Sunday, May 24, 2020
The Horror of Gas Chamber Poison Zyklon B
Beginning in September 1941, Zyklon B, the brand name for hydrogen cyanide (HCN), was the poison used to kill at least a million people in gas chambers at Nazi concentration and death camps such as Auschwitz and Majdanek, both in Poland. Unlike the Nazis earlier methods of mass murder, Zyklon B, which was originally used as a common disinfectant and insecticide, proved to be an efficient and deadly murder weapon during the Holocaust. What Was Zyklon B? Zyklon B was an insecticide used in Germany before and during World War II to disinfect ships, barracks, clothing, warehouses, factories, granaries, and more. It was produced in crystal form, creating amethyst-blue pellets. Since these Zyklon B pellets turned into a highly poisonous gas (hydrocyanic or prussic acid) when exposed to air, they were stored and transported in hermetically sealed metal canisters. Early Attempts at Mass Killing By 1941, the Nazis had already decided and attempted to kill Jews on a mass scale. They just had to find the fastest way to accomplish their goal. After the Nazi invasion of the Soviet Union, Einsatzgruppenà (mobile killing squads) followed behind the army in order to round up and murder large numbers of Jews by mass shootings, such as at Babi Yar. It wasnt long before the Nazis decided that shooting was costly, slow, and took too high a mental toll on the killers. Gas vans were also tried as part of the Euthanasia Program and at the Chelmno Death Camp in Poland. This mode of killing used carbon monoxide exhaust fumes from trucks to murder Jews crammed into the enclosed back area. Stationary gas chambers also were created and carbon monoxide was piped in. These killings took about an hour to complete. Test Using Zyklon B Pellets Crematorium 1 at Auschwitz concentration camp. Ira Nowinski/Getty Images Rudolf Hà ¶ss, commandant of Auschwitz, and Adolf Eichmann, one of the German officers in charge of exterminating Jews and others, searched for a faster way to kill. They decided to try Zyklon B. On September 3, 1941, 600 Soviet prisoners of war and 250 Polish prisoners who were no longer able to work were forced into the basement of Block 11 at Auschwitz I, known as the death block, and Zyklon B was released inside. All died within minutes. Just days later, the Nazis transformed the large morgue room at Crematorium I in Auschwitz into a gas chamber and made 900 Soviet prisoners of war go inside for disinfection. Once the prisoners were crammed inside, Zyklon B pellets were released from a hole in the ceiling. Again, all died quickly. Zyklon B proved to be a very effective, very efficient, and very cheap way to kill large numbers of people. The Gassing Process Aerial reconnaissance film of Auschwitz concentration camp, 1st August 1944. à Bettmann/Getty Images With the construction of Auschwitz II (Birkenau), Auschwitz became one of the largest killing centers of the Third Reich. As Jewish and other undesirables were brought into the camp via train, they underwent a Selektion, or selection, on the ramp. Those deemed unfit for work were sent directly to the gas chambers. However, the Nazis kept this a secret and told the unsuspecting victims that they had to undress for a bath. Led to a camouflaged gas chamber with fake showerheads, the prisoners were trapped inside when a large door was sealed behind them. Then, an orderly, who wore a mask, opened a vent on the roof of the gas chamber and poured Zyklon B pellets down the shaft. He then closed the vent to seal the gas chamber. The Zyklon B pellets turned immediately into a deadly gas. In a panic and gasping for air, prisoners would push, shove, and climb over each other to reach the door. But there was no way out. In five to 20 minutes, depending on the weather, all inside were dead from suffocation. After it was determined that all had died, the poisonous air was pumped out, which took about 15 minutes. Once it was safe to go inside, the door was opened and a special unit of prisoners, known as the Sonderkommando, hosed down the gas chamber and used hooked poles to pry the dead bodies apart. Rings were removed and gold plucked from teeth. Then the bodies were sent to the crematoria, where they were turned into ash. Who Made Zyklon B? Zyklon B was made by two German companies, Tesch and Stabenow of Hamburg and Degesch of Dessau. After the war, many blamed these companies for knowingly creating a poison that was used to murder over a million people.à The directors of both companies were brought to trial. Tesch and Stabenow director Bruno Tesch and executive manager Karl Weinbacher were found guilty and given death sentences. Both were hanged on May 16, 1946. Dr. Gerhard Peters, the director of Degesch, was found guilty only as an accessory to homicide and was sentenced to five years in prison. After several appeals, Peters was acquitted in 1955.
Sunday, May 17, 2020
Preventative Methods Of Alzheimers Disease - 1824 Words
Preventative Methods of Alzheimerââ¬â¢s disease Now that the disparity between Alzheimerââ¬â¢s disease prevalence in men and women, as well as the different rates of incidence in different countries has been established, it is now applicable to discuss what can be done to prevent this disease. There are many ways that researchers believe people can use to prevent Alzheimerââ¬â¢s disease. Studies by researchers have found that cannabinoids could stimulate the brain cells and slow the progression of the disease. Conversely, some believe that Alzheimerââ¬â¢s is impossible to fight, regardless of the precautions taken. This paper will examine Alzheimerââ¬â¢s disease and also explore in depth on the following topics: the prevalence of Alzheimerââ¬â¢s in males vs.â⬠¦show more contentâ⬠¦Frank Longo said it best when he stated,â⬠We have cured Alzheimerââ¬â¢s in mice. Why canââ¬â¢t we move that success to people?â⬠(Time Magazine) There is research that suggests altering the lifestyle can lower the risk of developing Alzheimerââ¬â¢s disease. There are also two more ways that people can stay healthy and they are: using cannabinoids and avoiding benzodiazepines. The former is found in marijuana and the latter in anxiety, epilepsy, and sleep medications. In the benzodiazepine study, the researchers took hundreds of Canadian participants that were over the age of 66 and grouped them based on whether they had ever used benzodiazepines. This research was conducted by de Gage, Moride, Ducruet, Kurth, Verdoux, Tournier, Pariente, and Begaud in 2014. The study on cannabinoids, a significant component found in marijuana, was done by Bachmeier, Beaulieu-Abdelahad, Mullan, and Paris in 2013. These studies play an essential role in illustrating how this disease can be prevented. There may not be a definitive cure for those who are already deeply afflicted with this disease, even in the future. However, examining studie s on cannabinoids and benzodiazepines may help those who are in the early stages or have no clinical signs of Alzheimerââ¬â¢s. In regards to the benzodiazepine study, the participants who did not ever use benzodiazepines were placed in the control group (de Gage 2014). The main finding of this study was the fact that benzodiazepine use is correlated to
Thursday, May 14, 2020
Christmas and New Year Quotes
What do the wise and witty say about Christmas and the New Year? You can use these quotes for inspiration and see who is a kindred spirit. You might want to include one in your holiday greeting cards, social media posts, or family Christmas letter. Reach out to friends or relatives on the other side of the planet and shower them with these caring words. Phillips Brooks Christmas day is a day of joy and charity. May God make you very rich in both. W. J. Cameron There has been only one Christmasââ¬âthe rest are anniversaries. Sydney Smith Resolve to make at least one person happy every day, and then in ten years you may have made three thousand, six hundred and fifty persons happy, or brightened a small town by your contribution to the fund of general enjoyment. Erma Bombeck Theres nothing sadder in this world than to awake Christmas morning and not be a child. Pat Boone The Christmas spirit -- love -- changes hearts and lives. Isabel Currier It is the personal thoughtfulness, the warm human awareness, the reaching out of the self to ones fellow man that makes giving worthy of the Christmas spirit. Patricia Clafford Christmas is a time to expand our giving encompassing the friendless and needy... near and far. Christmas is sharing. Debbie Harry I always work on New Years Eve, no matter what. Charles Lamb No one ever regarded the first of January with indifference. It is that from which all date their time, and count upon what is left. It is the nativity of our common Adam. Edward Payson Powell The old year has gone. Let the dead past bury its own dead. The New Year has taken possession of the clock of time. All hail the duties and possibilities of the coming twelve months! Mark Twain Yesterday, everybody smoked his last cigar, took his last drink and swore his last oath. Today, we are a pious and exemplary community. Thirty days from now, we shall have cast our reformation to the winds and gone to cutting our ancient shortcomings considerably shorter than ever. Buddha There is only one time when it is essential to awaken. That time is now. Pierre Teilhard de Chardin The ills from which we are suffering have their seat in the very foundation of human thought. But today something is happening to the whole structure of human consciousness. A fresh kind of life is starting. Charles Dickens It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the spring of hope, it was the winter of despair. T. S. Eliot For last years words belong to last years language. And next years words await another voice. And to make an end is to make a beginning. Ralph Waldo Emerson Finish each day and be done with it. You have done what you could; some blunders and absurdities have crept in; forget them as soon as you can. Tomorrow is a new day; you shall begin it serenely and with too high a spirit to be encumbered with your old nonsense. William Thomas It wouldnt be New Years if I didnt have regrets.
Wednesday, May 6, 2020
The American Dream And Its Reality For Minority Americans
From the settlement of Jamestown and Plymouth colonies to modern times, Americans have always been determined to improve themselves both economically and socially. Even today, we are attempting to make society better by extending marriage rights to homosexuals and arguing the merits of flying the Confederate Battle flag over government buildings in non-historical situations. At the same time, concerns such as the impact of the Greek economic collapse on American business and the long-term cost of the Office of Personnel Management s data breech impact our belief in the continued economic improvement of our society. Arguments about the truth behind the American Dream and its reality for minority Americans leave many wondering and confused about our ability as a society to balance the desire to do good socially with our ability to do well economically. The same concerns existed for Americans in the early 1800s. Efforts to improve society through the abolition of slavery, the temper ance movement, and public health and sanitation were central to American life. But Americans were also concerned with efforts to improve ourselves economically in the construction of new transportation networks, the founding of a national economic infrastructure, the creation of the American System combining tariffs on foreign imports with the expenditure of government funds on infrastructure projects, and the improvement of the ways in which we manufactured goods and made ourShow MoreRelatedLet America Be America Again Poem Analysis792 Words à |à 4 PagesThe American Dream or Nightmare? In ââ¬Å"Let America Be America Again,â⬠Langston Hughes addresses the reality of inequality and discriminative behaviors of the American people in the pre-Civil War era. Many Americans during this time felt the American Dream was just an illusion because they can never get the opportunity to make it their reality. In this poem, Hughes voices these silent Americansââ¬â¢ concern of how the founding principles of America are not being fulfilled unless a person is wealthy orRead MoreWomen And The American Dream1253 Words à |à 6 PagesThe American Dream is the belief that every person in the United States has an equal opportunity to become successful. However, some people are not entitled to the American Dream. Many Americans are not treated equally under the law. Some of the groups lose their right to vote, have a more difficult time finding jobs, or are a group that has been forgotten by politicians. The American Dream is a controversial issue today because many groups i n America have claimed that they have not received theRead MoreThe American Dream727 Words à |à 3 PagesThe American dream for minorities is a difficult to obtain goal because for minorities, everyday obstacles prevent them from obtaining this dream that was never meant for them. Despite the difficulties, there exists many instances throughout history of people from a wide variety of cultural backgrounds have fought for the simple right to be able to have the chance to reach that goal. Ironically, during one of the most devastating times in our nationââ¬â¢s history, historian James Truslow Adams coinedRead MoreThe Epic Of America By James Truslow Adams1533 Words à |à 7 Pages In James Truslow Adamsââ¬â¢ The Epic of America, the American dream is defined as an egalitarian ideology in which ââ¬Å"life should be better and richer and fuller for everyone, with opportunity for each according to ability or achievement.â⬠Established by an inherently advantaged Anglo American in an era of burgeoning racism, the American dream was and is still believed to provide equal opportunity for all, including minorities who, despite their onerous struggle against discrimination at the hands ofRead MoreThe Idea of the ââ¬Å"American Dreamâ⬠1101 Words à |à 5 PagesThe American Dream Final Exam By: Uday Govindswamy Period 2 The idea of the ââ¬Å"American Dreamâ⬠was first used in the book The Epic of America, written by James Truslow Adams, in 1931. Adams stated that the American Dream is, ââ¬Å"the dream of a land in which life should be better and richer and fuller for everyone, with opportunity for each according to ability or achievementâ⬠¦(31) ââ¬Å". The key elements of the American Dream include: access to a college education, owning a home, enjoying politicalRead MoreThe American Dream823 Words à |à 4 Pageswhat the American Dream is and what it takes to make it a reality. The most common and the most accurate idea of the American Dream is for all to have the opportunity to have a chance at living a nice life. This includes all immigrants and anyone else who seems to lack better opportunities often. The American Dream is the belief that anyone, regardless of race, class, gender, or nationality, can be successful in America (read:rich) if they just work hard enough (Wulick). The American Dream is alsoRead MoreWho Is The American Dream?1326 Words à |à 6 Pagesachieve success and certainly no way to achieve the American Dream. Critical to ensuring any chance of achieving the ââ¬Å"American Dreamâ⬠in this day and age is to obtain a college education. Although it is possible to attain without attending college, it is extremely unlikely. For those with an education, the dream still at least has a pulse. For the majority of people who either do not think they need an education or cannot afford one, the dream probably lost. Adults are often saying ââ¬Å"when I was aRead MoreMartin Luther King s I Have A Dream Speech961 Words à |à 4 PagesKing Jr.ââ¬â¢s Historic ââ¬Å"I Have a Dreamâ⬠Speech Dr. Martin Luther Kingââ¬â¢s ââ¬Å"I Have a Dreamâ⬠speech was written and delivered on August 28, 1963, on the steps of the Lincoln Memorial and remains one of the most historically influential and world-changing speeches of all time. Fifty-two years later, this speech is considered to be one of the best persuasive speeches ever delivered. Dr. King is not only attempting to persuade his audience to understand the plight of minorities in the United States, but heRead MoreThe American Dream : The Reality Of America860 Words à |à 4 PagesAmerica throughout time has been known as a country for opportunity and freedom, where anyone can come and have a fair chance at living their ââ¬Å"American Dream.â⬠The stereotypical American dream is having a two parent family, with stable income, owning a home with a white picket fence with two children. But the reality of America is that this ââ¬Å"dreamâ⬠is achieved more easily by white men. Even though America is suppos edly ââ¬Å"The land of the freeâ⬠and provides ââ¬Å"Liberty and Justice for allâ⬠, these statementsRead MoreHas Dr. Martin Luther Kings Dream Become Reality?870 Words à |à 4 PagesMartin Luther King, Jr. in his acclaimed I Have a Dream speech become a reality in twenty-first century America? Though relevant government statistics are limited and do not go back to the 1960s, available data suggests that our country still has a long way to go before attaining true equality of opportunity for black and white Americans. Yet evidently as a nation we have come a long way to conquer the oppression of minorities. African American students can go to schools with white students, they
El Nino Essay - 688 Words
El Nià ±o and La Nià ±a Worksheet After exploring the websites, you will have enough information to answer the following questions. There are 19 true/false questions and 1 short answer question that need to be answered. Submit your work to your instructor and then complete the El Nià ±o and La Nià ±a Quiz. The information below explains how to answer the questions. * If the statement is True, answer True for full credit. * If the statement is False, answer False for half credit and then rewrite the sentence to make it a True statement. To make it True, you will likely only need to swap no more than 2-4 words that describe the main concept to make it true. Here are a couple of examples. Example #1: True/False: Mostâ⬠¦show more contentâ⬠¦Answer: 7. Warm ENSO episodes result in abnormally wet conditions over northern Australia, Indonesia, and the Philippines in both winter and summer seasons. Answer: 8. During a warm ENSO episode, storms tend to be more vigorous in the Gulf of Mexico along the southeast coast of the U.S. resulting in wetter than normal conditions in that region. Answer: 9. During a La Nià ±a episode, higher than normal pressure is observed over Indonesia and northern Australia and lower than normal pressure is observed over the eastern tropical Pacific. Answer: 10. The southeastern U.S. becomes warmer and drier than normal during a cold La Nià ±a episode. Answer: 11. El Nino is closely related to global atmospheric oscillation known as the Northern Oscillation. Answer: 12. La Nià ±a represents the warm phase of the ENSO cycle and El Nino represents the cold phase of the ENSO cycle. Answer: 13. NOAAââ¬â¢s Climate Prediction Center declares the onset of an El Nià ±o episode when the 6-month average sea-surface temperature departure exceeds 2.5 deg Celsius in the east-central equatorial Pacific. Answer: 14. El Nià ±o and La Nià ±a episodes typically occur every 2-7 years. However, in the historical record this interval has varied from 3-5 years. Answer: 15. El Nià ±o and La Nià ±a areShow MoreRelated El Nino Essay2743 Words à |à 11 PagesEl Nino We live on an incredibly large planet. Even broader than the size of the planet are the amount of changes and relationships between humans, animals, environment, weather, and the effects of each. Many times with busy schedules and modern lifestyles we forget the interaction that goes on between any number of concepts or ideas. We fail to realize that a specific weather occurrence in the Pacific Ocean can have an effect on every day life in the United States. El Nino is one of the largestRead More El Nino, La Nina and Hurricanes Essay467 Words à |à 2 PagesEl Nino, La Nina and Hurricanes How does the change in climate affect the frequency and the path of those powerful hurricanes and tropical storms in the tropical Pacific and Atlantic Oceans? Global warming has a profound vast impact on the Earth. Besides landmasses, ocean is warmed unevenly. Additionally, unexpected changes in ocean current will aggregate the uneven distribution of water temperatures along the globe. Warmer or cooler than normal sea surface temperatures occur alongRead More El Nino: Past, Present, and Future Essay example1296 Words à |à 6 PagesEl Nino: Past, Present, and Future El Nino is both an atmospheric and oceanic phenomenon affecting weather patterns all around the world. It is complemented by La Nina in a cycle that occurs approximately every 4 years, varying as much as every two years to every six years (Wang 1999, 3331). La Nina has almost the opposite effect, however differs in its strength and duration randomly, as does El Nino (Fedorov 2000, 1998). The cycle is often paraphrased as ENSO, standing for El Nino-Southern OscillationRead MoreEl Nino2863 Words à |à 12 PagesStates. El Nino is one of the largest scientific phenomenons that scientists have ever explored. The main concepts of El Nino are very simple and there are many variations, causes, affects, and relationships to study. The main idea behind El Nino is that the wind changes direction across the Pacific Ocean. In a non El Nino year (normal), the trade winds blow from east to west across the ocean, from North and South America towards the tropical regions of the Pacific Ocean. In an El Nino year, theRead MoreWhat Makes El Nino?2005 Words à |à 9 PagesEl Nino is a phenomena that occurs when the ocean and the atmosphere collide. The warm atmosphere mixes with the water and creates a moisture in the air creating a low pressure system. A high pressure system is created when the cold water reduces the air above it. During a low pressure system the air becomes moist and can create severe tropical storms, on the other hand when there is a high pressure system the cold dry air goes back down and takes away all of the moisture. When combined this canRead MoreThe El Nino Southern Oscillation1878 Words à |à 8 Pages Introduction The El Nino Southern Oscillation is a large scale circulation of atmospheric and oceanic interactions. It is a natural climate phenomenon where the tropical Pacific Ocean experiences higher than normal ocean temperature. The opposite, La Nina, refers to the unusual cooler than normal sea surface temperatures. It gained its name ââ¬Å"the Christ childâ⬠in Spanish (ââ¬Å"the girlâ⬠for La Nina) because the characteristic is most obvious around Christmas alone the western coast of South AmericaRead MoreEl Nino And Its Effects852 Words à |à 4 PagesEl Nià ±o and its Effects Recently, the weather has varied greatly from traditional for many areas within the United States; the East Coast has had next to zero snow, while Midwest states have been hit by several heavy snowstorms. Although this change in weather patterns, compared to the average year, may appear unordinary and confusing, it can be attributed to the fact that a very strong El Nià ±o is currently underway. El Nià ±o occurs when trade winds in the Pacific Ocean decrease in magnitude, whichRead More El Nino Essay1144 Words à |à 5 Pages El Nino nbsp;nbsp;nbsp;nbsp;nbsp;Typically, the level of ocean water around the world is higher in the western Pacific and lower in the eastern, near the Western coast of South and North America. This is due primarily to the presence of easterly winds in the Pacific, which drag the surface water westward and raise the thermocline relatively all the way up to the surface in the east and dampen it in the west. During El Nino conditions, however, the easterlies move east, reducing the continuingRead MoreGlobal Warming As Causes Of El Nino Southern Oscillation Phenomena2540 Words à |à 11 Pagesââ¬Æ' ESSAY PLAN Global Warming As Causes Of El Nino-Southern Oscillation Phenomena The advancements in various sectors in the life of human beings, which often exploit natural resources without control, directly or indirectly lead to changes in the environment sustained effect unconsciously towards the emergence of a disaster. The other thing is the changes of natural phenomena that occur periodically turned into irregular and even a negative effect on habitat and human life. People unrealizedRead MoreThe El Nino : A Weather Phenomenon1548 Words à |à 7 PagesThe El Nià ±o story starts on the eastern Pacific Ocean. Peruvian fisherman have alway known the usually very cold and plentiful waters every so often become exceptionally warm, followed by the collapse of fish stocks. These unusual events return every 3-7 years and, and peak around December (Christmas), the fishermen named the phenomenon El Nià ±o (Spanish for boy child). For decades, El Nià ±o was considered to be a weather phenomenon only correlating with the countries of western South America. Scientists
Relevant information on the Functioning of PI-3 Kinase
Question: Describe about the Relevant information on the functioning of PI-3 Kinase was contained in it which is also known as PTEN? Answer: The presentationgave a clear and detailed account of the seminar. Relevant information on the functioning of PI-3 Kinase was contained in it which is also known as PTEN. Cell growth, proliferation, cell motility; cell polarity, cell metabolism etc. cellular processes are being regulated by PI-3 Kinase. This has been mentioned and described in details.PTEN is a liquid phosphatase. It is also described how it dephosphorylates PIP3 into PIP2 thus, antagonizing the action of PI-3 Kinase which is generally a suppressant for tumors. But, the mechanism of the regulation of glioma cell invasion along with the cell architecture of epithelial cells by PTEN has not been described aptly.It has been found in the lab that this process occurs independently to ATKkinase but has failed to conjure up the mechanism of the whole process. This is in contrary to the assumption that the cellular mechanisms are driven by inactivating ATK kinases. In this particular seminar various chemical engineering concepts are regarding discussed but some of the points are not elaborated in detail. Therefore, some understanding gaps are being produced for the same. The cellular process hypothesis was the primary base of the study. On the other hand, the qualitative and quantitative processes were not adapted in such places to collected the required information. The presentation explained all the information that was given in the seminar. It was pretty much detailed and did not require much effort in grasping the whole idea that was presented.
Tuesday, May 5, 2020
Taxation Law and Practice Residency & Assessable Income
Question: Discuss about the Taxation Law and Practice Residency Assessable Income. Answer: Determining the tax residency The tax residency status of an individual tax payer provides estimation that what portion of the income is assessable for the taxation that is derived either from domestic sources or from foreign sources. As per the Section 6-5(3) of the Income Tax Assessment Act (ITAA), 1997[1], in case of foreign tax resident only the amount of proceeds that are generated with in Australia are considered for the assessable income. Therefore, it is essential to determine the tax residency status of the taxpayer in order to comment on the accessibility of incomes received from various sources. In the process of determining the tax residency status in case of an individual taxpayer, subsection 6(1) of ITAA, 1936 would be considered. There are lots of parameters under various tax rulings and case laws that can be applied to determine the tax residency. TR 98/17[2] is one of the imperative tax rulings that highlight the major tests to find the tax residency[3]. These tests are applied on a taxpayer in order to determine the tax residency for given financial year. These tests are highlighted below: 183 day Test: This test is applicable only when the concerned taxpayer is a foreign resident. Superannuation Test: This test is applicable only for the government officers who are residing in foreign land in order to complete their duties. Resides Test: This test is applicable only when the concerned taxpayer is a foreign resident. Domicile Test: This test is applicable only when the concerned taxpayer is an Australian resident. In the present case, Domicile test is applicable because the concerned taxpayer is an Australian resident. A detailed discussion of domicile test is as highlighted below: Domicile Test: There are mainly two conditions of the domicile test that need to be satisfied on behalf of the taxpayer in order to recognised as Australian tax resident for the respective financial year[4]. It is essential that the taxpayer must possess Australian Domicile as per Domicile Act 1982. The permanent residence as highlighted in the decision of Levene v. I.R.C.[5] case must be situated within Australia for the respective financial year It is noteworthy that if the concerned taxpayer does not satisfy both the above highlighted conditions, then the taxpayer would not be termed as Australian tax resident under domicile test. In application of the above tests, domicile determination is rather straightforward but the same cannot be said about the ascertaining of permanent abode location which is usually fraught with high degree of subjectivity and hence requires further assistance. The imperative tax ruling IT 2650 is used to comment on the aspects related to the ascertaining of the underlying location of the permanent residence[6]. These aspects are essential because the tax commissioner would use the below mentioned aspects while deciding on the permanent abode location[7]. Total stay in the foreign land, when the taxpayer is outside from Australia then the difference between the actual duration of stay and intended duration of stay would be considered. The reason/purpose on the part of the taxpayer to stay in the foreign land Rate of visits, which involves how many times the resident is going and staying on the foreign land Location of the asset and residential essential to the taxpayers such as rent or lease and so forth Any particular act on taxpayers part that indicates the willingness to reside outside from Australia on a permanent basis. Intensity of the personal and professional bonds of the taxpayer in Australia during the period of abroad stay also plays an imperative role in this regards, A critical aspect with regards to application of the test is to understand the contours of the word permanent which gives the perception that a permanent shift of the taxpayer from Australia would cause relocation of the permanent abode. However, this is not true. The F.C. of T. v. Applegate[8] case is the testimony in this context. According to this case, the concerned taxpayer who was having an Australian domicile was sent overseas for some professional work, then the long term duration of the stay in the overseas would be a significant parameter to decide the permanent abode of the taxpayer. In such cases, if the intended time of stay in the foreign land is not defined but the taxpayer has a strong will to go back to Australia in future after the work is finished, then the taxpayer would be considered as foreign tax resident. But, due to critical reason such as diseases, health issues he/she came back to Australia on permanent basis then also he/she would be recognised as foreign tax resident for the years which he /she has spent in the foreign land irrespective of the significant difference between the actual stay and intended stay in overseas. It is apparent that the concerned taxpayer Peter is an Australian resident and engaged in the profession of a guitarist in a well-known band in Australia. It has been found by the taxpayers that the band can get huge success in England and thus, the band members along with Peter decide to go to England. Taxpayer Peter has a strong willingness to return to Australia after getting significant popularity in England. In order to collect the requisite fund, Peter had a house which he rented and also sold his car and shares. When the band members and Peter had arrived in England, they had leased a house for 1 year. As estimated by the band member, a significant popularity was obtained by the band and derived subsequent proceeds, prices and royalties on the album sold along with live shows. In August 2017, it had been decided by members to return back to Australia and in October 2017, they came back to Australia. Additionally, Peter had leased the house with a validation till end of the yea r 2018 and thus, Peter had to make a stay in a rented house located in Australia. It is apparent that Peter is having an Australian domicile under the Domicile Act 1982. It means he satisfied one of the essential of domicile test. Moreover, in regards to comment on the permanent abode of Peter, it is apparent that he has leased his permanent house located in Australia and shifted to England for professional course of work for acquiring requisite popularity of band. It is evident that Peter does not have any clear idea regarding the duration of stay in England but expects it to be of long enough to stretch into years. Hence, he has leased his house for substantial period of time i.e. end of year 2018. This indicates that there is very less possibilities regarding the early return of Peter. Therefore, it can be concluded that for the time period, which he has spent in England, it would be considered that Peter had shifted the permanent abode and thus, he would be recognized as foreign tax resident as per the leading case F.C. of T. v. Applegate (1979) ATC 4307 case. Assessable income The tax treatment of an Australian tax resident under the provisions of Section 6-5(2) of ITAA, 1997[9] takes into consideration both foreign income as well as domestic income for the purposes of tax accessibility. This is in stark contract with a foreign tax resident for whom only income derived from sources situated in Australia would be taxable. Since, Peter is not an Australian tax resident, hence only sources located in Australia are eligible to contribute towards assessable income. According to the Australian tax law, there are two main parts of assessable income as identified below. Ordinary income as per Section 6(5) of ITAA, 1997 As name suggests, any income earned or derived from ordinary source of income such as due to investment, dividend, rental or lease amount, interest amount, professional works or through personal exertion are termed as ordinary income. There is no specific ruling or provision given in the statue for the ordinary income specifying the exact sources and thus, the leading case law and their verdicts are considered for the determination whether the income is assessable under the ordinary income concepts or not[10]. Moreover, any proceeds derived on the account of the royalty for the professional work would also be termed as assessable income under the ordinary income concept of TR 98/1 if the same is derived from skills related to profession. Also, profession related prize money as per the arguments in Scott v. Federal Commissioner of Taxation[11]would also contribute to ordinary income. Statutory income as per Section 6(10) of ITAA, 1997 One of the key components of statutory income is capital gains on which application of capital gains tax or CGT takes place. The income derived on liquidation of a capital asset would result the capital receipts and, if the capital gains is obtain than capital gains, then the same would be taxable as per the provision of CGT[12]. Moreover, capital gains received from a personal use asset that are used by the taxpayer for personal work or for entertainment would not liable for CGT under the Section 108-20(2), ITAA 1997[13]. Moreover, fifty percent discount would be validated for the concerned Australian resident taxpayer on the received long term capital gains as per the Division 115 ITAA, 1997[14]. Application Case facts Therefore, the income derived in Australia only would be liable for the computation of assessable income as per the provision of Section 6-5(3). For income tax year 2016 Sale of car Exempt from the capital gains tax Section 108-20(2) No assessable income Sale of shares Long term capital gains (Peter is not liable to get 50% discount because he is foreign tax resident in 2016) assessable income ($11000 - $5000) = $6000 ARIA award amount Ordinary income Section 6(5) assessable income ($20,000) Proceeds due to good performance Ordinary income Section 6(5) assessable income ($140,000) Lease amount results from the leased house located in Australia Ordinary income Section 6(5) assessable income For income tax year 2017 Royalty amount Ordinary income Section 6(5) assessable income ($30,000) ARIA award amount Ordinary income Section 6(5) assessable income ($10,000) Lease amount results from the leased house located in Australia Ordinary income Section 6(5) assessable income For income tax year 2018 Lease amount results from the leased house located in Australia Ordinary income Section 6(5) assessable income Royalty amount received after returned back to Australia Ordinary income Section 6(5) assessable income ($4,000) It is noteworthy that the income received from the foreign source (while residing in England) would not be considered as assessable income because in that period of time he is termed as foreign resident. References Websites Australian Taxation Office: Taxation Rulings: TR 98/17-Income tax: residency status of individuals entering Australia (25 November 1998), https://www3.austlii.edu.au/au/other/rulings/ato/ATOTR/1998/tr1998-017/ ATO, Guide to capital gains tax, https://www.ato.gov.au/Tax-professionals/TP/Guide-to-capital-gains-tax-2016/ Commonwealth Consolidated Acts: Income Tax Assessment Act 1997 SECT 6.5. https://www.austlii.edu.au/au/legis/cth/consol_act/itaa1997240/s6.5.html ATO, INCOME TAX ASSESSMENT ACT 1997, https://www.ato.gov.au/law/view/document?DocID=PAC/19970038/6-5 Books Sadiq, Kerrie, et. al., Principles of Taxation Law 2015, (Pymont,Thomson Reuters, 2015) Deutsch, Robert, et. al., Australian tax handbook. (Pymont, Thomson Reuters, 2015) Relevant Statutes Income Tax Assessment Act, 1936 Income Tax Assessment Act, 1997 Case laws Levene v. I.R.C. (1928) A.C.217 F.C. of T. v. Applegate (1979) ATC 4307
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