Essay on Frank Darabonts The Shawshank Redemption

Frank Darabonts The Shawshank Redemption The movie the Shawshank Redemption, based on the book by Steven King, I believe is one of the best movies ever made. The portrayal of prison life in the movie is the best I have seen and a star-studded cast including Morgan Freeman supports the characters and brings to life the everyday struggles of life behind bars. In this paper I will relate topics from class to the movie and discuss information we have learned through out the semester. One of the best things about this movie is its portrayal of prison life. There are many movies that deal with prison and the life of prisoners while incarcerated, but Shawshank I feel does the best job of giving you a real feeling of what prison life†¦show more content†¦In the film the inmates used cigarettes as money, a way to get things in the prison, a feat that seemed easily accessible in Shawshank at the time, due to the guards taking bribes from delivery drivers and the inmates themselves. It seemed to me that all of Shawshank was corrupt in its ways. In prison there are different levels of confinement and this was shown to play a big part in the prisoners life at Shawshank. If you were caught in the act of doing something against the rules or in Andy’s case, standing up to the warden, you were sent to solitarily confinement for a period of time. In the movie Andy spent two months in solitary with only bread and water to survive. This to me is a hell of a way to get what you want out of the inmates but some have nothing to lose so even solitary does not break them. One of the subjects that the film deals with is the idea of â€Å"institutionalization.† The idea that inmates that have spent so many years behind bars that they can no longer function in a free society. I can only imagine how difficult it would be to one day have to get yourself up out of bed, make yourself some food, and go to work in a society that has passed you by. After forty or fifty years of inmate life you become depended on the prison it becomes your world, your security. The example of this in the movie isShow MoreRelatedSpellbinding Metamorphosis. The Evolution Of The Shawshank1321 Words   |  6 PagesSpellbinding Metamorphosis The evolution of the Shawshank Redemption, from the literary prose of Stephen King to the cinematography of director and screenplay writer Frank Darabont, is nothing short of a spellbinding metamorphosis. Stephen King, diverging from his prolific tales of horror, presented his audience, Different Seasons, a collection of novellas in which, â€Å"Rita Hayworth and the Shawshank Redemption†, is included. It is a story of the hope, courage and friendships that, main characterRead MoreRita Hayworth And The Shawshank Redemption Analysis1362 Words   |  6 PagesClose Comparative Analysis Of Stephen King’s Rita Hayworth and the Shawshank Redemption and Frank Darabont’s The Shawshank Redemption When comparing the ending of Stephen King’s novella, Rita Hayworth and the Shawshank Redemption with the ending of the 1994 film adaptation by Frank Darabont, The Shawshank Redemption, there are key differences. These include additions, removals and slight changes in the narrative which arguably make the storyline better suited to the completely different mediumRead MoreTheme of Hope in Shawshank Redemption797 Words   |  4 PagesAn important theme in Frank Darabont’s film The Shawshank Redemption is hope. The film demonstrates that hope is a good thing and shows the consequences in having and lacking hope. It is important that Darabont’s film showed the theme of hope as it us also important in our lives today because having or lacking in hope affects people personally, nationally and worldwide. In our everyday lives we are presented with cases of people having hope through our own or someone we knows personal experiencesRead MoreAuthority Individual1437 Wo rds   |  6 PagesIn Fahrenheit 451, written by Ray Bradbury, authority is viewed as ruthless and the individual is portrayed as innocent. This is also emphasised in two related texts, Whose Life Is It Anyway? By Brian Clark, and Shawshank Redemption, directed by Frank Darabont. The themes of ruthlessness and innocence are exemplified throughout all three texts, through the concept of the authority and the individual. In Ray Bradbury’s Fahrenheit 451, authority is depicted as ruthless. This is shown throughout theRead MoreShawshank Redemption1197 Words   |  5 Pagespurpose and explore, in depth , one or two main visual/ oral techniques used to achieve this purpose. An important theme in Frank Darabonts film , The Shawshank Redemption is hope in humanity. The film demonstrates that hope is a good thing . The directors main purpose was to convey this idea through the film to the audience by using visual and verbal techniques. In Darabonts film the theme of hope in mankind is important as it enables the audience to relate this idea to their daily lives as eachRead MoreAnalysis Of The Shawshank Redemption By Frank Darabont1116 Words   |  5 PagesEvaluative Analysis: The Shawshank Redemption When it comes to movies, I am not exactly what you could consider well-versed. Had it not been for several close friends of mine, I would have never even seen blockbuster hits such as Harry Potter, The Lord of the Rings, or Back to the Future. The reason for this is not because I dislike watching movies, but rather due to the restrictive nature of my parents. Thus, I have not had the privilege to enjoy The Shawshank Redemption, Frank Darabont’s 1994 adaptationRead MoreThe Shawshank Redemption By Frank Darabont1000 Words   |  4 PagesThe Shawshank Redemption directed by Frank Darabont is a 1994 American drama film set in the Ohio State Reformatory in Mansfield, Ohio. The film is an enthralling film about the survival of one of its prisoners, Andy Dufresne, the protagonist convicted to life imprisonment in Shawshank prison during 1947. Facing incarceration, Andy’s character as a city banker forms a relationship with a prison inmate ‘Red’ to fight despair. Darabont uses film techniques such as camera work, soundtrack and lightingRead MoreThe Shawshank Redemption Essays3087 Words   |  13 PagesThe Shawshank Redemption AQA, the examination board, has asked selected pupils to submit written reports on possible films to be studied for the media section of the GCSE English exam, specifically of the â€Å"The Shawshank Redemption†. Write this review, aiming to show detailed understanding of Darabont’s themes and techniques, writing in an interesting, thought-provoking way. _______________________________________________ â€Å"I suppose it comes down to a simple choiceRead MorePortryal of Andy as a Symbol of Hope in Shawshank Redemption Essay1268 Words   |  6 PagesIn 1994, Frank Darabont’s film ‘The Shawshank Redemption’ received a poor reception when released; it only made a $0.3m profit. More recently the film has become known as one of the greatest movies of all time, it has inspired hope in many people, helping them to lose weight, leave abusive marriages and such like. The film is based mainly upon two convicts, and the idea of hope. Andy Dufresne is a ‘Hot Shot Banker’ imprisoned with two life sentences, for the suspected murder of his wife and her loverRead MoreThe Mist Review942 Words   |  4 Pagesfrom a Stephen King novella, sticks closely to the archetype. The Mist, a thriller written, produced and directed by Frank Darabont, was released on November 21 2007 by Dimension Films studio. Darabont is a Hungarian-American film director, screenwriter and producer who has been nominated for three Academy Awards and a Golden Globe. He has directed the films The Shawshank Redemption, The Green Mile, and The Mist, all based on stories by Stephen King. The film begins when David Drayton (played by

Callum Free Essays

Themes TRENCH LIFE BATTLE â€Å"Coughing Like Hags† – Dulce Et Decorum Est, Wilfred Owen â€Å"Guttering, choking, drowning† – Dulce Et Decorum Est, Wilfred Owen â€Å"Stuttering rifles’ rapid rattle† – Anthem for Doomed Youth, Wilfred Owen â€Å"A great mass of things unclean† – A Dead Boche, Robert Graves â€Å"Like several different kinds of Hell† –Brooke, in a letter on his day in the war â€Å"So much muscle and blood in the Earth† Birdsong, Sebastian Faulks â€Å"Beyond the boundaries of human behaviour† -Birdsong, Sebastian Faulks â€Å"The turned soil and torn flesh of war. – Birdsong, Sebastian Faulks â€Å"Meanwhile my self etcetera lay quietly in the deep mud† – my sweet old etcetera, e. e. We will write a custom essay sample on Callum or any similar topic only for you Order Now cummings â€Å"You think there’s no limit to what a man can bear? †Ã¢â‚¬â€œ Stanhope in Journey’s End, Sherriff LOSS â€Å"They expected to die† – Birdsong, Faulks â€Å"A dust whom England bore† – The Soldier, Brooke â€Å"Gentleness, in hearts at peace, under an English Heaven† – The Soldier, Brooke â€Å"As scared as any frightened child† – The Deserter, Letts â€Å"Looking on the face of grief, the face of dread† – June 1915, Charlotte Mew â€Å"The soldier dying dies upon a kiss, The very kiss of Christ† – Summer in England 1914, Alice Meynell â€Å" The holy glimmer of goodbyes† – Anthem For Doomed Youth, Owen â€Å" Each slow dusk a drawing down of blinds† – Anthem For Doomed Youth, Owen PATRIOTISM â€Å"Dulce et Decorum Est Pro Patria Mori† – Dulce Et Decorum Est, Owen â€Å" Who’ll give his country a hand? † – [i]Who’s For The Game, Jessie Pope â€Å" my father used to become hoarse talking about how it was a privilege† – my sweet old etcetera, e. e. cummings â€Å" There’s something rather romantic about it all† – Osborne in Journey’s End, Sherriff â€Å" He looked splendid. It – sort of made me feel†¦keen to get out here† – Raleigh in Journeys End, Sherriff â€Å" My hatred of the Kaiser is love true† – This Is No Case Of Petty Right Or Wrong – Thomas â€Å"As we love ourselves, we hate her foe† – This Is No Case Of Petty Right Or Wrong, Thomas WOMEN AND THEIR ROLES â€Å"You love us when we’re heroes† – Glory Of Women, Sassoon â€Å" Come along lads† – Who’s For The Game, Jessie Pope â€Å" Isabel created hundreds (and hundreds) of socks†Ã¢â‚¬â€œmy sweet old etcetera, cummings â€Å" Can’t you see it isn’t decent, to flout and goad men into doing what is not asked of you? – The Jingo-Woman, Helen Hamilton â€Å" We dare not weep who must be brave in battle† – Of All Who Died In Silence Far Away, Iris Tree â€Å" Anyone affected by the war is entitled to comment upon it† – Nasheen Khan GENERAL â⠂¬Å" Not quite clear†¦what the fuss was about† – He Went For A Soldier, Ruth Mitchell â€Å" The political errors and insincerities† – A Soldier’s Declaration, Sassoon â€Å" A war of aggression and conquest† – A Soldier’s Declaration, Sassoon â€Å" I am acting on behalf of soldiers† – A Soldier’s Declaration, Sassoon â€Å" An exploration of how far men can be degraded† – Birdsong, Faulks â€Å" You are going to fight and you are going to win. – Birdsong, Faulks â€Å" They didn’t believe in shellshock at all†¦it was just cowardice† – Regeneration, Pat Barker â€Å" The pity and terror the war experience inevitably evoked† – Regeneration, Pat Barker â€Å"It all seems rather silly, doesn’t it? † – Raleigh in Journey’s End, Sherriff â€Å" My subject is war and the pity of war. † – Wilfred Owen CRITI CAL COMMENTS ON THE WAR CANON â€Å" Passive suffering is not a theme for poetry† – Yeats â€Å"War equates with ombat thus limiting the canon† – James Campbell â€Å" The knowledge of combat is a prerequisite for the production of a literary text that adequately deals with war† – James Campbell â€Å"Anyone affected by war is entitled to comment upon it† – Nasheen Khan â€Å" The spectator, the contemplator, the opposer of war have their hours with the enemy no less than uniformed combatants† – Richard Eberhart Pre-WWI Literature ‘The Charge of the Light Brigade’ by Alfred Lord Tennyson †¢ Disastrous incident in the Crimean war. †¢ â€Å"Into the valley of death/ Rode the six hundred† – Celebrates devotion to duty and heroism in the face of certain death. The glamour of chivalry. †¢ â€Å"Honour the Charge they made! † â€Å"While horse and hero fell† – patriotic, presents war positively. †¢ â€Å"Someone had blunder’d† – blames Generals – interesting as it is before WWI, about the Boer war. So perhaps realistic in this sense? ‘Vitai Lampada, by Sir Henry Newbolt’ †¢ About the Boer War †¢ â€Å"The Gatling’s lamed and the colonel dead† – Presents the actuality of the war, reality. †¢ â€Å"The sand of the desert is sodden dead† – realism, huge scale of death. Alliteration of â€Å"s† and â€Å"d†. †¢ â€Å"But the voice of a schoolboy rallies the ranks, ‘play up! Play up! And play the game! – Compares war to a game of cricket, euphemism of war. Early War Literature – (1914-1915) ‘The Soldier’ by Rupert Brooke †¢ â€Å"Some corner of a foreign field/that is forever England† – Idealised. Accused of naivete and being a ‘ridiculous pastoral’. †¢ â€Å"If I should die, think only this of me† – More than a sentimental patriotic verse. The word ‘think’ acts as a message from Brooke for people to remember him. †¢ A dialogue between the living (survivors and civilians) and the dead (or soon-to-be). ‘The Call’ by Jessie Pope †¢ Jessie Pope (a. k. a Owen’s arch-nemesis! ) was incredibly pro-war. â€Å"Who’s for the trench – are you, my laddie? Who’ll follow the French – will you, my laddie? † – used for propaganda to young soldiers. ‘Men who March Away’ by Thomas Hardy †¢ Thomas Hardy didn’t fight in war. †¢ Written in the opening days of war. †¢ Expresses feelings of those enlisting as war was meant to be over by Christmas. †¢ â€Å"Braggarts must surely bite the dust† à ¢â‚¬â€œ sounds quaint naive. A letter written by Julien Grenfell †¢ â€Å"We are all awfully well, except those who have stopped something† – ‘Stopped something’ was slang for being shot! ‘As the Team’s Head Brass’ by Edward Thomas Conversation between an elder ploughman and a speaker uncertain whether or not to enlist. †¢ â€Å"’have you been out yet? ’ ‘No. ’ ‘And don’t want to, perhaps? ’† – series of questions. Later Literature – (1916-1918) ‘All the Hills and Vales Along’ by Charles Hamilton Sorely †¢ â€Å"And the singers† – optimism, calling soldiers ‘singers’. This is immediately undercut by describing them as â€Å"the chaps/who are going to die perhaps! † †¢ â€Å"So be glad, when you are sleeping† – ‘sleeping’ undertones of death, implicit suggestion of death as mos t desirable end, inevitable end for a soldier. â€Å"Sow your gladness for earth’s reaping† – celebrate chance of fighting, earth personified, harvesting future happiness planted by soldiers. †¢ â€Å"To the Gates of Death with song† – Almost Tennyson-like enthusiasm, cheerful death. †¢ Offset by the final line; â€Å"so be merry, so be dead† – sober view of death compared to Brooke’s. ‘To England – A note’ by Ivor Gurney †¢ In this sonnet each seemingly patriotic phrase is undercut. †¢ â€Å"The boys of England† – focuses on the facts that the soldiers are no more than boys, often just out of public school. The soldiers â€Å"do in silence† – the things they have to do, war is literally unspeakable. ‘A Dead Boche’ by Rupert Graves †¢ Speaks directly to those who only want to hear ‘of blood and fame’. †¢ â€Å"A certain cure for lust of blood† – Brusquely ironic tone. †¢ Second stanza confronts the horrors of war head-on, he describes a German Corpse. †¢ â€Å"Sat† and â€Å"Scowled† – alliteration attaches these actions of a living person to the corpse. †¢ â€Å"Big-bellied, spectacled, crop-haired† – still identifiable but the â€Å"black blood† turns corpse into an emblem of death. No mutual recognition or respect from one soldier to another (unlike W. O’s statement â€Å"I am the enemy you killed, my friend† – strange meeting) †¢ Reader challenged to disagree with the claim that it is a â€Å"certain cure for the lust of blood†. Post-WWI Literature ‘Journey’s End’ by R. C Sherriff †¢ Set in a dug-out in trenches, it explores tension in a group of officers waiting for their attack. †¢ Names emphasise essential Englishness (Stanhope, Osborne, Raleigh, etc). ‘Birds ong’ by Sebastian Faulks †¢ â€Å"†¦ so horrific†¦ beyond a war†¦ dehumanised to an extent that†¦ †¢ â€Å"This is not a war; this is an exploration of how far men can be degraded† – dehumanising, bitterness of those who experience it, no reason behind war. Modern. What Sebastian Faulks sets to explore in birdsong. (Stephen Wraysford) Glory of Women- Siegfried Sassoon 1917. Criticises those at home, particularly the women. †¢Ã¢â‚¬Å"You love us when we’re heroes, home on leave†¦Ã¢â‚¬  †¢Ã¢â‚¬Å"Trampling the terrible corpses, blind with blood† †¢Ã¢â‚¬Å"O German mother†¦while you are knitting socks to send your son His face is trodden deeper in the mud. † A Dead Boche Robert Graves 1916 Wirtten from an anti war perspective, graphic descriptions show the true horror of war. †¢Ã¢â‚¬Å"’War’s hell’† †¢Ã¢â‚¬Å"Sat a dead Boche, he scowled and stunk† †¢Ã¢â‚¬Å"Big-bellied, spectacled, crop haired, Dribbling black blood from nose and beard† Diasbled- Wilfred Owen 1917 Shows a strong anti-war view, criticises those at home who cannt see past the ‘glory’ of war. Poem shows a young boy who has been disabled by the war. †¢Ã¢â‚¬Å"Some cheered him home, but not as crowds cheer a goal† †¢Ã¢â‚¬Å"The women’s eyes passed from him to the strong men that were whole† †¢Ã¢â‚¬Å"Why don’t they come? † Dulce et Decorum Est- Wilfred Owen 1917 Again anti-war, satirises the view that war is a glorious thing, and that it is an honour to die for ones country. †¢Ã¢â‚¬Å"Bent double, like beggars under sack, knock kneed and coughing like hags. † †¢Ã¢â‚¬Å"As under a green sea, I saw him drowning†¦ gargling from the froth corrupted lungs† †¢Ã¢â‚¬Å"The old lie: Dulce et Decorum est Pro patria mori† The Send Off- Wilfred Owen 1917 This poem has a melancholic tone, which has a sinister effect as the poem focuses on the death and destruction caused by war. †¢Ã¢â‚¬Å"lined the train with faced grimly gay† †¢Ã¢â‚¬ Their breasts were stuck all white with wreath and spray, as mens are, dead. †¢Ã¢â‚¬Å"like wrongs hushed up they went† †¢Ã¢â‚¬Å"A few, too few for drums and yells may creep back, silent†¦ up half known roads. † Glory of Women- Siegfried Sassoon 1917. Criticises those at home, particularly the women. †¢Ã¢â‚¬Å"You love us when we’re hero es, home on leave†¦Ã¢â‚¬  â€Å" He looked splendid. It – sort of made me feel†¦keen to get out here† – Raleigh in Journeys End, Sherriff Rupert Brooke – patriotic There is some corner of a foreign field That is forever England† Sassoon â€Å"Does it matter? Losing your legs? † â€Å"The turned soil and torn flesh of war. † – Birdsong, Sebastian Faulks Charles Sorley – â€Å"nor honour. It is easy to be dead† Edmund Blunden – ‘Vlamertinghe’ – â€Å"who are these coming to the sacrifice? † Quiet protest: Ivor Gurney ‘Beauty’ â€Å"Man’ consolation sung on the quivering strings† Inspiring: Sir Henry Newbolt ‘Vitai Lampada† (the torch of life) â€Å"Play up! Play up! And play the game! † Jessie Pope â€Å"Who’s for the game? † Regeneration Sassoon: â€Å"A hundred years from now they’ll still be ploughing up skulls. † Owen, Disabled â€Å"All of them touch him like some queer disease. † â€Å" The holy glimmer of goodbyes† – Anthem For Doomed Youth, Owen Strange Meeting 1)Hill says in the Author’s Notes that her novel is a â€Å"microcosm of the ar† to create a â€Å"small world in the great would of the war†-she focusses on 2 main characters John Hilliard and David Blunden which makes it easier to communicate what the war was all about arther than taking a much larger perspective 2)the lack of understanding of the â€Å"coward complacence† as Sassoon puts it is another idea found in this novel-Hilliard goes home on leave and says â€Å"noone knew, nobody understood† Recruitment ‘The Call’ By Jessie Pope â€Å"Who’d rather wait a bit† ‘The Volunteer’ By Herbert Asquith â€Å"lifes tournament† ‘The Call’ By Robert Venede â€Å"lad† â€Å"man† â€Å"dreamer† â€Å"brothers† ‘In Flanders Field’ By John McCrae Take up our quarrel† Futility and Despair ‘Dulce et Decorum Est’ By Owen â€Å"vile incurable sores on innocent tongues† ‘Lamplight’ By May Wedderburn Cannan â€Å"we planned to shake the world together† ‘Anthem for Doomed Youth’ By Owen â€Å"each slow dusk, a drawing down of blinds† ‘Apologia pro Poemate Meo’ By Owen â€Å"hop es lay strewn† ‘Birdsong’ By Faulks â€Å"he himself did not believe there was a purpose to the war† ‘All Quiet on the Western Front’ By Remarque â€Å"weary, broken, burntout and without hope† Patriotism and Glorifying War ‘The Soldier’ By Brooke â€Å"some corner of a foreign field which is forever England† ‘The Call’ By Venede ogres† â€Å"faeries† â€Å"princes† ‘This is no case of petty right of wrong’ By Edward Thomas â€Å"She (England) is all we know and live by† ‘Channel Firing’ By Hardy â€Å"Camelot, and starlit stonehenge† ‘Peace’ By Brooke â€Å"as swimmers into cleanness leaping† ‘Happy is England Now’ By John Freema â€Å"destroying Dragon† ‘Men Who March Away’ By Hardy â€Å"England’s need are we† ‘Journeys End’ By Sherriff â€Å"There’s someth ing rather romantic about it all† (Osbourne) Physical Damage ‘Disabled’ By Owen â€Å"The womens’ eyes passed from him to the strong men that were whole† ‘The Ghost Road’ By Pat Barker â€Å"damaged brains and drooping mouths† The Conscript’ By Wilfred Gibson â€Å"mangled limbs, blind eyes† ‘All Quiet on the Western Front’ By Remarque â€Å"we see men without mouths, jaws, without faces† ‘A Dead Boche’ By Graves â€Å"Black blood oozing from his nose and beard† ‘In Memoriam’ By EA Mackintosh â€Å"piteous writhing bodies† Class ‘Oh What a Lovely War’ By Littlewood and Theatre Workshop â€Å"Blunders of boobies† (Mrs Pankhurst) ‘The Chances’ By Owen â€Å"Over the top tomorrer; boys we’re for it† ‘Strange Meeting’ By Susan Hill â€Å"not the natural camaraderie to be found among the officers† ‘Return of the Heroes’ By Sassoon â€Å"Prussian General† and â€Å"Sir Godfrey Stoomer† Mourning ‘A Girl’s Song’ By Katharine Tynan â€Å"My grief is in the weeping rains† ‘The Falling Leaves’ By Margaret Postgate Cole â€Å"now all withering lay† ‘Afterwards’ By Margaret Postgate Cole â€Å"shall you and I ever be young again? † ‘August 1914’ By John Masefield â€Å"So passionate once, so deep† ‘Now that you too muct shortly go away’ By Eleanor Farjeon â€Å"By immortal love, which has no first of last† ‘Do Not Weep’ By Stephen Crane â€Å"A field where a thousand corpses lie† ‘Letters From a Lost Generation’ By Vera Brittain Letters talking about her fiance’s death Cowardice ‘The Jingo-Woman’ By Helen Hamilton dealer in white feathers, insulter, self appointed† ‘Birdsong’ By Faulks â€Å"list of men executed for cowardice† ‘Recruiting’ By Mackintosh â€Å"Can’t you see them thanking God they’re over forty-one? † ‘Regeneration’ By Pat Barker â€Å"They didn’t believe in shell-shock†¦ it was just cowardice† Post War Thoughts ‘Blackadder Goes Forth’ By Curtis and Elton â€Å"Not even our generals are made enough to shell their own men† ‘Oh What a Lovely War’ By Littlewood and Theatre Workshop â€Å"it is slaughter†(soldier) â€Å"we need one big offensive to break through† (Haig) ‘Aftermath’ By Sassoon â€Å"Have you forgotten yet? â€Å" How to cite Callum, Papers

Income Tax Assessment Respective Business Resources

Question: Describe about the Income Tax Assessment for Respective Business Resources. Answer: Issue Based on the given facts, the given case aims to opine on the level of assessable income and their respective sources for Rogan Advertisement, its founder, Stephanie and her husband Ronald. Rule Tax Residency - Individuals When the underlying taxpayer is deriving income from foreign sources, in order to properly account for the same, it is essential to determine the tax residency status of the given taxpayer. This is in accordance with Section 6-5(2) which advocates that foreign income be held assessable for Australian tax residents[1]. On the other hand, Section 6-5(3) advocates that only domestic income (i.e. derived from Australia) would be held assessable for foreign tax residents[2]. The relevant tax residency tests are highlighted in the relevant tax ruling named TR 98/17 which elaborates on four different tests and also details the underlying circumstances under which each of these would be applicable[3]. The various associated conditions linked with each of these tests are outlined below. Domicile Test The applicability of the given test is limited to only the Australian residents as one of the conditions that is requisite for this particular tests is that the taxpayer should have an Australian domicile at the time of assessment[4]. Besides, there is additional requirement on the part of the taxpayer that the permanent abode of the same should not be located outside Australia. In the application of this test in reality, there are issues faced with regards to objectively determining the permanent residence location. In this regard, IT 2650 ruling is of immense helps as it highlights the various relevant factors to be considered to determine the location besides discussing the relevant tax cases in this regard. The relevant parameters taken into consideration by the Tax Commissioner to frame an opinion in this regards are mentioned below[5]. Intention on taxpayers part to settle abroad. Amount of time expected to be spent on foreign territory and the actual time spent and the comparison of the two with suitable reasoning for deviation. The frequency of visit of taxpayer to Australia and the level of personal and professional ties maintained. Resides Test This particular test would apply only on foreign residents and requires that the following factors be taken into consideration for reaching a verdict with regards to tax residency[6]. The significance of the intention behind taxpayers Australian visit The extent of relationship in the personal, professional and business sphere that are maintained in Australia by the taxpayer. The nature of social arrangement that have been put in place by the underlying taxpayer during Australian stay. 183 Day Test This test is also strictly relevant only for non- Australian residents and advocates that namely the outlined conditions below need to be satisfied[7]. The taxpayer needs to spend at least 183 days in Australia during the assessment year The taxpayer should have clear intent with regards to making Australia permanent residence in the future. Violation of even one of the above conditions would result in non-granting of Australian tax residency. Superannuation Test This is a test having limited use as it determines tax residency of only those government employees who are stationed abroad and the criterion for residency is participation in one of two mentioned superannuation schemes for this purpose[8]. Tax Residency -Company With regards to tax residency status of the a company, the requisite conditions to be satisfied are enumerated below[9]. The incorporation of the company has been done in Australia only. The business of the company should be based in Australia and either the companys majority shareholders comprise of tax residents of Australia or a significant amount of management control arises from Australia. It is noteworthy that one of the above two conditions is sufficient for Australian tax residency. Source of Income There are two section detailed in ITAA 1997 that lay the foundation of assessable income which are highlighted below Section 6(5) This section includes all proceeds which would be earned in the ordinary concept and includes the following proceeds[10]. Income earned by the taxpayer by indulging in business activities which need to distinguished from hobby using TR 97/11 Income earned by the taxpayer through personal exertion such as employment income salary and other employment related incentives. Income earned by the taxpayer through investments that would typically take place as interest (bank account), dividend (shares) and rent (property). Section 15(15) As per this section, any proceeds that are earned by the taxpayer through involvement in an transaction which is isolated would be assessable as per this section provided the activity has been undertaken driven by primary intention to make profit[11]. Application Tax Residency Status As both Stephanie and Roger are residents of Australia, hence out of the residency tests earlier discussed, the only relevant test is the domicile test and further attention needs to be paid on the determination of location of permanent residence of the taxpayer in accordance with IT 2650. .In accordance with IT 2650, it has been opined that if the foreign stay is for a period of less than two years then, it is considered as being temporary. Additionally, a relevant judgement in this regards is F.C. of T. v. Applegate (1979) 9 ATR 899 case where the judge opined that shift in permanent residence would typically take place when the underlying taxpayer has no intention to return to Australia in the foreseeable time. However, if the taxpayer has intention to return back to Australia for continuing their stay, then such taxpayer would be considered Australian tax residents. For Stephanie and Ronald, there expected tenure in Brazil is for almost 18 months commencing from the beginning of tax year 2015/2016 and ending in October or November 2016. Additionally, based on the information provided, it is apparent that they would return back as they have a house on lease in Australia and also have a business in Australia which cannot flourish without Stephanie. Hence, it may be concluded that both Stephanie and Ronald are Australian tax residents for both tax years. Additionally, Rogan Advertising would also be an Australian tax resident company as the company in all likelihood seems to be Australia incorporated only Besides, the shareholders for the given years are also Australian tax residents and hence company is Australian resident for tax purpose. Assessable Income STEPHANIE Section 6(5) Ordinary Income Proceeds from personal exertion Employment income from the company to the tune of $ 80,000 This salary is credited in bank account in Brazil and thus may seem to be a foreign salary but as the taxpayer is Australian tax resident, hence the payments would be assessable. Also, the lecture income to the tune of $ 24,000 would be classified under this section since she indulges in activities that had commercial value and are linked to her skills as a advertiser. Proceeds from investment The house has been leased and thus lease payment would be classified here. Since there is joint ownership of the house, hence assuming 50% stake for each, Stephanie and Ronald would obtain half of the lease payment each. Proceeds from lease payments= (450/2)*52 = $ 11,700 Also, interest income would be received based on bank accounts in Brazil and Australia. Since both are jointly owned, hence each would be entitled to 50% of the interest income in each tax year. Besides, as per the scheme of arrangement the residual profits of company are paid equally to both Stephanie and Ronald as un-franked dividends. For calculation of assessable income in FY2016, it is assumed that lectures were held during this year only. Further, for both years, any income discussed above not stated is assumed to be zero for convenience. Also, it is assumed that the couple do eventually return to Australia by end of October end, 2016. Assessable income of Stephanie (FY2016) = 80000 + 11700 + 24000 = $ 115,700 Assessable income of Stephanie (FY2017) = 80000 + 17*(450/2) = $ 83,825 RONALD Section 6(5) Ordinary Income Proceeds from personal exertion Employment income from the company to the tune of $ 80,000 This salary is credited in bank account in Brazil and thus may seem to be a foreign salary but as the taxpayer is Australian tax resident, hence the payments would be assessable. Proceeds from investment The house has been leased and thus lease payment would be classified here. Since there is joint ownership of the house, hence assuming 50% stake for each, Stephanie and Ronald would obtain half of the lease payment each. Proceeds from lease payments= (450/2)*52 = $ 11,700 Also, interest income would be received based on bank accounts in Brazil and Australia. Since both are jointly owned, hence each would be entitled to 50% of the interest income in each tax year. Besides, as per the scheme of arrangement the residual profits of company are paid equally to both Stephanie and Ronald as un-franked dividends. Assessable income of Ronald (FY2016) = 80000 + 11700 = $ 91,700 Assessable income of Ronald (FY2017) = 80000 + 17*(450/2) = $ 83,825 Rogan Advertising: The relevant information about revenue and expenses have not been provided and therefore it is not possible to calculate the taxable income. Further for convenience sake, it is assumed that the operating revenue and expenses are equal and hence the companys taxable income is zero for both the years. Conclusion In wake of the missing information, the following information needs to be provided for calculation of assessable income. The date in FY2017 when the couple return back Imperative for tax residency status of FY2017 Interest income from both banks (Brazil and Australia) Calculation of assessable income of individual taxpayers (FY2016 and FY2017). Dates on which Stephanie gave the lectures Proceeds to be appropriately derived in the same year when the lectures were delivered The details about operating revenues and expenses of Rogan Advertisement Determination of taxable income of company and also of dividend income for individual taxpayers (FY2016 and FY2017). 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