Construction Contracting in Arizona - Free Essay Example

Sample details Pages: 10 Words: 2936 Downloads: 6 Date added: 2017/06/26 Category Building Essay Type Research paper Level High school Did you like this example? Construction Contracting on Tribal Lands in Arizona: Both the State Tax and a Tribal Tax May ApplyPage 1 of 7 SALES TAXATION OF CONSTRUCTION CONTRACTING ON TRIBAL LANDS IN ARIZONA: BOTH THE STATE TAX AND A TRIBAL TAX MAY APPLY Randal T. Evans* Arizona is home to 22 federally-recognized Indian tribes. Tribal lands comprise over a quarter of Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s land base. Don’t waste time! Our writers will create an original "Construction Contracting in Arizona" essay for you Create order As a result, a significant amount of construction activity in Arizona takes place on tribal lands, including recent and ongoing large-scale development projects. Contractors performing services on tribal lands in Arizona are faced with the somewhat daunting task of determining what taxes apply to each particular project. In Arizona, this inquiry involves two separate questions: (1) does the Arizona transaction privilege tax apply, and (2) does a tribal tax apply? Both of these questions require an analysis of state or tribal tax law and federal Indian law, but the two questions must be analyzed independently. In many situations, a contractor performing services on tribal lands may be subject to both a state and a tribal tax, as Indian tribes and states are recognized as having concurrent taxing authority over non-Indian transactions on Indian lands, except in limited circumstances. Further, this inquiry must be done on a project-by-project basis, as the law in this arena is par ticularly fact-based, still evolving, and filled with nuances, subtleties, and complexities. This article briefly addresses each of these questions, focusing on some of the more significant federal and state court cases and the Arizona Department of Revenueà ¢Ã¢â€š ¬Ã¢â€ž ¢s ruling dealing with transactions involving tribal lands. This article is intended as an introduction only. Contractors performing services on tribal lands will need to undertake a careful analysis of what tax laws apply for each particular project, working closely with their legal counsel and/or a state and local tax professional with experience in this particular area of law. Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s Transaction Privilege (Sales) Tax on Construction Contracting Differs Significantly From Other States In place of a traditional sales tax, Arizona imposes a Transaction Privilege Tax (TPT) on specified business activities, including retail sales, personal property rentals, and construction contracting, among others. The Arizona transaction privilege tax is commonly referred to as a sales tax; however, the tax is imposed on the business engaged in a taxable activity, and is not a true sales tax. Although the transaction privilege tax is usually passed on to the consumer, the legal burden (incidence) of the tax is on the seller. Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax treatment of construction contracting is significantly different than that of other states. In most other states, sales of building materials are taxable, and there is no sales tax on a contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢s receipts from construction services. Arizona is just the opposite. In Arizona, sales of building materials to contractors generally are exempt from the retail sales tax, and a à ¢Ã¢â€š ¬Ã…“prime contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢sà ¢Ã¢â€š ¬Ã‚  gross receipts from construction contracting are subject to the transaction privilege tax. See A.R.S. 42-5061(A)(27), 42-5075. As of March 1, 2014, the combined state and co unty tax rates for construction contracting range from 5.85% to 7.6%. See  https://azdor.gov/transaction-privilege-tax/tax-rate-table. There are many nuances to how the Arizona sales tax applies to different construction contracting variations, such as speculative build, design-build, owner-build, construction manager, and other types of contracting arrangements. These nuances in the state tax structure are often amplified when the construction takes place on tribal lands. In Some Situations, Arizona Sales Tax May Apply to Construction Services on Tribal Lands Historically, the U.S. Supreme Court held that states had no jurisdiction within the territory of an Indian tribe. Indian tribes are still recognized as sovereign entities under federal law (see the very recent U.S. Supreme Court holding in Michigan v. Bay Mills Indian Cmty, __ U.S. __ (2014), affirming that Indian tribes are à ¢Ã¢â€š ¬Ã…“à ¢Ã¢â€š ¬Ã¢â€ž ¢domestic dependent nationsà ¢Ã¢â€š ¬Ã¢â€ž ¢ that exercis e à ¢Ã¢â€š ¬Ã‹Å"inherent sovereign authorityà ¢Ã¢â€š ¬Ã¢â€ž ¢Ãƒ ¢Ã¢â€š ¬Ã‚  and upholding a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s sovereign immunity from suit). Notwithstanding, federal courts à ¢Ã¢â€š ¬Ã…“long agoà ¢Ã¢â€š ¬Ã‚  departed from the view that à ¢Ã¢â€š ¬Ã…“à ¢Ã¢â€š ¬Ã‹Å"the laws of [a State] can have no forceà ¢Ã¢â€š ¬Ã¢â€ž ¢ within reservation boundaries.à ¢Ã¢â€š ¬Ã‚  White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 141 (1980). Even so, states do not have unlimited regulatory authority over activities that take place on tribal lands. See Nevada v. Hicks, 533 U.S. 353 at 362 (2001). In the context of state taxation, the general rule now is that states may impose a tax on transactions that occur on tribal lands, unless the federal government has expressly prohibited state taxation (that is, unless federal law preempts the state tax), or the state tax would unduly interfere with significant federal and tribal interests. See Cotton Petroleum Corp. v. New Mexico, 4 90 U.S. 163, 188-189 (1989). There are several situations, discussed below, where federal law may prohibit the state from imposing a tax on construction services performed on tribal lands. Arizona Sales Tax Does NOT Apply to On-Reservation Services Performed by the Tribe or a Tribal Member Under federal preemption principles, state sales taxes may not be imposed on the business activities of an Indian tribe, a tribe-owned entity, or an enrolled member of the tribe, if the activities take place on that tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. See, e.g., White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 144 (1980) (à ¢Ã¢â€š ¬Ã…“[w]hen on-reservation conduct involving only Indians is at issue, state law is generally inapplicable, for the stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s regulatory interest is likely to be minimal and the federal interest in encouraging tribal self-government is at its strongestà ¢Ã¢â€š ¬Ã‚ ). The Arizona Department of Revenue, in Transaction Privilege Tax Ruling (TPR) 95-11, details its position regarding the taxability of construction work performed on an Indian reservation. TPR 95-11 recognizes that Arizona sales tax does not apply to the gross proceeds derived from contracting activities performed on a reservation by the Indian tribe, a tribal entity, or an enrolled member of that tribe. TPR 95-11 I.A, C. Arizona Sales Tax Does NOT Apply to the On-Reservation Services of a Non-Member Contractor Performing Services Under Contract with the Tribe, a Tribal Entity, or a Tribal Member The Arizona sales tax also does not apply to construction services performed under a contract with an Indian tribe, a tribal entity, or an enrolled tribal member, if the construction activities take place within that tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. Where a non-tribal member makes a sale or performs a service on tribal lands, federal courts generally apply a à ¢Ã¢â€š ¬Ã…“balancing testà ¢Ã¢â€š ¬Ã‚  to determine whether state sales tax applies , weighing on one hand federal and tribal interests, and on the other, the stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s interests. See, e.g., White Mountain Apache Tribe v. Bracker, 448 U.S. 136 (1980). This analysis is referred to as the à ¢Ã¢â€š ¬Ã…“Bracker balancing test,à ¢Ã¢â€š ¬Ã‚  named after the Supreme Court case that established the test. In Bracker, the Supreme Court applied this test and determined that Arizona could not impose motor carrier and use fuel taxes on a non-Indian logging and hauling company hired by a tribe for on-reservation logging operations. In that case, the state was prohibited from imposing its taxes because the interests of the federal government and the tribe, as reflected in federal regulations, outweighed Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s general interest in tax revenue. Bracker, 448 U.S. at 144-53. Two years after the White Mountain Apache case, the Supreme Court applied the Bracker test in holding that New Mexico could not impose its gross receipts tax on a contra ctorà ¢Ã¢â€š ¬Ã¢â€ž ¢s proceeds from the construction of a school built on the Navajo Indian reservation by a local school board which had been formed by a chapter of the Navajo Nation. Ramah Navajo School Board, Inc. v. Bureau of Revenue, 458 U.S. 832 (1982). As for Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s sales tax, TPR 95-11 recognizes that the Arizona tax does not apply to proceeds from a construction project performed on an Indian reservation by a non-affiliated Indian or non-Indian prime contractor, if one of the following conditions apply: 1. The activity is performed for the tribe or a tribal entity for which the reservation was established; or 2. The activity is performed for an individual Indian who is a member of the tribe for which the reservation was established. TPR 95-11 I.C. Under Ramah and TPR 95-11, in order to be exempt from the Arizona tax, the contract must be with the Indian tribe, a tribal entity, or an enrolled member of the tribe. As illustrated by the two cases discussed below (Blaze and Greenberg), if the contract is with a federal or state agency, the project generally will be subject to the state tax, even though the project ultimately benefits the tribe or tribal members. Arizona Sales Tax Generally DOES Apply to Construction Services Performed on Tribal Lands Under Contract with a Federal or State Agency Under the Supremacy Clause of the U.S. Constitution, states are not permitted to impose a tax directly on the federal government. See United States v. New Mexico, 455 U.S. 720, 733 (1982). This limitation applies only when the tax is imposed directly on the federal government or a federal agency or instrumentality, but does not apply to federal contractors in states such as Arizona, where the legal incidence of the tax is on the contractor. Id. at 735-36; see also Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue v. Blaze Constr., 526 U.S. 32 (1999) (receipts from BIA contract for the construction of roads on six Indian reservations in A rizona subject to Arizona TPT because the legal incidence of the tax fell on the contractor, not the government purchaser); Tucson Mech. Contracting, Inc. v. Arizona Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue, 175 Ariz. 176, 854 P.2d 1162 (App. 1992) (Arizona contractors subject to TPT on federal contracts; mandatory receipt provision in contracts did not shift the legal incidence of the tax to the government purchaser). In the Blaze case, the U.S. Supreme Court held that for federal contracts involving construction on tribal lands, the Bracker balancing test (discussed above) does not apply. Rather, courts apply the general rule established in United States v. New Mexico, that federal contractors may be subject to state sales tax if the legal burden of the tax is on the contractor. See Blaze Constr. Co., 526 U.S. 32. The same rule applies to contracts with state agencies for construction projects on tribal lands. In a 1995 case, the Arizona Court of Appeals affirmed the taxability of a construction contract with an Arizona school district (a subdivision of the State of Arizona), even though the work was performed on an Indian reservation and ultimately benefitted tribal members. Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue v. M. Greenberg Constr., 182 Ariz. 397 (App. 1995). TPR 95-11 establishes Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s position that à ¢Ã¢â€š ¬Ã…“[t]he gross proceeds derived from construction projects performed on Indian reservations by non-affiliated Indian and non-Indian prime contractors for all other persons [other than for an Indian tribe, a tribal entity, or an enrolled tribal member], including the federal government, are subject to the imposition of Arizona transaction privilege tax.à ¢Ã¢â€š ¬Ã‚  Arizona Sales Tax MAY Apply to the Receipts of Tribe-Owned and Tribal Member-Owned Contractors Performing Services Off-Reservation, Including Other Tribesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Reservations The Supreme Court has held that tribes and tribal enterprises may be su bject to state taxation for off-reservation business activities. Mescalero Apache Tribe v. Jones, 411 U.S. 145, 148-9 (1973). This is a general rule, and there are exceptions where the state tax may be prohibited by federal law or treaty rights. In Arizona, tribe-owned or tribal member-owned contractors generally will be subject to state sales tax for off-reservation activities, including services performed on another tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. In a 1999 case, the Arizona Board of Tax Appeals upheld the application of the Arizona tax to the receipts of a construction contracting company owned by members of the Cherokee Nation for services performed under contract with the Tuba City Unified School District, a political subdivision of Arizona, located on the Navajo Nation. Flintco Inc. v. Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue, No. 1801-99-S (Oct. 19, 1999). Although, unlike Greenburg, the contractor was an Indian-owned business, the board followed a line of federal cases tre ating a non-member Indian the same as a non-Indian for jurisdictional purposes, and thus concluded that the Arizona tax was not prohibited by federal law. A Tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s Tax May Also Apply Independent of whether the Arizona sales tax applies, a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax may also apply to the receipts of a construction contractor performing services on tribal lands. Indian tribes have the authority to levy taxes on activities that take place within their reservation and may impose tax on non-Indians. See, e.g., Kerr-McGee Corp. v. Navajo Tribe, 471 U.S. 195 (1985); Merrion v. Jicarilla Apache Tribe, 455 U.S. 130, 137 (1982). The following analysis may be used to determine whether a construction contractor is subject to tribal tax: 1.Has the Tribe Passed a Tax Ordinance? The first step in determining whether a tribal tax applies is to determine whether the tribe has been authorized by its constitution, charter, or other governing instrument to impose taxe s and whether the tribe has passed a tax ordinance pursuant to such authority. The best way to determine whether a particular Indian tribe has a tax ordinance in place is to contact the tribe itself. The Arizona Commission of Indian Affairs maintains a list of Indian tribes in Arizona, with contact information for each tribe, at https://www.indianaffairs.state.az.us/tribes/tribes.html. 2.Does the Tribal Tax Apply to Construction Contracting? Assuming that the Indian tribe has enacted a tax code, the next step is to determine whether the tax applies to construction contracting activities. Below are a few examples of tribal taxes that apply to contracting services performed within the Indian nation or community. The Navajo Nation imposes a sales tax on all sales of goods or services within the Navajo Nation, including construction services. See 24 NNC 607. Effective January 1, 2013, the Navajo Nation Sales Tax Rate is 5%. See www.NavajoTax.org. The Navajo Nation also imposes a Business Activity Tax (BAT) that is subject to certain business transactions that fall outside the scope of the Navajo Sales Tax. In November 2013, the Office of the Navajo Tax Commission issued a Public Ruling on the Taxability of Pre-Construction Activities Under the Navajo Nations Sales Tax and Business Activity Tax. See navajotax.org/public_rulings_directory. The Salt River Pima-Maricopa Indian Community imposes a privilege license tax on business activities, including contracting, conducted within the Community. See Salt River Pima-Maricopa Indian Community Code 15-51, 15-52. The tax is structured similarly to the Arizona transaction privilege tax, with the tax computed on 65% of the prime contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢s receipts for construction services performed within the Community. See Code 15-52(a). The tax rate depends on the ownership of the business. The tax rate for businesses owned and operated by non-Community members is 1.65%, while the rate for businesses owned and operated by Community members is 7.95%. This difference in rates follows the rule discussed above, that transactions conducted by Community members within the Communityà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation are not subject to the Arizona transaction privilege tax. See www.srpmic-nsn.gov/government/treasurer. The Gila River Indian Community imposes a license privilege tax on business transacted by persons on account of their activities on the Reservation. See Gila River Indian Community Law and Order Code, Title 13 (Business Licenses and Taxation), Chapter 3 (Imposition of Privilege Taxes). The Gila River tax on construction contracting is also structured similarly to the Arizona transaction privilege tax, allowing for a 35% standard deduction. See Code 13.311(A) (Construction contracting). Effective December 1, 2013, the tax rate is 6%. Id. If the project is subject to the Arizona transaction privilege tax, a deduction equal to 75% of the gross proceeds may be taken when computing the Gila River tax; however, this deduction only applies where the contract is between the contractor and a tenant in areas designated by the Community for the promotion of economic development. Code 13.311(C). See www.gilariver.org gt; Departments gt; Revenue/Internal Audit Department. 3.Is the Project Located on Indian Lands? The final step to determine whether tribal tax applies is to confirm that the construction project is fact on land that is part of the Indian reservation or community. A tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s power to tax non-Indian business activity extends to reservation lands (lands held in trust for the tribe), as well as trust allotments of tribal members and other lands that are considered part of à ¢Ã¢â€š ¬Ã…“Indian Country,à ¢Ã¢â€š ¬Ã‚  as that term is defined by federal law. Mustang Production Co. v. Harrison, 94 F.3d 1382 (10th cir. 1996), cert. den., 117 S.Ct. 1288 (1997) (tribe may impose a severance tax on non-Indian oil and gas producers operating on trust allotments outside of the tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation). Except in limited circumstances, a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s authority to tax generally does not extend to non-Indian fee land (or the equivalent of fee land), even if that land is within the exterior boundaries of the reservation. See Montana v. United States, 450 U.S. 544, 565 (1981) (with limited exceptions, Indian tribes lack civil authority, including taxing authority, over the conduct of nonmembers on non-Indian fee lands); Atkinson Trading Company, Inc. v. Shirley, 532 U.S. 645 (2001) (applying Montana and holding that the Navajo Nation did not have the authority to impose its Hotel Occupancy Tax on a hotel located on fee land situated within the exterior boundaries of the Navajo Reservation). Conclusion The tax treatment of construction contracting on tribal lands in Arizona involves the overlap of three distinct areas of law: (1) Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax treatment of construction contractors, which differs significantly from most other states; (2) tribal law governing the taxation of activities conducted on tribal lands; and (3) federal Indian law issues relating to the taxation of Indian tribes, tribal members, and those doing business with them. Each is a complex arena filled with nuance, subtleties, and complexities. Together, they create a perfect storm that churns up unique legal issues and requires careful and individualized analysis at the outset of each construction project involving services performed on tribal lands.

The Wolf Of Wall Street Essay - 1753 Words

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Greater London Authority Free Essays

This business report aims to investigate the policies affecting the environment in London. A review will be made into the responsibilities of the Greater London Authority (GLA) and the mayor. A critical evaluation of the evidence will be provided. We will write a custom essay sample on Greater London Authority or any similar topic only for you Order Now A survey of opinions amongst GSM students will be presented and a conclusion drawn on the effectiveness of the Greater London Authority (GLA) and the Mayor in tackling key issues which relate to the environment. It has been estimated that London, the capital of England, has a population of more than eight million (www. tandard. co. uk). With a 0. 7% fall in GDP in the second quarter of 2012 (GLAEconomics, 2012) the Mayor of London (MoL) plays an important role in ‘improving London for all’ (london. gov. uk). The Greater London Authority (GLA) is a top-tier administrative body for London (http://en. wikipedia. org/wiki/Greater_London_Authority) which consists of an elected mayor, the London assembly and permanent members of GLA staff who collaboratively work towards design a better capital (www. london. gov. uk/who-runs-london/greater-london-authority). The MoL is responsible for the economic, environmental, social enhancement of the city (www. london. gov. uk/who-runs-london/mayor/role). Plans and policies are developed to tackle the issues effect London such as transport, housing, health inequalities and environmental issues (www. london. gov. uk/who-runs-london/mayor/role). Environmental issues can be defined as the overuse of natural resources (Fransson and Garling, 1999) and can be categorised into air, water, radiation and odor pollution (http://www. environment-agency. ov. uk). The United Kingdom (UK), ranked eighth in the world for emit the highest carbon dioxide emissions (http://www. ucsusa. org). The UK generates 586 million tonnes of carbon dioxide a year. Even though significant efforts are being made to reduce our carbon footprint such as building the world’s largest wind farm, pollution due transportation however still remains a major problem in the UK (http://www. actionforourplanet. com). Environmental concer n has risen on the political agenda since 2003. Various olicies have been introduced since then, relating to the environment. In 2009, a document entitled ‘Leading to a Greener London’ was published setting out the aims for London to reduce its carbon foot print and become ‘one of the worlds greenest cities’ (https://www. london. gov. uk/priorities/environment/vision-strateg. The Mayors Municipal waste strategy (2011) sets out to improve the life of Londoners by retrofitting London, greening London and cleaner air for London (http://www. london. gov. uk/sites/default/files/Municipal%20Waste_FINAL. pdf). Retrofitting or mordenising our homes and workplaces to be more energy efficient is considered to be a vital action, as this accounts for nearly eighty percent (80%) of the cities emissions. Greening London consists of increasing London’s tree coverage and green spaces in order to improve air quality, reduce the impact of extreme weather conditions and increase the vibrancy of the city. The mayor has already made various steps towards achieving cleaner air for London which includes introducing new cleaner hybrid buses (http://www. london. gov. k/priorities/transport/green-transport/hybrid-buses), charging points for electric cars (https://www. sourcelondon. net) and barlays cycle hire is due to be expanding to south west London in 2014 (http://www. tfl. gov. uk/corporate/media/newscentre/archive/25711. aspx). Nevertheless, evidence shows that air pollution in our capital has exceeding EU limits and proves that London has a long way to go to improve emissions (http://www. londo n. gov. uk/media/press_releases_london_assembly/new-figures-reveal-limits-harmful-air-pollution-breached-across-capital). The business waste Strategy (2011) sets out to direct the management of business waste. London currently produces 20 million tones of waste a year. With London growing, this amount is due to increase. The aim of this policy is to educate and encourage Londoners to reduce, reuse and recycle their household and support business’s to dispose of their waste more efficiently and effectively (http://www. london. gov. uk/priorities/environment/vision-strategy/waste). These policies have filtered down to local councils and a proposal has been drawn in the borough of Croydon to target those who persistently refuse to recycle with a fixed penalty of ? 0 (http://www. croydon. gov. uk/environment/rrandw/recycling-rates/). However, even with the governments increasing efforts to try a reduce waste and encourage recycling, there are many areas in society where this is not happening. For example, the government’s voluntary scheme to cut the use if throwaway bags issued by supermarkets has been a disappointment. The use of plastic bags has increased for the second year running (http://www. guardian. co. uk/environment/2012/jul/05/plastic-bag-use-rise-supermarkets). In response, a proposal making it mandatory to charge all single use carrier bags may be enforced (http://www. ondon. gov. uk/media/press_releases_assembly_member/news-jenny-jones-am-calling-charge-all-single-use-carrier-bags). In conclusion, government will always make proposals and draw up policies however sometimes implementing these policies at a local level is very challenging. Even though the GLA want to see improvements and continuously demand, support needs to be made at a local level to help guide local authorities through continuous changes enforced upon them. REFERENCING FRANSSON, N. GARLING,T. (1999) ENVIRONMENTALCONCERN: CONCEPTUAL DEFINITIONS, MEASUREMENT METHODS, AND RESEARCH FINDINGS. Journal of Environmental Psychology, 19 (4) pp 369–382 http://www. actionforourplanet. com/#/top-10-polluting-countries/4541684868 http://www. london. gov. uk/media/press_releases_london_assembly/new-figures-reveal-limits-harmful-air-pollution-breached-across-capital http://www. london. gov. uk/priorities/transport/green-transport/hybrid-buses http://www. london. gov. uk/sites/default/files/Business%20Waste_FINAL. pdf). http://www. london. gov. uk/sites/default/files/Business%20Waste_FINAL. pdf http://www. london. gov. uk/sites/default/files/londons_economy_today_no119_26071 How to cite Greater London Authority, Papers

Importance of Learning Indigenous Australian- myassignmenthelp

Question: Discuss about theImportance of Learning Indigenous Australianfor Nurses. Answer: History and culture defines an individual or community way of thinking, communication and what of value and important in their life. History shape the present time and determine how people think about their future. Culture, being a part of human lives, influences values, views, hopes, loyalties, fears and worries (Ford, 2012). The indigenous Australian comprise of Torres Strait Islander and Aboriginal. The Indigenous Australians have their history dating back 75000 years. They are amongst the world oldest cultures and demand consideration and respect (Mitrou et al., 2014). The indigenous Australian culture has been adversely affected when Australia was colonized by Great Britain and its impact is felt to date. The historical injustices have led to the most problems experienced among the Aboriginals and Torres Islanders communities and continually shape their lives. Understanding culture and history enables a professional to build relationships with individuals and community that help to attain effective delivery of services. Therefore, it important for professional working closely with indigenous communities to understand their past and culture in order to successfully deliver on their workplace. The following essay critically discusses the importance and value of nurse professionals completing a course in introduction to indigenous Australia. This will involve exploring the usefulness of learning about the histories and culture of Indigenous Australians and the impact of the past to future generation. The essay will also discuss the issues of cultural differences and diversity. Nursing as a profession in health care sector plays an important role on caring for families, individuals, and communities so that they can attain, recover or maintain optimal health. Nurses are involved promotion, protection, and optimization of health, facilitation of healing, prevention of injury and illness, alleviation of suffering and advocacy of care to group, communities, families, individuals, or special population (Shepherd, Li, Mitrou, Zubrick, 2012). Nurses aim to improve quality of life through optimal health care. Nurses work closely with Indigenous Australians and it necessary for them to understand their history and culture to deliver optimal. First, nurses completing the unit on introduction to indigenous Australia will be able to understand health in Torres Strait Islander and Aboriginal context. Health is viewed in a more holistic content as compared to non-indigenous Australians. Health encompasses physical and mental health, culture and spiritual health. In addition, land is central to indigenous Australians wellbeing (Downing, Kowal, Paradies, 2011). This is different from the non indigenous Australian where health is viewed as mental and physical wellness with land playing not part of wellbeing. The nurses have to understand that in order to achieve optimal health among indigenous Australians they have to enhance harmony of interrelations of physical and mental health, culture and spiritual health. Otherwise, the individual unwell health will persist. Secondly, it important for nurses to understand the indigenous Australian history contest and its impact. Nurses working with Aboriginals and Torres Strait Islander need to have sound understanding of Australian history since colonization. The Australian history has profound impact that has influence on the contemporary life. The indigenous Australia history from pre-colonization, colonization, white assimilation to stolen generation has created disruption that require understanding to solve the health problem of Aboriginals and Torres Islander(Mitrou et al., 2014). The history of indigenous Australians is a social determinant of health to their contemporary life. The indigenous people were subjection to colonization led to increased substance abuse and mental health unwell being. Colonization led to loss of culture and traditional ways, people and communities (Paradies, 2016). The people got disconnected to traditional law, food, language, and cultural practices. The indigenous were therefore unable to resist new diseases that caused significant deaths and ongoing health problems. Nurses will therefore be able to understand the beginning of the health problem that the Aboriginal and Torres Islanders face in Australia. The nurses will also be able to understand the reason behind the indigenous Australians behavior. Secondly, nurses are able to understand the impact of colonization to mental health. The nurses are able to understand histories of colonization, removal of children and assimilation policies are the causes of traumatic distress, physical ill-health, chronic anxiety, depression and substance abuse in the indigenous lives today (Gracey, King, 2009).. The nurses then are able to understand the impact of history that has continually affected the lives of indigenous Australians. This will help nurses formulate appropriate health care promotion strategies that aim to solve root cause of the problem and not just the symptoms. Understanding the root cause will also enable nurses to advocate for health policies holistically solve the history injustice causing unwell being among indigenous Australians. The nurses will also be able to appreciate the indigenous people culture, traditions, and beliefs. Nurses will get expose to indigenous people traditions, culture, and beliefs. Culture, traditions, and beliefs shapes ones thinking, attitude, and perception that influence the human behavior. The course explores important concepts such as living under the Act, self determination, arts, and indigenous identity. These concepts are important to nursing professionals in learning how to appreciate the indigenous people way of living. The impact of historical injustice, assimilation, and children separation has a profound impact on the future generations of indigenous people on how they integrate with the non indigenous Australians (Parker et al., 2012). Appreciation of the indigenous people will enable the nurses to widen the scope of health care provision. The completion of studying indigenous history will also enable the nurses recognize the European invasion was as the direct outcome of the contemporary experienced unwell being among indigenous Australia. The Europeans caused cultural disruption that led to cultural unwell being. This cause the indigenous people to fear to be treated by white nurses (Garnett et al., 2009). It also causes mistrust between the indigenous people and the white professionals. Recognizing this fact will enable the nurses to start a reconciliation and building of trust while working with indigenous people. Failure to reconcile and build trust can lead to patients from Aboriginals and Torres Islanders refusing to attend to medical attention fearing that they will die in the hands of white nurse or doctors (Whelan Wright, 2013). The nurses will also be able to recognize the role of kinship, family, and community in administering health care. Recognition will help the nurses incorporate a wide scope and invol ve the family and builds trust in order to undertake their activities effectively and deliver quality health care to indigenous communities. Lastly, completing the course will enable nurses to attain culture competence skills. The nurses will be able to interact effectively with indigenous people. Nurses will understand, appreciate, and recognize indigenous people traditions, beliefs, and culture (Mitrou et al., 2014). The nurses will be able to understand the expected behaviors from indigenous people. The nurses will not look down or stop them proceeding to practice their traditions, or beliefs. The nurses will encourage them to participate and align the practices to attain harmony that will lead to healthy life of the patient. Appreciating the indigenous culture will enable the nurses to incorporate the culture in their treatment. For instance, the nurses can use the indigenous community arts in healthy centers or community ambulances to create a sense of belonging to the community. Appreciation will therefore create an enabling environment where the indigenous people will feel appreciated and will visit for health chec kups or medical attention. Cultural competence also enable the nurses recognize the cultural practices, traditions and beliefs. This will build successful relationship that will be used to provide quality health care. Culture compete is therefore important for nurses to effectively deliver quality health care to indigenous people that meet their cultural, social and linguistic need. From the discussion of the essay, the completion of introduction to indigenous Australia is an important study to nurses who will work with indigenous communities. The course exposes nurses to history of indigenous people before colonization, during colonization, assimilation, and stolen generation. The course is important to nursing profession because of nature of their work that require trust, relationships and understanding. Nursing professionals are able to appreciate, understand, recognize, and acquire cultural competence from the course that are useful in delivering effective health care to indigenous people. Appreciating, understanding and recognizing indigenous people culture is importance to settling cultural differences and encouraging diversity among the indigenous and non indigenous Australians. Therefore, the essay concludes that introduction to indigenous Australia is an important course that extends understanding, appreciation, recognition and enhances cultural compete nce skills that professionals can use when working with indigenous communities in Australia. References Downing, R., Kowal, E., Paradies, Y. (2011). Indigenous cultural training for health workers in Australia. International Journal for Quality in Health Care, 23(3), 247257. https://doi.org/10.1093/intqhc/mzr008 Ford, J. D. (2012). Indigenous health and climate change. American Journal of Public Health, 102(7), 12601266. https://doi.org/10.2105/AJPH.2012.300752 Garnett, S. T., Sithole, B., Whitehead, P. J., Burgess, C. P., Johnston, F. H., Lea, T. (2009). Healthy country, healthy people: Policy implications of links between indigenous human health and environmental condition in tropical Australia. Australian Journal of Public Administration, 68(1), 5366. https://doi.org/10.1111/j.1467-8500.2008.00609.x Mitrou, F., Cooke, M., Lawrence, D., Povah, D., Mobilia, E., Guimond, E., Zubrick, S. R. (2014). Gaps in Indigenous disadvantage not closing: A census cohort study of social determinants of health in Australia, Canada, and New Zealand from 1981-2006. BMC Public Health, 14(1). https://doi.org/10.1186/1471-2458-14-201 Paradies, Y. (2016). Colonisation, racism and indigenous health. Journal of Population Research, 33(1), 8396. https://doi.org/10.1007/s12546-016-9159-y Parker, E. J., Misan, G., Chong, A., Mills, H., Roberts-Thomson, K., Horowitz, A. M., Jamieson, L. M. (2012). An oral health literacy intervention for Indigenous adults in a rural setting in Australia. BMC Public Health, 12(1). https://doi.org/10.1186/1471-2458-12-461 Shepherd, C. C. J., Li, J., Mitrou, F., Zubrick, S. R. (2012). Socioeconomic disparities in the mental health of Indigenous children in Western Australia. BMC Public Health, 12(1). https://doi.org/10.1186/1471-2458-12-756 Whelan, S., Wright, D. J. (2013). Health services use and lifestyle choices of Indigenous and non-Indigenous Australians. Social Science and Medicine, 84, 112. https://doi.org/10.1016/j.socscimed.2013.02.013