Graduation Speech 3 Idiots, And Its States Do Not...

One quote that I live by on a daily basis both in and out of school comes from an Indian movie called 3 Idiots, and its states, â€Å"Do not chase success. Follow excellence, then success will chase you.† In my school life, this pursuit of excellence has allowed me to reach great levels of achievement in all of my subject areas in high school. However, I especially excel in the areas of math, science, and social studies. My excellence in these areas of learning can be attributed to many factors, including a natural curiosity about these topics, an ability to grasp information easily, and my drive to work hard in all of these areas. Ever since I was little, I have always been curious about our world and why it is the way it is. Initially, this curiosity was manifested in the form of social studies, especially history and geography. History allowed me to see the progression of events that led to our current global situation, while geography allowed me to learn about the ea rth’s physical characteristics and how that influences the importance and usage of various areas of the earth. As I continued on in school, I slowly figured out that fundamental laws, which can be explained by math and science, govern the earth. Math and science work together to allow us to see the ways by which the world works. These three subjects together have allowed me to gain a complete view on the world’s current situation, how we got to where we are today, and why the world is the way it is.Show MoreRelatedThe Five Dysfunctions of a Team a Leadership Fable46009 Words   |  185 Pagesthis publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the publisher, or authorization through payment of the appropriate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, 978-750-8400, fax 978-646-8600Read MoreProject Mgmt296381 Words   |  1186 Pagesprojects 2.3 Stakeholders and review boards 12.1 RFP’s and vendor selection (.3.4.5) 11.2.2.6 SWAT analysis 6.5.2.7 Schedule compression 9.4.2.5 Leadership skills G.1 Project leadership 10.1 Stakeholder management Chapter 11 Teams Chapter 3 Organization: Structure and Culture 2.4.1 Organization cultures [G.7] 2.4.2 Organization structure [9.1.3] 9.1.1 Organization charts 1.4.4 Project offices Chapter 4 9.2 Building the team (.1.3) [3.5.3] [App G.2 Building teams] 9.4 ManagingRead MoreIgbo Dictionary129408 Words   |  518 Pages..................................................................................................... 4 2. The development of the present work ....................................................................................................... 6 3. Onitsha Igbo ................................................................................................................................................ 9 4. Alphabetization and arrangement......................................................Read MoreStephen P. Robbins Timothy A. Judge (2011) Organizational Behaviour 15th Edition New Jersey: Prentice Hall393164 Words   |  1573 PagesOrganizational Behavior This page intentionally left blank Organizational Behavior EDITION 15 Stephen P. Robbins —San Diego State University Timothy A. Judge —University of Notre Dame i3iEi35Bj! Boston Columbus Indianapolis New York San Francisco Upper Saddle River Amsterdam Cape Town Dubai London Madrid Milan Munich Paris Montreal Toronto Delhi Mexico City Sao Paulo Sydney Hong Kong Seoul Singapore Taipei Tokyo Editorial Director: Sally Yagan Director of Editorial Services:

The Fight for Social Justice Essay - 892 Words

It has been proven that often, the fight for social justice and the common good comes at a great cost to those involved. Through writings such as Dr. Martin Luther King’s â€Å"Letter from a Birmingham Jail† and Sophocles’ â€Å"Antigone†, as well as, lectures such as Dr.Colbourn’s lecture â€Å"Confronting History and the Good Life: Life after Rosewood† it is demonstrated how life, freedom, and a normal everyday life suffer as a cost of fighting for social justice and the common good. To begin with, Dr. Martin Luther King as well as many other African- Americans fought for equality, social justice, and a better life for African- American resulting in a great cost. Dr. Martin Luther King Jr. was ridiculed and was the target of many attacks simply for†¦show more content†¦In the end, Dr. Martin Luther King Jr. paid the ultimate cost when fighting for social justice and the common good, with his life. On April 4th, 1963, he was assassinated by someone who didn’t like him and the cause he was fighting for. Although Dr. King lost his life, his actions resulted in a better life for African-Americans in terms of equality and social justice. Moreover, Sophocles’ â€Å"Antigone† shows how freedom, life, and a normal everyday life was the cost of fighting for social justice and the common good. In attempt to give her brother Polyneices the appropriate burial, chaos erupts in the kingdom of Thebes. Antigone wanted to honor her brother and the gods by burying her brother even though it was against the wishes of King Creon. Antigone knew her punishment would be death, but she did not care. Antigone was willing to risk her life in order to do what she felt was right. In regards to freedom, Antigone’s arrest and exile were both costs of her fight for social justice and the common good. Antigone’s fight for the common good affected her life as well as the lives of those around her. Her fiancà © Haimon tried to fight for a good life for himself and Antigone by going against his father’s word. In the end, Haimon took his life as a result of Antigone’s death and his mother Eurydike committ ed suicide as a result of Haimon’s death.Show MoreRelatedThe Fight For Social Justice Essay2115 Words   |  9 PagesThe main purpose of social work is to advocate for those who have no voice. Throughout history, many individuals have served as role models and proponents of social justice, helping to create policies and programs so future generations can benefit. Jane Addams, Elizabeth Cady Stanton, Rachel Carson, and Harriet Tubman worked tirelessly and devoted their entire lives to the pursuit of justice. We have learned through their sacrifices that change is just one person away, and that it takes tremendousRead MoreHuman Rights And Fights For Social Justice Essay1633 Words   |  7 Pagesadvanced generalist practitioner to conduct research in order to engage in meaningful social work practice. This essentially means that someone who engages in advanced generalist practice is someone who incorporates various theories and methodologies into research and assessment to c reate a meaningful practice that advances human rights and fights for social justice. Research can mean everything to a social justice issue in terms of expanding knowledge and aiding in helping a particular cause. WithoutRead MoreThe Paradox of Dominate Ideologies in the Fight of Social Justice. 2476 Words   |  10 Pagesare only living together for the summer, until they part their own ways again. The paradox between art and social justice would be that art can be shown to fight for and against social justice. In this essay we will be comparing how The Hills is showing the dominant ideology of an upper white class structure that fights against social justice, while Jersey Shore is fighting for social justice by not showing the dominant ideologies of upper class, instead showing working class Americans. The essayRead MoreAnalysis Of Lakota Woman By Mary Crow Dog1688 Words   |  7 Pageshave been introduced to the Indigenous people social rights justice that has been fighting for many decades to stop waichu from taking every possession of their property, freedom, and racial equality. In the book called â€Å"Lakota Woman† by Mary Crow Dog, she has been describing her childhood to the age of 39 which has been related to many historical events associated with the American Indian Movement. Many of those American Indian Movement was to fight for their rights to have a safer future for theirRead MoreThe Death With Dignity Act913 Words   |  4 Pagesall complicated matters such as this, the law is very contradictory in this field. Social workers who are well informed about life and death issues in the light of cultural and religious beliefs and practices, advanced directives, and the legislation related to them, will be more competent in assisting clients to express their desires and to make choices that encompass their life choices. Such knowledge enhances social work intervention by empowering the elderly to use their autonomous rights relatedRead MoreCommon Sense, by Thomas Paine and Letter to Any Would-Be Terrorists, by Naomi Shihab Nye1305 Words   |  6 PagesReaching for justice throughout human history has been one of the primordial dreams chased by most humans while at the same time, hunted as a mere fugitive by others in order to satisfy their appalling thirst for injustice. â€Å"Injustice anywhere is at threat to justice everywhere† as stated by Martin lather King, if one doesn’t fight for justice he/she might end up having to face the sad reality of injustice taking over everywhere. In order to not let such a thing take place we need to fight against injusticeRead MoreCritical Race Theory On Racism751 Words   |  4 Pagesfuture, it does not seem plausible due to the fact that little progress has been made to reform the societal structures that marginalize people based on their race. Although racism is permanently embedded within the United States, working towards social justice is a necessity because it reassures communities facing marginalization that there is a possibility that the p resence of racism will be less visible in society. In Critical Race Theory, or CRT, it is recognized that racism is lodged into theRead MoreMountains beyond Mountains: Dr. Paul Farmer Essay example1336 Words   |  6 Pagestreatment, no matter their ability to pay. Dr. Farmer makes sacrifices and advocates for the poor throughout his journey, showing the rest of the world how one man can make a difference. Global Social Welfare Haiti is a prime example of how human needs in one area of the world are interdependent with social conditions elsewhere in the world. Haiti, for most of its history has been overwhelmed with economic mismanage and political violence. 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Portfolios Project In Dynamic Environments †Myassignmenthelp.Com

Question: Discuss About The Portfolios Project In Dynamic Environments? Answer: Introduction The report presents a brief overview of the strategic management. It explains the linear approach and its limitations. Further, it explains the various approaches to the strategic management. It explains that how the Coca-Cola, Starbucks, IBM, Unilever company uses the various strategic management approaches to gain the competitive advantages and to achieve the organizational goals and objectives. The main objective of the strategic management is to evaluate and analyze the external and internal environment of the company. Strategic management is the process of formulation and execution of the major goals, objectives, and initiatives which are taken by the organizations top management on behalf of the owners based on the deliberation of resources and evaluation of the interior and exterior environment. This management provides overall direction and guidelines to the enterprise and it includes the organization goals, objectives, plans and policies and allocation of resources to achieve the organizational long-term objectives and goals. Another side, it defines as the art and science to formulate, evaluate, and implement cross-cultural decisions in order to meet organizational goals and objectives. It is not related to a single specialization but it covers overall organization. It is the broad area which covers overall functional areas of the association. Therefore, it plays a significant role in every organization. There is three basic principles of strategic management; they are discussed below (Batema n Snell, 2013). Creation of profit and revenue by aligning organization activities and operation with a strategic mission and vision. Generate a unique and effective position in the market. Compromise operations and activities in order to achieve satisfaction and morale and determine activities to gain the competitive advantages (Paiola, Saccani, Perona and Gebauer, 2013). The Standard linear strategy in an association is strategy under which business plans, policies and procedures implement and execute their strategies in an organization accordingly. The linear model of strategic management focuses on the planning process in order to meet the goals and objectives according to the requirements of the company. The linear approach provides a good framework for the organization (Foss Knudsen, 2013). There are various shortcomings of linear approaches. The objective of this approach is very complex and it is very difficult to understand the financial, social, and institutional constraints. The objectives and functions of the approach are not clearly specified by the company. Lack of communication and coordination, the company faces many challenges and key issues. It is very complex and intricate approach. All these challenges are faced by the company so it should be managed and controlled by the organization. The company should reduce all these shortcomin gs and limitations to build a sustainable organization (Bateman Snell, 2013). Approaches to strategic management The approaches of strategic management play a significant role in every organization. The company uses the various approaches to identify and evaluate the success and growth of the organization. The approaches of strategic management have been discussed below (Vogel Gttel, 2013). Stakeholders approach and example The stakeholder's approach is a theory of business ethics and organizational management which addresses values and morals to manage and control the association. The stakeholders strategic management approach creates positive and favorable relationships with various stakeholders with the help of suitable management. In stakeholder strategic approach, stakeholders focus on the prerequisite and services of the organization to attain the goals and objectives of the company. It is the integrated and vital approach to the strategic management. There are various stakeholders exist in the organization, they include suppliers, creditors, employees, unions, project manager, sponsor, community, customers and professional organization, etc. There is a close relationship between stakeholders and organization (Paiola, Saccani, Perona and Gebauer, 2013). They play a significant role in an organization because they help to determine the outcomes of the business. An effective stakeholders approach ma intains a favorable relationship between management and stakeholders of the company. Stakeholders monitor and analyze the activities and globalization plans of the company. They help to maintain good communication in an organization and they identify and analyze the key issues and benefits of the association. They generate new ideas and plans to gain the long-term success and growth of the organization. Stakeholders may include different people that come from various areas of the business. This approach protects the interest of the stakeholders and provides satisfaction to them. This approach is important to generate high revenue and profit of the company and it also increases the satisfaction level of the customers. Through this approach, the association can take various opportunities and control on the various key challenges. Further, the stakeholder's approach is executed through the following ways (Pearlson, Saunders Galletta, 2016). The Company should identify the company stakeholders group for doing the work. The company stakeholders include the partners, employees, shareholders, society, and suppliers. The second step is to create a value proposition for each and every stakeholder's There are three elements of values such as financial (volume, ROI, price, margin), emotional ( offering security to maintain trust) and functional ( providing flexibility, increasing and enhancing the shareholder's productivity). The value creation should be balanced by the company to gain the return and revenue. The organization should identify the capabilities to execute and implement the plans and procedures. The organization should use the useful information to create and generate a profit model to manage and control the certain tradeoffs among the stakeholders of the company. Finally, the company should determine the set of key performance indicators to manage the operation and activities of the business (McKelvie and Davidsson, 2009). Ford motor company is one of the biggest companies which uses the stakeholder's approach in their management. The company uses this approach to maintain sustainability and growth of the organization. The variety of stakeholders includes the bottling partners, customers, consumers, employees, communities, government, regulatory authorities, and suppliers. The company conducts stakeholders engagement session and programs for the various stakeholders. The company encourages and enhances the stakeholders approach to gain the competitive advantage in the market. In this way, the company is using the stakeholder's approach in the organization. Through the stakeholders theory, the association understands the various needs and expectations to accomplish the goals and objectives. The stakeholders are the owners and founders of the company and they work for the success and growth of the company. Dynamic capabilities and example In the organizational theory, the dynamic capability is the capacity of an association to utilize the resources of the company. The dynamic capabilities approach shows the firm ability and integrity to achieve the goals and objectives of the company. It emphasizes on the capabilities and potential of the company to perform the task and duties effectively and efficiently. This theory provides various guideline and support to the top management and seniors of the company to do work effectively (Klievink and Janssen, 2009). It includes the three capabilities such as ability, integration, and transformation which are compulsory for every organization. First, ability shows the working capacity of the employees for doing the work. It is the ability of the workers to adapt and learn changes within an organization. Second is the integration of new assets of the company so the organization procedures, process, and plans are initiated and astly, the reuse and transformational of assets utilize d. The stages in dynamic capabilities have been discussed below (Jantunen, Ellonen, and Johansson, 2012). Learning: It is the first stage of dynamic capabilities and it plays a significant role in every organization. In this stage, managers and employees are required to reorganize and reschedule their daily routines to promote and enhance interactions. In this way, this approach helps to maintain collaboration and communication in the organization. Dynamic capabilities help to resolve the various problems and it reduces the dysfunction of the company. Human resource management plays a significant role in dynamic capabilities approach. This department should evaluate the capabilities and potential of the employees to improve the performance and efficiency of the employees. New assets: It is the second stage of the dynamic capabilities and the assets exist in the company creates and expands the efficiency of the association. It helps to improve quality and performance of the employees (Petit, 2012). Transformation of existing resources: It is the important stage of the dynamic capabilities. The company can accomplish goals and objectives when the organization converts all the available assets and resources of the company. Therefore, the interior and exterior factors should be associated in order to accomplish the goals and objectives of the organization. Co-specialization: It is the broad concept of the dynamic capabilities. If the company wants to create co-specialization then it should ensure the maximum utilization of available resources (Grant, 2016). Coca-cola, Ford motor company, IBM, and apple are the example of the dynamic capabilities strategic management approach. These companies use the dynamic capabilities approach to maintain sustainability in the market. Apple Company ensures the maximum utilization of resources through dynamic capabilities approach (Kindstrm, Kowalkowski and Sandberg, 2013). The Ford motor company, IBM, and Coca-Cola Company are also using the various dynamic capabilities to overcome on the competitors. These companies are taking various advantages with the help of dynamic capabilities approach of the strategic management. They can evaluate and analyze the various plans, policies, business activities and operations of the competitors (Laczniak and Murphy, 2012). Sustainable approach and example This approach ensures the growth and development of the organization. In this approach, the management focuses on the sustainability and development of the company. It is the process of growth and development which uses the various resources within the organization. Through sustainable approach, maximum utilization of resources can be done by the company. If the company maintains the sustainable development then it can easily gain the organizational goals and objectives. Further, there are various aspects of sustainability which are important for the success and growth of the company (Priem and Swink, 2012). This approach helps to make decisions effectively and it provides support for collaboration and teamwork. The managers and top management should maintain the sustainability of the organization. It will also help to reduce the global warming activities. Further, there is a close relationship between corporate social responsibility and sustainable development. There are three pilla rs of the sustainability; they are such as economic development, environmental protection, and social development. It helps in economic and social growth and development. It promotes environmental education and awareness to achieve the mission and vision of the company. Thus, the managers need to analyze and evaluate the market conditions and they analyze the relationship between the customers and company. It helps to reduce the pollution and waste generation. In this way, this approach maintains the effective sustainability in the organization (Peppard and Ward, 2016). There are various companies which use the sustainable approach in order to meet long-term growth and success. Starbucks, Coca-cola and Unilever companies exercise and maintain the sustainability of the organization to flourish and expand its business activities and operations across the world. The star bucks corporation uses the sustainable approach to attract the more customers in the market. After the various researches, it has been found that sustainable approach is initiated and implemented by the many companies (Rettie, Burchell and Riley, 2012). The suppliers, customers, and local community give full contribution in sustainable development. Many software companies also use the sustainable development approach to reduce the carbon emissions. Sustainability help to build the good position in the market. Through sustainability, the company can identify the threats and risks of the market as well as the competitors. In this way, it takes various competitive advantages and benefits. The organization can identify and analyze the plans and policies of the competitors through excellent sustainable development (Luyet, Schlaepfer, Parlange and Buttler,2012). All these strategic management approaches play a significant role in every organization to face the various challenges and obstacles. Limitations of strategic management approaches Although, entire approaches of the strategic management are playing a vital and integral role in every business organization. But the organization faces many challenges and difficulties. The interest of the stakeholders is the big issue in these strategic management approaches. The company cannot measure the interest of the stakeholders in monetary terms. Involvement of stakeholders in the stakeholder's approach takes a lot of time. Therefore, various limitations exist in the stakeholder's approach (Osbaldiston and Schott, 2012). On the other hand, there are various limitations exist in the dynamic capabilities. Through this approach, many companies annoy the various existing resources in order to gain long-term competitive benefits across the world. In this way, they waste the various resources to gain long the long-term growth and success in the market (Hassini, Surti and Searcy, 2012). Another side, many organization face various difficulties with using the sustainable development approach within the organization. The sustainable approach affects the national policies adversely. Sustainable development is based on the set of requirements, therefore, it creates various problems within the organization. It is affecting the culture and social services of the country. Therefore, the company needs to focus on these limitations and weaknesses in order to meet long-term mission and vision of the corporation (Garcs-Ayerbe, Rivera-Torres and Murillo-Luna, 2012). Recommendation After the various researches, it has been analyzed that the company is using the various strategic management approaches in the organization. The main objective of the strategic management is to gain long-term sustainability. The company should comply the various rules, regulations, laws and corporate social responsibilities. It should focus on the limitations and shortcomings of the strategic management approaches. In this way, the company can meet and achieve the various long-term goals and objectives of the organization. Further, the company should use innovative technologies to gain the competitive benefits in the market across the world. To reduce the limitations and obstacles, the organization should develop and build the effective human resource management. Conclusion The report is based on the strategic management. The strategic management approaches play a vital role in the growth and sustainable development of the company. These approaches help to maintain the trust among the various stakeholders. The strategic management helps to build and maintain the strong and effective position and goodwill of the company in the market. On the other hand, these approaches consist some limitations which are not good for the success and growth of the company. These limitations affect the business activities and operations adversely. Now it is concluded that the company must make the effective strategies to overcome on the competitors. The organization should use the maximum utilization of resources and assets. In this way, the company can increase its revenue and outcomes. The association should focus on the key challenges and barriers of the strategic management approaches. The company should maintain the sustainable human resource department to formulate a nd implement the various policies and plans for the success and growth of the organization (Sangr, Vlachopoulos and Cabrera, 2012). References Bateman, T.S. and Snell, S., 2013.Management: Leading collaborating in a competitive world. McGraw-Hill Irwin. Foss, N.J. and Knudsen, C. eds., 2013.Towards a competence theory of the firm(Vol. 2). Routledge. Garcs-Ayerbe, C., Rivera-Torres, P. and Murillo-Luna, J.L., 2012. Stakeholder pressure and environmental proactivity: Moderating effect of competitive advantage expectations.Management Decision,50(2), pp.189-206. Grant, R.M., 2016.Contemporary Strategy Analysis Text Only. John Wiley Sons. Hassini, E., Surti, C. and Searcy, C., 2012. A literature review and a case study of sustainable supply chains with a focus on metrics.International Journal of Production Economics,140(1), pp.69-82. Jantunen, A., Ellonen, H.K. and Johansson, A., 2012. Beyond appearancesdo dynamic capabilities of innovative firms actually differ?.European Management Journal,30(2), pp.141-155. Kindstrm, D., Kowalkowski, C. and Sandberg, E., 2013. Enabling service innovation: A dynamic capabilities approach.Journal of business research,66(8), pp.1063-1073. Klievink, B. and Janssen, M., 2009. Realizing joined-up governmentDynamic capabilities and stage models for transformation.Government Information Quarterly,26(2), pp.275-284. Laczniak, G.R. and Murphy, P.E., 2012. Stakeholder theory and marketing: Moving from a firm-centric to a societal perspective.Journal of Public Policy Marketing,31(2), pp.284-292. Luyet, V., Schlaepfer, R., Parlange, M.B. and Buttler, A., 2012. A framework to implement Stakeholder participation in environmental projects.Journal of environmental management,111, pp.213-219. McKelvie, A. and Davidsson, P., 2009. From resource base to dynamic capabilities: an investigation of new firms.British Journal of Management,20(s1). Osbaldiston, R. and Schott, J.P., 2012. Environmental sustainability and behavioral science: Meta-analysis of proenvironmental behavior experiments.Environment and Behavior,44(2), pp.257-299. Paiola, M., Saccani, N., Perona, M. and Gebauer, H., 2013. Moving from products to solutions: Strategic approaches for developing capabilities.European Management Journal,31(4), pp.390-409. Pearlson, K.E., Saunders, C.S. and Galletta, D.F., 2016.Managing and Using Information Systems, Binder Ready Version: A Strategic Approach. John Wiley Sons. Peppard, J. and Ward, J., 2016.The strategic management of information systems: Building a digital strategy. John Wiley Sons. Petit, Y., 2012. Project portfolios in dynamic environments: Organizing for uncertainty.International Journal of Project Management,30(5), pp.539-553. Priem, R.L. and Swink, M., 2012. A demand?side perspective on supply chain management.Journal of Supply Chain Management,48(2), pp.7-13. Rettie, R., Burchell, K. and Riley, D., 2012. Normalising green behaviours: A new approach to sustainability marketing.Journal of Marketing Management,28(3-4), pp.420-444. Sangr, A., Vlachopoulos, D. and Cabrera, N., 2012. Building an inclusive definition of e-learning: An approach to the conceptual framework.The International Review of Research in Open and Distributed Learning,13(2), pp.145-159. Vogel, R. and Gttel, W.H., 2013. The dynamic capability view in strategic management: A bibliometric review.International Journal of Management Reviews,15(4), pp.426-446.

Determination Of Permanent Establishment †Myassignmenthelp.Com

Question: Discuss About The Determination Of Permanent Establishment? Answer: Introducation The present study is concerned with the evaluation whether Taite and Aramis British resident planning to establish a trade of land development whether or not they would be considered assessable for purpose of taxation under the Permanent Establishment. The definition of permanent establishment is provided under subsection 6 (1) of the Income Tax Assessment Act 1936 will be applied under of ITAA 1997 and Schedule 1 of the Taxation Administration Act 1953, given that there is a different intention (Kiprotich 2016). The above stated rulings will be applied on an individual who is an Australian resident and carries out the activities of trade overseas or is a non-inhabitant of Australia performing business activities in Australia and looking for direction on having a place with the reason under subsection 6 (1) of the definition (Pope, Rupert and Anderson 2016). It is noticed that Taite and Aramis are British resident and they are looking to establish a parent company by using borrowed money through corporate structure and by financing the sum borrowed at the commercial rate to a completely owned auxiliary company. As noticed in the study that the definition of Permanent Establishment is defined under Subsection 6 (1) of the concept used in tax treaties of Australia. As defined under the Taxation Ruling TR 2002/5,Permanent Establishment can be defined as the place from where a person performs the commercial functions from the reference to the place which is used to perform the business activities (Chan 2013). Since Taite and Aramis have decided to set up parent company in Australia, the place becomes the elements of permanence both physically and temporally. Permanence must be understood in the current context as the element fact and degree. Hence, permanence in regard to Taite and Aramis proposal of setting up the business do not signify everlastingly. The type of business undertaken by Taite and Aramis is temporary and consists of use of land for land development and disposal. A place through which a person performs the business in present scenario of the definition stated under subsection 6 (1) must be enduring but in present situation the business is not permanent of nature (Miller and Oats 2016). The second criterion to conclude the place of executing the trade is stated in the definition of PE under subsection 6(1) is temporary business. The nature of business for Taite and Aramis consists of development of land for only five year. According to subsection 6 (1) of the PE the trading activity must execute its functions for the period. This must be determined in the current scenario of the business and becomes the piece of evidence. As held in Applegate v. FCT78 ATC 4054 at 4060; (1978), permanent does not mean forever. The phrase permanent is used in the sense of something that needs to be differenced either provisional or temporary (Christie 2015). Permanence does mean forever and this is only sense, which is applied in this ruling. It is a matter of truth and degree that whether temporary permanence prevails. Nevertheless, being an advisor if Taite and Aramis operate at or from a place continuously for greater than the period of six months that place will be considered as temporally permanent. Role of permanent establishment plays in determining the tax liability in Australia: As defined under subsection 6 (1) of PE under ITAA 1936 the definition of permanence originated and sustained in the previous approach (Zeff 2016). The definition of permanent establishment defined under 1946 UK DTA indicates mainly the introduction of force of law to the UK 1946 Double Tax Agreement. The notion Permanent Establishment plays a vital role in assessing the tax liability in the international and domestic taxation law. It is generally used in Australia in determining tax treaties with UK created in 1946 (Fleurbaey and Maniquet 2015). In the domestic taxation law of Australian it purposely appeared out of the tax treaty context in 1959. Permanent establishment plays a vital role in assessing the tax treaties of Australia, which represents that, the permanent position of business from where the business activities of the enterprise are completely or partially executed. On assuming that the taxable entities involved are the inhabitant of Australia for the purpose of taxation under the Taxation Rulings TR 2004/4 it considers the deductions for interest that is occurred prior to the commencement of or consequent to the cessation of vital revenue earning activities (Kabinga 2015). As observed from the present study that, the business model consist of deal of subsidiary company by shares to accommodate the application for tender and its successive refinancing from the present need of loan including the interest expenses. According to Taxation Rulings TR 2004/4 it is considers the deductibility of the interest expenditure that is occurred prior to the beginning of the revenue earning activities and interest expenses that takes place after the income earning capacities have ceased. Taxation Rulings TR 2004/4 is applicable to the income years, which commences both prior to and after the date of issue. The deduction of interest in the current situation of Taite and Aramis is typically determined based on evaluation of borrowing and the uses of such borrowings (Razin and Sadka 2014). Citing a reference to the case of Steele v. FC of T99 ATC 4242; (1999) 41 ATR 139 generally, the objective of borrowings was assessed from the nature of usage of borrowed funds. Interests that are outgoing is understood as recurring expenses. As a fact borrowed funds may be used to get hold of capital asset but does states that the outgoing interest is based on the capital account. As held in Steele v. FC of T99 ATC 4242; (1999) 41 ATR 139 interest incurring that period prior to the commencement of significant taxable income will occur in attaining or producing the taxable income. Therefore, it is not introductory to the revenue earning actions and it does not result in those actions. Citing the reference of Kidston Goldmines Ltd v. Federal Commissioner of Taxation the judgement lays down the explanation on the theory that the use of funds and a persons purpose in vital in measuring the deductions of the interest in the form of tool in supporting the resolution (Laporte and Rota-Graziosi 2014). The statutory issue that surrounds the current scenario of Taite and Aramis is whether the outgoing of interest occurred in the course of income producing activity or under the criterion of second limb of the section 8-1 of the ITAA 1997. In deciding the present case, the interest expenditure is regarded as an outgoing that occurred in producing the taxable income. It is vital to remain indulged in addressing the difference between the purpose of the taxpayer while borrowing the money and use of borrowed funds. The principles of financing stated in the case of FC of T v. Roberts defines that borrowing to refinance funds and using the same in the business will be regarded for deductions if the funds takes the form of partnership capital. Citing the case of Texas Company (Australasia) Limited v. FC of T(1940) 63 CLR 382 the system of Australian taxation takes into the considerations the borrowed interest funds to protect the capital in regard to the existing income producing activities (Schreiber 2013). Interest paid in getting hold of the capital asset that is used in the later stages as the income producing activities is considered as an enduring asset and can be put into use for the planned activity. In the current scenario of Taite and Aramis the implication is that interest expenses is considered as capital expense and it is capital in nature. As observed from the present study, that capital asset is created and the payment of interest is regarded as recurring in nature. Interest is gene rally recurring or cyclic payment, which does not consider an enduring advantage as an alternative the usage of the borrowed funds all through the term of finance (Ma 2017). Deductibility of anticipated loss: The deductions of loss comprises of interest stated section 8-1 of the Income Tax Assessment Act 1997 is primarily dependent on the satisfaction of the words for the above defined section. According to the TR 95/2, the anticipated loss or the outgoing incurred by the taxpayer in achieving the taxable revenue of the taxpayer and the loss does not consist of capital in nature (Djambov et al. 2016). The existing scenario of Taite and Aramis evidently reflects that whether or not the taxpayer incurs loss or outgoing interest, it suits the requirement of section 8-1 based on the information and materials linked with the loss that was incurred by the taxpayer in query. As stated in the case of FC of T v. Smith92 ATC 4380 interest on borrowing to fund the repayment of money that was at first stage advanced by the associates and used in the form of capital in partnership firm that will be regarded for deductibility under subsection 51 (1). Interest on borrowing will be regarded as deductions to the extent where the capital was used in the trade that was executed with the purpose of generating or acquiring the taxable income (Barkoczy 2016). The present case of Taite and Aramis determines whether the interest will be considered for deductions in the commercial context at the time when the business borrowed funds. On applying the analysis of federal court in FC of T v. Roberts, interest on borrowing by the company should be regarded for deductions. (Tan, Braithwaite and Reinhart 2016) It might be under that circumstance where the borrowed funds is put into the use for refunding the reimbursement of share capital to the shareholders along with the capital that is repaid was used as the working capital in the business activities executed by the company with the purpose of producing assessable income. Expenses will be regarded for deductions under section 8-1 if the required aspects of the expenses has adequate link with the activities that directly leads in generating assessable income of the assessor (Blakelock and King 2017). Citing the case of FC of T v. Riverside Road Pty Ltd90 ATC 4567 the court provides the summary regarding the applications of principles regarding the deductions under section 51 (1) of the Act. It is worth mentioning that expenses must possess adequate connection with the functions, which directly produces taxable income to fulfil the statutory criteria in performing the business (Braithwaite 2017). In assessing the deductions of loss for Taite and Aramis required attention must be given on the objective surrounding the event of loss. The present scenario of Taite and Aramis clearly meets the requirement of the taxpayers under section 8-1. Capital gains tax can be defined as the tax which is paid on the capital gain on the yearly income tax return. If a person acquires an empty land for the personal purpose or for the purpose of investment it is usually considered in the form of capital asset which is subjected to capital gains tax (Woellner et al. 2016). If a person purchase land for using it in the business activity transacting in land it would be regarded as trading stock. Land is generally treated as trading stock in determining the tax liability rather than regarding it as the capital asset as Taite and Aramis were engaged in the activities of land dealing and acquired the land for reselling it. Trade activities that consists of transacting in land comprises of acquiring the land with the purpose of developing or subdividing and selling the same (Robin 2017). It is worth mentioning that land acquisition is not necessary to be repetitive in nature. A single acquisition of land for the purpose of development, subdivision and sale by the assessor in the current context would lead the land being treated as a trading stock. Therefore, land used as trading stock, capital gains is not applied on it. Proceeds from land should be treated as the ordinary income and should not be regarded as capital gains and the cost that is associated would be considered for deductions. Identification of business risk: There are few types of risk which is associated with this plan are as follows; Increase in the rate of interest leading in greater cost of holding: It is apparently better to service the loan and make repayments where the rate of interest is low. Nevertheless, the assessor should take into the considerations the elements that is likelihood of rising the rates over the span land development (Almeida, Hankins and Williams 2016). There are examples where the seasoned land developers have fell in the trap of rising interest rate when they borrow huge sum of money on the reduced interest rate. Increased in the cost of construction: This is another kind of trap where most of the land developers fall. This comprises of set of narrowing cost in their budget at the time of commencing their plan irrespective of any kind of contingency plan in place of likelihood of probable increase in cost taking place yearly in the trade of land development. The developers are either compelled to borrow fund or they are forced to dispose their incomplete business project and shoulder the loss. Variations in demand and supply resulting in unpleasant variation in the price of real estate: Since large number of land developers understand the differences in the principles that runs the market of property it is also obligatory for them to evaluate the altering level of supply and demand during any period of time. Social alternations such as immigration and higher rate of interest represents declining activity of the purchaser and this might result in declining demand of customers. Risk assessment methods: Sensitivity analysis: Sensitivity analysis can be defined as the vital approach of analysing risk. Sensitivity analysis assist in assessing the effect created on profit associated to important variables (Almeida, Hankins and Williams 2016). The objective of senility analysis is to assess the set of alterations that will assist the appraiser in advancing from the stage of identification or outcomes for the variables that are controlled by distributing the likelihood to each of the variables. Risk evaluation is understood as the procedure of evaluating the recognized risk together with the correlation between the risks. At the time of risk assessment, a particular risk situation for any specified risk portfolio is plotted and becomes the base of subsequent risk control. To derive the answer of over viewing the correct actions of risk identified becomes the second step in analysing and evaluating. 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