Thursday, September 3, 2020

Persuasive Speech Essay Sample free essay sample

 ·Specific Purpose Statement: Today I will trust to convey you why I feel the Euthanizing of invigorate creatures can be erroneous.  ·Central Idea: Today I will trust to convey you in why I feel killing is off base. I will state you about the benefits of kindness murdering. tailing I will state you about the fortunes in which I am against benevolence murdering and answers for how I feel we can help killing rates dab.  ·Organizational Structure Used: Topical Order  ·Visual Aids Used: ImagesIntroductionI. Enticement: Harmonizing to the online Merriam Webster Medical Dictionary. â€Å"Euthanasia: the demonstration or example of murdering miserably sick or harmed people ( as people or residential invigorate creatures ) in a nearly effortless way for grounds of forgiveness. † II. Explicit PURPOSE/TOPIC REVEALED: Today I will trust to convey you why I feel the euthanizing of enliven creatures can be a terrible idea. III. Believability/BACKGROUND INFO/RELEVANCE TO AUDIENCE: As a person who has chipped in vitalize being covers throughout the late spring for as far back as two mature ages I feel am ready to discuss why kindness slaughtering is non a decent idea. We will compose a custom paper test on Enticing Speech Essay Sample or on the other hand any comparable theme explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page IV. Focal IDEA ( THESIS )/OVERVIEW OF MAIN POINTS: Today I will trust to convey you in why I feel killing is off base. I will state you about the upsides of leniency executing. tailing I will state you about the fortunes in which I am against leniency murdering and answers for how I feel we can help killing rates dot. Entry: I will premier get somewhere around talking about the benefits of euthanizing quicken creatures. BODY I. First Chief Point: There are a few favorable circumstances to the euthanizing of quicken creatures. A. Subpoint/Supporting Material: One of the benefits of seting invigorate creatures to kip is the point at which a quicken being is sick and can non be relieved. 1. Sub-Subpoint-When an invigorate being can non be relieved because of health employments the vitalize being is so put to kip. a. Sub-Sub-Subpoint-In an article â€Å"Why We Euthanize† by People for the Ethical Treatment of Animals ( PETA ) . show pictures of some invigorate creatures who have health employments that can do harming and distress. b. Sub-Sub-Subpoint-One of these pictures is of a feline named â€Å"Diamond. † who â€Å"was suffering from an excruciating facial tumor that was simple eating off at his face. † ( PETA ) c. Sub-Sub-Subpoint-Although I do non hold with the euthanizing of energize creatures I do encounter that quicken creatures ought to be put to kip if an enliven being has a h ealth work that can non be relieved. 2. Sub-Subpoint-Another favorable position of leniency murdering is in fleshly testing. a. Sub-Sub-Subpoint-When vivify creatures are utilized for research many are harmed from the side of impacts. b. Sub-Sub-Subpoint-In an article by Dana Bidnall named â€Å"Animal Testing† she expresses that â€Å"a large whole of lab enliven creatures endure seclusion. apathy. nervousness. mental hurt. detachment from their female guardians soon after birth. also, alertness. These uncomfortablenesss are in add-on to the physical harming the vitalize creatures suffer during open introduction of the tests. † ( Bidnall 50 ) c. Sub-Sub-Subpoint-Due to the quicken creatures harming and desolation vivify creatures ought to be euthanized to maintain a strategic distance from this stinging. B. Subpoint-Animal abuse is another ground why using leniency slaughtering is a decent idea. 1. Sub-Subpoint-In the article â€Å"Noted NY bodily hospice hit with barbaric treatment charges. † by Mary Esch states that â€Å"People for the Ethical Treatment of Animals said the test discovered immobile Canis familiariss hauling themselves around until they grew grisly covering ulcers while their wheeled trucks held tight a fencing new ; quicken creatures kept in nappies for a few yearss. doing pee burn ; vivify creatures with loosened injuries and respiratory diseases that weren’t taken to a veterinarian. † a. Sub-Sub-Subpoint-This fleshly hospice is intended to be utilized as a topographic point for exigency consideration for energize creatures. however energize creatures are being manhandled. b. Sub-Sub-Subpoint-These energize creatures who are non being taken consideration the way they ought to require to be removed from their wretchedness since they are in harming and anguish. Entry: Now that I have revealed to you a portion of the benefits of euthanizing. I will currently state you about the fortunes in which benevolence executing is inaccurate II. Second Main Point-There are various grounds to why the euthanizing of pets can be off base. A. Sub-Point-One of the grounds is the euthanization of enliven creatures due to overpopulation. 1. Sub-Subpoint-Harmonizing to an article by Animal Welfare on preferred populace done in 2011 it expressed that â€Å"it is assessed that between 6 to 8 million American pets are euthanized every twelvemonth as a frantic and deplorable offices by underfunded and under staffed associations as a strategy for populace control. This means 16. 438 to 21. 917 pets euthanized every twenty-four hours! † a. Sub-Sub-Subpoint-This shows in the U. S totally. there are 1000000s of energize creatures come ining covers and an incredible figure of them are being euthanized as a result of this. b. Sub-Sub-Subpoint-Animal Welfare other than states that â€Å"the greater part of these enliven creatures were youthful. sound. adoptable. also, at any rate 25 % per centum of them were purebreds† c. Sub-Sub-Subpoint-These invigorate creatures that are put to kip. are non simply vivify creatures who have been harmed in any way however are other than enliven creatures who can embraced in to new places. 2. Sub-Subpoint-Another ground why individuals euthanize invigorate creatures is a result of conduct issues. a. Sub-Sub-Subpoint-In an article named â€Å"Euthanasia geniuses and cons† by Steady Health it expresses that â€Å"some individuals choose to set their pet to kip because of the way that it has change d its conduct adversely. going unmanageable. capricious or hazardous. † b. Sub-Sub-Subpoint-I feel that owners who have euthanized enliven creatures in light of conduct issues could hold forestalled these employments by having guidance on these issues and canine arrangement ; vivify creatures ought to non be to blame for the mistakes individuals make. c. Sub-Sub-Subpoint-In a paper article by Jeff Hampton in the Virginian-Pilot he expounds on a how a â€Å"10 month old male kid was killed in view of the family dog† ( pittbul blend ) . † the Canis familiaris who was euthanized for this. on another point the Canis familiaris had nibbled the more established child. d. Sub-Sub-Subpoint-This could hold been forestalled if the family unit would hold searched out to happen approaches to choose Canis familiariss conduct occupations with readiness ; the family unit would hold their kid and their Canis familiaris. B. Subpoint-There is other than the issue that an enliven being can be euthanized when it has a place with individual else. 1. Sub-Subpoint-A delineation of this is found in the article â€Å"Who’s quicken being right? † by Cherie Travis she expounds on how in an occurrence â€Å"a grown-up male comes into your metropolitan safe house with a Canis familiaris he says is his. He says the Canis familiaris spot him and petitions that your establishment euthanize the Canis familiaris. † ( pg. 48 ) â€Å"municipal cover euthanized the Canis familiaris in this manner that evening. That eventide. a grown-up female came in with fitting proof that she claimed the Canis familiaris and was crushed to larn that the Canis familiaris had been murdered as an outcome of her irate ex passing on the Canis familiaris to the sanctuary and misleading staff. † ( pg. 48 ) a. Sub-Sub-Subpoint-This happens when an individual presents a vitalize being for acquiescence to a safe house or liberation and discovers in this way that this individual did non hold lawful approval to surrender the quicken being. b. Sub-Sub-Subpoint-Another representation that shows this is found in the article â€Å"When We Kill Our Pets† by Jessica Pierce ; she expounds on a military Canis familiaris named â€Å"Target† who was received by a trooper ; â€Å"Target† later got away from her place and was gotten by invigorate being control and taken to an asylum she had no jewelry and on Friday pictures of â€Å"Target† were put on the safe houses site. on Monday the owner went to the haven to happen her. he found that she was put to kip. 2. Sub-Subpoint-Pierce expresses that â€Å"the cover specialist responsible for euthanizing vitalize creatures that twenty-four hours had apparently selected the mistaken Canis familiaris from the pen. † ( Pierce 1 ) a. Sub-Sub-Subpoint-Due to this a guiltless vivify being was euthanized. b. Sub-Sub-Subpoint-If the euthanizing did non occur in covers this could hold been forestalled. Entry: I have now enlightened you regarding the fortunes wherein benevolence executing is erroneous and will currently state you about ways we can aid lower kindness murdering rates. III. Third Main Point-There is various manners by which we can help with dropping willful extermination rates. A. Subpoint-One of these ways is by investigating what kind of Canis familiaris is beneficial for you. 1. Sub-Subpoint-A person who is non dynamic does non want to purchase a Canis familiaris that is extremely dynamic. a. Sub-Sub-Subpoint-From experience when I was more youthful I claimed a Siberian Eskimo hound. ( Sparky ) he was extremely dynamic and wanted to dive. at whatever point I would come place from school I would come spot to hear that my mama needed to trail Sparky down the road since he had bounced the fencing. b. Sub-Sub-Subpoint-This happened in any event twice a hebdomad. what's more, was settled when my folks fabricated a higher fencing. c. Sub-Sub-Subpoint-This appeared there a re changed sorts of Canis fami

Saturday, August 22, 2020

Oil and Gas Exploration at ANWR Assignment Example | Topics and Well Written Essays - 3250 words

Oil and Gas Exploration at ANWR - Assignment Example The major and new innovations that have prompted an expansion in oil penetrating are the water powered cracking method and the even boring strategies. These innovations make it conceivable to bore oil, from tight shale rock developments. Cogswell, in this manner, clarifies that these innovations will figure out how to expand the creation of oil in the United States by around 30%.  However, there is an impressive discussion on whether to permit seaward boring in the United States. The issue of seaward boring increased a wide media inclusion when President Bush dropped an official, gave by the then President in the year 1990. Besides, President Bush was requiring an expansion in the oil boring of the Arctic National Wildlife Refuge. There is an extensive discussion that encompasses this issue, on whether to penetrate or not to bore oil in this locale. President Obama is against the boring of oil in the Arctic National Wildlife Refuge, refering to the way that it would prompt natural harm and contamination. Then again, President Bush was an ardent supporter of boring of oil in this locale. His contention was that it would help in fulfilling the oil needs of the nation. Regardless of the presence of this discussion, this paper stands firm that penetrating of oil in the ANWR is destructive to nature, and there is a need of managing organizations answerable for boring oil in this region. The issue and issue viable are that the boring of oil in the ANWR is hurtful to the earth of United States.

Friday, August 21, 2020

Ell Assessments Essay Example for Free

Ell Assessments Essay With the ascent in migrant understudies comes an ascent in understudies who don't communicate in English. Schools are confronting the need to show these understudies their customary scholastics as well as another dialect. In Guthrie, Oklahoma, there may appear there would not be as much requirement for such projects however the truth of the matter is that English language students are likewise here. ELL understudies need help from the schools they go to so as to ace their English abilities and have the option to become profitable residents when they graduate. Schools have needed to think of systems to recognize ELL understudies, survey and screen their learning and capability, keep instructors educated, and guarantee ELL understudies access to review level substance and create language all the while. At the point when another understudy enters school in Guthrie, Oklahoma first they are required to round out a home language study structure, (Oklahoma Department of Education, 2012). This structure essentially asks what the essential language spoken at home is. On the off chance that another dialect other than English is spoken, at that point understudies are required to take the WIDA situation test, (Miles, 2013). On the off chance that an understudy scores beneath a 5. 0 they are viewed as an English language student, (Miles, 2013). That is the manner by which they distinguish ELL understudies at Guthrie Public Schools. Guardians additionally should be educated regarding these tests shrink 30 days before school begins or inside about fourteen days of school beginning, (Oklahoma Department of Education, 2012). All through the school year schools need to evaluate ELL understudies to decide their advancement. At Guthrie government funded schools ELL understudies in primary school are observed for progress each quarter by a bilingual mentor, (Miles, 2013). In junior and secondary school understudies are observed day by day by their instructors for progress, (Miles, 2013). The mentor and educator screen understudies social exercises, their customary homeroom condition, their movement in class, conduct, learning perception, just as formal appraisals. Formal evaluations are tests done each quarter to perceive how much an understudy has advanced from the past quarter. On the off chance that an understudy is being social with different understudies during break, effectively taking an interest in class, and learning the educational program being shown then the ELL understudy is viewed as learning and appreciating English. ELL understudies are excluded from stepping through normalized exams for a long time so they can get capable in how to peruse, compose, talk, and get English, (Miles, 2013). Understudies must show capability in English so as to not be viewed as ELL any longer, (Oklahoma Department of Education, 2012). Another significant piece of guaranteeing the advancement of ELL understudy is keeping their instructors educated regarding ELL understudies status. The manner in which Guthrie government funded schools educate instructors regarding the ELLs status is by sending them and email or letter with a duplicate of their grades, (Miles, 2013). Instructors need to make lodging for the understudies since they need the ELL understudies totally drenched in English. ELL understudies go to ordinary classes with normal friends, (Miles, 2013). Instructors evaluate ELL understudies day by day simply like they survey non ELL understudies. They do casual appraisals like how they partake and impart in the homeroom to evaluate how they are advancing in English language capability and fathoming the educational plan. Formal evaluations instructors may do would be schoolwork sheets where understudies need to fill in the clear with the right word or a spelling test. Instructors take the evaluations ELL understudies make in their group and survey if understudies need additional assistance like a mentor to better their English capability abilities, (Miles, 2013). The manner in which a school enables an ELL understudy to accomplish capability will fluctuate contingent upon the necessities of the school region and state. Guthrie government funded schools is situated in focal Oklahoma. In the 2009-2010 Guthrie government funded schools had 108 English language students out of 3,309 absolute understudies took a crack at the school region, (USA. com, 2011). They have adjusted the entirety of the state necessities which meet the government No Child Left Behind act. Notwithstanding, of the quantity of ELL understudies or area of the school, there school consistently be an approach to recognize, survey progress and capability level, keep educators educated regarding ELLs language capability and guarantee ELL understudies approach grade-level substance and grow new dialect abilities at the same time. Schools ought to consistently be set up to get new understudies into their school and welcome them with a positive school soul. REFERENCES Miles, S. (2013). Telephone talk with, Head of ELL office for Guthrie Public Schools. Oklahoma Department of Education. (2012). Distinguishing proof and Exit Criteria for Oklahomas English Language Learners. Recovered from: http://alright. gov/sde/locales/alright. gov. sde/documents/Bilingual-ID-ExitCriteria. pdf.

Wednesday, June 17, 2020

37 Best College Memories From the 90s

Does saving for your kid's college bring back memories of your own life on campus? Times sure have changed, haven't they? Most of today's students wouldn't even dream of taking notes in an actual notebook or writing a paper in their school's computer lab. But we had it pretty good, right? Spending our days watching epic movies like Pulp Fiction, Swingers and Clueless and listening to our favorite CDs from Snoop Dogg, Pearl Jam and Blind Melon was ï ¿ ½the bombï ¿ ½! And we had no room to complain when it came time to pay tuition. According to the National Center for Education Statistics, twenty years ago the total cost of tuition and room and board at a four-year in-state public school was $10,330. This year, students at the same type of school can expect to pay around $19,700. Yikes! And that's not even including the costs of laptops, cell phones, tablets and other electronic devices students in the ï ¿ ½90's could only dream of. Yet what's even more frightening is how much you're likely to pay for your own children to go to college one day. Dreaming of a four-year in-state public university for your newborn son? You'll be looking at $169,470 for total tuition, fees and room and board costs, according to the College Board. The good news is that you have plenty of time to save. With a 529 plan, your savings will grow tax-free and won't be taxed when you withdraw the money to pay for college. Try our World's Simplest College Calculator to see just how much you'll need to put away to reach that goal. If you're wondering if college is still worth the cost, check out these 37 things you'll only understand if you went to college in the '90's from Buzzfeed. We think you'll agree that your child deserves the chance to make his own list of college memories one day. Does saving for your kid's college bring back memories of your own life on campus? Times sure have changed, haven't they? Most of today's students wouldn't even dream of taking notes in an actual notebook or writing a paper in their school's computer lab. But we had it pretty good, right? Spending our days watching epic movies like Pulp Fiction, Swingers and Clueless and listening to our favorite CDs from Snoop Dogg, Pearl Jam and Blind Melon was ï ¿ ½the bombï ¿ ½! And we had no room to complain when it came time to pay tuition. According to the National Center for Education Statistics, twenty years ago the total cost of tuition and room and board at a four-year in-state public school was $10,330. This year, students at the same type of school can expect to pay around $19,700. Yikes! And that's not even including the costs of laptops, cell phones, tablets and other electronic devices students in the ï ¿ ½90's could only dream of. Yet what's even more frightening is how much you're likely to pay for your own children to go to college one day. Dreaming of a four-year in-state public university for your newborn son? You'll be looking at $169,470 for total tuition, fees and room and board costs, according to the College Board. The good news is that you have plenty of time to save. With a 529 plan, your savings will grow tax-free and won't be taxed when you withdraw the money to pay for college. Try our World's Simplest College Calculator to see just how much you'll need to put away to reach that goal. If you're wondering if college is still worth the cost, check out these 37 things you'll only understand if you went to college in the '90's from Buzzfeed. We think you'll agree that your child deserves the chance to make his own list of college memories one day.

Monday, May 18, 2020

The National Labor Relations Act ( Nlra ) - 933 Words

North Carolina is an at-will state, and this by no means gives any employer the right to act as they wish in the work place. Certain laws govern the workplace that have to be honored with each and every employee. One such law is the National Labor Relations Act (NLRA). This law was endorsed in July of 1935 and was modified by both the Taft-Hartley amendment in 1947, and Landrum Griffin amendments in 1959 (George Pozgar, 2012, p, 474). This law is responsible for stopping and relieving unfair labor practices by employers, their agents, and or organizations. The NLRA is independent of the Department of Labor, but entrusted to the National Relations Labor Board (NLB) (Pozgar, 2012, p. 474). To illustrate, in the setting of a hospital, there are two violations that would certainly grab the focus of the NRLA; discrimination against an employee who engages in union activity, and retaliation against an employees who file unfair labor practice charges. Furthermore, in the face of a strike ce rtain rights of patients come into play to protect the patient and ensure they continue to receive quality care. Violation of the National Labor Relations Act The NLRA is entrusted by the NLB, which protects collective bargaining in the private sector. Some of the activities of the NLRB is to primarily conduct elections to determine whether or not employees want union representation, and to investigate and relieve practices that are unfair by employers and unions (Joe Twarog, 2005). When aShow MoreRelatedThe Impact Of National Relations Labor Act ( Nlra ) And The Fair Labor Standards Act1181 Words   |  5 PagesLabor Legislation in the 20th Century Much of what we know about the improvements in the workforce came from 20th century advancements with the workforce that we know today. Important developments came in the form of methodology and data collection efforts. The 20th century was a remarkable period for the American workers. Despite the initial stages of labor management, working conditions, wages and benefits improved over the last century with the workforce increasing six fold over theRead MoreThe Law Of The United States1512 Words   |  7 PagesRepublic Steel that requires an employee fired in violation of the NLRA to find another similar job as soon as possible to mitigate damages or risk the being awarded back pay or the legally unsupported Brown University case, decided by one of the most conservative Boards in recent history, held, â€Å"as a matter of policy,† that graduate student workers were students and, and, therefore, could not be employees as defined by the NLRA. Republic Steel, Dannin, sup ra note 44 at 260–63. Id. See ConsolRead MoreCollective Bargaining And The Bargaining Process1104 Words   |  5 PagesCollective bargaining is the process by which conditions of employment are negotiated between management, and the labor organization representing employees in the bargaining unit. 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Beth Ethier, Accused of Retaliating Against Workers, Walmart Says It Closed Stores Over Plumbing Problems, SLATE (Apr. 20, 2015), http://www.slate.com/blogs/the_slatest/2015/04/20/walmart_accused_of_closing_stores_to_punish_activist_workers_union_files.html. Picchi, supra note 1. Steven Greenhouse, Walmart Illegally PunishedRead MoreLabor Relations724 Words   |  3 PagesLabor Relations Grand Canyon University: HLT-520 James Webb September 23, 2015 The National Labor Relations Act (NLRA) started in July 1935 to protect the rights of employees, rather, they be union or nor-union employees (Pozgar, 2012). The employees are protected under the Act or may employ in bubble-like, rigorous goings-on in situations other than the customary union organizations and cooperative bargaining. The National Labor Relations Board regulates the employers from interfering with

Wednesday, May 6, 2020

Innovation Diffusion Framework-Policy Adoption - 1431 Words

Essay Question 1: Innovation Diffusion Framework-Policy Adoption Policy diffusion is the study of policy adoption and why state and national governments make certain decisions that they make, and how those decisions affect policy adoption. The Policy Diffusion Framework examines how the influence of neighboring states and other governments influence each other to implement different policies. The Framework is a resource policy practitioners use to contrast and explain policy innovation and what factors or constraints lead government to adopt new policies. Policy diffusion is defined as the â€Å"process by which and innovation is communicated through certain channels over time among the members of a social system† (Rogers 2003). The Policy Diffusion Framework studies what leads to policy adoption at the local, state, and national level. Diffusion in itself is a tool that helps lead governments to adopt innovative polices. Several policy scientist will use this model in various applications, but much of the research that has been conducted analyzes diffusion at the state level. They will analyze when states adopts innovative polices, what leads to this innovation, which states innovated first, and was the policy successful elsewhere. Frances and William Berry (1990) political scientist at Florida State University developed three conclusions about how states facilitate policy diffusion. First, states will learn from one another analyzing the extent of how well a policyShow MoreRelatedThe Diffusion Of Innovation And Innovation1904 Words   |  8 PagesWalker, and Avellaneda (2009) write that â€Å"the study of innovation hardly needs justification as scholars, policy makers, business executives, and public administrators maintain that innovation is a primary source of economic growth, industrial change, competitive advantage, and public service† (p. 650), it is misleading to suggest that there is a consensus in scholarly research on the use of the diffusion of innovations framework. In essence, diffusion is the process where adopters (individuals or organizations)Read MoreApplication Of A Standardized Curriculum1302 Words   |  6 PagesRogers’s model parsimoniously carries over to research in schoo l health: several researchers have conceptualized implementation within a diffusion of innovation paradigm (Hausman Ruzek, 1995; Henderson Dancy, 2008; McCormick, Steckler, McLeroy, 1995; Parcel et al., 1989; Payne, Gottfredson, and Gottfredson, 2006; Penberthy Millar, 2002). For example, Rogers’s adoption-invention continuum has been helpful to identify which elements of a reform are modified and directly adopted. Henderson Dancy (2008)Read MoreModern Agricultural Biotechnology And Its Potential Usefulness And Effectiveness961 Words   |  4 Pagesagriculture. Biotechnology, he writes, is â€Å"†¦revolutionary not in transcending modern agriculture as a technological paradigm, but for its detrimental social and environmental impacts† (3). 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But in BangladeshRead MoreTheory of Social Marketing5832 Words   |  24 Pagesmore commonly mentioned theories and models in social marke ting programs including: health belief model, the related theory of reasoned action,, social cognitive theory, the transtheoretical model of behavior change (or stages of change), diffusion of innovations and an overview of other models/theories mentioned or used in specific contexts. 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Assessable Business Income Taxation Law

Question: Discuss about the Assessable Business Income for Taxation Law. Answer: 1. Issue The case presented states certain information about Fred who has come to Australia to setup office for a British company. He is being accompanied by his wife while his children are in a college in London pursuing their studies. The prime concern is to use the above facts and the relevant statutes and tax rulings to determine if Fred is a tax resident of Australia for the year under assessment. Rule In order to determine the tax residency of any individual taxpayer, TR 98/17 is of significance since it highlights the various tests that may be applied for objectively testing the tax residency status. It is imperative that compliance with even one of the tests would result in the taxpayer getting the recognition of Australian tax resident (Barkoczy, 2014). The relevant details of these tests are outlines below. Domicile Test This is commonly used to ascertain residency status for tax purpose of Australian domicile holders who are residing abroad for a multitude of reasons. Fulfilment of this test requires that the taxpayer should comply with both the clauses mentioned below (Woellner, 2014). Australian domicile should be there with the taxpayer. Permanent abode of the taxpayer must be situated in Australia To determine permanent abode of the given taxpayer, factors outlined in IT2650 are often deployed.(Deutsch et, al., 2016). Resides test Limited information is available on this in the concerned legislation and hence guidance sought from precedents of court cases and relevant tax rulings. The critical factors worth considering are the underlying significance of the taxpayers purpose of visit, nature of various ties that exist in Australia along with the nature of social life that the taxpayer leads in Australia. Tax residency is granted taking into consideration all the factors (Coleman, 2011). 183 day test It essentially requires both the following conditions to be met (Deutsch et. al., 2011). Stay of atleast 183 days (in Australia) in the given assessment year Intention to settle in Australia in the long run irrespective of whether it materialises or not. Superannuation Test The tax residency of Australian government officials serving in foreign nations is determined on basis of their contribution to particular superannuation schemes (Barkoczy, 2014). Application Domicile Test Fred has come from England and does not hold Australian domicile. Test failed. Resides Test Freds visit purpose is significant since he has come for unemployment and duration also seems several months even though exact time not given. Further, his life in Australia is comparable to that in country of origin i.e. England. Considering both above facts, the test is deemed to be passed. 183 day test First condition satisfied since Fred has resided in Australia for a period in excess of 183 days. However, no intention to settle in Australia as house in England is rented and no fixed asset has been purchased in Australia, even house is on short term lease of 12 months. Hence, test failed. Conclusion For the current assessment year, Fred would be considered as a tax resident of Australia. 2. 1. Californian Copper Syndicate Ltd v Harris (Surveyor of Tax) (1904) 5 TC 159 When the concerned taxpayers or shareholders are a part of a scheme of making profit, then in such cases the receipts will be termed as revenue receipts and would be treated as per the ordinary income concept of the taxation. A significant example of such cases can be examined in Californian Copper Syndicate Ltd v Harris case, in which a company bought a land in New Zealand. This land was basically copper enriched and the company used all their capital to purchase the copper land. However, no single mining activity was performed by the company due to unavailability of the working capital. The shareholders of the company initially knew about the financial position that they would not be left with enough working capital after spending all the capital to own the land .Hence, copper land was liquefied to another firm which was performing mining activities. The return amount would be decided as the shares of that company in the exchange of the copper land (Barkoczy, 2014). The court ruled about the case that the focus of the company behind the buying of the copper mine was to sell the land to the other company. There was no intent of the taxpayer to begin the mining. Therefore, the business intent of the taxpayer to sell the land would be liable for tax under the section 25(1) of ITAA, 1936 as per the ordinary income concepts on the part of the taxpayer (Manyam, 2010). Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 In this case, the coal enriched land was used for coal mining by the Scottish Australian Mining Company. After years of conducting the mining operation on the land, the land got exhausted in the coal content. There was no possibility for further coal mining on the land. Thus, it was decided by the company to sell the land for residential purposes to the potential land and plot buyers. For this action, a large section of the land was subdivided and subsequent activities of land development were performed by the company. This included sub section of the land into different size plots, road construction around the plots termed as Russel Roads and water and sewage plants, railway station, and park, church, hospitals were also made in this large land. It was stated on the part of the company that the received income should be treated as the capital receipts and would not be accountable for income tax. The honourable court ruled that the company was initially contributed in the coal mining and when the land was prepared for ripe process, it was decided by the shareholders to sell the ripe land, beside this factor, the land was huge in the size and it was essential to developed the land in order to make it feasible for residential purpose. Therefore, this trading of the land to the various potential buyers would be treated as mere realisation of the available asset (Jade, 2016). FC of T v Whit fords Beach Pty Ltd (1982) 150 CLR A beach land was purchased in regards to dry the shacks that are the basic component of the fishing business in the year 1953. This land was liquefied to land development companies, which were searching for a land nearby beach in the year 1967. The new shareholders intentionally divided the land into sub sections and same had been updated into article of the association of the firm. Companies made several plots on the land and subsequently sold them to the respective buyers. This activity of selling land plots caused sizable earning from isolated transaction. Therefore, the court pronounced that the intent of the shareholders is sufficient to determine the business intent of profit making. These land development activities on the land performed by the shareholder were also explained the mind set and willingness of the taxpayer to earn profit and also same activities were registered in the new article of association of the company. Thus, the income earned from isolated transaction wou ld be ordinary income and taxed as per relevant taxation norms (CCh, 2016a). Statham Anor v FC of T 89 ATC 4070 Two trustees named Statham Anor received a deceased farm land from their uncle. In order to use the land, they planned to begin a small cattle business to provide financial support to their families. This cattle business could not sustain for long and caused a loss also. Finally they decided to sell some specific part of the land to get some money to improve the financial issues. The tax commissioner ruled in this case that the received income from selling of the deceased land would be labelled as assessable income and would be taxed. This ruling of the commissioner was not accepted by the taxpayers and hence, they appealed to court. Court had taken the initial facts into consideration and decided that no activity of the taxpayer indicated the involvement in carrying business of selling the land also the taxpayer used the remaining land for farming business. The activity of the sale of the land would not be considered under the concepts of ordinary income. This was non assessable in come and derived from realisation of the available land asset (CCh, 2016b). Casimaty v FC of T 97 ATC 5135 There are several aspects that can help to examine the nature of the transaction and the involvement of the taxpayer in the profit making schemes or business. Also, any change in the prime intention on the part of the taxpayer will also change the type of the received income. This case can be viewed in the highlights of the above mentioned aspects. Casimaty who was initially involved in the farming activity sold a large part of his land by sub dividing it into several parts. These parcels of the land were made a sizable profit on the part of the taxpayer. Moreover, he was facing some financial shortage, which forced the taxpayer to sell his farm land. He had not sold the entire part of the land because he did not want to earn money by sale of the land. Additionally, he did not have enough capital to divide the land hence, he borrowed fund to divide the land. This also indicated his low financial condition. Hence, to improve financial condition, he sold some part of the land. This act ivity of selling of the land would be termed as mere realisation of the capital asset and received income would be capital receipts (CCh, 2016c). Moana Sand Pty Ltd v FC of T 88 ATC 4897 The Mona Sand Company was involved in the sand excavation on a purchased land. After years of the sand excavation process from the sand land, it was exhausted in the total sand mass and become ready for ripe process. The company had expected revenue of around $ 500,000 from sale of the land. For this respect the company systematically divided the land into plots of specific size, construct roads and parks, water supply units to improve the commercial worth of the land. The court ruled that the action of dividing the land into specified plots size and installation of various extra facilities would be lead the characteristics of owning a business of land development (Deutsch et, al., 2016). Thus, the earned revenue would be constituted according to the ordinary concepts. The revenue receipts would be taxed under the section 26(a) and 25(1) of ITAA, 1936. It was commented from the above arguments that only the receipts received from sale of the subdivided plots would be taxable due to t he business nature of the transaction. The reason being there was no intention on the part of the taxpayer to indulge into profit deriving activity from sale of land. Hence, the tax tribunal pronounced the decision in the favour of the company that sale of the land caused due to the involvement in the realisation of the land asset (Austax, 2016). Crow v FC of T 88 ATC 4620 Taxpayer had taken loan from various financial funds in order to purchase a five block land. In the early days, the taxpayer was involved in farming activity on this five block land. After few years of farming, a subsequent and systematically land subdivision took place by the taxpayer. Fifty one of various sized blocks were made from the farm land and sold among several land buyers. This resulted in an approximate revenue of $388,288. The court said that Crow the taxpayer had completely involved in the business of selling of the plots by conducting repetitively and systematically land division. However at the initial time frame, some farming was also performed by Crow but the main intent on behalf of the taxpayer can be taken from the evidences like he borrowed funds to purchase the land so that after few years of farming he could sell the land by dividing it into several blocks and earn sizable amount. There was continuously selling of the subdivided blocks which expressed the purp ose on the part of the taxpayer. Therefore, based on the ordinary nature of the transaction from business carrying activity would lead for taxation (CCh, 2016d). McCurry Anor v FC of T 98 ATC 4487 McCurry Anor the concerned taxpayers had bought a land, which was having few small old buildings. In order to develop the land, three newly design town houses were constructed on the land by the taxpayers. Taxpayers exclusively involved in the activity of advertising about the selling of the new constructed town houses. However, they were not successful in the sale of the houses and started using one townhouse for their own living. After 12 months of living, they were sold the town houses and earned net revenue of $150,000. The tax authority pronounced that the taxpayers were completely engaged in the commercial activity of land development and selling of the land and earned revenue was ordinary in nature. However, taxpayers disagreed with the decision given by the tax authority and claimed that in order to overcome from financial issues, they sold the land. The honourable court said that if taxpayers were facing financial difficulties than they were not in the situation to construc t newly designed townhouses. They constructed the townhouses in order to sell them to get higher return revenues. Also, it was pronounced that purchasing of the land house would not be considered under investment activity hence, it was not be realisation of the capital asset. There was full intent on the parts of the taxpayers to sell the land to earn sizable profit. Hence, the received revenue from isolated transaction coming from sale of the townhouses would be considered as assessable income and liable for the taxation under the section 25(1) of ITAA, 1936 (CCh, 2016e). References AusTax 2016, Assessable Income: Subdivision of pre-CGT land, Available online from https://austaxpbr.com.au/document/PBR_3062 (Accessed on August 29, 2016) Barkoczy,S 2014,Foundation of Taxation Law 2014,6th eds., CCH Publications, North Ryde CCh 2016a, FC of T v Whit fords Beach Pty Ltd (1982) 150 CLR, Available online from https://www.iknow.cch.com.au/document/atagUio549860sl16841994/federal-commissioner-of-taxation-v-whitfords-beach-pty-ltd-high-court-of-australia-17-march-1982 (Accessed on August 29, 2016) CCh 2016b, Statham Anor v FC of T 89 ATC 4070, Available online from https://www.iknow.cch.com.au/document/atagUio544343sl16788832/statham-anor-v-federal-commissioner-of-taxation-federal-court-of-australia-full-court-23-december-1988 (Accessed on August 29, 2016) CCh 2016c, Casimaty v FC of T 97 ATC 5135, Available online from https://www.iknow.cch.com.au/document/atagUio539843sl16716249/casimaty-v-fc-of-t-federal-court-of-australia-10-december-1997 (Accessed on August 29, 2016) CCb 2016d, Crow v FC of T 88 ATC 4620, Available online from https://www.iknow.cch.com.au/document/atagUio545564sl16800674/crow-v-federal-commissioner-of-taxation-federal-court-of-australia-17-august-1988 (Accessed on August 29, 2016) CCh 2016e, McCurry Anor v FC of T 98 ATC 4487, Available online from https://www.iknow.cch.com.au/document/atagUio539084sl16707683/mccurry-anor-v-fc-of-t-federal-court-of-australia-15-may-1998 (Accessed on August 29, 2016) Coleman, C 2011, Australian Tax Analysis, 4th eds., Thomson Reuters (Professional) Australia, Sydney Deutsch, R, Freizer, M, Fullerton, I, Hanley, P, Snape, T 2016, Australian tax handbook 9th eds., Thomson Reuters, Pymont Jade 2016, Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188, Available online from https://jade.io/j/?a=outlineid=64663 (Accessed on August 29, 2016) Manyam, J 2010, Taxation Of Gains From Banking and Insurance Businesses In New Zealand, Revenue Law Journal, Vol. 20, No.1, pp. 1-29 Woellner, R 2014, Australian taxation law 2014, 8th eds., CCH Australia, North Ryde