR 98/17 would be considered to be a resident when he has crossed the stay period of six months and have begun demonstrating behavior which is constant with residence in Australia. Fred will not be thus classified as a resident as the main factor of residence is only not complied with; he has only for setting up his companys branch in the country. Other than this there is no intention of settling in Australia, further within the first year only he has returned back to Australia indicating that no behavior was demonstrated by him maintaining a residence in country. Part 2 California Cooper Syndicate Ltd. v Harris (Survey or of Taxes) (1904) 5 TC 159 This case the main objective of the company was of acquiring of land that contained copper. There however, was no extraction of copper from the land. Subsequently this land was sold by the company to another company and as consideration the company was given the shares of that company (California Cooper Syndicate Ltd. v Harris (Survey or of Taxes), [1904]). It was opined by the court that the revenue generated from the lands sale is in nature income because the companys main purpose behind the land was for making profit by selling the land. Therefore, this would form an incident which is ordinary of the business of taxpayers and the nature of it would be income. Scottish Australian Mining Co. Ltd. FC of T 1950 81 CLR 188 This case the business which was being carried out by the company was that of coal mining on the parcel of land that was owned by it. After the company had extracted the entire coal from the said parcel of land over a period of time, the decision was made by it to sell this piece of land (Scottish Australian Mining Co. Ltd. FC of T, [1950]). To ensure that the land becomes more capable of being sold it was subdivided by the company and there were roads and such other infrastructure which was built on the land. It was opined by the court in this case that the profit which the company had made from the lands sale cannot be assessed since the business of the company was not of selling land and the purpose merely for selling the said piece of land was for realizing its capital asset to the best possible advantage of itself that it could. The nature of the profit was thus in nature capital. FC of T v Whitfords Beach Pty Ltd (1982) 150 CLR This case the company was a taxpayer which had been incorporated mainly for the purpose of acquiring of a parcel of undeveloped land which was located at the Whitfords Beach (FC of T v Whitfords Beach Pty Ltd, [1982]). It was beach frontage access that the land had and a company was formed by a group of people so that they could have over the beach an access to be able to fish there. A few years later due to an offer which had been made to them, the issued share capital of the company, which was a taxpayer, was sold off. The shareholders who had bought the shares from the previous owners so that they are able to get the lands control and that they would be able to subdivide, develop and the sell the sites as residential and make a profit out of it. Eventually when this subdivided land was sold, it was argued by the new shareholders that the profit that was accrued from the sale was not in nature income but the capital asset realization of the company. However, it was opined the High Court that the companys development of the land and the eventual sale business and the profits which were accruing from this sale would be assessed as being ordinary income. It was further stated by the court that when the new shareholders had acquired this company the main intention that they had was they would develop, subdivide and eventually sell the land, thus changing the intention from that of the previous owners which had been for purposes that were non-commercial in nature. Thus the court held that it would be the business ordinary course of activity that the sale of land would fall into and therefore it would be an income which is assessable. Statham Anor. v FC of T 89 ATC 4070 This case a deceased estates trustees were the taxpayers. A parcel of land, which was for farming, had been acquired by this deceased with the intention that the family would be raised and some farm activities would be engaged with (Statham Anor. v FC of T, [1989]). The deceased a few years later sold the half portion of this land to company which was being controlled by the members of the family. Till this time also there was no intention which was there for reselling of the said property and making a profit out of such sale. A partnership was entered into by the new owners to raise on this land, cattle. There was no good performance that the partnership showed and it was eventually decided by the owners that they would subdivide this land and then sell it. During the time of the sale of land which was subdivided the deceased passed away. It was argued by the commissioner that the profit generated from the subdivided lands sale some of the land were income which was assessable of t he estate who had deceased. It was however, argued by the tax payers that the proceeds which were obtained from the sale of the land would not amount to income which was ordinary. The courts opined that the profit that would be generated from the sale of the land would not amount to ordinary income since, the parties activities indicated that the sale of the land was not for the conducting of business or for the generation of profit scheme or undertaking. Further, it was only because the business of farming and the partnership for cattle had failed that the decision had been taken by the owners for selling the land, this does not however, mean that it would automatically lead to the realization of the asset to become taxable. Casimaty v FC of T 97 ATC 5135 This case a farming property had been acquired by the taxpayer from his father and for the next twenty years he carried out on this land the business of primary production (Casimaty v FC of T 97, [1997]) . However, because of the debt that was growing and the poor health, it was decided by the taxpayer subsequently that he would subdivide and sell the lands large portion off. Over a period of 18 years a total of 8 subdivisions were made and roads, sewerage, fences and water facilities were constructed by the tax payer as the subdivisions part. It was contended by the commissioner that the profits which had accrued from the individual blocks sale were in nature ordinary income and thus they would be assessable on the basis that the business of subdivision of land was being carried out by the taxpayer. The court however, on appeal opined that the profits that had accrued from the sale were merely that capital assets realization and there was no business of land subdivision that was bei ng carried out by the taxpayer. Tax payer had acquired the land originally for farming purposes and for using it as a private residency and no evidence was available there that there was a change in this purpose. Mona Sand Pty Ltd. v FC of T 88 ATC 4897 This case the company had acquired a land which was located in Adelaide. A couple of years later a company acquired this land and the intention that had been stated was for the business of selling and/or working of the sand which was there (Mona Sand Pty Ltd. v FC of T, [1988]). After an application was received that the government wished to mine this land that was owned by them. A number of letters were then sent by the taxpayer stating their objection for the same. It was stated by them that the land had been held by them with the aim of subdividing and then selling it. It was later discovered by the taxpayer that the government had rezoned this land as being rural and there was later an intention of the Government for preserving this land was discovered. The Government eventually resumed that said land for a cost of $500,000. The payment of this amount was made in two tranches. It was contended by the Commissioner that this amount was the taxpayers ordinary income, since the tax p ayer had stated its intention of subdividing and selling the property for a profit. It was however argued by the taxpayer that the acquiring of the parcel of land was initially only for selling of sand and later sometime they had thought of subdividing it. Therefore there existed both an intention to be able to derive from the said land income and also to be able to sell this land at a later stage. The court however, opined that the amount which they had was ordinary income, since though it was through a transaction that was isolated that this amount was received, the ultimate intention of the taxpayer for selling this land was still indicated by it. Crow v FC of T 88 ATC 4620 This case there a large amount of money which had been borrowed by a farmer for purchasing five blocks of land over a ten year period. This land was for some time used for the purposes of grazing, farming and for crop cultivation (Crow v FC of T, [1988]). However, eventually there was subdivision of this land. For the starting two years and then over a period of number of year there were 51 blocks which had been sold by the taxpayer eventually and he made a net profit overall of $388,288. It was opined by the Federal Court that, the profit which had been made by the taxpayer was assessable as a business of land development was being carried out by him. The court although, did acknowledge that for a short period of time at the very beginning where the use of the land was as a farm. However, evidence was found considering the amount of debt that had been taken by him that at the outset the taxpayer knew that it would be required to sell some of the land off. There was a systematic and repetitive characteristic of the transactions which were there in the said case with the purchasing of different properties and then subsequently subdividing and selling the parcels of land. There was difference that was made in this case and the Scottish Australian Mining Company case stating that the company had used the property for mining for a substantial period of time unlike this case where the business of farming was continued for only a short period of time. McCurry Anor v FC of T 98 ATC 4487 The taxpayers in this case had purchased a plot of land. There was an old house on this land. This house was removed by the taxpayers and there were three townhouses that were constructed in this place. Even before these townhouses were completed they were advertised for sale. This was however, not a success (McCurry Anor v FC of T, [1998]). The Tax payer and his family moved into two of the townhouses subsequently and lived there for a period of one year approximately, they were sold at this point of time and total net profit which was made was of $150,000 approximately. The taxpayers a few years later then purchased another parcel of land where units were constructed by them and these were then sold. It was contended by the Commissioner that the profits which accrued from the townhouses sale were income that was ordinarily assessable as it was a result of a profit making activity which was commercial in nature. It was argued by the taxpayers that the sale of the land was merely to realize the capital asset and therefore could not be classified as ordinary income since, these townhouses were being used for residential purposes and it was only when there were financial difficulties that it was sold. It was opined by the court that the lands sale was ordinary income because the purpose with which the land had been acquired was commercial and the view behind it was for making profit for selling it. It was not for an investment purpose that the land was purchased and hence cannot be stated to be realization of capital asset. References Ato.gov.au. (2016).Examples of residents and foreign residents | Australian Taxation Office. [online] Available at: https://www.ato.gov.au/Individuals/International-tax-for-individuals/In-detail/Residency/Examples-of-residents-and-foreign-residents/ [Accessed 23 Aug. 2016]. Ato.gov.au. (2016).Residency tests | Australian Taxation Office. [online] Available at: https://www.ato.gov.au/Individuals/International-tax-for-individuals/Work-out-your-tax-residency/Residency-tests/ [Accessed 23 Aug. 2016]. Australian income tax assessment act 1936-1974. (1975). North Ryde, N.S.W.: CCH Australia Ltd. California Cooper Syndicate Ltd. v Harris (Survey or of Taxes)[1904]5 TC 159. Casimaty v FC of T 97[1997]ATC 5135. Clinton, A. (2016).; Bentley, Duncan; James, Simon --- "The New Zealand Definition of "Residence" for Individuals: Lessons for Australia in a "Global" Environment" [2001] JlATax 1; (2001) 4(1) Journal of Australian Taxation 40. [online] Austlii.edu.au. Available at: https://www.austlii.edu.au/au/journals/JlATax/2001/1.html [Accessed 23 Aug. 2016]. Crow v FC of T[1988]88 ATC 4620. FC of T v Whitfords Beach Pty Ltd[1982]150 CLR. Levene v IRC[1928]AC 217. McCurry Anor v FC of T[1998]98 ATC 4487. Mona Sand Pty Ltd. v FC of T[1988]88 ATC 4897. Scottish Australian Mining Co. Ltd. FC of T[1950]81 CLR 188. Statham Anor. v FC of T[1989]ATC 4070. Wills, M. (1997). The Income Tax Implications of a Foreign Individual Contracting to do Business in Australia, with Particular Reference to the Concepts of 'Residence' and 'Source'.Bond Law Review, 3.
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