Waste of Time free essay sample

College Is a Waste of Time and Money In this essay that came from Caroline Bird’s book â€Å"The Case Against College†, she claims that most students that are in school not because they want to be, but because it is now the thing to do or to get away from their parents. (Bird 647) She also goes on to say a little later essay that she notices when she goes on campus that the students look sad. She says, â€Å"I have been overwhelmed by the prevailing sadness on American campuses†. Bird 469) Birds has very good arguments, from how expensive college is, why a lot of students fail out of class, to letting high school graduates make up their minds on whether or not they want to go to college or not. Personally in my opinion I disagree with this essay. She talks about the money that goes into college, but fails to talk about the end outcome or should I say results. We will write a custom essay sample on Waste of Time or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Her reasons for this argument don’t even give her the right to say that college is a waste of time and money. She has no real evidence, and saying that you have been to many campuses where the people look sad just â€Å"Aint gonna cut it! † When I first read this essay, what caught my eye about it was the title. â€Å"College is a Waste of Money†, that is exactly how I was feeling. I was feeling like school was a set up for young adults to take out loans and be in debt. By just reading the title she draws you in because you’re like finally im not alone. Its is then when I snap back into reality, because I know that college is to help me. College is beyond learning for your profession, you learn so much more about life and yourself when you go off to college and you experience new settings. I do however agree with some of the things that she says, such as when she says that â€Å"if students believe that college isn’t necessarily good for them, you cant expect them to stay on for the general mankind†. (Bird 470) Meaning that if I say I don’t want to go to college because I don’t think that it is for me don’t force me to go because most likely im not goin to be focused on my school work, im going to be stressed out, which could cause me to fail out.

buy custom The Gothic Genre essay

buy custom The Gothic Genre essay Gothic genre is a style of literature that puts together both elements of horror and romance. It is thus sometimes referred to as Gothic fiction or gothic horror. It is believed to have evolved in the 1960s from a novel the Castle of Otranto by Horace Walpole. The literature was designed to scare readers by use of mystery and blood-curdling accounts of horrific scenes such as murder, villainy and use of supernatural beings. It is also associated with architecture commonly seen in Europe characterized by flying buttress, gargoyles (grotesques fitted into their nooks), biblical symbols and vaults. Distinct elements of Gothic fiction were ghosts, haunted houses, death, hereditary curses and terror. Gothic literature gained popularity when there was a rise of rationalism over religion and the changing of peoples lifestyle. During the evolution of gothic literature it thus filled a gap due to condemnation of Catholicism (Valdine, 1999). During this time the society was under pressure to change due to technology involved. It is evident, through the changing roles in women in the society. Through this women are made to choose their own fate. The emergence of divorce comes into play as society accepts it unquestioningly. Women are hence becoming more and more knowledgeable as gothic novels become their pal and writers. Therefore with the gothic situation made women to have voice as womens deep rooted fears about being powerlessness had since been faded away. Women were thus accepted into the genre which was not far dominated by men and hence used as an avenue to explore womens power. Notably there are various works of gothic from different writers such as Jane Austen (Northanger Abbey) and Mary Shelley (Frankenstein). They are thus both women who established there works through the genre. In this event women were able to explain the female and male interaction on a female perspective. The position of women was displaye d and the inequality in the society shown clearly through this art (Valdine, 1999). Northanger Abbey The gothic genre has played a critical role in social progress that is both politically, socially, and in economics structuring. Social progress which is still being realized has been accounted through theories that try to explain this progress in life. During the age of enlightenment reason was advocated for the achievement of lifelong goals. The age has since ended during the French revolution. In the Jane Austens Northanger Abbey she is observed as a Victorian as she designed the novel during the regency period, that is, during the end of the eighteenth century. Abbey mimicked the gothic genre. Composition of her novels took place before the romantic period. Works produced during this time were known as Neo-Classical which was highly linked to Enlightenment. During this period Europe saw the emergence of novels as a major genre. Austen hence educates women on the essence of life from the novels platform. She also promotes writing and embracement of literature works i.e. gothic gen re. She mimics Ann Radcliffes (Mysteries of Udolpho) her character as Morland is completely not as expected from the gothic point of view. She is in this way seen to be boring and has problems in luring men. Under normal situations she thinks otherwise, supernatural. In this event Austen manages to mimic the genre (Stephen, 2004). The romantic period saw the bringing forward of strict rules and guidelines. Thus romantic literature featured nature, freedom and exotic. Gothic literature makes romanticism as its peripheral it however, includes elements of fantasy and mystery. This works makes the reader to be placed among the ancient features being depicted hence he/ she becomes a character. It enhances its worth through psychologically involving the reader into examining themselves by employing reflections. Readers are put on the pulpit to make judgment on their own self (Stephen, 2004). Jane has brought forward gender equality and feminism into the forefront. Through her works lessons of womanly virtue are seen. Women are encouraged to improve on the ever competitive world and play major roles as popular social symbols. Women in this event are taught to be independent and eliminate traces of being second-class citizens. This is through their roles of protecting the males and total obedience. Hence social deviance was from women who are likeable in the public domain rather than within the house. Jane as a feminist had sought to change this situation and bring a wave of feminism in the society. It was during this period that saw the emergence of child daycare, family planning techniques and equal rights with their male counterparts. In addition to this women also engaged in politics and in the media. However through it negative social behavior sprouted, lesbianism came into existence as women tried to be independent. Statistics show that womens role are ever changing drastically. Womens roles invade mens initial roles in sciety. Some roles such as caring of children, division of household chores and gender related roles i.e. cohabitation and marriage (Honan, 1987). In her gothic novel Jane Austen focuses on societal issues which since that time have faced vigorous changes. Major issues that she emphasized on were money, marriage, legalities of marriage and its alternatives, place of women in the society, settlement, women and leadership and education. With this in mind very many issues surround it with the involvement of civil rights group the issues are on a cycle of change on the wake of another day. Frankenstein On the other hand Mary Shelley was a British novelist well known for her work Frankenstein. It has since inspired many in the field of literature. Shelley in her works argued that cooperation and pity that women harbor were the only way for social progress and creation of necessary reforms. She goes further and tries to educate the political forefront not have greed but have the compassionate heart of the female character. She values equality and harmony is the way forwards. In the novel Victor Frankensteins setbacks as a parents shows the anxiety of how we should embrace social progress. She thus focuses on the family as the key element in a society. Apart from this she also relays the significant role played by women and their role as women. This impacts to the importance the two which the civil society cannot do without. The novel promotes education and womens role in the society. It has hence it compels women to be less independent, showing that a man can not have a baby without a woman and vice versa. Therefore when feminist values reign over the violence and destructive men would express a better nature i.e. compassionate, sympathetic and generous (Paula, 1995). In the novel the protagonist Victor Frankenstein objects traditions and structures his own life. He is hence obliged to live his family in pursuit of his set goals. In Shelley enlightenment idea she saw that individuals could exercise healthy politics to improve the society. However, she also knew that misuse of excessive power would lead to the demise of society. For instance Frankenstein reads books that majorly deal with fundamental visionaries but this does not bring any impact on his life. Humanity could be perfected through good societal ethics if practiced. Through Frankenstein she shows revolution aging and rejection of romanticism and enlightenment visions which could be an alternative. Shelley therefore, portrays the reader as the decision maker who owns assumption at the end of the perusal. Frankenstein sees creation of life from corpses is wise. His main aim is to help mankind to overcome death and diseases. However at the end of his pursuit he realizes that he has far cr eated an ugly monster. He abandons what he has created. Victors attitude dramatically changes characterized by living his friends and sudden change of behavior. Shelley hence criticizes his ambition and responsibility rather than his creation works. He thus appeals to everyone for avoiding the careless use of science. In this sense Victor plays the role of scientist, whom from their works intends to be popular, this will dehumanize the society (Paula, 1995). In a different perspective Victor Frankenstein is compared to Prometheus who in mythology (Greek and Roman) he creates mankind similar to the likeness of God. He then takes the precious fire and gives it to mankind without any consent. Afterwards he faces Zeus wrath by being chained and his liver fed to the eagle. Therefore, this depicts someone who emerges above all forms of authority. Prometheus rose above gods by doing this. Here, Frankenstein is a rebel whereby he rebel against nature by trying to cheat death. Frankenstein as a result is romantic promethean hero by failing in his ventures, creation of human through corpses. His attempt to help man fails (Chris, 1990). Theory such as the feminist theory postulates that Victor is a sinner. He sins against God and nature. Apart from being sinful it is demeans women as the centre of natural procreation. The creation destroys the feminist ethic as the monster is as a result of a mysterious act, gothic in nature. Eventually women become less vital to the existence of humans. The man who is the centre of power deprives women the chance to procreate who without her existence life does not exist then. The creation of perfect beings through cloning borrowed ideas from this. Victor in his conscious nature realized he had committed a crime against females which is evident in his dream. Before the creation of the monster he killed his mother and girlfriend. Further he does not take responsibility as a father and abandons his child after its birth and leaves it under its mothers care. At the end Victor feels deeply committed he expressed it in rather a strange way. He gives up the creation of a perfect being ho wever his hopes does not fade away because he thinks someone else willl continue from where he stopped. It thus fully shows that Shelley did not condemn science but contrary forbid the careless use of science (Chris, 1990). A different face of the monster is shown when he saves a little child and helps De Lacey family. It also apart from that learns read and talk though his scary appearance. After being rejected several times he develops dislike on his creator and all humans. If the society had welcomed the monster it could have been otherwise. Mankind is to blame for not accepting the monster into their system with its outstanding physic and power. She further emphasizes that the impact of the life of human beings are as a result of social environment. The things we do and what affects us is all about nature, suggesting that wickedness comes with ill treatment. The risks posed to humans do not actually germinate from science but from the society in which we live in. From that extent Frankenstein words become clear that someone else should go on with his experiment and eliminate the defects of the monster he had initially created. Through this he wanted the creature at the end to be accepted into the so ciety, perfect human (Susan, 2007). Other critics view Frankenstein in more a different way i.e. ill criticism to religion. They view the creation of the being as commitment of sin against God. Thus his materials (corpses) are generated from social unrest during that time. It witnessed that scientist would only work to the satisfaction of mankind without restricting themselves to church values and ethics. Shelley agrees to this notion in The necessity of Atheism where God is put to question for lack of valid evidence of his existence. Hence Victor is not a qualified surgeon making sense why he cannot create a being (Susan, 2007). However, Marys main goal was to write a gothic fiction book, obtaining her idea from her hideous progeny inspired by a French translator. This contradicts with the book as gothic genre is characterized by supernatural beings, which is not depicted in the novel. Instead of the scary stylistic features she uses normal beings and natural scientific events. The perfectly evil and the good deeds are not completely noticed as use in gothic. It hence shows the development of the monster from it tender age to an adult. The setting of the story is in the 18th century rather than 15th as most gothic novels and is set on a Romanticism context (Susan, 2007). The novel is based on scientific ideas. Victor could in this way be a trigger to science fiction novel and promoter of social progress. In the recent years there emerged the test-tube babies which clearly show the borrowing of ideas from the monster creation. Besides test-tube babies we also have the creation of robots. Perhaps a more perfect idea is organ transplant which has so far made tremendous change in peoples life. The novel is seen as a symbol of changing times where modernization is rapidly encroaching. The social life of many societies observed changes both in nature and science. The monster is hence a foundation of ever improving technology from its toddler stage to full maturity. In todays world science plays a very critical role eating a humble pie from the gothic genre and its core founders. It is much clear that science has brought an understanding of the past, present and future and it is ever in a constant loop. Scientific progress should credit the establishment of the gothic genre. Social life is improving day by day by creating a more comprehensive idea of human philosophy (David, 1998). Impact of Gothic Genre The gothic genre has hence improved social life but not acted as a reaction to it. However, it has very minute incidence of reactions to Enlightenment ideals of reason, harmony and social progress. Such incidences include: womens position in the society is natural and are a symbol of natural procreation. The male partner cannot exist independently as a unit but will need assistance from the woman. This shows that society without the interaction of beings it is bound to fail in its existence. We have also witnessed that nature puts women into their position as the caretaker of the male while obeying him. However much we try to oppose it through change of roles it still remains natural and one cannot distort natures dramas. Perfection is not for man but for God as it is seen that as far as many tries to discover scientific projects perfection cannot be fully be reached. The monster in Frankensteins creation shows this (Fergus, 1991). The gothic genre is hence a calling for women to wake up. Social progress will be evidence through this as gothic ideas were seed to some scientific discoveries. We should in this way embrace the gothic genre and credit it for its eye opening. Society has then seen equality and progression through attainment of knowledge. Buy custom The Gothic Genre essay

The Fabrication Of Bipolar Junction Transistors By Diffusion Planar Lab Report

The Fabrication Of Bipolar Junction Transistors By Diffusion Planar Process - Lab Report Example The fabrication of BJT comprises of various sub-steps like RCA (Cleaning Process), Thermal Oxidation, Photolithography, Diffusion, Metallization, Alloying Process etc. The process of fabrication starts by cleaning the substrate of impurities by the RCA procedure followed by developing a layer of SiO2 on the planar surface by the process of oxidation. The wafer is then coated with an appropriate photoresist material and developed by exposure to UV through base mask (mask #1). After sufficient time of exposure, the SiO2 is removed by etching out from the region of base-diffusion followed by cleaning away the covering of the remaining photoresist coating. The P-type base i.e. Boron is diffused into this region followed by re-oxidation to develop the layer of SiO2. Next, by the process of Photolithography, the oxide layer is stripped off from the regions of collector and emitter by mask #2 and Phosphorous (N-type) is diffused on it. The entire sample is re-oxidized and once again coated with the photoresist material and developed. The substrate is then exposed to vapors of Aluminum which are allowed to condense upon it. The excess Aluminum on the substrate i.e. at non-contact regions is removed chemically by ‘lift-off’. The final step in the process is alloying of the contacts. RCA Dust, SiO2, oxides and metallic contaminants are removed. Consequently, the process has three chief procedures namely the Organic Clean, the Oxide Clean and the Ionic Clean. [5] â€Å"The RCA clean procedure should be performed immediately prior to any crucial step, especially those involving high temperatures.†[2] The RCA clean procedure consists of the following steps: Mixing of Organic, Inorganic and Oxide Stripping Solution 1. The Organic Solution is prepared by adding 1000 ml of H2O to 200 ml H2O2 and 200 ml of NH4OH. Heat the solution for 15 min at a temperature of 80  °C. [2] 2. The Ionic Solution is prepared by adding 1000 ml of H2O to 200 ml H2O2 and 200 ml of HCl. Heat the solution for 15 min at a temperature of 80  °C. [2] 3. The Oxide Stripping Solution is prepared by adding 2000 ml of H2O to the polypropylene vat. Add 40 ml of HF acid into it. [2] Bubbler Rinse Set-Up The bubbler rinse station is filled with deionized water and nitrogen is bubbled in it. [2] O rganic Clean This step removes dust, grease and other organic impurities from the substrate. The substrate is submerged in the Organic Solution for 15 min and then placed in the Bubbler Rinse Set-up for 5 min. [2]

Portable fun instrument Research Paper Example | Topics and Well Written Essays - 500 words

Portable fun instrument - Research Paper Example Therefore in this age, it is important for the company to come up with applications for smartphones to remain in market. There are two most commonly used operating systems in smartphones; Android and Apple. Android is the operating system found in different smartphones manufactured by Samsung, LG, HTC and others. However, smartphones of Apple uses its own operating system, iOS. iOS will only run in smartphones and tablets manufactured by Apple. However, android is found in different smartphones and tablets produced by other companies. In order to select which operating system, it is important to know that both these operating systems have their pros and cons. Android allows users to have more flexible applications. However one issue with android is that there are many versions of android available. On the other hand, Apple offers exceptional experience. Retina  display technology has been introduced by Apple and it is the most pixel-rich display on any phone till date. Applications of Apple are more exclusive when compared with android. Moreover, applications of iOS generate more revenue and are sold more. So it depends on what features the company would like to go for. However, as iOS is more exclusive and has more revenue than Android, therefore the company should go for Apple (Yarow). PART 2 The number of smartphone users is increasing and therefore it has become important to come up with an application for smartphone users. Smartphones are no more used by business professionals but people of different ages use smartphones. In order to come up with an application for smartphone, one has to choose from either android or iOS. Therefore it is important to analyze the strengths and weaknesses of these two operating systems. The number of users of Android is increasing and this provides more opportunities for the company. Moreover, there are more applications coming in the market related to Android so this shows the trend of the

The long term effects of drug abuse on the unborn fetus of a pregnant Dissertation

The long term effects of drug abuse on the unborn fetus of a pregnant mother - Dissertation Example It is believed that drug abuse by pregnant mothers causes maladaptive behaviors stemming from Axis II diagnosis including (but not limited to) bipolar disorders, borderline personality disorders, schizophrenia, conduct disorders, antisocial and learning disorders. Introduction Substance abuse is linked to a number of different physical and mental defects in the offspring of abusers. A large volume of research exists on the phenomenon and its various dimensions. The physical and mental disabilities endowed to the fetus of substance abusers are complex and have thus been categorized into various systems for closer examination. This research will largely be concerned with a systematic study of long term effects on the fetuses of substance abusers based on Axis II diagnosis alone. A large amount of rich material both of a qualitative and quantitative nature exists for the current research area. The current research will rely on the examination of existing literature since it has both qua ntitative findings and quantitative findings. This will allow the current research to utilize qualitative methods in order to derive qualitative findings that are supported by quantitative results. The current research could have been geared for a pure mixed methods research but the shortage of time and resources precludes any such methods. In order to investigate fetuses that are born from substance abusing mothers, a large sample set and an adequate amount of time is required. The typical time required for such research would be at least a few years since the born child would only display Axis II disorders when they reach their early learning years. However, the shortage of time and the lack of access to a large sample set ready to participate in quantitative research require that the current research be geared towards qualitative methods alone. As mentioned before, the provision of both qualitative and quantitative results also supports the contention that a comprehensive literat ure review would suffice for the current research. Background to Drug Abuse during Pregnancy Drug abuse refers to the consumption of drugs without direct medical advice or supervision. It is widely believed that drug abuse relates to the recreational abuse of mood altering substances but the use of any drugs for performance enhancement is also essentially drug abuse. Based on this classification, drug abuse involves drugs that are mood altering, performance enhancing as well as psychoactive in character. The use of any forms of drugs, whether legal or illegal, is considered as drug abuse as long as there is no medical justification for their use (Ksir & Ray, 2002). Another major feature of drug abuse is the dependence created by drug use. Drug abusers or substance abusers require continuous consumption of the subject drug in order to satisfy their body’s urges. The number of drugs being abused around the world is too large to be discussed within the framework of this research alone. However, the most common feature displayed by all used drugs is the tendency of the user to rely excessively on the subject drug for mood altering or performance enhancement purposes (Barrett, Meisner, & Stewart, 2008). The dependency of the drug abuser on the drugs causes the greatest problems during pregnancy because the drug abuser is unable to

Principles of Australian Taxation Law

Principles of Australian Taxation Law Sita  Samtani Introduction This paper will critically discuss the proposals made by the Organisation for Economic Co-operation and Development (OECD) for a mandatory disclosure regime in Australia. In May 2016, the Australian Government sought input into the framing of the recommendations made by the OECD, in its Discussion Paper.[1] Mandatory disclosure rules are examined in the OECDs Final Report of the Base Erosion and Profit Shifting (BEPS) project.[2] Primarily, these rules seek to combat aggressive tax arrangements, which pose a threat to revenue authorities worldwide. This paper will analyse the purpose and framing of these rules, their advantages and disadvantages and whom and what they should target, having reference to the Discussion Paper and other valuable sources. Additionally, there will be a critical analysis as to whether a mandatory disclosure regime would be an effective addition to Australian taxation legislation and how it may impact solicitors that advise on revenue law. Background Mandatory disclosure rules should be framed having regard to the integrity measures found in current legislation. A key point of distinction is discerning between lawful tax planning activity and unlawful tax evasion. Tax avoidance, which is the focal point of the mandatory disclosure rules, lies between the two polarities. It involves entering into arrangements that exploit loopholes in the legislation.[3] Under Australian taxation law, there are a number of anti-avoidance measures already in place. These include specific anti-avoidance rules (SAARs), general anti-avoidance rules (GAARs) and a promoter penalty regime. There are many types of SAARs that target specific tax avoidance activities, for example, the Personal Service Income (PSI) rules and transfer pricing. On the other hand, GAARs (Part IVA of the Income Tax Assessment Act 1936 (Cth)) act as safety net or fall back provisions. Justice Pagone highlighted the fact that GAARs occupy a special role in tax law because their ro le is to underpin the effectiveness of the primary operative provisions when those primary provisions fail to achieve their purpose.[4] Additionally, the promoter penalty regime in Divisions 290 and 298B of Schedule 1 to the Tax Administration Act 1953 (Cth) seek to force promoters to disclose potential tax exploitation schemes. The promoter penalty regime bears resemblance to what a mandatory disclosure regime might achieve. Therefore, a key priority will be ensuring that a new regime does not unnecessarily overlap with existing disclosure rules.[5] It is vital to avoid duplication of and inconsistency with other legislation, as well as excess compliance costs on the vast majority of taxpayers who voluntarily comply with their tax obligations.[6] This regime must also be framed not to infringe on Australian legal rights such as confidentiality, legal professional privilege (LPP) and the privilege against self-incrimination.[7] It is essential that such legislation be shaped in a way that balances policy considerations, the integrity of revenue authorities and fundamental rights. Definition of a Mandatory Disclosure Regime A mandatory disclosure regime is a mechanism that requires taxpayers to disclose upfront to the tax administration system of the use of tax avoidance schemes with certain features or hallmarks.[8] According to the OECD, the purpose of mandatory disclosure rules is to require tax advisers to make early disclosure of aggressive arrangements (often before income tax returns are lodged) with the view to providing tax authorities with timely information on arrangements that have the potential to undermine the integrity of the income tax system.[9]This statement provides a useful matrix to ascertain the essential elements of a mandatory disclosure regime.[10] The purpose of a mandatory disclosure regime is to supply prompt information to revenue authorities of possible aggressive tax schemes and to identify the promoters and users of such schemes.[11] The purpose of this detection is to improve the effectiveness of compliance activities of tax authorities.[12] In regards to the core purpose of mandatory disclosure rules, the supply of early information would allows administrators to identify, address and counteract tax avoidance schemes in their initial stages before they escalate and potentially subvert the integrity of the revenue base.[13] This information can also be utilised to enhance and better focus existing audit processes.[14] Mandatory disclosure regimes can enable countries to quickly respond to tax avoidance risks by providing early access to potential avoidance schemes. The Policy Rationale of a Mandatory Disclosure Regime The main policy rationale behind implementing a mandatory disclosure regime in Australia is to bolster the current anti-avoidance mechanisms by allowing the Commissioner of Taxation prompt disclosure of potentially aggressive tax schemes. This in turn will prevent the exploitation of loopholes that exist within the tax system. These rules will provide the Australian Taxation Office (ATO) with information as early as possible in relation to certain tax arrangements that are being designed and promoted by certain advisers and engaged in by certain taxpayers.[15] A further policy rationale of the new rules is to deter advisers and taxpayers from engaging in these types of arrangements in the first place.[16] In Australia, the current series of anti-avoidance legislation is elaborate, there are SAARs, GAARs and promoter penalty regimes which all seek to prevent the erosion of the revenue base. Table 1 of the Discussion Paper details the current legislation. There are a range of income tax disclosure rules in relation to large businesses and multinationals. These include disclosures made by companies both before (e.g. Advanced Pricing Agreements) and as part (e.g. Reportable Tax Positions) of their tax returns.[17] Mandatory disclosure rules should capture not only large entities but also high net-worth individuals or individuals that seek to exploit or promote the exploitation loopholes in the Australian taxation system. This is important to ensure a level playing field for all and so that the regime is ubiquitous. In relation to what activities a mandatory disclosure regime should exclude, it may be useful to look to what the GAARs (Part IVA of the Income Tax Assessment Act 1936) do not apply to. The GAARsdo not apply to a typical husband and wife partnership business agreement. Under this set up, the couple conduct a business in partnership and as the relevant Partnership Act provides, share equally in profits and losses, despite the fact that only one party performs the main amount of work.[18] When regard is had to the eight matters in Part IVA, it would not be objectively concluded that the main purpose of the partnership arrangement was to obtain a tax benefit through the equal division of profits and losses.[19] Similarly, it is possible that a mandatory disclosure regime should not apply to these partnership arrangements for the same reasons. A comprehensive disclosure regime in Australia would give rise to several advantages and disadvantages. Firstly, a main advantage would be the expeditious identification of potentially aggressive tax planning schemes. This means that the ATO would have to spend less time and utilise less resources in order reduce tax avoidance.[20] Targeted groups would not be as likely to exploit loopholes which exist if Australia had a mandatory disclosure regime. This would firstly lead to enhanced audit and compliance activities which would ultimately lead to quicker dispute resolution in cases where tax avoidance is ascertained.[21] The rise of the technology has also lead to the proliferation of real time intelligence. The need for revenue authorities to access real time information is particularly critical in the current technologically advanced world, where transactions and information can be transmitted internationally and almost instantaneously.[22] Thus access to fast and accurate informat ion is vital for revenue authorities to monitor and police such transactions. The main disadvantage of a mandatory disclosure regime would be the difficulty in finding an appropriate balance between enhancing information available to the ATO to crack down on tax avoidance and avoiding unnecessary compliance burdens on tax payers.[23] In this regard, the legislation should be very clear on its face that the mandatory disclosure rules would only be triggered in relation to defined tax arrangements with specific features and the rules are targeted at advisers who are actively involved in these tax arrangements.[24] A tension also exists between legal professional privilege (LPP) and a mandatory disclosure regime.[25] LPP is sacrosanct in Australia and is referred as part of the functioning of the law itself.[26] If an entity is obliged to disclose a document that would be protected by LPP, the function of LPP would be undermined which may in turn be a breach of an Australian civil right. In Australia, there are already rules in place that capture and penalise activity by taxpayers and advisers that results in non-compliance with tax laws, particularly in relation to aggressive tax planning schemes. The mandatory disclosure rules adopted into the Australian tax system would therefore need to complement the other integrity measures already in the system. The Drafting, Framing and Targeting of a Mandatory Disclosure Regime Australias rules must be tailored for Australias circumstances and in particular to complement its pre-existing disclosure and anti-avoidance measures.[27] The introduction of a mandatory disclosure regime should be specifically directed at people who are required at law to disclose to the Australian Federal Commissioner of Taxation in relation to certain tax arrangements.[28] Who should disclose under a Mandatory Disclosure Regime? It is great importance that the legislation sets out the meaning of particular terms. The initial views of the Australian Government are that mandatory disclosure rules should apply primarily to tax advisers involved in the design, distribution and management of aggressive tax arrangements. Moreover, the Government is also of the view that where the relevant tax adviser is offshore, the Commissioner may instead require the taxpayer to make the disclosure.[29] The OECD has advised that the rules could apply to tax advisers, taxpayers or both. The mandatory disclosure rules should be narrow and targeted, so that the scope is not too wide to incorrectly identify the actual perpetrators of tax avoidance schemes.[30] Taxpayers will be caught under the mandatory disclosure rules where they have participated in arrangements that become the subject of mandatory disclosure.[31] However, as taxpayers already have a general obligation to disclose information about arrangements and transactions that give rise to tax implications for them, it is not necessary that a separate obligation to disclose be imposed on taxpayers under these rules.[32] Similar to the UK, the suggestion is that disclosure made should be by promoters of schemes with the onus only shifting to the tax-payer in certain situations. In line with the Australian Governments views, the new rules would have to provide a clear definition of tax advisers or promoters for the mandatory disclosure rules. It is logical that the obligation should be in line with promoter definition under the promoter penalty regime under the Taxation Administration Act 1953 as they already have significant obligations. Thus, it is possible that compelling promoters to disclose relevant information in relation to tax arrangements pertaining to the hallmarks would simply consolidate and extend their existing obligations under the promoter penalty regime. Additionally, the promoters of such schemes would be in possession of the information relevant to formation of such avoidance schemes. If this existing definition of a promoter under the current legislation was utilised, then an entity would be a promoter if: they encourage growth of a scheme, they receive consideration in respect of developing a scheme and if they have a substantial role i n advancing the scheme. It is important to note that an entity should not be regarded as a promoter just because they provide advice about a scheme. This is particularly relevant when it comes to legal professionals providing advice which will be discussed later in the paper. What types of arrangements should be targeted? The effectiveness of any disclosure regime will revolve around the drafting of hallmarks or the trigger points for disclosure.[33] It is impractical for a mandatory disclosure regime to target all transactions that raise tax avoidance concerns. Taxpayers will be obliged to disclose transactions that fall within the descriptions or hallmarks set out in a regime.[34] In the Discussion Paper, there is significant emphasis on the targeting of aggressive tax arrangements. However, there is little reference to what this actually means. Both the Canadian and the UK disclosure regimes target arrangements in which the main (or one of the main) purposes of the arrangement are in order to obtain a tax benefit. Under the general anti-avoidance rules, section 177D in Part IVA of the ITAA 1936 sets out factors relating to the schemes used to obtain tax benefits. This section has often proved difficult in its application because the factors are quite narrow. To avoid issues like this, a lower threshold should utilized under a mandatory disclosure regime. It would be preferable that the test should be whether one of the main purposes of the arrangement is obtaining a tax benefit.[35] This lower threshold would mean that a wider range of schemes could be identified and disclosed.   The Australian mandatory disclosure rules should also have an objective test for disclosure, meaning that the administrator would not have to inquire into the subjective state of mind of the taxpayer.[36] Additionally, the Australian Government may also want to consider whether an aggressive tax arrangement may be in line with the definition of a tax exploitation scheme under the promoter penalty rules.   The definition of a tax exploitation scheme is whether it would be reasonable to conclude that an entity that entered into the scheme has a sole or dominant purpose of acquiring a tax benefit in which it is not reasonably arguable that the benefit sought is or would be available at law.[37] The definition of tax exploitation scheme would likely be very similar to that of an aggressive tax arrangement under the mandatory disclosure regime. It would be most effective if mandatory disclosure rules target arrangements in which one of the main purposes is to obtain a tax benefit that may potentially amount to tax avoidance. This should be an objective test, for example, would a reasonable person believe that the arrangement might be in order to obtain a tax benefit that may potentially amount to tax avoidance? What are the benefits and drawbacks of providing the Commissioner of Taxation a broad discretion to determine what is an aggressive tax planning scheme? There are already a number of mechanisms through which information relating to aggressive tax arrangements is disclosed to the Commissioner. Currently, the Commissioner has the broad administrative powers to require the disclosure of information. However, in the case of the proposed mandatory disclosure rules, the Commissioner can require disclosure to be made without knowing who needs to make the disclosure.[38] It is important the mandatory disclosure rules require the Commissioner to have evidence of the tax arrangements that he intends to be disclosed pursuant to the rules before he can exercise his discretion and make a publication requesting disclosure.[39] Otherwise, if the Commissioners powers are too broad, the process may become ineffective and counter-intuitive. The Commissioner should clearly articulate why the arrangement is an aggressive tax arrangement in line with the objective purpose test.   This will then allow advisers to effectively determine whether they are involved in these arrangements and whether they have an obligation to make a disclosure to the Commissioner. In line with the Australian Governments view, the legislation should make it clear that mandatory disclosure rules would only be triggered in relation to aggressive tax arrangements with specifically described features.[40] This will ensure the disclosure rules can be limited to particular arrangements implemented by a specific targeted cohort, rather than imposing more general disclosure requirements on all taxpayers. What are the implications of early disclosure? An early disclosure regime would provide the ATO with information about aggressive tax schemes as well as the parties to such schemes. In comparison with the United Kingdom, the Disclosure of Tax Avoidance Schemes (DOTAS) regime provides early information to Her Majestys Revenue Customs (HMRC). This information enables HMRC to legislate to amend the relevant taxation legislation to better target anti-avoidance activities.[41] The UK mandatory disclosure regime provides prompt information to the revenue authority allowing for easier identification of the users of anti-avoidance schemes.[42] The United Kingdoms DOTAS regime has successfully eliminated over  £12 billion in tax avoidance schemes and loopholes.[43] This is a strong indicator that such a regime in Australia may have the same effect. The UK regime has lead to over 2500 disclosures and the enactment of 60 different measures contained in the UK Finance Acts.[44] Similarly, a regime in Australia may guide in the legislating of better targeted SAARs and GAARs. It is likely that a similar disclosure regime in Australia would have a similar effect. The implications of early disclosure allow for revenue authorities to either use the information to improve risk assessment systems, review guidance and ruling products to determine suitable and contemporaneity, undertake additional educational programs and undertake case reviews and audits where appropriate or necessary.[45] Would mandatory disclosure rules be a necessary and valuable addition to Australian tax legislation? It is likely that a mandatory disclosure regime would be a necessary and appropriate addition to Australias existing anti-avoidance armoury. This paper weighs the advantages and disadvantages of such a regime and the legislative form that the regime should take. The necessity to acquire early information in regards to aggressive tax schemes is crucial to revenue authorities. While there are several ways that Australia acquires information now, it is possible that a mandatory disclosure regime is a more methodical approach. After researching the current anti-avoidance legislation, it is likely that the introduction of a regime would enhance rather than take the place of the current tax legislation. A key aspect of the implementation of a mandatory disclosure regime is the expeditiousness. These rules will allow for the ATO become aware of participators in aggressive tax avoidance schemes quicker which will in turn will prevent exploitation of the tax system. There are different ways in which tax administrations can use the collected information to alter behaviour and to counteract tax avoidance schemes, for example, risk assessments and changes to legislation.[46] There are arguments for the fact that given the plethora of disclosure rules already contained in the Australian law, there is little need for a mandatory disclosure regime to be introduced into the system. Particularly, the existence of the promoter penalty regime is fundamentally similar to what a mandatory disclosure regime may be like. However, cases such as Commissioner of Taxation v Ludekens Anors,[47]highlights that the scope of promoter penalty regime is quite limited.   In that case, Justice Middleton found that one of the parties was a promoter of the Plan within the meaning of section 290-60, but the other was not. However, it was held that the party that was a promoter did not contravene subsection 290-50(1) because his Honour found that the Plan was not a tax exploitation scheme within the meaning of section 290-65. Taking this into consideration, mandatory disclosure rules would likely assist with uniformity and the defining of certain key terms in the realm of tax-avoidance. Moreover, if a mandatory disclosure regime were introduced, the ATO would likely have early information on such schemes before they would need to be litigated. It may also be argued that Australian taxpayers currently only have limited disclosure obligations in relation to reportable tax positions (RTP) and certain international dealings via the International Dealings Schedule (IDS).[48] The introduction of a mandatory disclosure regime may be superior as a single comprehensive regime which would promote administrative efficiency, reduce compliance costs for taxpayers and avoid duplication with existing laws.[49] The Impact of a Mandatory Disclosure Regime on Legal Advice Mandatory disclosure rules would likely impact solicitors which advise on taxation law. Due to the fact that the term tax adviser is broad and vague, legislation would need precisely defined the term so that it is clear to which people the rules apply and the circumstances in which they would apply. In the past, lawyers who hold themselves out to be experienced in a particular area (for example, revenue law) the scope of their duty is quite wide. In the case of Tip Top Dry Cleaners Pty Ltd v Mackintosh,[50] the lawyer was held to have had a duty to give comprehensive advice to the client which touched on all relevant matters. This duty was held to include a duty not only to advise on whether the proposed transaction might come within the tax deductibility provisions of the legislation but also upon the possible application of the anti-avoidance provisions of the transaction.[51] This authority may be applicable if mandatory disclosure regimes come into play because lawyers advising on revenue law may need to provide advice about it. The relationship between a lawyer and a client holds confidentiality in the highest regard so there may be problems in regards to the mandatory disclosure of information. Australias rules must be designed not to infringe established civil rights such as confidentiality, legal professional privilege and the privilege against self-incrimination any more than is necessary or appropriate. In particular, any disclosures made must be on a without prejudice basis so as not to be used as evidence to that effect in proceedings involving the discloser or any other person.[52] Furthermore, there should be strict limits as to the use the ATO may make of the information.[53] There should not be a requirement to disclose previously comprehensively disclosed information and whether a disclosure is comprehensive ought depend upon whether it enables the Commissioner to identify the particular aggressive tax arrangement or the participation of the taxpayer in such an arrangement.[54] Conclusion The implementation of a mandatory disclosure regime in the Australian tax legislation would likely improve Australias anti-avoidance armoury. This new set of rules would improve and support the current mechanisms that are already in place by providing comprehensive and prompt information to the ATO.[55] By drawing upon other regimes such as that in the United Kingdom as well as examining the current views in Australia, this paper has considered how mandatory disclosure rules in Australia should be framed. The framing should take into regards the current tax legislation and also the impact on taxpayers. Furthermore, special contemplation should take place to ensure that the rules do not infringe on Australian civil rights and do not unnecessarily impact legal professionals that provide advise on tax law. A mandatory disclosure regime would significantly increase transparency, a problem faced by many tax jurisdictions. The introduction of mandatory disclosure rules in Australia would need to be incorporated logically into pre-existing legislation to ensure value and efficacy. Overall, it is likely that a mandatory disclosure regime would be a beneficial addition to Australian revenue legislation. Bibliography Articles/Books/Reports Australian Government, OECD Proposals for Mandatory Disclosure of Tax Information Discussion Paper (3 May 2016)https://treasury.gov.au/~/media/Treasury/Consultations%20and%20Reviews/Consultations/2016/OECD%20Proposals%20for%20Mandatory%20Disclosure%20of%20Tax%20Information/Key%20Documents/PDF/OECD_proposals_mandatory_tax_disclosure.ashx> Australian Tax Office, Part IVA: The General Anti-Avoidance Rules for Income Tax (December 2005) https://www.ato.gov.au/assets/0/104/997/1030/6f068803-a0d3-406a-b7bc-4d44615af99f.pdf Australian Tax Office, Promoter Penalty Law (13 September 2016) https://www.ato.gov.au/General/Tax-planning/Promoter-penalty-law/ Carades, Stephanie,   Mandatory Disclosure Is it Necessary? (3 September 2016) http://search.informit.com.au/fullText;dn=310740505898598;res=IELAPA Law Council of Australia, Submission to Australian Government, OECD Proposals for Mandatory Disclosure of Tax Information, 15 July 2016 https://www.lawcouncil.asn.au/lawcouncil/images/3172_-_Mandatory_Disclosure.pdf OECD, OECD/G20 Base Erosion and Profit Shifting Mandatory Disclosure Rules, Action 12: 2015 Final Report (5 October 2015) OECD, OECD/G20 Base Erosion and Profit Shifting Project 2015 Final Reports Frequently Asked Questions (2015)   http://www.oecd.org/ctp/beps-frequently-asked-questions.pdf Oxford University Centre for Business Taxation, The Disclosure of Tax Avoidance Schemes Regime: Paper 2 (3 December 2012) http://www.sbs.ox.ac.uk/sites/default/files/Business_Taxation/Docs/Publications/Reports/DOTAS_3_12_12.pdf Pagone, G.E, Part IVA: The General Anti-Avoidance Prov

Similarities of hip-hop and the blues :: rap music

Rapping the Blues: The Similarities of hip-hop and the blues Hip-hop is one of the major music genres of today like the blues were in the 1950's. Stanley Crouch views hip-hop as being vulgar and obscene while he sees the blues as being one of the classic music genres. In actuality, these two genres are similar in many ways. A very important part of Stanley Crouch's life is his love for the blues. Many of his essays are related to or have aspects of the blues contained within them. Crouch relates topics that he writes about to the blues, because this is a subject he believes he is very familiar with. In The All American Skin Game, Stanley writes, "Jazz is very important to my vision of life in our time." (Lamb, 1). Jazz gives him a feeling of individuality and community. This means that when individuals push him, and he pushes them back, they both become better individuals as well as a better community. For Stanley, the blues tell the stories of the African-American community. Some of the stories talk about the harshness of their lives, but they also talk about the good times they had. [People] play the blues to get rid of the blues not to get them." (Lamb, 1). When people play or even listen to the blues, they are letting all of their worries go. They are not worrying about their job, the bills, or their kids. They are just trying to enjoy the moment when the blues are playing. The blues are some people's release from the stresses of their lives. To say it lightly, Stanley Crouch does not like the hip-hop genre of music. The dreadlocks, the clothing style, and the "vulgar": gold chains are just a few things he does not approve of at all. (Crouch, 1 ) It astounds him to see how far African-American music has fallen since the days of the Motown. Stanley was quoted as saying this about rap, "It is rudeness, vulgarity, and pornography disguised as ‘keeping it real.'" (Crouch, 1) He also went on to say the hip-hop music genre has the worst impact of all music genres on our culture today. (Crouch, 2) Crouch believes one does not need much talent to become a successful rapper unlike the jazz greats he listens to all the time. In Stanley Crouch's view, the only messages that rappers put in the minds of todays' youth is that they need to have sex, kill people, and do drugs all the time. Similarities of hip-hop and the blues :: rap music Rapping the Blues: The Similarities of hip-hop and the blues Hip-hop is one of the major music genres of today like the blues were in the 1950's. Stanley Crouch views hip-hop as being vulgar and obscene while he sees the blues as being one of the classic music genres. In actuality, these two genres are similar in many ways. A very important part of Stanley Crouch's life is his love for the blues. Many of his essays are related to or have aspects of the blues contained within them. Crouch relates topics that he writes about to the blues, because this is a subject he believes he is very familiar with. In The All American Skin Game, Stanley writes, "Jazz is very important to my vision of life in our time." (Lamb, 1). Jazz gives him a feeling of individuality and community. This means that when individuals push him, and he pushes them back, they both become better individuals as well as a better community. For Stanley, the blues tell the stories of the African-American community. Some of the stories talk about the harshness of their lives, but they also talk about the good times they had. [People] play the blues to get rid of the blues not to get them." (Lamb, 1). When people play or even listen to the blues, they are letting all of their worries go. They are not worrying about their job, the bills, or their kids. They are just trying to enjoy the moment when the blues are playing. The blues are some people's release from the stresses of their lives. To say it lightly, Stanley Crouch does not like the hip-hop genre of music. The dreadlocks, the clothing style, and the "vulgar": gold chains are just a few things he does not approve of at all. (Crouch, 1 ) It astounds him to see how far African-American music has fallen since the days of the Motown. Stanley was quoted as saying this about rap, "It is rudeness, vulgarity, and pornography disguised as ‘keeping it real.'" (Crouch, 1) He also went on to say the hip-hop music genre has the worst impact of all music genres on our culture today. (Crouch, 2) Crouch believes one does not need much talent to become a successful rapper unlike the jazz greats he listens to all the time. In Stanley Crouch's view, the only messages that rappers put in the minds of todays' youth is that they need to have sex, kill people, and do drugs all the time.