This thesis analyses the Australian approach to taxation of goodwill and related intangibles. It asks the questions: 'Is the current Australian approach to taxation of goodwill coherent?'; and 'Could a different approach minimise any distortions?' The thesis identifies the increasing importance of goodwill and other intangible property in a modern information-based economy. It identifies benchmarks for a 'good' tax system ??? such as efficiency, simplicity, and equity. It emphasises the criteria of simplicity and efficiency but includes other criteria and specifically considers the issue of alignment of accounting and legal concepts. It concludes that the current misalignment makes it difficult for the tax system to deal with goodwill coherently. The thesis criticises the treatment of goodwill under various Australian taxes, including stamp duty; Goods and Services Tax; taxation of capital gains; and income tax. It specifically considers the treatment of intangible sources of goodwill and their relationship with goodwill itself. The discussion of income tax pays particular attention to the role of goodwill and other intangibles in international transfer pricing. The thesis draws conclusions about the treatment of goodwill in Australia and whether the Australian approach meets the benchmarks established at the outset. The thesis demonstrates that the current Australian approach leads, inter alia, to tax avoidance. The current approach also offends a number of other criteria of a 'good' system. The thesis considers the UK tax treatment of intangibles held by resident companies and considers this model for Australia. It also considers the abandoned 'Tax Value Method' previously proposed for Australia. From this and other material, it suggests possible new directions and an alternative approach to taxing goodwill in Australia. These include a consistent and coherent definition of goodwill for tax that is compatible with law and accounting. The thesis also urges the development of a consistent approach to taxing goodwill at both the state and federal levels; and suggests greater reliance on the existence of goodwill as a means to establish jurisdiction to impose tax in international tax situations.

During the past few years a development of breeding llamas and alpacas took place in Czech Republic. Increasing interest in those animals entails the need to determine how they respond to the conditions of our country. The aim of this thesis is to evaluate the growth ability of crias, some of the physical dimensions (withers height) and bodyweight of adult llamas. The same indicators are to be evaluated for alpacas as well. The results are to be compared with the standard for llamas and alpacas. A total of 104 animals were measured and weighted, namely 44 llamas and 60 alpacas, and 280 pairs of weight and height data were obtained. Weighing and measuring of adult llamas and alpacas took place once a year around the end of August for two years (2009 and 2010). Young llamas were weighed and measured at approximately monthly intervals according to the possibilities of their breeders. Young alpacas were weighed at approximately weekly intervals. The thesis is divided into two parts. The first part evaluates llamas. It was discovered that the average birth weight of llamas in the Czech Republic is 11 kg. Once mature, they reach an average live weight of 130.3 kg and average height of 110.2 cm. Average daily gains were observed as follows: from birth to 7 weeks 0.20 kg per day, from 7 weeks to 24 weeks 0.18 kg per day and from 24 to 72 weeks 0.13 kg per day. The second part of this thesis is devoted to alpacas, for which the same parameters as for the llamas were monitored. It was found that the average birth weight of alpacas in the Czech Republic is 6.5 kg. Once mature, they reach an average live weight of 65.6 kg and average height at 88.4 cm. Average daily gains are at the following levels: from birth to 7 weeks 0.1 kg per day, from 7 weeks to 24 weeks 0.09 kg per day and from 24 weeks to 72 weeks 0.08 kg per day. It was found that these two species reach final physical maturity later in the Czech Republic than stated by literature. Compared to the standard, most of the llamas and alpacas are up to their standards.

abstract: I examine the degree to which stockholders' aggregate gain/loss frame of reference in the equity of a given firm affects their response to the firm's quarterly earnings announcements. Contrary to predictions from rational expectations models of trade (Shackelford and Verrecchia 2002), I find that abnormal trading volume around earnings announcements is larger (smaller) when stockholders are in an aggregate unrealized capital gain (loss) position. This relation is stronger among seller-initiated trades and weaker in December, consistent with the cognitive bias referred to as the disposition effect (Shefrin and Statman 1985). Sensitivity analysis reveals that the relation is stronger among less sophisticated investors and for firms with weaker information environments, consistent with the behavioral explanation. I also present evidence on the consequences of this disposition effect. First, stockholders' aggregate unrealized capital gain position moderates the degree to which information-related determinants of trade (e.g. unexpected earnings, firm size, and forecast dispersion) affect abnormal announcement-window trading volume. Second, stockholders' aggregate unrealized capital gains position is associated with announcement-window abnormal returns, consistent with the disposition effect reducing the market's ability to efficiently incorporate earnings news into price. / Dissertation/Thesis / Ph.D. Accountancy 2012

This thesis is an attempt to bridge some research gaps in the area of behavioural finance and investment through adopting the three essays scheme of PhD dissertations. There is a widespread belief that the traditional finance theory failed to provide a sufficient and plausible explanation for (1) what motivates individual investors to trade, (2) the pattern of their trading and the formation of their portfolios, (3) the determinants of cross section of expected returns other than risk. Behavioural Finance, however, offers more realistic assumptions based on two building blocks; behavioural biases of irrational investors and the limits of arbitrage that prevent the arbitrageurs from correcting mispricing and pushing prices back to fundamental values. This dissertation is structured as follows: In the first essay, the disposition effect is defined as the propensity of investors to realize gains too early while being loath to realize losses. Capital gains overhang is a measure of unrealized capital gains and losses that is associated with the disposition effect and the trading activities of behaviourally biased investors. We discover that firm characteristics can play a role in explaining variations in the capital gains overhang that is consistent with the activities of behaviourally biased and disposition investors. Specifically, we find that capital gains overhang is increasing in firm attributes that attract behaviourally biased investors, namely, earnings per share, leverage, growth and size. Capital gains overhang is also declining in market liquidity, possibly because liquidity allows behaviourally biased investors to excessively trade shares and beta and corporate earnings, probably because when high risk and inefficient firms experience losses, disposition investors experience capital losses that they are reluctant to realize. In the second essay, quantile regressions are employed to analyse the relationship between the unrealized capital gains overhang and expected returns. The ability of the disposition effect to generate momentum is also considered for the extreme expected return regions (0.05th) and (0.95th) quantiles. To do so, 450,617 observations belonging to 5176 US firms are employed, covering a time span from January 1998 to June 2015. Following the methodology of Grinblatt and Han (2005), the findings show significant differences across various quantiles in terms of signs and magnitudes. These findings indicate a nonlinear relationship between capital gains overhang and expected returns since the impact of capital gains overhang as a proxy for disposition effect on expected returns vary across the expected return distribution. More precisely, the coefficients of capital gains overhang are significantly positive and decline as the expected returns quantiles increase from the lowest to the median expected return quantiles. However, they become significantly negative and rise with the increase in expected returns quantiles above median expected returns quantiles. The findings also suggest that the disposition effect is not a good noisy proxy for momentum at the lowest expected return quantile (0.05th). However, interestingly it seems to generate contrarian in returns at the highest expected returns quantile (0.95th). In the third essays, we try to discover systematic disagreements in momentum, asymmetric volatility and the idiosyncratic risk momentum return relationship between high-tech stocks and low-tech stocks. We develop several hypotheses that suggest greater momentum profits, fainter asymmetric volatility and weaker idiosyncratic risk-momentum return relation in the high-tech stocks relative to the low tech stocks. To this end, we divide 5795 stocks that are listed in the Russell 3000 index from January 1995 to December 2015 into two samples SIC code and analysed them using the Fama French with GJR-GARCH-M term. The results show that the high-tech stocks provide greater momentum profits especially for portfolios that have holding and ranking periods of less than 12 months. In most cases momentum returns in the high-tech stocks explain a symmetric response to good and bad news while the momentum returns in the low-tech stocks show an asymmetric response. Finally, the idiosyncratic risk-momentum return relation is insignificant for high-tech stocks while it is significant and negative for low-tech stocks. That is, as idiosyncratic risk increases, momentum decreases for low-tech stocks. These findings are robust to different momentum strategies and to different breakpoints.

The aim of this diploma work was to evaluate the level of beef utility at particular breeds. The breeds were bred in different climatic conditions of foothills and mountain regions of the Southern and the Western Bohemia. It was observed the use of permanent green grass by beef cattle´s pasture in relation of reached utility. There were included in total 31 farms in monitoring. The farms keep 7 breeds (Aberdeen Angus, Galloway, Hereford, Highland, Charolais, Simentál and Salers). There were 16 farms situated in regions under 600 meters above sea-level and 15 farms in regions over 600 meters above sea-level. The data were collected during 5 years. At cows, month of calving and occurrance of complicated births, have been recorded. The weight of calves at birth, in the age of 120, 210 and in certain cases also 365 days, has been checked. There were counted the average daily gains to mentioned weights. The group has been sorted according to breeds, elevation above sea-level and sex of the calves.

Investments with exit flexibility require decisions regarding both the investment and holding period. Because selling an investment often leads to taxable capital gains, which crucially depend on the duration of an investment, we investigate the impact of capital gains taxation on exit timing under different tax systems. We observed that capital gains taxation delays exit decisions but loses its decision relevance for very long holdings. Often the optimal exit time, which indicates the maximal present value of future cashflows, cannot be determined analytically. However, we identify the breakeven exit time that guarantees present values exceeding those of an immediate sale. While, after-taxes, an immediate sale is often optimal, long holding periods might also be attractive for investors depending on the degree of income and corporate tax integration. A classic corporate tax system often indicates holdings over more than 100 periods. By contrast, a shareholder relief system indicates the earliest breakeven exit time and thus the highest level of exit timing flexibility. Surprisingly, high retention rates are likely to accelerate sales under a classic corporate system. Additionally, the worst exit time, which should be avoided by investors, differs tremendously across tax systems. For an integrated tax system with full imputation, the worst time is reached earlier than under partial or non-integrated systems. These results could help to predict investors' behavior regarding changes in capital gains taxation and thus are of interest for both investors and tax policymakers. Furthermore, the results emphasize the need to control for the underlying tax system in cross-country empirical studies. (authors' abstract) / Series: WU International Taxation Research Paper Series

We build a general Ricardian model of international trade, which extends Eaton and Kortum (2002), in order to analyze the sources of the gains from trade, the effects of trade openness on productivity, and the role of nominal exchange rates. For general distributions of industry efficiencies, welfare gains can always be de- composed into a selection and a reallocation effect. The former is the change in average efficiency due to the selection of industries that survive international competition. The latter is the rise in the weight of exporting industries in domestic production, due the reallocation of workers away from non-exporting industries. This decomposition, which is hard to calculate in the general case, simpli es dramatically with Fréchet- distributed efficiencies, providing easy-to-quantify model-based measures of these two effects. For an average of 46 countries in 2000 and 2005, the selection effect turns out to be somewhat more important than the reallocation effect. By analyzing the relationship between trade openness and total factor productivity (TFP), we propose a novel methodology to measure the latter. The logic of our approach is to use a structural model and measure TFP not from its "primitive" (the aggregate production function), but from its observed implications. We estimate TFP levels of the manufacturing sector of 19 OECD countries, relative to the United States, in 1985-2002, as the average productivity a proxy for aggregate TFP that best ts data on trade, production and wages. Our measures turn out to be easy to compute and are no longer mere residuals. To examine the role exchange rates in a model of real consumption and production decisions with no money, we follow an insight of Keynes (1931) and replicate a currency depreciation with an increase in import barriers and a symmetric decline in export barriers. By mimicking changes in exchange rates with changes in the model parameters, we can demonstrate a series of classical results and conjectures, in a very general framework with many countries, tradeable goods and non-tradeable goods. We show not only that a depreciation has no real effects with flexible wages, but, with sticky wages, we are able to prove that an undervalued currency causes involuntary unemployment abroad, while at home it determines inefficiently high employment in the export sector, raising real GDP but lowering welfare. If the currency is overvalued, we also show that there exists an appropriate depreciation that restores competitive prices, with welfare-enhancing effects, proving Friedman's conjecture (1953).

Magister Legum - LLM / The utilisation of trusts has become a popular trend among taxpayers, especially high net worth individuals1 (hereafter HNWI) who wish to reduce potential estate duties. The SARS Strategic Plan stated that there is a ‘compliance risk posed by HNWI and the use of trusts to conceal their income’.2 The SARS Strategic Plan announced that trust reform would be prioritised. Minister of Finance, Pravin Gordhan (hereafter Gordhan) referred in his 2012/2013 budget speech3 to various measures proposed to protect the tax base and limit the scope for tax leakage and avoidance. Gordhan reiterated the state’s position regarding the abuse of trusts by indicating that reforms will be made regarding the taxation of both local and offshore trusts which have long been a problem for global tax enforcement due to their flexibility and flow-through nature. National Treasury and SARS are concerned about trusts, largely because of the income-splitting opportunities that trusts afford taxpayers. There are envisaged tax amendments which will impact South Africa’s (hereafter SA) trust landscape and could derail many carefully drafted trust structures. It will thus be important for estate owners to consider these envisaged tax amendments when they come into operation, in order to ascertain the full extent of the implications and then it can also further be determined what the impact of these 1 Income in excess of R7 million, alternatively R75 million in assets. South Afican Revenue Service (hereafter SARS) Strategic Plan (2012/13- 2016/17) 19 available at http://www.sars.gov.za (accessed 6 November 2013) (hereafter SARS Strategic Plan). 2 SARS Strategic Plan 19. 3 2012-2013 budget speech 22 available at http://www.sars.gov.za (accessed 6 November 2013) (hereafter budget speech). 11 changes will be on the effectiveness of the discretionary family trust as an estate planning vehicle in SA in the future. The purpose of this thesis is to determine the impact of the current statutory anti-tax avoidance provisions on the effectiveness of the discretionary family trust as an estate planning vehicle in SA, especially due to the fact that the trust form has been abused in the past for tax avoidance purposes.

This study was conducted to determine if the use of the technology known as Classroom Performance System (CPS), specifically referred to as “Clickers”, improves the learning gains of students enrolled in a biology course for science majors. CPS is one of a group of developing technologies adapted for providing feedback in the classroom using a learner-centered approach. It supports and facilitates discussion among students and between them and teachers, and provides for participation by passive students. Advocates, influenced by constructivist theories, claim increased academic achievement. In science teaching, the results have been mixed, but there is some evidence of improvements in conceptual understanding. The study employed a pretest-posttest, non-equivalent groups experimental design. The sample consisted of 226 participants in six sections of a college biology course at a large community college in South Florida with two instructors trained in the use of clickers. Each instructor randomly selected their sections into CPS (treatment) and non-CPS (control) groups. All participants filled out a survey that included demographic data at the beginning of the semester. The treatment group used clicker questions throughout, with discussions as necessary, whereas the control groups answered the same questions as quizzes, similarly engaging in discussion where necessary. The learning gains were assessed on a pre/post-test basis. The average learning gains, defined as the actual gain divided by the possible gain, were slightly better in the treatment group than in the control group, but the difference was statistically non-significant. An Analysis of Covariance (ANCOVA) statistic with pretest scores as the covariate was conducted to test for significant differences between the treatment and control groups on the posttest. A second ANCOVA was used to determine the significance of differences between the treatment and control groups on the posttest scores, after controlling for sex, GPA, academic status, experience with clickers, and instructional style. The results indicated a small increase in learning gains but these were not statistically significant. The data did not support an increase in learning based on the use of the CPS technology. This study adds to the body of research that questions whether CPS technology merits classroom adaptation.

Section 12N, introduction into the Income Tax Act by way of Taxation Laws Amendment Act and which became effective on 2 November 2010, provides for allowances on the leasehold improvements on government-owned land and land leased from certain tax exempt entities as stipulated in section 10 (1) (cA) and (t). As section 12N deems the lessee to be the owner of the leasehold improvement, the lessee now qualifies for capital allowances which were previously disallowed.