Writing essay for scholarship
Wednesday, September 2, 2020
3 Errors Involving Correlative Conjunctions
3 Errors Involving Correlative Conjunctions 3 Errors Involving Correlative Conjunctions 3 Errors Involving Correlative Conjunctions By Mark Nichol A correlative combination is a word that corresponds with, or is integral to, another such development, building up an association or an examination in a sentence. Every one of the sentences underneath wrongly utilizes a couple of correlative conjunctions in a flawed grammatical structure, and the conversation that follows each portrays the issue, while a modification exhibits the arrangement. 1. An all around structured methodology not exclusively can assume a key job in a companyââ¬â¢s business forms, yet in addition in its more extensive technique. Sentences that present a ââ¬Å"not just . . . be that as it may, alsoâ⬠point-contrast relationship frequently do so erroneously. This happens when the essayist grammatically arranges the sentence with the goal that words speaking to different grammatical forms are not set effectively to serve their capacities. For this situation, on the grounds that the action word express ââ¬Å"can play a key roleâ⬠relates to the two decisions (ââ¬Å"a companyââ¬â¢s business processesâ⬠and ââ¬Å"its more extensive procedure), that expression must go before ââ¬Å"not onlyâ⬠: ââ¬Å"A all around structured methodology can assume a key job in a companyââ¬â¢s business forms as well as in its more extensive strategy.â⬠2. This distribution is neither proposed to be a legitimate investigation nor a nitty gritty cookbook of steps to take in each circumstance. A similar kind of mistake happens in a sentence that incorporates the correlative conjunctions neither and nor-planned applies to the two decisions, so it must go before the whole correlative development: ââ¬Å"This distribution is proposed to be neither a legitimate examination nor a nitty gritty cookbook of steps to take in each situation.â⬠(Alternatively, the sentence can be composed ââ¬Å"This distribution isn't expected to be a lawful investigation or a point by point cookbook of steps to take in each situation.â⬠) 3. A talented planner can deliver a staggering diagram, however an accomplished temporary worker will disclose to you whether the structure in that outline can be created, and at what cost. Blunders including the correlative combination whether and additionally are once in a while mistakes of wrong punctuation; for the most part, the blunder is including ââ¬Å"or notâ⬠after whether when the expression is superfluous: ââ¬Å"A talented modeler can create a dazzling outline, yet an accomplished contractual worker will disclose to you whether the structure in that diagram can be delivered, and at what cost.â⬠Need to improve your English quickly a day? Get a membership and begin accepting our composing tips and activities day by day! Continue learning! Peruse the Grammar classification, check our well known posts, or pick a related post below:50 Rhetorical Devices for Rational WritingPrecedent versus PrecedenceGlimpse and Glance: Same or Different?
Saturday, August 22, 2020
WHY UNIONS Essay Example For Students
WHY UNIONS? Article Associations are gatherings of working individuals who join to converse with bosses about wages and states of work rather than laborers conversing with managers on an individual basis.1 Because they represent everyone, associations can show signs of improvement bargain for every specialist than one representative could by haggling with the business. As found in the short film WHY UNIONS?, non-unionized laborers discusses the uncalled for treatment they involvement with the work place. Through aggregate activity, laborers shaped associations so they could have a voice in choosing compensation, hours, working conditions and managing the numerous issues emerges in the working environment. Associations are not simply associations attempting to get more dollars and pennies or better working conditions for individuals who hold association cards. Individuals who dont appreciate the advantages of association assurance get benefits as well. The work development was in the bleeding edge of the battles for general social insurance, for state funded training, for least wages, occasions and business conditions. We will compose a custom exposition on WHY UNIONS? explicitly for you for just $16.38 $13.9/page Request now 2 1 D. Martin, Form War To Peace, Canadian Labor Congress, Quebec, 1991, P.17 2 Notes On Unions, Canadian Labor Congress, Quebec, 1992, P.1 P. 2 UNION NOWADAYS Unions resemble organizations: their prosperity relies on drawing in and holding purchasers (new individuals). As of late, one of the serious issues looked by the association development is that couple of Canadians comprehend what administrations associations come into public.3 The open likewise dont realize the association is additionally helping Canada in different pieces of zones, for example, economy, and so forth. The open imagine that the main opportunity associations come into the publics eye is because of strike or withdrawal of administrations. This is a result of the dazzled strikes held by the association laborers. The important one would be the strike held by the Toronto Transit Commission laborers back in September 1991. The absence of transportation brought about bothers among people in general. The Canadian open gets steamed at strife. The strikes cause the general population to disregard the commitments of associations in different regions. From a promoting point of view, the association development has situated itself like the atomic business it gets consideration just when it is going to explode, dissolve or leak.4 Five significant requirements for association developments are: 3 Alistair Davidson and Ian Mckinnon, Unions need to contemplate showcasing, The Globe and Mail, May 8 1984, Business segment, P.8 4 D. D. Carter, Canadian Industrial Relations In The Year 2000, Industrial Relations Center, Kingston, 1992, P.50 P.3 1) work protection 2) wellbeing safeguarding in the work environment 3) day-care 4) retraining 5) budgetary arrangements for the benefit of individuals Union pioneers and individuals must become as modern as the board to help the endeavor by Canadian business to endure furious universal rivalry. 5 There are around 4,000,000 individuals from Canadian associations and 10.5 million individuals from co-agents. There are two decisions: generally, associations have just attempted to build their individuals way of life by arranging a higher pay, more advantages or less hours. The association development has assumed a significant job in the past in the arrangement of new establishments, for example, credit associations. Today, new requests on the association development will compel it to look at its vital choices.6 Above all, the association development must structure itself to help the endurance of Canadian industry and Canadian occupations in a savagely serious world market. 5 Bryan D. Palmer, Solidarity: The Rise And Fall Of An Opposition In B. C., New Star Books, 1987, P.63 6 Peter Sinclair, Unemployment: Economic Theory And Evidence, Oxford Press, 1987, P.215 P. 4 CANADIAN Labor CONGRESS At the national level, the association of associations is the Canadian Labor Congress (CLC). The CLC is the focal body in Canada and is made out of around 85 national and universal associations speaking to about 2.2 million specialists. Works SOCIAL OBJECTIVES The social targets of the Canadian work development are an impression of the points and wants of a huge portion of the countrys working populace. 7 somehow or another, the targets are identified with the economy. The goals are: Health Programs the absence of accessible social insurance to all Canadians made the work development increase its long-standing endeavors to have a national medicare plan by which required clinical administrations would be accessible to all Canadians whatever their money related methods. Medicare as an arrangement of widespread human services must be viewed as an open assistance and not just as a protection program under which just a predetermined number of administrations are accessible. 7 Notes On Unions, Canadian Labor Congress, Quebec, 1992, P. 5 P.5 Pensions Unions have been reliably arranged upgrades in benefits plans. By insights, just 41.4% of utilized Canadians (50. 1% of men and 33.7% of ladies) have a place with organization benefits plans. The CLC is persuaded that a redesigned all inclusive arrangement would dispense with any dread and need from mature age. Destitution and Regional Disparities The CLC has constantly caused to notice the uncalled for inconsistencies existing among different areas of Canadian culture and among various districts. Human Rights The Canadian Labor Congress has committed extensive exertion to combatting segregation and securing fundamental human rights. Training A fundamental human right, instruction must be accessible to all Canadians. The obligation to introduce a balanced image of every single partaking accomplice in the Canadian mosaic is an essential rule of instruction framework. Lodging The CLC proposes that the lodging be viewed by governments as a social need and not as a controller of monetary action Taxation There CLC recommends that there is a solid inclination among patrons that changes ought to be made to convey all the more fairly the weight of charges. .u0284513552c2e9fae7efcef20dc3ed60 , .u0284513552c2e9fae7efcef20dc3ed60 .postImageUrl , .u0284513552c2e9fae7efcef20dc3ed60 .focused content zone { min-tallness: 80px; position: relative; } .u0284513552c2e9fae7efcef20dc3ed60 , .u0284513552c2e9fae7efcef20dc3ed60:hover , .u0284513552c2e9fae7efcef20dc3ed60:visited , .u0284513552c2e9fae7efcef20dc3ed60:active { border:0!important; } .u0284513552c2e9fae7efcef20dc3ed60 .clearfix:after { content: ; show: table; clear: both; } .u0284513552c2e9fae7efcef20dc3ed60 { show: square; progress: foundation shading 250ms; webkit-change: foundation shading 250ms; width: 100%; obscurity: 1; progress: haziness 250ms; webkit-progress: darkness 250ms; foundation shading: #95A5A6; } .u0284513552c2e9fae7efcef20dc3ed60:active , .u0284513552c2e9fae7efcef20dc3ed60:hover { murkiness: 1; change: mistiness 250ms; webkit-progress: obscurity 250ms; foundation shading: #2C3E50; } .u0284513552c2e9fae7efcef20dc3ed60 .focused content zone { width: 100%; position: relative ; } .u0284513552c2e9fae7efcef20dc3ed60 .ctaText { fringe base: 0 strong #fff; shading: #2980B9; text dimension: 16px; textual style weight: intense; edge: 0; cushioning: 0; content enrichment: underline; } .u0284513552c2e9fae7efcef20dc3ed60 .postTitle { shading: #FFFFFF; text dimension: 16px; textual style weight: 600; edge: 0; cushioning: 0; width: 100%; } .u0284513552c2e9fae7efcef20dc3ed60 .ctaButton { foundation shading: #7F8C8D!important; shading: #2980B9; outskirt: none; fringe span: 3px; box-shadow: none; text dimension: 14px; textual style weight: striking; line-stature: 26px; moz-outskirt sweep: 3px; content adjust: focus; content enhancement: none; content shadow: none; width: 80px; min-tallness: 80px; foundation: url(https://artscolumbia.org/wp-content/modules/intelly-related-posts/resources/pictures/straightforward arrow.png)no-rehash; position: supreme; right: 0; top: 0; } .u0284513552c2e9fae7efcef20dc3ed60:hover .ctaButton { foundation shading: #34495E!important; } .u02 84513552c2e9fae7efcef20dc3ed60 .focused content { show: table; stature: 80px; cushioning left: 18px; top: 0; } .u0284513552c2e9fae7efcef20dc3ed60-content { show: table-cell; edge: 0; cushioning: 0; cushioning right: 108px; position: relative; vertical-adjust: center; width: 100%; } .u0284513552c2e9fae7efcef20dc3ed60:after { content: ; show: square; clear: both; } READ: Computers and Society Essay Consumer Services Efforts have been made to have the administration embrace an examination of the difference between food costs paid to ranchers and those charged to buyers. P.6 HOW IT IS RELATED TO THE ECONOMY Unions significant goal is to can hope for a superior pay. Work is the fundamental component of a countrys economy. Without work, there won't be items which are made in Canada. On the off chance that the work are dealt with unjustifiably in their working environment, they dont have the soul to work harder.8 subsequently, the nature of Canadian item will be dropped and lose the opposition on the worldwide market. Subsequently, there ought to be an understanding among managers and workers. The business side gets the greatest benefit while the worker side despite everything gets a good compensation. In any case, Canadas work get higher compensation on the planet. Thusly, the expense of items are quite high. Contrast with the universal market, the cost of Canadian items are higher as a result of higher wages. Perhaps its a side-effect of the haggling increasingly elevated wages. The Canadian items will lose their intensity in the market. It is one reason why Canada is encountering downturn at the present time. Another issue which influences Canadas economy is the unhindered commerce understanding among Canada and the United States. Through the procedure of this understanding, Canadian Labor development has been attempting to dismiss this proposition. Notwithstanding, the administration despite everything passed it. The work development is dismissing 8 David Edward, Times Of Trouble, National Library of Canada, Ottawa, 1983, P.30 P. 7 it since they foresee that the organized commerce will pulverize the economy of Canada. In addition, speculators are moving to the U.S. since there is lower cost. Organized commerce is another integral purpose behind Canada
Friday, August 21, 2020
Understanding Psychology Essay Example for Free
Understanding Psychology Essay I picked Karen Salmansohn and Don Zindellââ¬â¢s How to be Happy, Dammit (2001) basically due to the titleââ¬â¢s initial introduction upon meââ¬it didn't give off an impression of being an ordinary self improvement guide that paid attention to itself. Many individuals appear to disdain perusing self improvement guides and this book appear to be outfitted precisely towards those sorts, and I was interested with respect to what this book brings to the table. The illustrations looked engaging just as the bookââ¬â¢s unordinary measurements. Obviously, I additionally thought about that I ought to get something for myself when perusing a book to survey, the title recommends that the writer is fairly increasingly keen (or if nothing else utilizes a progressively canny methodology) than the regular self improvement writer. The bookââ¬â¢s postulation is that an individual (the skeptic) can get glad by choosing to get cheerful. The book declares that an individual must keep up a discerning brain and should settle on dynamic choices (and not simply latently hang tight for lifeââ¬â¢s pseudo irregular occasions) to legitimately influence his perspective. She underpins this by welcoming on forty-something life exercises that, saw with the best possible viewpoint, really bodes well. The creator attempts to keep away from the standard thing, drawn-out adages by referencing different regions. It is peppered with clever comments and draws motivation from various fields, for example, brain research, pharmaceuticals, science, math, hiking, even Bazooka Joeââ¬â¢s shrewdness: ââ¬Å"Never bargain your dreamsâ⬠. It truly isnââ¬â¢t that sheââ¬â¢s saying something new, yet she has an invigorating way to deal with some old thoughts. The essayist influences an unconventional, recognizable tone that makes for simple perusing. It was a simple perused, taking me pretty much an hour to complete, and would maybe qualify as a foot stool book, however is something truly interesting. She has a tolerable comical inclination and doesnââ¬â¢t appear to pay attention to herself, and yet sounds genuine. She makes farces of acclaimed and natural lines to drive her focuses over, such as focusing on that one ought to have ââ¬Å"Great Non-Expectationsâ⬠, or that one ought to have ââ¬Å"the power in: I Think Therefore I Haveâ⬠. The Psychological hypothesis might be that feelings can be legitimately influenced by the cognizant choices that an individual makes. Similar to the possibility that similarly as being cheerful makes an individual grin, grinning can likewise make a despondent individual somewhat more joyful. By being a balanced being, as in Carl Jungââ¬â¢s guess one who controls his activities by speculation (Morris 340), one would, as the creator puts it, accomplish the ââ¬Å"secret to satisfaction. â⬠Another life exercise in the book that represents this is the attestation that one could generally pick how he anticipates his sentiments toward life, that we generally have a decision. Life is a progression of irregular occasions, yet we can control what course weââ¬â¢re going (or possibly we can control our sentiments, regardless of what the conditions. ) The books target group is the despondent frustrated group, the individuals who hate and wince at the idea of perusing self improvement guides. The book has, in some capacity, given me thoughts, or possibly made a solid representation of thoughts that have consistently been above water in my brain in some obscure structure. Karma is, amusingly, something you can make, and that life must be lived now. I would prescribe this book to somebody who is bored or appears to have lost expectation being upbeat. It wonââ¬â¢t take long to peruse, and whoeverââ¬â¢s perusing it could sure value the diversion. It could possibly end up being the way to extreme joy however it would in any event make a fun and intriguing read. Works Cited Morris, Charles G. also, Albert A. Maisto. Getting Psychology. Upper Sadle: Prentice Hall, 2001. Salmansohn, Karen and Don Zindell. The most effective method to Be Happy, Dammit: A Cynics Guide to Spiritual Happiness. Berkeley: Celestial Arts, 2001.
Tuesday, May 26, 2020
Assess the Effectiveness of SOX Legislation Research - 825 Words
Assess the Effectiveness of SOX Legislation Research (Essay Sample) Content: Students NameProfessors NameCourseDateAssess the Effectiveness of SOX LegislationQuestion 1According to Garber and Sox, the enactment of SOX comprises two important ethical components that have the ability to act as prevention to unethical organizational practices (1806). The first component implies that a code of ethicsshould be set up for senior financial officers in an association, while the second component entails that all the time outside lead auditors within a firm ought to be rotated. In the first component, it should have implications on social responsibility with regards to mandatory publication of ethics codes as indicated in the SOX legislation.The article Audit Committee Composition and Effectiveness by Malik suggests that the second component did not reach out sufficiently far and that there ought to be a necessity for the rotation of review firms rather than just lead auditors (67). This review rotation prerequisite was implemented to ensure that outsid e auditors are autonomous and impartial of the organizations that they are auditing and, as indicated by the article, the legislature should oppose industry weight with respect to these arrangements. In addition, it was implemented to ensure that they ought to conceivably be extended. In addition, according to SOX legislation, it has suggestions on social obligation with respect to required distribution of morals codes.Question 2As indicated by Sox, financial fraud and abuse are still being experienced despite the passage of SOX because there are still complexity on the accounting fraud such as that experienced at Enron which is typically hard for the average normal retail investor to find out (203). According to Selby, the Ivy League holding Wall Street Analyst did not exposed the Enron fraud, but the exposure was done by the journalist who utilized diary articles and open filings in their due diligence procedures (98). Regardless of entry of SOX, the statement of financial fraud r emains excessively basic occurrence, regularly affect the retirement of individuals as well as instructive investment resources. Engaging (SOX) first on the scene to reveal a fake organization can be extremely lucrative from a short merchant's viewpoint and can be rather gainful to a distrustful financial investor who is weighing the general market conclusion.Question 3Based on my research, one recommendation for enhancing SOX is to avoid conflicts of interest. As to my understanding, SOX has provided counseling services and this is the correct step for the goodcourse since Andersen was achieving more income from counseling as compared to that from administrations. However, some other conflict of interest may arise; for example, there is an issue with the recently made Public Company Accounting Oversight Board (PCAOB).According to Garber andSox, the board individuals are not designated by the President and the SEC does the contracting and terminating (1811). This perhaps abuses the regulation of detachment of forces. In any case, the PCAOB will be the government arm; at that point, it will be good if the president chose the individuals from the board.The second way of improving the SOX legislation is to take into consideration the five-year rotation of the auditors. As of now, SOX is in need of the audit rotation partners; however,they can still all be from a similar firm. Therefore, a superior method for rotation is to achieve the rotation for the entire firmQuestion 4Beyond the scope of SOX, the organization ought to have legitimate plans set up so as to diminish fraudulent exercises from happening. Allowing employees to be aware on the company policy is among the best method to prevent behaviors caused by fraudulent activities. ...
Saturday, May 16, 2020
Student s Performance As Cause Effect Phenomen A...
Studentââ¬â¢s Performance as Cause-Effect Phenomena: A Multilevel Approach Introduction: Education plays a vital role in the human and country development at all stages. There are key determinants that affect the education level which ultimately translate into human and country s development. Quality education ensures the achievement of knowledge and required skills that enable individuals to enhance the productivity and improve their living standard and access to basic needs. This increase in productivity further translate towards new sources of earning which also further enhances the economic growth of a country (Saxton, 2000). Student performance is a key component of quality education that result in better outputs in the long run. Student intellectual performance measurement has received substantial consideration in previous research literature, it is a challenging aspects of academic literature. Student performance are affected by many factors including social, mental, economic, environmental and personal factors. These factors strongly influence on the student inte llectual performance, but these factors vary from person to person and country to country. During the last decade in Pakistan, the enrollment at primary, secondary and higher level has been increased substantially. Literacy for all (LFA) is a project initiated by government of Pakistan in 2005 which encourage the overage people to engage in getting primary education. Similarly, some other
Wednesday, May 6, 2020
Discuss the Portrayal of Portia and Jessica in the...
In The Merchant of Venice Shakespeare used Portia and Jessica as his stereotypical characters through which he successfully conveyed greatness and challenged the perception of 17th century society. Shakespeare, by doing so, has accomplished them with what they lacked. Quotation serves to emphasise Shakespeares drama since the word `accomplished implies that it is Shakespeare who created the two characters to appear as mens equals and that otherwise this equality would not be attainable within the society of the contemporary time. At the beginning of the play, Portia appears to have no real identity despite all her greatness and worth whereas Jessica, being a Jew appeared as a character with low self-esteem and emerges as havingâ⬠¦show more contentâ⬠¦Shakespeares use of the word `curbd imply means of restraints that in this context could provide the notion that Portia is restrained to her own will and thereby completely `bound by her fathers will. With regards to Jessicas character, Shakespeare endeavoured to generate a slightly different sympathy. Jessica is known to be Shylocks daughter, her character is assumed to be that of low self-esteem and without potential greatness., thus, Jessica is regarded as inferior to other Christians due to her Jewish origins and religion. This is partly manifest through Shakespeares language and partly through plots development. Jews in this play are regarded as dehumanised beings as becomes apparent from Antonios speech that called Shylock a `dog. Jessica, being biologically bound to her father, is also regarded as inferior to Christians, maybe providing the reason why she eloped with a Christian man in the end. None the less, her low self-esteem is drawn by her acceptance to be Lorenzos torch-bearer. Shakespeare provided a negative imagery by Lorenzos speech. Torch-bearer insinuates the image of a slave and an owned individual which we assume Jessica becomes after her marriage ceremony. As opposed to Portias respectful and obedient manner Jessica is conveyed as a rebellious and disobedient character. Due to the fact that Jessica eloped from her father, quoting that Alack, what heinous sin is it in me to beShow MoreRelatedShylock as a Victim of Villain Essay2293 Words à |à 10 PagesShylock as a Victim of Villain Throughout the play ââ¬ËThe Merchant of Veniceââ¬â¢ there are constant references to various characters and the way they relate to one another, however there is no character so diverse and so complex as Shylockââ¬â¢s character. Shakespeare tries to portray Shylock in a number of ways however I believe his main focus in the play, is on his villainous side. This may be portraying the time of Shakespeare where ethnic minorities likeRead MoreAnalysis Of Film Production Of The Merchant Of Venice1249 Words à |à 5 PagesFilm Review Michael Radford s 2004 film production of The Merchant of Venice provides a well-executed and generally faithful rendition of Shakespeare s play. Radford s production especially succeeds in both its casting and set design that elevates the mood and drama contained in Shakespeare s text. In addition to the filming, particular attention was taken to following the original text, but some interesting in liberties in plot details were taken. Radfordââ¬â¢s production serves as an exemplar
Tuesday, May 5, 2020
Australian Taxation Law Customs Duties
Question: Discuss about theAustralian Taxation Lawfor Customs Duties. Answer: Significance of Cases in the Development of Australian Tax Law In the ancient past, the Australian taxation system was based on the excise and customs duties. Gradually, the state governments in Australia introduced state income tax and then in early nineties, the Australian federal government introduced federal income tax. The coverage of types of transactions under income tax was limited in the early years of application of income tax. Further, the definition of income given under the taxation laws was also narrow and conflicting. Since the year 1915[1], the government of Australia has carried out developments at large scale in the area of income tax. The definition of income has undergone changes several times since the introduction of income tax regime. Before the year 1985, the capital gains tax was not introduced, which laid to conflicting issues in levying income tax on the commercial transactions. Since, the capital gains tax was not applicable; therefore, the taxation authorities had to make a rigorous exercise in deciding as to whether the profits earned on sale of land and properties are to be taxed as income or to be considered as capital receipt and hence no tax to be levied. Until the introduction of legal provisions on capital gains tax, the case laws pave the way for the taxation authorities in deciding as to which income is to be treated as profits chargeable to tax and which will be considered as capital receipt not assessable under income tax laws. Few of the prominent cases clarifying such issues are being discussed as under: Californian Copper Syndicate v Harris (1904) 5 TC 159 In the case of Californian Copper Syndicate v Harris (1904)[2] the issue of taxation of the profits on sales of land was taken up. The taxpayer company sold a piece of land acquired for mining and mineral extraction purpose in exchange of shares. The issue arose that whether the profit earned on such sale transaction should be taxed as income or be deemed as mere capital receipts and not to be taxed hence. At that time when this case was taken up, the capital gains tax was not in the legal system of Australian taxation. Therefore, if the transaction did not satisfy the conditions of the income, the profit was not taxable at all. The conflict as regard taxation of profits was mostly in the cases involving transactions of purchase and sale of land. In this case, the court observed that in order to conclude that the profit is taxable as income, it is essential to make sure that the land was used in business with the explicit or implicit intention to make profit. Thus, the existence of profit motive is critical to bring the profits earned on sale of land under the ambit of tax. Further, another principle was laid in this case which assists in determination of the fact that whether the taxpayer had profit motive or not. The determination of profit motive is to be looked in the light of various dimensions. The court put down out that no single factor could be fixed to determine the profit motive of the taxpayer. This case law provided direction to the taxation authorities to for determination of the profit motive of the taxpayer. Therefore, in this way, the case of Californian Copper Syndicate v Harri helped in administration of the income tax laws in Australia. This case law provided a solid foundation to the taxation authorities to finalize the cases involving conflicts at the very first stage without going through the time consuming litigation process. Whitfords Beach Pty Ltd v FCT 82 ATC 4031 This case also came in front of the honorable judges of the court before the promulgation of the capital gains tax by the Australian government. The issue involved in this case was also the same as attained in the case of Californian Copper Syndicate v Harri. However, the circumstances of the case were different this time. In fact, this time the major issue was whether the isolated transaction done by a taxpayer falls under the ambit of transactions in the ordinary course of business. After considering all the facts and evidences of the case, the court gave its judgment making it clear as crystal that the isolated transactions if carried with the profit motive would be liable to tax. The decision in this case further clarified the conflicting issues in the taxation of profits. The judgment of this case provided a foundation for tax ruling TR 92/3[3]. The Australian taxation authorities issued TR 92/3 to provide rules in regard to taxation of the profits earned on the isolated transactions. The ruling TR 92/3 provided proper explanation on the isolated transactions and the tax consequences of those transactions. Further, the ruling comprehensively clarified as to which type of transactions will fall under the isolated transactions category and which types of transactions will be covered under the tax net. Further, the landmark decisions in the case like Whitfords Beach Pty Ltd v FCT also pave the way of promulgation of the capital gains tax in Australia. Myer Emporium Pty Ltd v FCT 87 ATC 4363 The high court of Australia pronounced its decision in the case of Myer Emporium Pty Ltd v FCT in the year 1987[4]. In this case, the decision of the court further clarified the law regarding taxation of the profits derived from business activities. The court undertook comprehensive discussion on the nature of revenues and capital receipts. It was later on claimed that the decision in this case widened the scope of income which helped the income tax authorities in levying tax on the commercial transactions with more clarity. There was not any proper definition of the term income in the income tax assessment act 1936. The absence of proper definition of income laid many conflicts in regard to taxation of the profits earned from the isolated transactions. The main reason of conflict was difference in taxation of the capital and revenues receipts. The revenues receipts or profits were liable to tax while the money receipts of capital nature were not liable to tax until the promulgation of the capital gains tax. In the absence of proper definition of income it was quite contradictory to decide as to which receipts are of revenue nature and which are of capital nature. Further, the provisions of income tax assessment act 1997 were also not clear in regard to definition of income. There is a very casual definition of income given in section 6-5(1) of the income tax assessment act 1997. This section provides that the assessable income means the income in ordinary sense. There are no further clarifications and explanations on the term ordinary income. Thus, the clarification in regard to the term, income is not sufficient in the income tax assessment acts. Therefore, the case of Myer Emporium Pty Ltd v FCT assumes importance in the area of defining the term income neatly. Introduction of the Capital Gains Tax and Its Impact on the Landmark Cases The capital gains tax was introduced in Australia in the year 1985[5] with the primary of objectives bringing the profits on sale of capital assets like property under the tax net. Prior to the year 1985 when the capital gains tax was not introduced, the conflicts in taxation in regard to levy of tax on the profits earned on sale of capital assets were common. The capital receipts were not taxable prior to introduction of capital gains tax therefore the taxpayer were used to claim the sale of assets like land as capital receipts to escape from tax. The conflicts between the tax authorities and the taxpayers were observed on several grounds which gave rise to litigations. Thus, prior to introduction of the capital gains tax, the conflicts between the tax authorities and the tax payers were used to resolve through litigation process. There many cases such as Californian Copper Syndicate v Harris (1904) 5 TC 159, Whitfords Beach Pty Ltd v FCT 82 ATC 4031, and Myer Emporium Pty Ltd v FCT 87 ATC 4363, which have been referred since years to resolve the conflicts. These cases provide comprehensive explanations in regard to taxation of land and other capital assets. However, after introduction of the capital gains tax the application of these cases has been limited. The income tax assessment act 1997 provides a thorough coverage of the capital gains tax. The provisions of capital gains are contained in chapter-3 of income tax assessment act 1997[6]. This chapter covers definitions, explanations, and allied matters as regard capital gains tax in a great detail so that the likelihood of conflicts could be diminished. However, it should be noted that though th e application of case laws as discussed above is limited after introduction of capital gains tax, but still the principles laid down in these cases holds importance in laying the foundation of the law and carrying the objectives of law forward.
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