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ng and there exist a business relation between the reward provider and consumer of the loyalty points. Also it considers if benefit is transferable indirectly or directly to money or if the consumer is carrying on a business. According to the ruling of Rabbi S. Binyomin Ginsberg against Northwest reward gotten by an employee in consumer loyalty program can be made fringe benefit so that it can be taxed if facts indicate that there was an agreement between the employer and employee in that provision of reward has a sufficient and material connection to employment. That is, the reward takes on the character of being a benefit received 'in respect of employment.

Question 1b

4. Factors affecting taxable income影响应纳税所得额的因素

4.1. Education expense, allowable and disallowable education expense 
The following are issues that affect taxable income of a taxpayer in the taxation law it  sets out guidelinesand the circumstances which individual self-education cost is allowable as for deduction to persons subject to Income Tax Ass essment Act 1936 (ITAA 1936) and or the Income Tax Assessment Act 1997 (ITAA 1997). It elaboratestypes of education expenses that are regarded asallowable. Self-education cost is deducted in section 8-1 where it is observed that there have is relevant relation to the individual recent income-earning duties.If individual income-earning daily activities are in regard of the utilization of special knowledge or skill and self-education enhances an individual to maintain that knowledge or skill, the self-education cost will be an allowable deduction.

5. conclusion总结

Also if self-education will lead to, or may lead to, an increment in an individual taxable income, the self-education cost will be an allowable deduction. In the case where studies shall enhance a taxpayer chances of getting employment or new employment and or open new income-earning undertaking is not enough ground by itself to make self-education cost to be an allowable  deduction.For example studies in occupation or profession, and or areas of employment by which an individual is not involved yet. The expenses are considered incurred in a situation too soon for them to be considered as incurred in producing or enhancing income. Deduction of expenses is done in section 8-1 in consideration if it has essential elements of an incurred income-producing cost. The essential factor is determined in the objective evaluation of all surrounding circumstances. These are situation where apart under section 8-1 is needed. 

References文献

Charles Moore & Co (WA) Pty Ltd v. FC of T (1956) 95 CLR 344 at 349-350; (1956) 11 ATD 147 at 148; (1956) 6 AITR 379 at 384; FC of T v. Cooper 91 ATC 4396 at 4403; (1991) 21 ATR 1616 at 1624; Roads and Traffic Authority of NSW v. FC of T 93 ATC 4508 at 4521; (1993) 26 ATR 76 at 91
FC of T v. White 75 ATC 4018; (1975) 5 ATR 192; FC of T v. Kropp 76 ATC 4406; (1976) 6 ATR 655; Case G65 75 ATC 474; 20 CTBR (NS) Case 36
Lunney v. FC of T; Hayley v. FC of T (1958) 100 CLR 478 at 497 498; (1958) 11 ATD 404 at 412
Ronpibon Tin NL v. FC of T (1949) 78 CLR 47 at 56; (1949) 8 ATD 431 at 435

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