Gilberto Vargas is an affluent Brazilian citizen who has lived in Rio Essay

Gilberto Vargas is an affluent Brazilian citizen who has lived in Rio since 1965. He is the controlling shareholder of a multina - Essay Example The test of connection that decides whether the person comes under the jurisdiction of UK taxation is primarily the test of residence (Baistrocchi, 2013, p. 2).The network that exists amongst the scores of double tax treaties (DTTs) forms an important part of the international law. The existing DTTs are all bilateral and based on two existing models; the OECD model and the UN Model. All the DTTs have stark similarities in terms of the topics covered, the order in which the topics are presented and the language in which the articles are described. This makes the DTT network such an important element in the tax regime, that the general rules have become a feature of the international law and might become binding in situations of governing taxation of income in cases of cross border transaction. This paper deals with the case of a Mr. Vargas who is a businessman and considers moving base to London for seven years. The OECD Model of DTT The DTT that follows the OECD Model is particularly applicable for the developed countries. It â€Å"reduces tax on royalties to zero but has a positive rate on interest and dividends† (Avi-Yonah, 2007, p. 3). There is harmful tax competition in which two issues are identifiable. Firstly, tax havens have been identified â€Å"as jurisdictions with no or nominal income taxes and also one or more of lack of effective exchange of information, lack of transparency, and lack of substantial activities by tax payers†. Secondly, preferential tax regimes have been identified as regimes that offer â€Å"no or low effective tax rate and one or more of ring fencing, lack of transparency, and lack of effective exchange of information† (Baistrocchi, n.d.). The prevalence of tax havens and preferential regimes has been condemned by the OECD which has stated it to be a harmful tax competition. The basis of taxation applicable for Mr. Gilberto Vargas: Arising basis or Remittance basis In the given case study, there is OECD Model based tax treaties between the relevant countries. Gilberto Vargas is the controlling shareholder of a multinational enterprise which is based in Brazil and holds investments in the real property market in Brazil, China and India. He is a citizen of Brazil and is considering a migration to the United Kingdom, along with family, for seven years. He is then a foreign national to the UK and his income is liable to taxation for only that amount that arises to him in the UK. The status of becoming a â€Å"resident in the UK† (Judgement, 2010, p.6) creates the platform for UK tax under the provisions of â€Å"Income Tax (Earning and Pensions) Act 2003† (Judgement, 2010, p.6). He is to be considered as a resident of the United Kingdom under the 183-day rule which states that if any person stays in the UK for one hundred and eighty three days, which is approximately half of a tax year (starting form 6th April of any year and continuing till 5th April of the next year) he is c onsidered a â€Å"resident in the United Kingdom† (BN1-British Citizenship, n.d., p. 5) for tax purposes occurring in that tax year. For the citizens of UK, unless a person spends the entire tax year outside the UK with no return visits to the UK, he would be treated as a resident of UK â€Å"for the tax years in which† (You are a UK resident taking a holiday or working holiday abroad, 2010) a citizen of the UK spends any time in the United Kingdom. But when the person is a non-UK domiciled, ie, his

Nursing Care Plan Assignment Example | Topics and Well Written Essays - 2750 words

Nursing Care Plan - Assignment Example Discuss with the client the entries in the notebook and teach alternative responses to maladaptive behaviors. Ventilation of feelings provides a release of emotional tension. It will also facilitate the exploration of underlying reasons of committing suicide. Active listening and silence allows the client to verbalize feelings, anger and fear (Townsend 2003). Community resources and crisis centers provide adequate social support. Phone numbers of these agencies are helpful for the client especially when there is a sudden impulse to commit suicide (Videbect, p.365). Furthermore, client reported â€Å"having no suicidal ideation† and â€Å"desire to live life and correct mistakes†. She identified community resources and phone numbers to call at the first instance of impulse to harm self. The client gained independence in deciding to engage in individual psychotherapy and counseling. In addition, client kept a record of her emotions and developed insights as to the situations that cause her to think about committing suicide. With a non- judgmental attitude, provide feedback for each client attempts to interact with other people. Help the client identify her negative behaviors and practice by role- playing on alternative ways on communicating effectively. After learning to interact with the nurse, the client can be ready to engage in group interaction. Recognizing the client’s absence in each group activity reinforces the idea that the client is valued and her feelings are being considered (Townsend 2003). Client attempts of interaction need to be corrected as necessary to ensure that the client develops effective techniques of communication. Role- playing facilitates learning and strengthens therapeutic nurse- client relationship (Townsend 2003). Cognitive restructuring aims to replace negative thoughts with positive ones. Thought- stopping intends to halt the negative patterns of self- thought by