The Preprogrammin of a Child Essay -- essays research papers

A youngster is a clear book and a parent is the pen. A parent or senior says something or makes a move, and a youngster regularly will react by emulating what has been said or done. The quintessence of a youngster is one of honesty just as guilelessness. Grown-ups fill in as a plenitude of information, rules, and guidelines, which a kid should live and submit to. Not all youngsters will comply with the guidelines expected of them, yet certain standards are more basic than others. While teaching kids, guardians and grown-ups take rules relating to sex determinations considerably more truly than most different subjects of acquiescence, without recognizing they are rehearsing such practices. Sexual orientation differentiations are clear inside the manner in which kids are addressed, how they are treated in specific circumstances, and the toys they play and interface with. At last in a media driven society, for example, America, it would be almost difficult to bring up a youngster libera ted from sexual orientation generalizing. Through the span of later years the particular sex characterized universe of toys has been diminished, yet a large portion of these generalizations despite everything appear to have all the earmarks of being engrained into a child’s mind nearly from birth.      As ahead of schedule as the introduction of a youngster there are indicated sexual orientation detachments. When conceived, a youngster is recognized by either the shading blue or pink. You can see a pink stork on the corner for another infant young lady or a blue stork for another child kid. Obviously these hues are not fathomable to the youngster, yet kids all through the remainder of the local view these signs. A parent may say something relating to the neighbors having another child kid just in light of a blue sign. This could be one of the underlying oblivious remarks a parent or grown-up may make, which ingrains such convictions that shading characterizes sex. All through youthfulness it is an irregularity to see a little fellow wearing a pink shirt, in light of the fact that there is a disgrace related with a little fellow wearing the shading pink. We take such an insufficient idea, a shading, and spot behind it preference. Later on in life wearing the shading p ink can invoke suppositions of homosexuality. These decisions have no approval to them, aside from the shame American’s related with this shading all through youth encounters and understandings.      Another case of the accentuation of shading on sexual orientation can be aimed at the legos toy.... ...bsp;Children are clear books who need course; clearly guardians are not by any means the only ones holding the pen to direct their insight. Different grown-ups, friends, and society go ahead in denoting their region. So as to bring up a kid liberated from sexual orientation generalizations, that kid must be self-taught, not permitted to engage themselves with most perusing material accessible, and couldn't be allowed to associate with anybody outside their â€Å"regulator.† The manner by which society has been built limits the degree of restriction accessible outside the home. As it were this general public has such a huge measure of sex generalizations inside each part of the outside world that it would be just about difficult to out run their effect. In a perfect world every individual ought to have the option to move beyond what society directs, yet it is a lot simpler to fall into the snare of acknowledgment. It is extremely hard to march a kid of two years of age, in a pink outfit without feeling the gaze of dissatisfaction from untouchables. Individuals must utilize the term acknowledgment instead of rejection, on the grounds that the most noticeably terrible persecution is what is set on a kid who doesn't have the capacity to get their decisions.

Research in Consumer Behavior Customer Service Problems

Question: Depict about a Research in Consumer Behavior for Customer Service Problems? Answer: Presentation So as to accomplish the elevated level of achievement in the business, the associations need to comprehend the necessities of the clients to give the better administrations than them. All the business associations are attempting to comprehend the conduct of the clients for giving them best administrations. A wide range of business associations are confronting immense rivalries in the current market as there are numerous organizations with similar kinds of items or administrations (Sashi 2012). The opposition is running over the pace of consumer loyalty and the organizations are attempting to get the ideal degree of accomplishment by giving the best client administrations among the contenders. The issue is that all the business associations can't offer the types of assistance in the degree they are anticipating. The explanation for this issue is the disappointment of understanding the clients necessities. Various reasons of confronting issue in giving the client administrations will b e talked about in this report (Paul and Rana 2012). Less fixation in the aggregate data from the clients One of the significant reasons of confronting issue in giving the unrivaled degree of client support is the absence of gathering in the aggregate data from the clients. As indicated by Hawkins (2012), it is difficult to anticipate what the clients are really thinking, however it ought to be accepted by watching the practices of the clients. The compelling recognition about the purchaser conduct can be created by social affair the important data from the clients. Around there, the assortment of pertinent aggregate data from the clients is significant. The hole with respect to the data is intense issue in the territory of client support. The corporate limited time techniques and ordinary advertising are not all that compelling today for gathering the important aggregate data from the clients. The suppliers can watch the clients who are in the store and ready to gather the data from them (Chen, Chen and Huang 2012). The issue is that the greatest clients of a business association are in the outside zone of the stores. In this situation, the suppliers believed that they are gathering the important data from the clients can comprehend their recognitions about the association. Along these lines, most extreme clients are not considered for the aggregate data. Another issue is that more often than not, the purchasers are made a big deal about gathering the data just about the item and administrations. As per Belk et al. (2012), a proficient specialist co-op should accumulate data pretty much all points of view of their business and administrations from the clients. Around there, data about various kinds of approaches followed by the business association, execution norms and the security principles ought to be assembled to comprehend the client necessities. Don't concentrating on the client explicit structures Another significant territory of the client care issue is the planning of the items or the methodology utilized for offering the types of assistance to the clients. The situation of the current market has been changed and the new advancements have been shown up for various areas of the business tasks. In this manner, a large portion of the business associations are concentrating on the utilization of new advancements and imaginative thoughts for structuring the items or offering types of assistance to the clients (Sheth 2011). Here, regularly the business associations don't concentrate on the clients particulars. As per Mooij and Hofstede (2011), preceding applying any structures, the business associations should concentrate on the realities favored by the clients. Here, various sorts of decisions may originate from the clients end and the business associations may befuddled about the decision of the new structure. It has been discovered that the decision of the structures shifts ove r the sexual orientation and age of the clients. Along these lines, it's anything but a simple undertaking to create client explicit plans for the clients. Purchasers can't follow the client explicit structures for every single new item or administrations. So as to contending in the expanded market rivalry, the business associations are attempting to embrace inventive thoughts for the plans (Mazaheri, Richard and Laroche 2011). Here, the business associations ought to receive the particulars of the significant clients or in complex circumstances they can likewise embrace procedure of structuring configuration sorts of same items for various kinds of clients. Client explicit plans ought to be followed for not just the structures of the new items or administrations. The business associations ought to think about the clients determinations while structuring the hierarchical or business technique. Around there, the absence of client explicit structuring can be seen in the greater part o f the associations. As the fundamental thought process of every single business is to give the best client administrations, they should center in the client determinations while building up the promoting and business techniques (Lu 2011). Holes between the authoritative expectations and the client necessities In some cases, it tends to be discovered that the business associations neglect to meet their ideal degree of achievement due the holes between their goal and the clients necessities. In these kinds of cases, the clients can't comprehend that the associations are attempting to satisfy their necessities. It happens on account of an inappropriate techniques followed by the business associations. There is an immense hole between the speculations and the down to earth utilizations of the client administrations. It is hard to comprehend what the clients will like for the most part (Haucap and Heimeshoff 2011). The bleeding edge representatives of a business association are answerable for social event the fitting insights regarding their recognitions with respect to the administrations gave by the association. It has been discovered that the clients feel upset for giving inputs about the administrations gave by the business associations or a the new administrations they are attempting to c onvey, where these are assembled for satisfying their necessities (Solomon et al. 2014). It occurs because of an inappropriate methodologies picked for the correspondence. The real expectation of the business association ought to be productively conveyed to the clients. The expectation of satisfying the clients prerequisites isn't sufficient, the business associations need to comprehend the necessities of the clients first and afterward should choose a legitimate technique which can have the option to meet their goal (Oliver 2014). Around there, the business associations ought to build up a solid relationship with their clients. Once in a while this hole is created because of the wasteful preparing of the forefront representatives. So as to accomplish the ideal degree of progress, the business associations should give compelling preparing to the bleeding edge representatives about how to create solid relationship with the clients and comprehend the method of imparting the real goal of the associations through their administrations (Kardes, Cronley and Cline 2014). Holes between the aim and genuine conveyance of the administrations Another large issue of the client support is the contrasts between the aim of the association and the genuine items or administrations conveyed by them. It occurs because of the ineffectualness on building up the apparent item or administrations by the business associations. It has been discovered that numerous business associations has the aim of giving one kind of administration yet the administrations doesn't meet the necessities of their aim. It occurs because of the miscommunication among the representatives of the associations (Lantos 2015). So as to discard this hole, the business association ought to build up a worldwide technique straightforward to all the representatives of the business associations. All the representatives ought to convey a similar data about the administrations or items. So as to do this, the business associations need to give legitimate preparing to all the workers. They ought to convey the worldwide goals of the business and the viable method of satisfy ing the destinations by conveying the administrations which can meet the real aim of the association. So as to offer the types of assistance according to the aim of the association, they ought to comprehend the clients fulfillment rate from their administrations (Cermak, File and Prince 2011). It tends to be happen that an association believes that they are offering the types of assistance which can satisfy every one of their goals however the clients are not content with the administrations. These sorts of episodes are the reasons for client maintenance and disappointment of making benefit from some particular items or administrations. This issue ought to be dodged by the business association by propelling demo item or administrations for the clients. Along these lines, they can have the option to dispatch the full scope of items by understanding the interest of the clients or in the wake of making the important changes for satisfying the client necessities. A portion of the busine ss associations are utilizing the demo testing methodology for precluding the hole between the expectation and the truth of the administrations, however greatest are not utilizing which is a significant issue in the territory of client administrations gave by the associations (Brodie et al. 2011). Cost requirements or inability to satisfy the guidelines which can influence the administration quality Cost is the most significant truth of offering types of assistance to the clients. The clients are intrigued to get the prevalent quality items however they are additionally searching for the less bits of the items. The greater part of the business associations are battling about the costs of the items or administrations in this exceptional market rivalry (Liu, Guo and Lee 2011). It has been discovered that a portion of the business associations have neglected to give th

Lakota Sun Dance And The Sufi Whirling Dervis Religion Essays

Lakota Sun Dance And The Sufi Whirling Dervis Religion Essays Lakota Sun Dance And The Sufi Whirling Dervis Religion Essay Lakota Sun Dance And The Sufi Whirling Dervis Religion Essay In the Native American confidence, the genuine noteworthiness of the Sun Dance lies in the holiness and divinity that the custom itself speaks to. ( McLean 1889: 3 ) The Sun Dance is the cardinal one-year custom of the conventional Lakota confidence and removes topographic point from doorss throughout the late spring. ( Walker 1917: 12 ) The limitless of the custom move is hovered around a tree and is made with notice to main issues that model customary universe in the Lakota human advancement. ( Holler 1995: 23 ) The soul of the Sun Dance depends on relinquish, as all terpsichoreans have swore to persevere. From a fundamental perspective, this would influence moving in the Sun, without supplement or H2O, runing from two to four yearss. ( Holler 1995: 23 ) Extreme signifiers of relinquish include the penetrating and film altering of human fragile living creature and infixing sticks that are hence expelled to complete the relinquish. ( Holler 1995: 23 ) In looking at, Sufi Whirling is a custom move that is rehearsed among those of the Sufism religion so as to achieve a more grounded point of convergence on God. ( Trimingham 1998: 122 ) Sufism is characterized as the internal and supernatural element of Islam that accentuates the neglecting of individual self-significances and wants for the memory of God. ( Godlas 2001 ) The move itself underscores the cosmopolitan existence of the spaces, and central focuses on three physical procedures to achieve strict world: move, whirling and jumping. ( Trimingham 1998: 226 ) Both the Sun Dance and Sufi Whirling topographic point emphasize on the capacity of the Sun as a strict part of the custom move, however to various degrees. The mental encounters related with the formal examples of both the Sun Dance and the Sufi Whirling share much for all intents and purpose. The physical responses of the Sufi Whirling are multifaceted and influence a combination of various condition of affairss as they emerge from both dissociative variables and insouciant elements. Kenneth Avery states that ongoing grounds recommends that physical responses that point to a dissociative reason from profound inside the brain, for example, epileptic and daze like responses, speak to just the minority of such cases. ( Avery 2004: 230 ) However, the greater part of cases show that insouciant components are answerable for responses, for example, nervousness, dismay and enthusiastic discharge. ( Avery 2004: 230 ) It gives the idea that the mental encounters of the Sun Dance would be somewhat like those of the Sufi Whirling, generally because of the significant union of exercises between the two rituals. The two customs permit people and, pa rtly, witnesss to see an adjusted region of world, and since the Sun Dance other than uses exercises, for example, fasting and unshakable inflection, apparently it is ready to trip changes in cognizance to a much more noteworthy degree than the Sufi Whirling as it is well more. The Sufi Whirling as often as possible keeps going three to four hours while the Sun Dance can last wherever from two to four yearss. In this way, it tends to be reasoned that both the Sun Dance and the Sufi Whirling utilize comparable strategies, for example, fasting and articulating to change a man s area of cognizance and will let for comparable mental encounters. In any case, given that the Sun Dance can other than incorporate the utilization of baccy, pipes and the piercing of substance, apparently it is reasonable to envision a considerably more prominent mental result on take separating people. ( Avery 2004: 231 ) There are two similitudes between the Sun Dance and Sufi Whirling which merit a more noteworthy examination. Initially, the noteworthiness of the Sun in both these ceremonies ought to be noted. In the Sun Dance, the Sun maps as a sort of godlikeness, or higher capacity to which relinquishes are made. It is the accepting arrangement of all the Sun Dance speaks to ; the name of the custom itself features the way that the Sun is the point of convergence of the Sun Dance. In spite of the fact that the guide or criticalness of the Sun is perhaps non as extraordinary in Sufi Whirling for what it's worth in the Sun Dance, the way that it holds some importance demonstrates that the use of the Sun in ceremony is non unprecedented. This incessant utilization of the Sun as a ceremonial point of convergence in numerous religions mirrors the perhaps cosmopolitan hugeness of the Sun. The Sun as a heavenly nature has been recorded through history on army events over a completeness of religions and conviction frameworks. It represents force and quality, each piece great as magnificence and metempsychosis. It is habitually the mostly point of convergence of numerous ceremonies, and this part can be seen in both the Sun Dance and in Sufi Whilring. While the two religions are extremely not quite the same as each other, their point of convergence on the Sun in these two rituals speaks to the catholicity of the Sun as an incredible otherworldly image. There is plentifulness of recorded grounds to show the use of the Sun in otherworldly rituals. There are sun divinities present in Hinduism ( for example Surya ) , Buddhism ( in the signifier of a Bodhisattva ) , and in the beliefs of Ancient Egypt, China, and among grouped African people. It can clearly be seen that the utilization of the Sun rises above geological limit lines. Solid grounds of this amazing quality comes in the signifier of paleontologic finds, saved Bibles, and of class, the numerous perceptions that are made in cus toms over the universe today. Perhaps the significance of the Sun created in the Lakota custom for similar grounds it was held in such high regard in different conventions ; conceivably it turned into the point of convergence of the Sun Dance for its notoriety as an image of intensity and quality, and as an astronomical segment deserving of extraordinary relinquish. In Sufism, the Sun is bit of numerous stories as a cardinal astronomical force. While the Sun is non loved as a holiness itself, as that would give a false representation of the point of convergence of their gyration ( which is the One God ) , the Sun is rather bit of a more noteworthy framework that is made by the One God. One of the most delightful imaginative exercises, the Sun has the right to be incorporated and perceived as an inherent bit of one s venture which carries the member closer to Allah. Consequently, independent of the guide the Sun shows in every custom, its essentialness can non be denied, nor can its catholicity as an image of intensity, excellence, and strength. The second likeness between the two customs with is meriting exploring is the splendid mental result they have on their members. As was referenced prior, procedures in both the Sun Dance and in Sufi Whirling let the members, and some of the time their perceivers, to see a changed world. Stupor like regions are every now and again accomplished as members become so focussed on the custom and its aim. In the Sun Dance, dreams every now and again go with this daze like territory and think about Indigenous thoughts the connection among universes and nature. Regularly saw in Sufi Whirling, daze like areas are much of the time seen as delighted at this point they typically speak to an all around centered, more clear vision of the universe. Essentially the purpose of this experience is to determine a superior fear of the Oneness of Allah, and the excellence of the entirety of His innovative exercises. This comparable experience, seen in both the Sun Dance and in Whirling, features the potent ially cosmopolitan goal of formal charms and adjusted mental areas. While the term stupor can plan a few things, it is all around alluded to as a methodology, procedure, area of head, or awareness accomplished either willfully or automatically. Both the Sun Dance and the Sufi Whirling influence higher territories of awareness and cognizance of grown-up male s relationship with a higher force ; in the Sun Dance, that higher force is the Sun, and in Sufism, that higher force is the One God. Seen in numerous different customs, charms are other than related with arranged signifiers of hypothesis and petition. In the Sun Dance, the utilization of psychotropic substances may increase the member s experience. The two customs utilize audile and motor strategies to welcome on this area of head and the two conventions use it as a vehicle to accomplish a higher cognizance of their conviction frameworks. Typically charms are related with an acknowledgment or elevated cognizance of one s relatio nship with their milieus, with nature, or with an all the more impressive being. Charms are again, generally perceived as considerations of these acknowledge and are utilized in both Sufi Whirling and in the Sun Dance, alongside different customs, to determine simply that. By reducing one s point of convergence on outside components, and focusing on the elaboratenesss of one s inward functions, charms become instruments by which people can see clarity, harmony, and plan.

College Essay Samples

College Essay SamplesCollege students are in a hurry to get their college essays finished and ready for the exams so they can get accepted into their favorite colleges. Fortunately, there are some samples of college essay samples that have been prepared by those who have graduated from those colleges.The writing samples that you will find here are not that difficult to read and understand because they include college papers that the writers made a masterpiece out of. You will find this as an example of college essay samples. The writer of this article should be very proud to be seen as one of the best essay writers that ever lived.Some of the recent ones are described below:'Can You Change a Person's Essay?' This is the question that is asked by the essay writers when they write an essay. In this sample, the writer writes about how this person changed his essay at the end of the chapter. It tells a story about how the student managed to make his students admire him more each time he wrote an essay.'This is Your Opinion of the Essay?' The last essay sample is given in which the writer writes about how he feels about an essay.'How I Changed My Essay and Changed It', or 'I Changed My Essay' is the last one that is given in which the writer tries to convince the reader of what he says is true. It tells about how he kept changing his student's opinion every time he wrote an essay. The story goes through how the college student decided to change the topic of his essays so that it would catch the attention of his fellow students.When you have found your sample, then you can begin reading the way the writer made his readers feel. It is better if you can compare it with the other samples of college essay samples that you have encountered in the past.

Assessment An Essential Element Of The Counselling...

1. Assessment is an essential element of the counselling process and ethical client care. Through assessment, counsellors are able to ascertain important information about the nature, magnitude and impact of the problem ; the interplay between family , relationships and past experiences with respect to the problem; the client’s strength and readiness for counselling ; and whether counselling can be beneficial to the client (Drummond Jones, 2010). 2. There are two main approaches to successfully achieve a systematic and fully descriptive view of evaluation and assessment in counselling – the quantitative and qualitative approach. Both are effective ways to assess and communicate the nature, background and outcomes of the case. Results can provide the counsellor with the interpretation of certain behaviours and emotions of the client. 3. Quantitative assessment is the collection of data that can be analysed in terms of numerical scores and ratings. This task entails working with statistics, gathering, analysing, interpreting, and charting results, trends, and norms. Quantitative methods show the degree to which certain characteristics are present, such as frequency of activities, opinions, beliefs, or behaviours within a group (2nd Edition – Outreach Evaluation Resource Centre, 2013). 4. Qualitative assessment is data collection that does not lend itself to numerical methods but rather to interpretive standards. The measurement is more focused on comprehensiveShow MoreRelatedEssay Professiona and Organisational Issues in Counselling6158 Words   |  25 Pages1- Understand what is meant by Counselling 1.1 The term counselling facilitates personal and interpersonal functioning across the lifespan with the main focus on emotional, vocational, social, educational, health related and developmental concerns this encompasses a broad range of practices that help people to improve their well being, alleviate stress and maladjustment, reslove crisis and increases their ability to live more fully functioning lives. Counselling is unique in its attention toRead MoreMy Core Philosophy And It s Ongoing Development2547 Words   |  11 PagesIn formulating this essay I will give a descriptive account of my core philosophy and it s ongoing development. I will evidence my way of working in context to counselling theory, relating this to the course s guidelines. 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Ting´s Test A Short Story Essay - 1128 Words

Our story begins with the beautiful musical sounds of the world driven from their instruments by the onset of a mechanical age no-one predicted, nor expected. An awful time when rough toned noise crept remorselessly through every doorway, every window, polluting every passageway and quiet place until silence abandoned the people to their plight and was gone. With the passing of ages into centuries the population of Middleseton dwindled. Some, a handful at most had seen remnants of books, torn pages alive with mute pictures of dancers pirouetting to something unimaginable. And even now, when all was nearly over they continued to dream, to believe in music. A dream no-one had ever heard. Ting is a small sound, a sound hardly used. In the†¦show more content†¦Without them Middleseton as a town, as an entity had no claim to its place on the map. When all was finally lost, the musical Sounds abandoned their daily practice, rehearsals and performances, slipping away from their instruments not knowing when the world would hear their music again. No more vibrating with strings or disturbing the air through holes drilled in pipes. No Sounds sang children to sleep, nor lead them marching through lifes tapestry, clapping in time to their favourite tune, happy or sad. Ting was struggling, his natural instincts for survival were fading, he was losing the resolve to fight on. An overwhelming feeling to sit on the ground, to wait for the last chord to sound was getting harder to resist. Weighed down with angry emotions and unthinkable thoughts Ting, not looking where he was going stumbled down into a dark cavernous hole; a protected place shrouded in darkness where neither noise, nor rain was welcome. Ting scrambled to his feet. Where am I? A small glimmer of light, barely shining through the gloom brought a little comfort to Ting. It was a faint glow of hope that crept in with Ting, when inadvertently he dislodging a flagstone with the palms of his hands and fell forward. A rough edged tunnel snapped open. Ting tried to regain his balance, instead, he tumbled down a long, stone stairway coming to rest in a dark place where he peered with wide open eyes but sawShow MoreRelatedOil Boom in North Dakota5022 Words   |  21 Pagespack the city s two clubs, Whispers and Heartbreakers, every night. They smell like work. They wear dirty T-shirts. They fall asleep face first on the bar. And then there are the prostitutes. Tatiana, who asked that her real name not be used, noticed them wandering though the crowd looking for customers on her first night in North Dakota. They re not in there to tip the dancers, she says with a laugh. Williston is the heart of Bakken oil country, the Fort McMurray of the U.S. s north, for allRead MoreDisneyland Hong Kong8209 Words   |  33 Pagesenvironment. The report also comprises of an extensive analysis of the external, industry and internal environments. The external analysis uses the PESTLE factors to identify key environmental forces and trends. The industry analysis includes the Porter s five forces being employed in the case of Disney HK to analyse the competitive environment in which the potential profitability and survivability are greatly dependent on followed by the key success factors, competitor analysis and strategic group analysisRead More Jamaican Patois and the Power of Language in Reggae Music Essay4989 Words   |  20 Pagespublishing and creating poems in written in Creole such as, dub poetry, and dialogue in novels, short stories, and plays. In most written Creole modified Standard English is used. Following is an example of the variance of spelling of S tandard English to words in British Creole (Sebba 1, 1996). Table 1. Difference of Spellings in British Creole and Standard English Standard English Variants thing t’ing, ting nothing nutten, not’n’, notin’ no nuh, noh, nu can’t cyan, cyaan, kaan, kean (be)cause cawRead MoreConsumer Behaviour Towards Watches26763 Words   |  108 Pagesthe UK. Snowball sampling method was applied to distribute online questionnaire. In this study, the statistical data analyses in a form of SPSS with the help of Microsoft Excel were conducted by applying a method of inferential statistics T-test and F-test. The combinations of qualitative and quantitative were used to aid the explanation of the results. This work mainly focuses on culture, motivation, status and material consumption, generation Y and gender. 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Taxation - Theory - Practice & Law Residence and Source

Question: Discuss about theTaxation, Theory, Practice Law for Residence and Source. Answer: Residence and Source The taxability of the income depends upon the residential status of a person, thus, it is crucial for the tax purposes to determine the residential status of a person (Prince, 2013). In Australia, the residential status of an individual is determined by referring to the provisions of Australian tax law and the rules framed by the Australian Taxation Office in this behalf. Although, there is a proper definition of the term Resident in the Australian tax laws but in certain complex situations, one may lead to refer to the judicial case laws. The judicial case laws also provide foundation to resolve the complex issues related to the taxation matters. However, it should be kept in mind that the judicial cases are referred to only in the situations in which the issues could not be resolved by referring to the statutory provisions of taxation law (TaxConnections, 2016). According to the rules framed by the Australian Tax Office, the primary test that is conducted to work out the residential status of an individual is the Resides Test. As per this test, an individual already residing in Australia is deemed as resident for the tax purpose without applying any other provision or rule. This implies that an individual residing permanently in Australia will always be deemed as resident for tax purposes. In case of individuals not already residing in Australia, there are three conditions stipulated by the Australian Tax office, if any of these conditions get satisfied, the individual is regarded as resident for tax purposes. These three conditions are discussed as under: Domicile Test: Prescribed that the individual having permanent place of residence in Australia is deemed as resident (Australia Residency Test, 2016). 183 Day Test: If an individual has stayed in Australia for a period of 183 days or more in the year for which status is sought to be determined, then he/she is deemed as resident of (Residency- 183 day test, 2016). Superannuation Test: As per this test, the Australian government employees posted outside Australia are treated as resident of Australia. However, in regard to the above discussed first two conditions, it is to be noted that if the Australian Tax Office is satisfied that the permanent place of abode of the individual is outside Australia, then these conditions will not apply and the individual may not be regarded as resident of Australia in that case (Australia Residency Test, 2016). In the present case, Fred, who has migrated to Australia from the United Kingdom, satisfies the 183 day test as he has been in Australia for 11 month (Australia Residency Test, 2016). Further, considering the prevailing circumstances in the current case, the permanent place of adobe for Fred could also not said to be outside Australia. This is primarily due to two reasons, first is that he is living in Australia with family (not considering children here because they could not be migrated due to unavoidable reasons) and second is that Fred has rented out his residential property of the United kingdom. Therefore, concluding the discussion, it could be articulated that Fred is resident of Australia for tax purposes and thus, he will be liable to pay taxes to the government on income earned there. Case study 2: Ordinary Income The outcomes in respect of the cases have been discussed as under: Case 1: Californian Copper Syndicate Ltd v Harris (Surveyor of Taxes) (1904) 5 TC 159 The primary issue arose before the court in this case was that whether a single transaction could be regarded as business and tax can be levied under the head business income on the person who carried out that transaction. Addressing this question, the first assertion of the court was that rather than thinking about the size of the transaction, one should consider the source from which that income emanates (Manyam, 2011). Thus, it becomes clear that for taxation purpose, even one single transaction could be brought to tax under the head business income, if the transaction was carried out with the business motive. Further, the court held that if the transaction related to land and property and securities was not with the business motive, rather the land, property or securities were held as investment, the gains can not be taxed as business income. The major outcomes of this case were as under: In case of land, property, and securities which are held as investment, the gains arising on sales or otherwise transfer of such land, property, and securities are not to be taxed as business income (MinterEllison, 2016). However, in cases wherein it is apparently clear that the activities are of business nature, the gains arising on sale or otherwise transfer of the securities, land, or property are to be taxed as business income (MinterEllison, 2016). Further, the court held that whether the transaction was a single transaction and whether or not it was commercial in nature, the gains arising from it shall be regarded as income, however, taxed it may be under any of the heads (MinterEllison, 2016). Further, the court stipulated that each case must be considered separately by going through the exact nature of the transaction (MinterEllison, 2016). Case 2: Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 Among various key cases on revenues and capital distinction for tax purposes, the Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 is an important one (Smith, 2003). In this case, the major issue that came up before the court was that whether the sale of land, which was being previously used in the mining operations by Scottish Australian Mining Co Ltd, could be taxed as revenue income merely because that some business nature operations were performed by the company to bring that land in a saleable condition. Addressing this question, the court held that the income arising on sale of such land is not assessable income. The court based this decision on the assertion that business nature activities were taken up only to realize the land in the most advantageous way. Thus, in this case, the sale of land was held to be as not an assessable income (Smith, 2003). Case 3: FC of T v Whitfords Beach Pty Ltd (1982) 150 CLR This case involved a substantial question of law as regards taxation of sale of land. In this case, Whitfords Beach Pty Ltd purchased land in the year 1954, which was sold later on by carrying out some development work. Although, the primary issues in this case was same as that was raised in the case of Scottish Australian Mining Co Ltd but the circumstances were totally different. Court observed that the sale land in this case took place after altering the articles of association of the company so as to include wherein land development and sale as a business activity (Australian Government, 2016). Further, it was observed by the court that there was a change in the ownership that took place after the land was purchased. The court, by clearly making distinction between this case and the case of Scottish Australian Mining Co Ltd, held that the sale of land was assessable as business income. The judiciary observed that in this case, the taxpayer company was involved in more than the me re realization of the asset. Therefore, overriding the decision of the court in the case of Australian Mining Co Ltd, the court held that the sale of land by Whitfords Beach Pty Ltd was chargeable to tax as business income (Wolters Kluwer, 2016). Case 4: Statham Anor v FC of T 89 ATC 4070 In this case also the issue of tax on the sale of land was the reason of dispute between the taxpayer and the tax authorities. The taxpayer sold land, the net proceeds of which were assessed as the income from the business activities by the commissioner of income tax (Statham Anor. 2016). The taxpayer raised objections against the tax treatment given by the commissioner in respect of sale of such land. The taxpayer appealed in the court claiming that the tax treatment given by the commissioner is grossly wrong and the gains arising on the sale of land should not be taxed as business income. The court decided the case in favor of the taxpayer holding that the gains arising on the sale of land could not be regarded as the ordinary income or the income from business activities. The court based its decision on certain crucial grounds; one of them was that the activities of the taxpayer were not of business nature. In this regard, the court observed that the taxpayer was not working on any profit making scheme that could be associated with the sale of that land (Court Cases, 2016). Thus, in the prevailing circumstances, the taxpayer could not be held to be carrying on a business of land development. Further, the court ruled out that the mere fact that the farming business of the taxpayer was closed down, does not make the sale of land taxable as business income. Therefore, referring to the judicially pronouncements of other cases and considering the circumstances of the current case, the court held that the net proceeds of the sale of land can not be taxed as business income. Final order of the court also directed the commissioner to reimburse the expenses incurred by the taxpayer in connection with this appeal (Court Cases, 2016). Case 5: Casimaty v FC of T 97 ATC 5135 The law promulgated through this case was also to assist the taxation of the sale of land. In this case, the taxpayer was gifted a farm by his father. On this farm, the taxpayer was carrying on primary production activities and using a part of it for residential purposes. Later on, after several years, the taxpayer sold a part of the land from that farm (Casimaty's case, 2002). The tax authorities demanded tax on the gains arising on sale of that part of the land. The taxpayer challenged this decision of the tax authorities in the court by appealing that the gains on sale of part of the farm land were not chargeable to tax under section 25 (1) of the income tax assessment act (ITAA) 1936 (Australian Government, 2016). However, the decisions of the administrative appeal tribunal and the federal court came against the taxpayer. The federal court based its decision on the ground that the taxpayer was actively involved in planning and managing the sales of land, which in no case can be s aid to be involvement for mere realization of the asset. Challenging the decisions of the administrative appeal tribunal and the federal court, the taxpayer appealed in the high court. The high court turned down the decisions of the administrative appeal tribunal and the federal court by deciding the case in favor of the taxpayer. The high court held that the activities carried out by the taxpayer in connection with the sale of part of the land were not in the nature of business of land development (Casimaty's case, 2002). Thus, the gains arising from the sale of part of the land could not be taxed in the hands of the taxpayer under section 25 (1) of the ITAA 1936. The high court based its decision on the ground that the taxpayer was not directly involved in advertising the sale of land and other activities that are considered to be indicative of business of land development (Casimaty's case, 2002). Case 6: Moana Sand Pty Ltd v FC of T 88 ATC 4897 The sale of land and the dominant purpose of the taxpayer in selling that land was the primary finding of this case. The court observed that it is a well established law to consider the dominant purpose and intention of the party to use the land in deciding to tax the proceeds of sale of land. At the first stage, the tribunal asserted that the intention of the taxpayer was not to make profits from the sale of property. It was found that the taxpayer was using the land for the use in connection with the business activity such as sale of sand. Thus, the property was being used as the permanent asset in the business by the taxpayer and not as a trading asset. Based on these arguments, the tribunal held the gains on sale of land not chargeable to tax as ordinary business income (Moana Sand Case, 2016). However, on further appeal, the federal court pronounced that the sale of land in this case was chargeable on revenue account as well as capital account. Case 7: Crow v FC of T 88 ATC 4620 In this case, the court held that the activities of the taxpayer were identifiable in the nature of business of land development. Therefore, the court held the transaction of sale of land in this case was on revenues account and thus, liable to tax under section 25(1) of ITAA of 1936. The court observed that the description of the activities that the taxpayer was carrying in relation to the land development showed that these activities were in the nature of business (Crow v FC, 2016). In this regard, the court noted that the taxpayer carried out various land development tasks on such land before disposing that off finally. Further, in the case, the purpose behind purchase of the land was clearly identifiable, which was to carry out land development by subdividing it. Therefore, considering the stated purpose of use of land and the nature of the substantial activities that were being carried out by the taxpayer in relation to development of that land, the court pronounced that the sal e of land need to be brought to tax under section 25 (1) of ITAA 1936 (Crow v FC, 2016). Case 8: McCurry Anor v FC of T 98 ATC 4487 In this case, the court observed that the activities of the taxpayer in relation to land were not merely to assist in realization of the land, but these were more than that and signifying the existence of profit making motive. In this case, two brothers purchased a land and constructed three houses on that land. However, they were not able sale the houses initially and for that reason they decided to use two of the houses as residence. After some time using those houses for own residence, they sold them making huge profits out of that sale. The taxpayers were of the view that the profit earned on the sale of the houses was not chargeable to tax as ordinary income (Webb Martin, 2016). However, the court pronounced its decision based on the inherent intention of the taxpayer, which was to use the land in profit making activities and earn profit. The court based its decision on the finding that the taxpayer did not take required steps to let out the property and further, it was likely that to repay the heavy bank loan, they would be selling the property shortly (Webb Martin, 2016). References Australian Government. 2016. Income tax: whether profits on isolated transactions are income. [Online]. Available at: https://law.ato.gov.au/atolaw/view.htm?DocID=TXR/TR923/NAT/ATO/00001 [Accessed on: 10 August 2016]. Casimaty's case. 2002. Sale of subdivided farm land - Income or capital gain? [Online]. Available at: https://law.ato.gov.au/atolaw/view.htm?docid=AID/AID2002273/00001 [Accessed on: 10 August 2016]. Court Cases. 2016. Statham Anor v. Federal Commissioner of Taxation, Federal Court of Australia, Full Court, 23 December 1988 [Online]. Available at: 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: 10 August 2016]. Crow v FC, 2016. ATO Interpretative Decision. [Online]. Available at: https://www.ato.gov.au/law/view/document?docid=AID/AID200155/00001 [Accessed on: 10 August 2016]. Australian government. 2016. Federal Register ofLegislation. [Online]. Available at: https://www.legislation.gov.au/Details/C2013C00040 [Accessed on: 10 August 2016]. Manyam, J. 2011. Taxation of Gains from Banking and Insurance Businesses in New Zealand. Revenue Law Journal, 20(1), pp. 1-29. MinterEllison. 2016. Australian tax brief. [Online]. Available at: https://www.minterellison.com/Pub/N/201002_ATB/ [Accessed on: 10 August 2016]. Moana Sand Case. 2016. Moana Sand Pty Ltd v FC. [Online]. Available at: https://www.austlii.edu.au/au/journals/JlATax/1999/13.html [Accessed on: 10 August 2016]. Prince, J.B. 2013. Tax for Australians for dummies. John Wiley Sons. Residency- 183 day test. 2016. [Online]. Available at: https://www.ato.gov.au/Individuals/International-tax-for-individuals/In-detail/Residency/Residency---the-183-day-test/ [Accessed on: 10 August 2016]. Residency Test. 2016. [Online]. Available at: https://www.ato.gov.au/Individuals/International-tax-for-individuals/Work-out-your-tax-residency/Residency-tests/ [Accessed on: 10 August 2016]. Smith, A. 2003. Taxation Institute of Australia. [Online]. Available at: file:///C:/Users/Abasus%20Solution/Downloads/d020520030207_prop_development_smith.pdf [Accessed on: 10 August 2016]. Statham Anor. 2016. Statham Anor v. Federal Commissioner of Taxation. [Online]. Available at: https://law.ato.gov.au/atolaw/view.htm?locid=%27JUD/89ATC4070%27PiT=99991231235958 [Accessed on: 10 August 2016]. Webb Martin. 2016. Complex tax issues taking up time. [Online]. Available at: https://www.webbmartinconsulting.com.au/#!PropertySubdivision/c7zf/551ba1e30cf215f35a2ff93e [Accessed on: 10 August 2016]. Wolters Kluwer. 2016. Federal Commissioner of Taxation v. Whitfords Beach Pty. Ltd., High Court of Australia, 17 March 1982. [Online]. Available at: 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: 10 August 2016].