Education Reform Essay -- Education

Ideas swarm around us everyday. They run through our heads and at times they alter our thoughts, believes, and perception. The question is, what ideas, events, or words affect us so that we do the things we do and say the things we say. If we understand the causes and know the effects, we have yet to fully understand the â€Å"chain.† In essence, the real question is not â€Å"what† ideas, events, or words affected the person but rather â€Å"why† it affected them. To understand the why, we must first understand the initial cause and effect. George Santayana’s philosophies found in his essays, â€Å"Intellectual Ambition† and â€Å"Intuitive Morality,† were enthused by the rise of education and change in literature during the time. The cause and effect can be as simple as the rise of education and such forth brought Santayana to write these essays; however, with the lack of detail, the lack of evidence, and no answer to why these things affected his writing, it is impossible to complete the chain of cause and effect. Basically, the causes, effects, details, and evidence must first be analyzed then organized in order to understand the question of why. During the late 1880s and early 1890s, reforms in education allowed for a more open view of education and the world sparking creativity and independence in schools. (America Past and Present, paraphrase) The world, especially the United States, was beginning to understand that through creativity and education beyond the core subjects the spectrum of knowledge known would spread beyond regions imaginable. The curiosity spread through out the U.S and eventually influenced many great people, one being George Santayana. In his essay, â€Å"Intellectual Ambition,† Santayana signifies the strength of creativity and... ...Works Cited Santayana, George. â€Å"Intellectual Ambition.† The Oxford Book of Essays. Oxford University Press. ED. John Gross. 1991. 341-342 Santayana, George. â€Å"Intuitive Morality.† The Oxford Book of Essays. Oxford University Press. ED. John Gross. 1991. 342-345 Saatkamp, Herman, "George Santayana." The Stanford Encyclopedia of Philosophy (Fall 2010 Edition), Edward N. Zalta (ed.) . â€Å"Chapter 19: Towards an Urban Society, 1877-1900.† America: Past and Present. Ed. Michael Boezi. 8th edition. New York: Pearson Longman, 2007. 538-570 â€Å"Chapter 20: Political Realignment in 1890s.† America: Past and Present. Ed. Michael Boezi. 8th edition. New York: Pearson Longman, 2007. 572-598 â€Å"George Santayana.† Britannica. 2005. 17 Jan. 2006 .

Hope Wireless HR Proposal Essay

In support of launching a total reorganization of Hope Wireless, the third leading wireless company in the United States, the Human Resource Department will review and enhance several processes to include but not limited to staffing, performance appraisal, training and development, total rewards, and organizational behavior and processes. The goal is to transition Hope Wireless from good to great; from not only being an American company but a global company. The goal of this strategic organization proposal is to attract and retain the most qualified employees, improved company performance, customer satisfaction, prevent churn and increase revenue. Employees are Hope Wireless number one resource and a long term investment in employees is a long-term investment for the organization. Part I – Hope Wireless HR Proposal Plan Hope Wireless offers a broad range of wireless and wire line communications services encouraging mobile freedom to consumers, business and government users. By the end of the first quarter 2013, Hope Wireless had served more than 55 million customers with an employee base of approximately 60, 000 people. This is over 15 million more customer than one year ago. Hope Wireless is widely recognized for offering the most innovative technology and cutting edge devices and the most sophisticated network of all mobile carriers. Hope Wireless’s business objective is to position the organization to be the leading wireless company in the telecommunications industry. Hope Wireless is striving to offer world-class customer service, proactively identifying and meeting the wireless needs of customers and to offer benefits unlike any other organization. â€Å"Organizations in which people work affect their thoughts, feelings, and actions in the workplace and away from it. Likewise, people’s thoughts, feelings, and actions affect the  organizations in which they work† (Brief & Weiss, 2002). Over the past five years, Hope Wireless has progressively earned numerous customer service awards but most importantly the American Customer Satisfaction Index award. The American Customer Satisfaction Index group rated Hope Wireless No. 1 amongst all national carriers in most improved customer service particularly over the last four years. â€Å"Customer satisfaction is an important goal for providers of both services and products, and customer surveys are a commonly used instrument for evaluating that satisfaction† (Ammar, Moore & Wright, 2008). Approximately five years ago, Hope Wireless was failing customer service surveys miserably and the customer satisfaction rate was fluctuating between anywhere from 65% to Part I – Hope Wireless HR Proposal Plan 72%. The telecommunications industry customer satisfaction goal is 85% or better. It was obvious across sites, states and countries that employees were not satisfied with their work environment and conditions. A supervisor task force proposed ideas to incite change across the organization. â€Å"Operation Smile† became a nationwide Hope Wireless initiative in addition to the â€Å"Go Fish† campaign. Operation Smile all employees to smile whether it was towards another employee or customer. Everyone in the organization was presented 20 SMILE cards of which agreements were electronically signed that each employee would award any employee they â€Å"caught† smiling. The quality analyst were charge to give a SMILE cards to employees they heard SMILING through the phone. The Operation Smile initiative alone increased the overall customer satisfaction rate by 9%, sometimes higher. Any employee who accumulated increments of 10 or more cards could earn exciting gifts. This was a six-month initiative that cumulated with a grand-prize drawing that varied depending upon the site and locality. The next morale boosting initiative which would have a direct positive impact on organization effectiveness was implementing the â€Å"GO Fish† campaign. Seattle’s Pike Fish market was the source of this idea as they are a living example of the principles supported by this initiative†¦.†being present† and â€Å"making someone’s day†. If an employee was present for the  customer or peer, they were awarded a fish by their supervisor or manager. The receiving employee would solicit a fish for their peer from a supervisor or manager. The quality analyst would award the fish if they witness an employee â€Å"being present† and â€Å"making someone’s day† towards their customer. Part I – Hope Wireless HR Proposal Plan Each team was also given a stuffed fish to throw to the person who received a fish. Whenever the random bell tolled, the person holding the fish would receive an immediate reward, most often a gift card. Just as the SMILE initiative, any employee who accumulated increments of 10 or more fish could earn very exciting prizes. This was also a six month morale boosting plan. Customer satisfaction results have continually progressed and have been maintaining ratings of 85% or better on a monthly basis. Hope Wireless began and continues to see a decrease in churn, decrease in employee turnover, increase in employee relations and retention and a dramatic increase in customer satisfaction. The aforementioned action plans greatly influenced employee morale and encourage positive customer behavior while increasing the effectiveness of the organization. â€Å"The loss of employees is a disruptive event. Organizations often pursue innovative ways to reduce employee turnover, often with limited success† (Murphy & Taylor, 2006). In addition to random initiatives, Hope Wireless offers on-going employee relation and retention resources such as the manager, site director open door policy, human resource specialist, employee assistance hotline, anonymous corporate security hotline and email address and a on-line suggestion box is set up in each site. Hope Wireless needs to supports diversity management by â€Å"ensuring that factors are in place to provide for and encourage the continued development of a diverse workforce by melding these actual and perceived differences among workers to achieve maximum productivity† (Mondy & Mondy, 2008). Hope Wireless needs to offer various employee resource groups in support of sexual preference, gender, race, veteran status, etc. The employee Part I – Hope Wireless HR Proposal Plan resource groups will be voluntary, open to all employees with them not being limited to having access to only one group. The Employee Resource Groups (ERG) will offer many benefits to employees such as unique development and networking opportunities, acquisition of practical skills and mentoring programs. In addition, ERG offers connections with people and information not generally accessible. The aforementioned connections to aid employees in positively impacting the organization by become part of the solution. Association with ERG provides allows employees exposure to company leaders, to serve and volunteer in the community as a representative of the organization and most importantly exposure to and learning about different cultures. Hope Wireless has utilized both internal staffing processes and temporary staffing agencies. Research has suggested employees that were hired on a permanent basis out-performed temporary worker. The permanent workers demonstrated ownership and allegiance to the company coupled with documented higher customer satisfaction ratings. The recommendation is to maintain the internal hiring practice. Hope Wireless is successfully trending in the right direction. The aforementioned initiatives, processes and resources, customer service ratings and referenced awards have aided and proven that Hope Wireless is now offering world-class customer service. In addition, the number of net-adds in one year’s time, demonstrates Hope Wireless’s ability to meet and exceed the mobile needs of customer base. Hope Wireless continues to strive for on-going growth and success. REFERENCES Ammar, S., Moore, D., & Wright, R. (2008). Analyzing customer satisfaction surveys using a fuzzy rule-based decision support system: Enhancing customer relationship management. Journal of Database Marketing & Customer Strategy Management, 15(2), 91-105. doi:http://dx.doi.org/10.1057/dbm.2008.2 Brief, Arthur P., & Weiss Howard M., â€Å"Organizational Behavior: Affect in the Workplace†, (2002), pp. 279-307. Mondy, R. W., & Mondy, J. B. (200*) Human Resource Management (10th ed.), Upper Saddle River, NJ: Pearson Prentice Hall Taylor, Lloyd J., I., II, Murphy, B., & Price, W. (2006). Goldratt’s thinking process applied to employee retention. Business Process Management Journal, 12(5), 646-670. doi:http://dx.doi.org/10.1108/14637150610691055 Part II – Hope Wireless Performance Appraisal Hope Wireless offers a broad range of wireless and wire line communications services encouraging mobile freedom to consumers, business, and government users. Performance appraisal methods are essential in support of â€Å"Human Resource planning, recruitment and selection, training and development, career planning and development, compensation programs, internal employee relations and assessment of employee potential† (Mondy & Mondy, 2008). The appropriate performance appraisal method for Hope Wireless, considering the type of organization and the number of employees is the rating scales method. â€Å"The rating scales method is a performance appraisal method that rates employees according to defined factors† (Mondy & Mondy, 2008). â€Å"Performance management systems are effective when they are based on goals that are jointly set and are driven by an organization’s business strategy† (â€Å"What Makes Performance Appraisals Effective?† 2012). Performance appraisal imperatives for Hope Wireless will include: Do It Now (resolve); Delegate & Empower (engage appropriate resource/make a decision); Be Accountable (ownership); Focus on Customers (attentive); Teamwork & Camaraderie (work and win as a team); Compete like Winners (always strive for the top); Develop Yourself & Others (stay abreast of the business policies/procedures; peer-to-peer coaching); Acting with Integrity (adhere to code of conduct) and Have Fun (enjoy what you do). The advantage of the rating scales method is that the process is controlled and uniform. With the large number of individuals employed by Hope Wireless, the rating scales method allow for easy comparison and contrast. ‘The rating scales method allows each employee to be subjected to the same appraisal process and rating criteria, with the same range of responses. Part II – Hope Wireless Performance Appraisal Rating scale methods are easy to use and understand. The concept of the rating scale makes obvious sense; both appraisers and evaluated employees have an intuitive appreciation for the simple and efficient logic of the bipolar scale. The result is widespread acceptance and popularity for this approach† (â€Å"Appraisal Methods†, n.d.). â€Å"Organizational culture change is dynamic and depends on leadership and  management. The concepts of organizational change focusing on process, culture change and leadership, and organizational culture change and the learning organization are central to organizational transformation and will be addressed next† (ConceiÃÆ' §ÃƒÆ' £o & Altman, 2011). â€Å"Training and development is the heart of a continuous effort designed to improve employee competency and organizational performance† (Mondy & Mondy, 2008). The training and development program projected for Hope Wireless will be inclusive of intense focus on the position of the front line employee. The front-line employee is the customer-interfacing employee which directly impacts the organization’s bottom line revenue. While training for the management team and other integral positions is very important, it is the customer interaction of which the organization thrives and allows the other positions to be vital and necessary. Taking into consideration the organization’s mission, goals and corporate plan, the training and development will be created to support the company’s culture. It is also important for Hope Wireless’s training and development plan to support the various job description tasks to include both internal and external customers. The final attribute in the training and development process is each employee’s personal training needs. This can be assessed by compiling knowledge, skills and abilities checklist and having each supervisor/manager administer the survey. Establishing training goals specific to each Part II – Hope Wireless Performance Appraisal Position will ensure effective training in support of expected execution. Goals should include purpose and objectives. Hope Wireless offers 60% instructor led training and development while 40% of the training is via on-line classes for all level of employees. The management staff will also receive enhanced development via team builders, instructor led leadership courses and off-site leadership classes. Career pathing at Hope Wireless will be facilitated through Hope University (HU). Hope University’s goal is to improve business performance innovative tools and resource to ensure on-going learning and development in support organizational success and employee career enhancement. â€Å"As a leader in learning and development, HU creates support tools that effectively  facilitate performer tasks while on the job (such as desktop decision-making tools) and knowledge-management solutions which allow organizations to capture and share their collective knowledge (like discussion forums, blogs, pod casts and case studies). These less traditional solutions are in addition to its more than 3,000 skills and knowledge development offerings and over 2.5 million hours of training delivered annually†(â€Å"Sprint†, n.d.) At Hope Wireless each employee is ultimately responsible for their career plan, with their manager’s and leader’s support. With expertise in performance support, development, and delivery, the HR staff has the knowledge and hands-on experience to help each employee reach their full potential through innovative and engaging solutions. On-line job development courses and interactive training classes are optional and available to any employee to be scheduled at Part II – Hope Wireless Performance Appraisal their leisure. The HR staff will provide assistance in identifying the appropriate classes in support reaching one’s career goals. Effective succession planning is the reward of training and development and career pathing. Both training and development and career pathing should be developed and executed with succession planning in the blueprint. Hope Wireless succession plan would include promoting from within as the potential candidate will be prepared to transition into the open position fully armed with the organization’s mission, goals and expectations. It will be important to focus on those individual who demonstrate the ethics, value and integrity of which the Hope Wireless culture represents. Potential leaders will be identified, partnered with existing leadership and provided the resources to enhance strong skillsets and enhance areas of opportunity. Company career goals will be identified along with the potential candidate identifying their personal career goals. Hope Wireless will extend every effort to fill key positions from within to enhance employee morale, avoid negative business impact and ensure continual career advancement. Part II – REFERENCES Appraisal Methods. Retrieved from http://www.performance-appraisal.com/ratings.htm ConceiÃÆ' §ÃƒÆ' £o, S., C.O., & Altman, B. A. (2011). Training and development process and organizational culture change. Organization Development Journal, 29(1), 33-43. Retrieved from http://search.proquest.com/docview/862094636?accountid=35812 http://linked2leadership.com/2013/04/01/10-steps-to-create-a-killer-succession-plan/ Mondy, R. W., & Mondy, J. B. (2008) Human Resource Management (10th ed.), Upper Saddle River, NJ: Pearson Prentice Hall Sprint. (n.d.). Retrieved from http://www.sprint.com What Makes Performance Appraisals Effective? (2012, October). Sage Journals, 44(4), 191-200. Retrieved from http://cbr.sagepub.com.ezproxy.apollolibrary.com/content/44/4/191 Part III – Hope Wireless Compensation Plan â€Å"Compensation is the total of all rewards provided employees in return for their services† (Mondy and Mondy, 2008). In support of meeting and exceeding Hope Wireless’ business objectives, a comprehensive compensation and incentive plan will be outlined as follows for the front line customer-interfacing employees. Hourly rate for customer service (CS) agents is $12.00 per hour based on the average industry hourly pay of $10 per hour. Overtime will be paid at one and one half hours for every hour worked over 40 hours. This does not include vacation hours, specifically worked hours. Bonus compensation will be paid when the criteria has been met as outlined in the bonus plan for each group. Paid time off (PTO) will accrue at the follow rate: tenure of one to three years will accrue two weeks of PTO; tenure of four to six years will accrue three weeks of PTO and tenure of six plus years will accrue five weeks of PTO. Each employee will only be able to carry-over 40 hours of PTO at the end of each calendar year. Every year each employee will accrue two eight hour floating holidays for personal use, which are not transferrable. CS agents will begin with a balance of 140 HAP (Hope Attendance Points) to be used for unscheduled absences. A five to eight hour unscheduled absence will result in deduction of 10 HAP. An unscheduled absence of four or less hours will result in a deduction of five HAP. Business impact days that are designated by Workforce, will have a double point deduction. Those days will be  identified at least two weeks prior to applicable timeframe. The aforementioned benefits and compensation are in support of employee satisfaction, retention and securing employees commitment to the organization. The CS agents will be Part III – Hope Wireless Compensation Plan provided a comprehensive outline of the PTO/HAP policies to include unacceptable HAP balances, the consequences of exhausting all balances including PTO and HAP, etc. The CS agents will also have the option of enrolling in medical insurance of which Hope Wireless will remit 70% of the premium. The CS agents will also have the option of dental and optical insurance where Hope Wireless will remit 70% of the premium. Employees will also have the option to participate in pre-tax flex-spending accounts. A self- initiated pre-tax monetary amount will be deducted from each paycheck and placed in a fund for medical/co-pay expenses for the employee and covered relations enrolled in the medical insurance program. This is a great savings and perks for the employees. Hope Wireless offers all employees an exciting 401K plan of which Hope Wireless matches dollar for dollar up to five dollars per pay period. Stock options are also available in addition to the 401K plan, both of which will be outline on the company’s intranet benefit site. Enrollment in 401K and stock options are available year-round. Tuition reimbursement is available for courses applicable to customer service/leadership/management and will be paid up to 90% for two courses annually after outlined criteria is met and approved by his/her manager. Criteria can be found on Hope Wireless’ intranet benefit site. Base pay increases are performance based and will be determined yearly once the employee has been rated by Supervisor via the annual performance review. The pay increases will be based on current rate per hour, performance rating and active corrective actions and performance action plans. Pay increases will be com mensurate with current industry standards at the time of the rating. Part III – Hope Wireless Compensation Plan The Human Resource team has rendered extensive research of surrounding call centers, conducted surveys of sister sites and concluded the outlined  compensation plan is inclusive of the most desired benefits of the most tenured employees who consistently exceed performance goals. The targeted employees also have consistently exceeded customer expectations per customer surveys. HR’s partnership with middle management is also a key element to successful operations and employee retention. HR will also outline a process of which middle management can execute separate and apart from the aforementioned proposal. â€Å"Practical strategies for supervisors include clearly identifying role responsibilities, implementing flexible scheduling, supporting role integration, applying job sharing principles, and remembering to reward and recognize employees†(Winterstein, Mazerolle & Pitney, 2011). Hope Wireless’ mission is to exceed the expectations of every customer who is in contact with the site. In order to enjoy such a reputation, every employee has to be engaged, empowered, committed, satisfied in their role and have allegiance to the organization and their team leads. Meeting performance expectations will allow each employee their hourly base pay. Surpassing performance expectations invites the opportunity to earn a bonus. WOWING every customer, owning the business, caring about your co-worker, volunteering in the community on behalf of the organization, etc. earns rewards and recognition. Recognizing employees for a job well done is more important than many leaders realize. Employees often times provide feedback via company surveys that their manager only meet with them to share/discuss poor performance. Being â€Å"caught in the act† of outstanding performance/behavior is a pay-off for the organization that is immeasurable. Great behavior Part III – Hope Wireless Compensation Plan breeds great behavior. Receipt of recognition in front of an employee’s peers not only enhances one self-esteem but often times deem an employee a subject matter expert. A go to person. â€Å"Since managers prefer to keep their good performers and employees that they like, it is important to understand their treatment of those individuals in promoting their desired continued personal development† (Adams, 2005). Hope Wireless will not only engage in  on the spot â€Å"Caught in the Act† positive feedback cards issued by an employee’s manager, the use of â€Å"Caught in the Act† certificates, posters and emails will also be initiated. Certificates will be presented in team meetings; posters will be posted in the team work area and emails will be sent to recognized employee with the entire team copied. Hope Wireless Trinkets will also be available to the management team in addition to the creation of the Hope Wireless Fun committee. The Hope Wireless Fun committee will be charged with engaging a mix of employees to create and execute fun activities for the site to reward and motivate employees such as team prizes for the best performers, best customer service surveys, etc. Hope Wireless is committed to working and winning as a team and to have the best team of employees in the wireless industry. REFERENCES Adams, S. M. (2005). Positive Affect and Feedback-Giving Behavior. Journal of Managerial Psychology, 20(1), 24-42. Retrieved from http://search.proquest.com/docview Mondy, R. W., & Mondy, J. B. (2008) Human Resource Management (10th ed.), Upper Saddle River, NJ: Pearson Prentice Hall Winterstein, A. P., Mazerolle, S. M., & Pitney, W. A. (2011). Workplace environment: Strategies to promote and enhance the quality of life of an athletic trainer. Athletic Training & Sports Health Care, 3(2), 59-62. doi:http://dx.doi.org Part IV – The Cultural Change The senior leaders of Hope Wireless prides themselves on being one of the top three wireless leaders. Hope Wireless has won sundry service awards and achieve many honors for most improved customer service. In addition, Hope Wireless offers innovative and competitive wireless devices of which the other wireless providers have been unable to match. While many of Hope Wireless’s policies and procedures will be addressed and enhanced as a result of this proposal, the last enhancement proposal is in support of the internal culture of the organization. The previous site director allowed employees to dress down daily. Dressing down allows denim, flip-flops, shorts, hats, etc. Employees who are dressed down are more relaxed and come across as such when speaking to customers lending to an unprofessional  environment and poor customer service interactions. A recent event involving an employee who had placed their sweatshirt hood on and laid their head on the desk while waiting on a call is the final motivation for the proposed change. While sleep, several customers came onto the sleeping employee’s line and dropped when no one responded. This resulted in an impact in customer service and service level. The news of the termination of the employee was wide-spread amongst the agent’s peers. This was the first step towards awareness that the organization will take immediate reaction to negative impact caused by an employee. â€Å"When people in an organization realize and recognize that their current organizational culture needs to transform to support the organization’s success and progress, change can occur. But change is not pretty and change is not easy† (Heathfield, n.d.). Part IV – The Cultural Change The first cultural change proposal is to initiate a change to the current dress code policy from daily dress down to dress down Fridays, Saturdays, Sundays, and holidays ONLY, unless otherwise specified. Currently, employees are only required to wear professional business attire when corporate visitors are expected on-site. The proposed normal day to day dress requirement will be business casual. Business casual dress guidelines will require men to wear collared shirts, khaki or dress pants and no tennis shoes or sandals. Business casual dress guidelines will require women to wear non- provocative, non-tight-fitting clothing void of denim and stretch material. Denim will not be allowed for either women or men. Women or men will not be permitted to wear shorts on business casual days. Women’s skirts and dresses must be knee length and the women’s shoe requirement will require dress shoes, no tennis shoes or flip flops. â€Å"Top-down attempts to change organization culture have a number of unintended consequences, amongst which is an emotional fall-out that becomes manifested in higher rates of absenteeism† (Carr, 2002). Human Resource has elected to release management of the task of owning and communicating this change. Employee focus groups will be formed to access to proactive strategize the most effective communication and reaction to opposition toavoid   negative impact to business. Agent dissatisfaction often translate to poor performance and reliability in call centers. Severe opposition is expected in response to this proposed change. The tentative initial communication to employees will be socialized to employees in team meetings by members of the employee focus group. Often times, peer buy-in lends to continued peer buy-in to change in an organization. In support of the opposition, Human Resources will also partner Part IV – The Cultural Change With the Communication team to begin sending out catchy, funny emails and launch internal television advertisements of the dress code change to occur in 30 days. The â€Å"why† documents will be drafted to include the goal of delivering superior, professional customer service. Anonymous pictures will be included of relaxed desk posture of agents who are dressed down versus those who are dressed business casual. Relaxed posture translate to relaxed conversations. Human Resources will also be prepared to hold optional brown bag meetings to share â€Å"relaxed† remote quality observations where unprofessional customer service was rendered versus calls observed on a professional dress day. Human Resources will set the expectation that the Management team will be held accountable to execute this change and maintain application and consistency of the policy change. All policy amendments are supported by 30 day adaptation grace period after which the following reaction will be instituted. Management will render a documented verbal warning for the 1st dress code violation. The 2nd dress code violation will result in the employee being sent home to change with an impact to pay for the time missed and documented warning. The 3rd dress violation will result in a 1st written warning and will continue to progress to termination. Human Resources will be open for feedback will be open to negotiate with employees holistically to encourage receptiveness to the dress code change. â€Å"Timing can be crucial. Conflict tends to develop through stages, from awareness that differences exist to a hardening of attitudes and, possibly,  open hostility† (â€Å"Abc of Conflict and Disaster: Approaches to Conflict Resolution,† 2005). The employee focus group will be the first reaction to conflict of which employees will be encouraged to provide open and honest feedback to and amongst their peers. Part IV – The Cultural Change This will provide an immediate forum for employees to react versus allowing dissatisfaction and conflict fester and result in unnecessary and avoidable conflict.  The aforementioned changes outlined in this proposal outline a cultural change that lends to effective start-up, encourage growth, prevent decline, encourage renewal and upward mobility and prevent death of the organization. CONCLUSION The Human Resource planning and partnership outlined in the aforementioned proposal will institute efficient, effective, consistent, and revenue impacting operations. The Human Resource team for Hope Wireless has prepared the blueprint to propel the organization to becoming the #1 wireless leader in the industry. REFERENCES Abc Of Conflict And Disaster: Approaches To Conflict Resolution. (2005, August). BMJ: British Medical Journal , 331(7512), 344-346. Retrieved from http://av4kc7fg4g.search.serialssolutions.com.ezproxy.apollolibrary.com Carr, A. (2002). Organisational culture: Organisational change? Journal of Organizational Change Management, 15(4), 425. Retrieved from http://search.proquest.com/docview/197601624?accountid=458 Heathfield, S. (n.d.). How to Change Your Culture: Organizational CultChange. About.com Guide, (), Retrieved from http://humanresources.about.com/od/organizationalculture/a/culture change.htm

Virginia Northern Flying Squirrel Facts

The Virginia northern flying squirrel (Glaucomys sabrinus fuscus and abbreviated as VNSF) is a subspecies of northern flying squirrels (G. sabrinus) that lives in high altitudes in the Allegheny Mountains in the U.S. states of Virginia and West Virginia. In 1985, this squirrel was listed as vulnerable in the International Union for Conservation of Nature (IUCN), but after its population rebounded, was delisted in 2013. Fast Facts: Virginia Northern Flying Squirrel Scientific Name: Glaucomys sabrinus fuscusCommon Name: Virginia northern flying squirrelBasic Animal Group: MammalSize: 10–12 inchesWeight: 4–6.5 ouncesLifespan: 4 yearsDiet:Â  OmnivoreHabitat:Â  Allegheny mountains of Virginia, West VirginiaPopulation: 1,100Conservation Status: Delisted (due to Recovery) Description The Virginia northern flying squirrel has dense, soft fur that is brown on its back and slate gray colored on its belly. Its eyes are large, prominent, and dark. The squirrels tail is broad and horizontally flattened, and there are membranes called patagia between the fore and hind legs that serve as wings when the squirrel glides from tree to tree. Adult VNFS range in size between 10 and 12 inches, and between 4 and 6.5 ounces. Diet Unlike other squirrels, the Virginia northern flying squirrel usually feeds on lichen and fungi growing above and below ground instead of eating strictly nuts. It also eats certain seeds, buds, fruit, cones, insects, and other scavenged animal material. Habit and Distribution This subspecies of flying squirrel is typically found in conifer-hardwood forests or forest mosaics consisting of mature beech, yellow birch, sugar maple, hemlock, and black cherry associated with red spruce and balsam or Fraser fir. Biological studies have shown that it prefers mature growth red spruce trees at high altitudes, because of the presence of downed trees which promote the growth of fungus and lichens. The Virginia northern flying squirrel currently exists in red spruce forests of Highland, Grant, Greenbrier, Pendleton, Pocahontas, Randolph, Tucker, Webster counties of West Virginia. Behavior These squirrels large, dark eyes enable them to see in low light, so they are very active during the evenings, especially two hours after sunset and one hour before sunrise, moving among trees and on the ground. Virginia northern flying squirrels live in family groups of adults and juveniles that share ranges. Home ranges of males are approximately 133 acres. The squirrels fly by launching themselves from tree branches, and spreading their limbs so the gliding membrane is exposed. They use their legs to steer and their tails to brake, and they can cover more than 150 feet in a single glide. They may build leaf nests but often opportunistically reside in tree cavities, underground burrows, woodpecker holes, nest boxes, snags, and abandoned squirrel nests. Unlike other squirrels, Virginia northern flying squirrels remain active in the winter instead of hibernating; they are social animals and have been known to share nests with multiple males, females, and pups in their families over the winter for warmth. Their vocalizations are varied chirps. Reproduction The breeding season for Virginia northern flying squirrels falls between February to May and again in July. Gestation lasts 37–42 days and one or two litters of live pups are born with two to six individuals and averaging four or five. The squirrels are born from March through early July with a second season in late August to early September. After theyre born, the mothers and the newborns move to maternal nests. The young stay with their mother until they are weaned at two months and become sexually mature at 6–12 months. VNFS have a lifespan of about four years. Threats In 1985, the primary cause for the decrease in population was habitat destruction. In West Virginia, the decline of Appalachian red spruce forests was dramatic beginning in the 1800s. The trees were harvested to produce paper products and fine instruments (such as fiddles, guitars, and pianos). The wood was also highly valued in the ship-building industry. The single most important factor in the squirrels population resurgence has been the regeneration of its forested habitat, reports the Richwood, WV, website. While that natural regrowth has been ongoing for decades, there is considerable and growing interest by the U.S. Forest Service Monongahela National Forest and Northeastern Research Station, the state of West Virginia Division of Natural Resources, Department of Forestry and State Park Commission, The Nature Conservancy and other conservation groups, and private entities to foster large spruce restoration projects that restore the historic red spruce ecosystem of the Allegheny Highlands. Since being declared endangered, biologists have placed and encouraged the public placement of nest boxes in 10 counties of western and southwestern Virginia. Primary predators of the squirrel are owls, weasels, foxes, mink, hawks, raccoons, bobcats, skunks, snakes, and domestic cats and dogs. Conservation Status The loss of red spruce habitat by the end of the 20th century necessitated the listing of the West Virginia northern flying squirrel under the Endangered Species Act in 1985. In 1985, at the time of its Endangered Species listing, only 10 squirrels were found alive in four separate areas of its range. In the early 2000s, federal and state biologists captured more than 1,100 squirrels at over 100 sites and based on that believe that this subspecies no longer faces the threat of extinction. In 2013, the Virginia northern flying squirrels were delisted by the International Union for Conservation of Nature (IUCN) and the U.S. Fish and Wildlife Service, due to population recovery. Sources Cassola, F. Glaucomys sabrinus. The IUCN Red List of Threatened Species: e.T39553A22256914, 2016.Diggins, Corinne A., and W. Mark Ford. Microhabitat Selection of the Virginia Northern Flying Squirrel (Glaucomys Sabrinus Fuscus Miller) in the Central Appalachians. BioONE 24.2 (2017): 173–90, 18. Print.Ford, W. M., et al. Predictive Habitat Models Derived from Nest-Box Occupancy for the Endangered Carolina Northern Flying Squirrel in the Southern Appalachians. Endangered Species Research 27.2 (2015): 131–40. Print.Menzel, Jennifer M., et al. Home Range and Habitat Use of the Vulnerable Virginia Northern Flying Squirrel Glaucomys Sabrinus Fuscus in the Central Appalachian Mountains, USA. Oryx 40.2 (2006): 204–10. Print.Mitchell, Donna. Spring and Fall Diet of the Endangered West Virginia Northern Flying Squirrel (Glaucomys Sabrinus Fuscus). BioONE 146.2 (2001): 439–43, 5. Print.Trapp, Stephanie E, Winston P Smith, and Elizabeth A Flaherty. Diet and Food Avail ability of the Virginia Northern Flying Squirrel (Glaucomys sabrinus fuscus): Implications for Dispersal in a Fragmented Forest. Journal of Mammalogy 98.6 (2017): 1688–96. Print.Virginia northern flying Squirrel (Glaucomys sabrinus fuscus). ECOS Environmental Conservation Online System.

The Theories Of Language Acquisition - 1237 Words

Behaviourism, one of the earliest scientific explanations of language acquisition was greatly influenced by theorist B.F Skinner (1957). The techniques of this learning theory have long been absorbed in the education setting to promote behaviours that are desirable and to dishearten those who are not (Stanbridge, 2014). As one of the developers of behaviorism B.F. Skinner (1957) accounted for language development by means of environmental influence, particularly a child’s reaction to reward and punishment. Skinner justified that behaviours that are rewarded, would be repeated, but behaviours that are disciplined or ignored will lessen. B.F Skinner (1957) also recognised two types of reinforcement, positive reinforcement and negative reinforcement, and explained how these strategies can strengthen the behaviour that follows. Skinner described positive reinforcement as a behaviour being followed by the presentation of a positive stimulus, thus the behaviour then increases (Hannum, 2006). For example, when a baby says ‘Ma, ma’ for the first time, we naturally get very excited and repeat the sounds back to the child, reinforcing the behaviour which makes it more likely for the child to produce that word again. (Centre for Learning Innovation, 2006, p. 8) This is called positive reinforcement. Naturally, children seek approval from people or teachers they admire and work for things that bring them a positive atmosphere (Cherry, 2015). By smiling, praising and commending theShow MoreRelatedThe Theories Of Language Acquisition1707 Words   |  7 PagesLanguage Developmental research is fascinated with how young children are able to acquire language. This fascination has led to the development of numerous theories of language acquisition. Two major theories of language acquisition include the behaviorist theory and the innatist theory. Both contrasting theories are influential to developmental research and inspire much research in an attempt to support or disprove each theory. Behaviorist Theory of Language Acquisition The behaviorist theoryRead MoreThe Theory Of Language Acquisition Essay1410 Words   |  6 PagesNumerous theories try to explain the process of language acquisition. These theories fall into one of two camps. The environmentalist (or connectionist) theory of language acquisition asserts that language is acquired through environmental factors (Halvaei et al. 811). Theorists in this camp believe that a child learns language by gaining information from the outside world and then forming associations between words and objects. The nativist (or rationalist) approach, on the other hand, assertsRead MoreLanguage Acquisition Theory And Language Learning1488 Words   |  6 PagesA language acquisition theory was first proposed by Skinner (1957). He argued that children acquire a language by being exposed to the influence of environment they live in. The hypothesis on the distinction between language acquisition and language learning was proposed by an American linguist and educational r esearcher Stephen Krashen. When we consider ‘language learning’ broadly speaking - we usually mean all activities performed by second language learners in order to attain a required levelRead MoreThe Theory Of Innate Language Acquisition994 Words   |  4 Pagesoriginal thoughts was Steven Pinker. In the early nineties Pinker’s debate of language acquisition became a popular notion due to the beliefs within his book ‘The Language Instinct’ (1994). The book describes the basic human instinct to learn and acquire language as a means to communicate and understand situations. In a similar vein to Chomsky he describes language as an instinct and not a skill that’s dependant on acquisition. This concept suggests that proof is merely the way that children can speakRead MoreThe Theories Of First Language Acquisition Essay1636 Words   |  7 PagesFIRST LANGUAGE ACQUISITION (3 points) Explain the three main theories of first language acquisition as we have studied them in this course (do not include Piaget as one of them). What are the limitations of the first two theories? How does the third better reflect the way we understand the acquisition of a first language? The three main theories of first language acquisition we have studied in this course are the following: Behaviorist Theory: States that first language acquisition is the resultRead MoreThe s Theory On Language Acquisition Essay1365 Words   |  6 Pagesclosing your eyes when exposed to extreme brightness, one of the most unique human instincts is language. Language is the system in which humans can communicate amongst each other, an incredible phenomenon, and yet for many years psychologists and scientists have yet to come up with one set theory as to how we acquire the languages we have. There are two fundamentally different theories on language acquisition that I will be presenting, the first by linguist Noam Chomsky and the second by psychologistRead MoreSecond Language Acquisition Theories1239 Words   |  5 Pagessee themselves as volunteer ‘tutors’ but rather as English buddies to their young ELL partners (see p. 175). Why would the researchers insist on this subtle, but real, shift in the identity of the volunteers? Discuss at least two second language acquisitio n theories that could plausibly be guiding the researchers. In Latino Children Learning English-The Steps in the Journey by Guadalupe Valdes, Sarah Capitelli, and Laura Alvarez we look the colleagues looking at the range of affordances on pageRead MoreTheories in Second Language Acquisition1470 Words   |  6 PagesThere has been a lot of research in Second Language Acquisition and there has many theories in this field. Since the 1970s more scholars have been very keen to explain the acquisition process. Particular attention has been given to the way we process information and this involves input and output. The major debate on this subject is what takes place in between the two stages. This essay will consider the contributions made by each of the above named scholars on the models of SLA. They each have theirRead MoreThe Theories Of Child Language Acquisition1963 Words   |  8 PagesThe great debate in theories of child language acquisition involves the initial stage of language learning. This is also called the nature versus nurture de bate, where some theorists argue that children naturally acquire linguistic skills from simple exposure to language. Others claim that it requires more deliberate teaching and education; it is not a merely natural phenomenon. In addition to the main stages of language acquisition, I hope to offer summaries of the key debates in the scholarly fieldRead MoreTheories Of Primary Language Acquisition2337 Words   |  10 PagesTwo theories of primary language acquisition emerged from 1950s psychological research: B.F. Skinner’s behaviorist theory and Noam Chomsky’s biological theory of language development. Primary language acquisition addresses specifically the way in which an infant’s native language is beginning to form, starting at birth. Primary language acquisition continues to develop throughout the rest of childhood within the critical period. Skinner argued that children acquire and develop language based purely

A Study On Metabolism Unfolded - 1733 Words

Metabolism unfolded Damian Sowa Institutional Affiliation(s) Integrity Disclaimer I certify that the work presented here is my own. I have cited sources appropriately, have paraphrased correctly, and have written the work myself. I have not shared my work with other students currently enrolled in any other courses at Greenville Technical College or papers previously written for any Biology course. Bio 101-B01 April 5, 2017 Name section date Abstract Metabolism includes all activities by which cells acquire and use energy as they build, break down of remodel organic molecules. The research done in the articles were on how metabolic syndromes affect the studied groups. The groups are studied over a period of time and†¦show more content†¦This study used 14 obese subjects, MRI determination of subcutaneous fat and plasma glucose, insulin. The results of that study was a significant correlation was observed between the amount of subcutaneous fat loss and the percentage reduction in both TNF-a, and IL-6 plasma levels (Formoso et al., 2012, p. xx). Metabolism unfolded We take a lot of consideration in the calories that we intake and how different types of food affect us. Some people use exercise as a way to combat the effect of caloric intake, while some people fast, what these people are trying to do is change how their bodies metabolism functions. What these three completely different experiments have in come is trying to find a solution of how people can eat and exercise for that metabolism to generate that body and keep it healthy while changing something like diet. Metabolism Defined Metabolism is all of the enzyme-mediated chemical reactions by which cells build and break down organic molecules; the body has metabolic pathways which are series of enzyme-mediated reactions by which cells build, remodel, or break down organic molecules. While some metabolic pathways are linear, which means that it goes in order from reactant to product. While other metabolic pathway reactions are cyclic, in cyclic normally the first requires the last step to precede it. Both pathways are common in cells, both involve thousands of molecules and are quite complex.Show MoreRelatedFactors That Affect The Cell Of Mitochondrial Proteins And Enzymes Of Electron Transport Chain2163 Words   |  9 Pagesresponse to stress. Mitochondria are deemed ‘endogenous stress detectors’ as they can sense stresses induced by high reactive oxygen species (ROS) levels and oxidative stress, membrane depolarisation, cellular energy levels, and an accumulation of unfolded proteins [5]. 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Taxation Tax Avoidance Includes Transactions

Question: Describe about the Taxation for Tax Avoidance Includes Transactions . Answer: 1. a) Reason for enacting section 260 of the ITAA 1936 Tax avoidance includes transactions that are undertaken with the aim to reduce the tax liability without committing any taxation or criminal offence. Tax avoidance can be conducted in multiple ways such as reducing assessable income, increasing the deductions, manipulating the structure of the business, manipulating the nature and type of transactions[1]. This tax avoidance are addressed by imposing various legislative limitations and provisions. The Income Tax Assessment Act 1936 is enacted by the parliament of Australia and it is one of the important legislation under which the income taxes of the individuals and the entities are calculated. In the society, tax is generally considered as a burden and many individual and entities seek legal means to avoid or reduce tax liability[2]. Therefore, section 260 of the ITAA 1936 is important because it provides general provisions relating to anti avoidance of tax. The section 260 of the ITAA 1936 states that the arrangement, contract and a greement that either is made orally or by writing is void if it is made for the following purpose: In order to alter the incidence of the income tax; In order to mitigate any person from the liability to pay tax or provide return; In ordered to avoid, evade and defeat any law that is imposed by this act; In order to prevent the implementation of the act; The section 260 in simple words make void any agreement, contract or arrangement that is made for the purpose avoiding tax. The section 260 along with the section 25(1) and the section 51(1) is very important for the tax planner. Therefore, from the above discussion it can be seen that the section 260 of the ITAA 1936 is the most important section that prevents avoidance of tax and helps to maintain the tax equity[3]. Therefore, it can be concluded that the reason for enacting section 260 is to provide deterrence to tax avoidance. Shortcomings of Section 260 of the ITAA 1936 The section 260 of the ITAA 1936 is a very simple and plain anti avoidance section. This has lead to a boarder interpretation and application of the section then it was initially intended. The shortcomings that ultimately lead to the replacement of this section as a principle anti avoidance rules are given below: Literal interpretation of the section The high court of Australia has always adopted a literal approach in the interpretation of the tax statues. This approach of law interpreting the provisions of the law came from the former Chief Justice Sir Owen Dixon of the High court of Australia[4]. However, in the recent years the literal approach of interpreting law has come into questioning due to its impact on the tax decisions. In 1921 in the case of Federal Commissioner of Taxation V Purcell, the CJ Knox said that section 260 of the ITAA 1936 if interpreted literally would apply to every transaction that has an effect of reducing the taxable income of the taxpayer. In the case of Federal Commissioner of Taxation V Westraders Pty limited, it was said in the judgment that if the provisions of the tax acts are applied literally then it is an open invitation to artificial and contrived tax avoidance. The judgment of the Cooper Brookes Pty V Federal Commissioner of Taxation 81 is a hint that Australian judiciary is moving away fr om the literal interpretations approach[5]. The other cases in which the judgments are made not based on literal interpretation of statue are Federal Commissioner of Taxation V Liberty 81, Ure V Federal Commissioner of Taxation 81, Deane and Croker V Federal Commissioner of Tax 82[6]. The principle of Choice In accordance with the principle of choice if the provisions of the act gives the taxpayer the two alternatives then in such cases the taxpayer can choose the alternative in which the liability to pay tax is less without worrying about the application of section 260. In the case of W P Keighery V Federal Commissioner of Taxation, it was held that the section 260 is not applicable to companies that have rearranged its operation to become the public company in order to avoid the private company taxation under Division 7[7]. The choice principle was first mentioned in the case of Clarke V Federal Commissioner of Taxation (1932). This principle of choice was approved in the subsequent cases of Federal commissioner of Taxation V Casuarina Pty ltd 71, Mullens V Federal commissioner of Taxation 76 and Cridland V Federal Commissioner of Tax 77[8]. In the Cridlands case, the principle of choice was extended and it was stated that the section 260 would not apply in cases where the taxpayer spe cifically adopts a particular option in which the provisions bestows fiscal advantage to the taxpayer[9]. The choice principle is the most important factor that destroyed the effectiveness of the section 260. In the Cridlands case the section 260 was rejected as the judgment stated that the Section 260 is a difficult provision inherited from earlier legislations and long overdue for reform by someone who will take the trouble to analyze his ideas and define his intention with precision before putting pen to paper. This judgment virtually rejects the application of section 260 and the principle of choice has destroyed the section 260[10]. Section 260 is a provision that does not have the power to reconstruct The section 260 had a serious limitation that it does not authorize the commissioner to make hypothetical reconstruction. The application of section 260 would not affect the incidence of tax unless there is a situation of antecedent transaction. Therefore, it can be said that the tax incidence remains unchanged unless it is exposed by the relevant facts that there exists situations that shows that the liability will arise[11]. Therefore, the above discussion has highlighted and critically analyzed the shortcomings of section 260. b) Has the problem with section 260 been mitigated by adoption of Part IVA The Part IVA was introduced to replace section 260 and to overcome the problems that was identified by the judicial decisions. It includes provisions relating to anti avoidance of tax and this are comprised in the section of 177A to 177G[12]. The provisions of the Part IVA are only applicable if the following three conditions are satisfied they are: The scheme must be entered into after 27th May 1981; The scheme is that which is defined under section 177A(1) and (3); The scheme must be carried out for obtaining tax benefit; The tax benefit must be obtained by the taxpayer; In the case of Blackman V Federal Commissioner of Taxation (1993) and Osborne V Federal commissioner of Taxation (1995) it was held that all the elements needs to be satisfied before application of Part IVA[13]. It is not only the commissioner but also the courts and tribunals are also required to inspect each of the elements and if any of the elements is not considered then it will be considered as an error of law. The part IVA was introduced to replace the section 260 of the ITAA 1936[14]. In order to evaluate whether the Part IVA has successfully overcome the problems of section 260 it is important to analyze each of the limitation of section 260. The judicial opinion has shifted away from the literal interpretation of the provisions of the act as was indicted in the Cooper Brookes case. There are numerous other decisions from the lower court to federal court that has shifted the opinion. In the case of Federal Commissioner of Taxation V Students World (Australia) Pty limited, it is stated in the judgment that legislature should introduce legislations in order to overcome the avoidance of tax and the court should provide wide interpretations so that the legislations could attain their objectives[15]. The section 260 is destroyed due to the application of the choice principle. As a result, the dominance of Lord Dennings Prediction test that is applied for section 260 is also expelled. The application of choice principle is surmounted by the introduction of Part IVA and especially by the adoption of statutory prediction Test as per section 177D of the act[16]. The word expressly is used in the section 177C (2) (a)(i) and (b) (i) and the word choice is not used in section 177(2) and (3). This is a clear indication that the choice principle should not be used in the application of Part IVA and particularly while conducting the statutory prediction test for scheme related to avoidance of tax[17]. In order to overcome the problem of section 260 in Part IVA under section 177F reconstruction powers are provided and under section 177G the powers are provided to the commissioner to amend the assessment. The powers that are provided to commissioner under section 177G are extensive and wide. These wide powers of commissioners are necessary in order to have an effective provision for reconstruction[18]. The Garfield Barwick developed the antecedent transaction principle because of which the section 260 was applicable only to limited circumstances. The statutory prediction test and other provisions of Part IVA is adopted to ensure that the application of the principle is discontinued[19]. In Pat IVA, there is no specific exclusion of the ordinary business or family dealings but the government has decided to hold back the application of the provisions of Part IVA in the mentioned circumstances. Therefore, from the above discussion it can be concluded that the adoption of Part IVA has successfully overcome various shortcomings of section 260. Difficulties of Part IVA The Part IVA has many limitations that have narrowed the scope of its applicability. The elements of Part IVA are considered to identify its difficulties: Part IVA is only applicable to scheme and not on sub scheme The section 177A (1) defines Scheme as any agreement, arrangement, understanding, promise or undertaking, whether expressed or implied and whether or not enforceable or intended to be enforceable by legal proceedings and any scheme, plan, proposal, action, course of action or course of conduct. The definition of Scheme is very wide and one of the elements for the application of Part IVA is satisfied. The scheme that has been identified should also satisfy the other elements so that Part IVA is applicable[20]. There are various court cases that have stated that it is not sufficient if only a part of the scheme that is a sub scheme satisfies the all the elements of the Part IVA. It should be noted that it is difficult to assess whether the dominant purpose of the scheme is to avoid tax or to take legitimate profit-making transaction. In the case of Federal commissioner of Taxation V Peabody (1994), the difference between a scheme and a sub scheme is highlighted. It is stated in the cas e that a scheme as opposed to a sub scheme should be able to stand in their own even if it is robbed of all practical meaning. It was given emphasis in the case of Spotless Service limited V Federal Commissioner of taxation (1995) that the definition of the scheme as provided in section 177A requires that the parties to the scheme must be identified[21]. The case also states that the terms and conditions along with the steps for particular course of action that are relevant for the purpose should be identified. The definition of scheme as provided in Part IVA does not state that a scheme includes a part of the scheme so in spite of wide definition of scheme the part of the scheme should not be considered as a scheme in itself as per the case of Federal commissioner of Taxation V Peabody (1994). In the case of Peabody V federal commissioner of Taxation (1994), it was held that if a scheme comprises of a series of steps then individual steps that are part of the scheme could not be co nsidered as a scheme in itself[22]. Relevant taxpayer should be the person obtaining the tax benefit The relevant taxpayer may be defined as an individual that has obtained tax benefit from the scheme as defined under section 177D. Therefore, the idea of taxpayer is interrelated with the idea of tax benefit as provided in section 177C. In the case of Peabody V Federal commissioner of Taxation (1992), it was held that the relevant taxpayer could not be chosen arbitrarily as it is governed by section 177C (1). The relevant taxpayer in section 177D should be the same person should be the same person who is a taxpayer in section 177C as held in the case of Peabody V Federal Commissioner of Taxation 1992[23]. Tax benefit The section 177C (1) defines tax benefit as the non inclusion of an item that would otherwise be included in the taxpayers income and it also includes that deduction that is otherwise not allowable is allowed only for the purpose of the scheme. The other tax benefits like rebate or credit is not included within the definition of tax benefit therefore it is not part of Part IVA as held in the case of Peabody V Federal commissioner of Taxation 1993. There is certain limitation that affects the scope of the idea of tax benefit. As per section 177C (1) before Part IVA is applied it is important to ascertain with certainty that the income should have been derived or the deduction is not allowed only for the tax avoidance scheme. In the case of Peabody V Federal Commissioner of Taxation 1993 it was held that the section 177C (1) (a) requires that not only possibility but also reasonable probability should have been existed that the income would have been derived by the taxpayer[24]. This r equired test to predict the event that would have occurred if the scheme were not applicable and the prediction should be reliable in order to be reasonable. In the case of Peabody V Federal Commissioner of Taxation 1994, it was seen that the idea of tax benefit was decisive in concluding that the part IVA is not applicable. Therefore it can be seen that in section 177C (2) there are certain elements of section 260 that has rendered it ineffective like antecedent transaction test and the choice principle. Purpose of obtaining the tax benefit The section 177D provides that the person should have entered into the scheme in order to enable the taxpayer to obtain the tax benefit. The person as mention in the section may or may not be the taxpayer. In the case of Federal commissioner of Taxation V Consolidated Press holdings Ltd 1999 it was held that the purpose mentioned earlier must exist at the time of entering the scheme[25]. In the case of Federal commissioner of Taxation V Spotless Service Limited 1996, it was held that the dominant purpose is the purposes that are most influential and prevailing or ruling purpose. Therefore, the dominant purpose should be determined through the objective consideration as was held in the case of Peabody V federal Commissioner of Taxation 1993[26]. Therefore, from the above discussion it can be concluded that the Part IVA has its own limitations. The Part IVA has been able to successfully overcome the shortcomings of section 260 but it has given rise to difficulties of its own. 2. In Australia, the Income Tax Assessment Act 1997 is an important legislation that governs the computation of the income tax that is required to be paid by the taxpayer. In section, 4-1 of the ITAA 1997 it is stated that income tax is required to be paid by each individual, companies and other entities. The ITAA 1997 in Division 7 has classified income as ordinary income and statutory income. The section 6-5 (1) states that assessable income of the taxpayer should income according to the ordinary concept. The ordinary income is further classified into income that are received from personal exertion, income received from profit making schemes and income received from property. The section 6-10 of the ITAA 1997 states that the incomes that are not ordinary income are the statutory income and this income should also be included in the assessable income. On analyzing the section 6-5 and section 6-10, it can be seen that in case of Australian resident income derived from all sources whe ther received directly or indirectly should be included in the assessable income. The section 6-5 and 6-10 of the ITAA 1997 also states that in case of foreign resident the income that are received from the sources within Australia should be included in the assessable income[27]. On analyzing the sections, it can be seen that the assessable income changes depending on the residential status of the taxpayer. Therefore, it is important to ascertain the residential status of the taxpayer before determining the taxable income. In the case of Federal Commissioner of Taxation V Applegate 1979, it was held that the residential status is determined by facts and it is an important criteria that is essential in determining the liability of the taxpayer. Therefore, the residential status should be determined on a year-to-year basis. The term Australian resident is defined in section 995-1 of the ITAA 1936 and it means an individual that is a resident of Australia. The Taxation Ruling 98/17 in Para 12 it is stated that if according to the ordinary concept an individual resides in Australia then other tests are not required to be conducted. If the individual is not an Australian resident then other tests should be considered for determining the residential status of the individual. The Para 32 of the Taxation Ruling 98/17 provides four tests for determining the residential status of the tax payer they are residency as per the ordinary concept; the domicile test; the 183 day tests and the superannuation fund test. I f the taxpayer fulfills any of the above tests then the taxpayer should be considered as a resident. In accordance with the first test if an individual resides in Australia, then the individual is considered as a resident taxpayer. The second test is the Domicile test and it states that an individual is considered as resident if the permanent place of abode is in Australia[28]. The third test is the 183 days test and it states that if an individual stays in Australia with or without break for 183 days or more then the individual will be considered as resident for the purpose of tax. It is to be noted that 183 days test is not applicable if the taxpayer is planning to have a place of residence outside Australia or it is established that the taxpayer is not willing reside in Australia. Then lastly, the superannuation tests are applicable to the government employees that are working abroad so that they can be treated as a resident for the purpose of tax. In this case lucky came to Australia in 2013 for studying. The lucky continued to stay in Australia for studying from February to November during the year 2013 to 2015. In the first two years lucky stayed in the campus, in June 2016 took permanent residence status of Australia. During the stay in Australia Luck received dividend income and the fess. Here in this case it is to be determined whether lucky is required to pay income tax in Australia. In order to ascertain this firstly it is required to determine the residential status of Lucky. As Lucky is born in, New Zealand so cannot be as considered as resident according to the ordinary concept. In the financial year 2013-14, 2014-15 and 2015-16 Lucky did not have a place of abode in Australia so Lucky is not a resident as per Domicile test. Therefore, the residential status of lucky is verified using the 183-day tests. The 183-day test requires the taxpayer to stay in Australia for 183days or more the calculation given below shows t hat Luck has stayed in Australia for 150 days during 2013-14, 303 days for 2014-15 and 153 days for 2015-16. Therefore, it can be concluded based on 183 days test that Luck should be considered as resident for the purpose of tax during the year 2014-15. During the year 2013-14 and 2015-16 Lucky should be considered as foreign resident for the purpose of tax. In the year 2014-15 as Lucky is considered as resident for the purpose of tax so the dividend income of $1200.00 and the fees that are received for the articles are taxable in Australia. In section 6-5(3) it is stated that if the income is received from Australian sources then in case of foreign resident it should be included in the taxable income. In the given case, the dividend income and the fees both are received from sources in New Zealand. Therefore, during the year, 2013-14 and 2015-16 the income received from dividend and fees are not taxable in Australia. In the case, it is also stated that after June 2016 Lucky took pe rmanent resident in Australia so any income received after June 2016 is taxable in Australia. Statement showing calculation of 183 day tests Months Financial Year 2013-14 Financial Year 2014-15 Financial Year 2015-16 July 31 31 August 31 31 September 30 30 October 31 31 November 30 30 December January February 28 28 March 31 31 April 30 30 May 31 31 June 30 30 Total Days 150 303 153 Reference Al Haj, Tarek, 'The Influence of the New Jordanian Income Tax Law upon Collections' (2003) 19Journal of Economic and Administrative Sciences1. Azzi, John, 'Tax Law Design and Drafting : Comparing Income Tax Laws of the World' (2000) 18Berkeley Journal of International Law196. Barney, Douglas K. and Tonya K. Flesher, 'a Study of the Impact of Special Interest Groups on Major Tax Reform: Agriculture and the 1913 Income Tax Law' (2008) 35The Accounting Historians Journal71. Barton, GA, 'The Recognition of Foreign Currency Gains and Losses in Australian Income Tax Law' (2008) 34University of Western Australia Law Review1. Biek, John A., 'State Law State Taxation Corner: Constitutional Income Tax Nexus of Trusts (Part II)' (2014) 17Journal of Passthrough Entities51. Buckles, Johnny Rex, 'The Case for the Taxpaying Good Samaritan: Deducting Earmarked Transfers to Charity Under Federal Income Tax Law, Theory and Policy' (2002) 70Fordham Law Review1243. Buss, David, David Hryck and Alan Granwell, 'The New Chinese Enterprise Income Tax Law: A Summary and Planning Strategies' (2007) 85Taxes: The Tax Magazine13. Cao, Fuli,Corporate Income Tax Law and Practice in the People's Republic of China(Oxford University Press, 2011) Changes to the Illinois Income Tax Laws' (2008) 96Illinois Bar Journal506. Cheng, Suwina and Shanshan Shi, 'The Impact of New Income Tax Law on Foreign Invested Enterprises in China' (2012) 38International Tax Journal17. Farr, Albert D., 'Taxation of Marine Shipping Income: A Critique of U.S. Tax Laws in the Energy Transport Industry' (2014) 39Tulane Maritime Law Journal221. Geier, Deborah A., 'simplifying and Rationalizing the Federal Income Tax Law Applicable to Transfers in Divorce' (2002) 55The Tax Lawyer363. Geisler, Gregory G., 'Federal Income Tax Laws that Cause Individuals Marginal and Statutory Tax Rates to Differ' (2013) 31Journal of Accounting Education430. Haj, Tarek Al, 'The Influence of the New Jordanian Income Tax Law upon Collections' (2003) 19Journal of Economic and Administrative Sciences1. Holland, David T., 'Tax Law - U.K. Windfall Tax Constitutes U.S. Income Tax Under I.R.C. 901 - PPL Corp. v. Commissioner' (2014) 47Suffolk University Law Review683. Kristanto, Priyohandojo, 'Indonesia's New Income Tax Law and its Impact on Business: Prijohandojo Kristanto Discusses Indonesia's New Tax Law, which Took Effect this Year. the Tax Law is Expected to Ease the Burden of the Income Tax and Help the Directorate General of Taxation to Widen its Tax Base' (2009) 10Corporate Business Taxation Monthly31. Levine, M.L. 2002, "CRE perspective: complexity in the federal income tax law",Real Estate Issues,vol. 27, no. 1, pp. 36. Likhovski, Assaf, 'Is Tax Law Culturally Specific? Lessons from the History of Income Tax Law in Mandatory Palestine' (2010) 11Theoretical Inquiries in Law1. McBride, Narelle, 'Taxation Law: Australian Income Tax Consolidation Regime - Retrospective Evolution' (2010) 62Keeping Good Companies245. Prebble, John, 'Justice Hill and the Autopoiesis of Income Tax Law' (2013) 28Australian Tax Forum7. Seidman,Seidman's Legislative History of Federal Income and Excess Profits Tax Laws 1953-1939(s.n.) Seidman,Seidman's Legislative History of Federal Income Tax Laws 1938-1861(s.n.) Sharkey, Nolan Cormac, 'China's New Enterprise Income Tax Law : Continuity and Change' (2007) 30University of New South Wales Law Journal, The833. Sivadasan, Jagadeesh and Joel Slemrod, 'Tax Law Changes, Income-Shifting and Measured Wage Inequality: Evidence from India' (2008) 92Journal of Public Economics2199. Stebbings, Chantal, 'Popular Perceptions of Income Tax Law in the Nineteenth Century: A Local Tax Rebellion' (2001) 22The Journal of Legal History45. 'Tax Law: Zambia: Income Tax (Amendment) Act (Government of Zambia Act no. 1 of 2005)' (2005) 31Commonwealth Law Bulletin115. Zelenak, Lawrence, 'Custom and the Rule of Law in the Administration of the Income Tax' (2012) 62Duke Law Journal829. Zollo, Thomas M. et al, 'Chinese Procurement Under the New Enterprise Income Tax Law' (2007) 33The International Tax Journal39.

Mary, Nickname Bloodymary, 1St Person Essays - Anti-Protestantism

Mary, Nickname: Bloodymary, 1St Person Mary the first was born on FEB. 18. 1516 at GREENWICH PALACE. I WAS THE DAUGHTER OF HENRY THE 8 AND CATHRINE THE FIRST OF ARGON. I WAS A GOOD STUDENT AND ACCOMPLISHEND LINGUIST. I LEARNED LATIN, FRENCH, SPANISH, ITALIAN, AND GREEK. I STUDIED ASTRONOMY, NATURAL SCIENCE, AND MATH. I PLAYED MUSIC, DANCED, AND EMBROIRED. MY FATHER WANTED ME TO MARRY MY HALF BROTHER BUT I DIDNT BECAUSE HE WOULD HAVE HAD TO NILLUFY HIS MARRIGAGE WITH MY MOTHER. I didnt like my fathers second wife b/c I FELT SHE WAS TRYING TO TAKE THE PLACE OF MY MOTHER. I WAS FORCED OUT OF MY HOUSE, AND SENT TO LIVE WITH MY SISTER ELIZABETH. B/C OF THIS I LOST MY TITLE OF PRINCESS, AND WAS DECLARED ILLIGITAMATE. LATER I TOOK AN OATH OF SUPREMACY, AND WENT BACK TO THE PALACE AND ONCE AGAIN BECAME CLOSE TO MY FATHER. WHEN I MOVED BACK I BECAME THE GOD MOTHER OF MY HALF BROTHER EDWARD. BECAUSE OF THE PARLIMENTARY ACT I WAS RESTORED TO THE ROYAL SUCCSSESION. WHEN MY BROTHER DIED IN 1553 I BECAME QUEEN. I WAS AN ATTRACTIVE WOME N WITH A STRONG DEMEANO, AND DIDNT LET PEOPLE UPSET ME. I HAD PRO-CATHOLIC AND PRO-SPANISH POLICES, AND I RESTORED THE CATHOLIC CHURCH. I MARRIED KING PHILIP THE SECOND OF SPAIN. THE ANNOUNCEMENT OF MY MARRAGE CAUSED CHANGES IN THE GOV'T. I DIDNT LIKE HERETICS- PEOLE WHO HELD AN UNORTHADOX OPINION, AND SPOKE OUT ABOUT IT. ABOUT 3000 PROMINANT PRODISTANTS WERE BURNED AT THE STAKE, THIS IS HOW I GOT THE NICKNAME BLOODYMARY. PHILIP LEFT ENGLAND FOR 10 MONTHS AND CONVINCED ME TO JOIN SPAINS WAS AGAINST FRANCE. I BECAME DISSAPOINTED IN PHILIP B/C HE FOUGHT IN THE WAR AND I FELT THAT HE SHOULD HAVE BEEN ABLE TO WIN THE WAR, AND ALSO B/C I WASNT ABLE TO PRODUCE AND HEIR TO THE THRONE. I DIED FROM NATURAL CAUSES ON NOV. 25, 1588. I WAS ALWAYS TRUE TO THOSE FAITHFUL TO ME. AND I WILL BE REMEMBERED AS THE LAST SUCCESSFUL TUDOR SOVERIGN. History Reports