Taxation of gains from banking and insurance businesses in New Zealand

There has been major contest over the taxation of business income. Questions are twofold: the factual one of defining the boundaries of the business activity. Second, that of determining whether a particular gain comes within the ambit of ‘business’. Recent NZ cases have sought to apply the guiding principle - that it is not the size of the gain but the source of it that determines the taxation consequences. Logically, this principle should apply to specialist businesses such as those dealing with banking and insurance. However, the NZ Commissioner has, until 10 years ago, argued that it is the size rather than the source of the gain that is the determining criterion. And since the questions of what is the scope of the particular business activity and whether the particular gain has arisen in the course of such activity are purely factual ones, they are to be guided by the facts of each case. This article concludes that the decisions are indeed based on their particular facts. Further, it investigates how important it is for the taxpayer to ponder the strategy that is to underpin the particular business. The evidence of such strategy being in place and having the practical effect of guiding the decision making of the taxpayer company’s business activities are highly significant in determining the taxation consequences of such decision making. The consistency with which such corporate strategy or policy is formulated and implemented tends to determine their taxation consequences

Solicitors’ personal undertakings for taxation obligations and the implications for solicitors: the New Zealand experience

The Commissioner of Inland Revenue (the Commissioner) is an officer of the Crown, charged by statute with the function of care and management of taxes on behalf of the Crown. In carrying out his statutory function of collecting taxation revenue, the Commissioner is legally obliged to fulfil this role by collecting over time the highest net revenue that is practicable within the law, in relation to the resources available, the importance of promoting taxpayer compliance and the compliance cost of taxpayers. It is pursuant to the exercise of this statutory discretion that the Commissioner is authorised to enter arrangements with taxpayers or their agents for the eventual payment of taxation indebtedness. Such arrangements may include agreements between the Commissioner and taxpayer for the payment of taxation debts by instalments. Worth noting however, is that the Commissioner has recently demonstrated a willingness, not only to accept solicitors’ personal undertakings for the payment of tax debts, but to enforce them when solicitors have chosen to dishonour them

Path Planning for Cooperative Routing of Air-Ground Vehicles

We consider a cooperative vehicle routing problem for surveillance and reconnaissance missions with communication constraints between the vehicles. We propose a framework which involves a ground vehicle and an aerial vehicle; the vehicles travel cooperatively satisfying the communication limits, and visit a set of targets. We present a mixed integer linear programming (MILP) formulation and develop a branch-and-cut algorithm to solve the path planning problem for the ground and air vehicles. The effectiveness of the proposed approach is corroborated through extensive computational experiments on several randomly generated instances

Path Planning for Multiple Heterogeneous Unmanned Vehicles with Uncertain Service Times

This article presents a framework and develops a formulation to solve a path planning problem for multiple heterogeneous Unmanned Vehicles (UVs) with uncertain service times for each vehicle--target pair. The vehicles incur a penalty proportional to the duration of their total service time in excess of a preset constant. The vehicles differ in their motion constraints and are located at distinct depots at the start of the mission. The vehicles may also be equipped with disparate sensors. The objective is to find a tour for each vehicle that starts and ends at its respective depot such that every target is visited and serviced by some vehicle while minimizing the sum of the total travel distance and the expected penalty incurred by all the vehicles. We formulate the problem as a two-stage stochastic program with recourse, present the theoretical properties of the formulation and advantages of using such a formulation, as opposed to a deterministic expected value formulation, to solve the problem. Extensive numerical simulations also corroborate the effectiveness of the proposed approach.Comment: 8 pages, 2 figures, submitted to International Conference on Unmanned Aircraft Systems (ICUAS

PRARANCANGAN PABRIK EKOSEMEN DENGAN KAPASITAS 100.000 TON/TAHUN

Prarancangan pabrik Ekosemen ini menggunakan Batu Kapur dan Abu insinerasi sebagai bahan baku. Kapasitas produksi pabrik Ekosemen ini adalah 100.000 Ton/Tahun dengan hari kerja 330 hari/tahun. Tahapan proses yang digunakan untuk memproduksi ekosemen meliputi : (1) Persiapan bahan baku, yaitu meliputi pengecilan ukuran, (2) Homogenasi bahan baku, (3) Pembakaran dan pendinginan raw mix dan (4) Penggilingan klinker dan pengepakan ekosemenBahan bakar batu bara jenis subituminus digunakan untuk mencapai temperature proses di dalam kiln. Bentuk perusahaan yang direncanakan adalah Perseroan Terbatas (PT) dengan menggunakan metode struktur garis dan staf. Kebutuhan tenaga kerja untuk menjalankan perusahaan ini berjumlah 132 orang. Lokasi pabrik direncanakan didirikan di Desa Batu Itam, Kecamatan Tapak Tuan, Kabupaten Aceh Selatan, Provinsi Aceh dengan luas tanah 113.000 m2. Sumber air pabrik Ekosemen ini berasal dari Sungai Alur Panjupian, Desa Batu Itam, Kabupaten Aceh Selatan, Provinsi Aceh dan untuk memenuhi kebutuhan listrik diperoleh dari generator sendiri dengan kapasitas sebesar 10.065 MWHasil analisa ekonomi yang diperoleh adalah sebagai berikut:1.Fixed Capital Investment= Rp.1.150.749.753.9542. Working Capital Investment= Rp.203.073.485.9923. Total Capital Investment= Rp.1.353.823.239.9464. Total Biaya Produksi= Rp.634.354.277.4005. Hasil Penjualan= Rp.1.999.999.584.0006. Lababersih= Rp.1.024.233.979.9507.ROR= 75,655

HRM Practices and Their Effects on Employee Performance: A Survey of Selected Hyderabad IT Companies

Human resource management (HRM) refers to the process of making effective use of an organization's workforce in order to achieve its strategic goals. An organization needs human resources to carry out a variety of business operations, and it must utilise these resources extremely effectively. The primary goal of this study was to investigate the impact that human resource management methods have on the organizational performance of companies operating in the information technology industry. We gathered the study's information using a standardised questionnaire. The target population members for this study were the employees at IT companies in Hyderabad. We used the SPSS software to perform quantitative data analysis. The study's findings indicated that human resource management methods have a significant impact on the functioning of organizations that are part of Hyderabad's IT companies. Because employees have a positive perception of HRM procedures, this research also shows that improvements in the organization have led to a decrease in human errors and an increase in product growth