#**Call for Papers** **_Tribute Edition Honouring Professor Michelle Markham_**

We invite submissions for a special tribute edition of the _Revenue Law Journal_ dedicated to the memory of our esteemed former Editor, Professor Michelle Markham, whose recent passing has deeply saddened the tax academic and professional community. Professor Michelle Markham served as the leading editor of and contributor to the _Revenue Law Journal_ with her unwavering commitment to advancing tax scholarship. Her legacy endures in the many contributions she nurtured and the generations of scholars she inspired. This edition will honour her contributions to the tax community by showcasing original research, reflections, and commentary about current domestic and international tax law issues and policy. We welcome: • Scholarly articles on contemporary tax issues • Reflections on her teaching and academic legacy • Case studies or policy analyses inspired by her work • Tributes from colleagues and collaborators **Submission Deadline: February 27, 2026** Word Limit: up to 3000 words Please direct any enquiries to rlj@bond.edu.au We look forward to receiving your contributions as we celebrate the life and legacy of a remarkable scholar and mentor. _____________________________________________________________________ We welcome the submission of articles and comments for publication in the _Revenue Law Journal_. Manuscripts are double blind reviewed by expert referees prior to acceptance for publication. The editorial policy is to publish articles of a tax policy or tax technical nature that are concise, analytical and clearly written. We are looking for articles that go further than pure description of the complex technical detail of the tax acts. We are looking as well for incisive analysis of the legislation, discussion and criticism of policy and innovative proposals for reform. This journal does not levy any Article Processing Charges for the processing or publication of a paper. All submissions must be accompanied by an abstract of 100-200 words. Manuscript length should be 4,000 – 10,000 words, excluding footnotes. # Submit Manuscript Manuscripts must be uploaded as a Word document only with all reference to author/s identify removed. Should submission of a revised manuscript be required, authors must upload the Word doc via ‘Manage manuscript’ only. All articles submitted to the Journal will be subject to checks for plagiarism using iThenticate plagiarism detection software. **Anonymity** In order to maintain anonymity in the review process, authors are required to ensure that all information that might identify the author to potential reviewers should be removed (including his or her credentials), references to his or her other publications (unless included as a general reference), and identification of affiliated organisation and/or geographic location. # _Authors Style Guide_ Articles must be in English. The electronic file name should not include the author name. The TITLE may be abbreviated to the first few key words. When the paper is accepted for publication, following the review and corrections, if any, the author(s) will be asked to submit a final file in Microsoft Word for the purpose of editing and typesetting. **Manuscript Format** The title of the paper should be in Sentence Case. Section Headings should be justified left and be in bold. Each main Section Heading should be numbered in Arabic numerals. Each subheading should be justified to the left (and formatted in italics), and follow the alphabetical numbering by A, B, C, etc. Manuscript must be typed on one side of the A4 paper, double spaced and with a margin of 2.5 cm on the left- and 2 cm on the right hand-side. Please use Arial font size 11. **Title Page** Please include a date on the title page of the manuscript, e.g. "Working paper, May 24, 20xx". **Abstract** The page containing the abstract must be the second page of the paper after the title page. The abstract page however must be numbered as the first page of the paper. The abstract should be complete, self-contained, and is no longer than 200 words. At least five key words/phrases must be provided below the abstract. **Tables and Figures** Tables and Figures should be in camera-ready form in the final version of the accepted paper. They should be numbered consecutively in Arabic numerals. Example: "Table 3" on one line, and in the next line include the title of the table before the table itself. Each table and graph must have self-contained descriptions to explain the contents. **Referencing** Manuscripts from the Law disciplines must be referenced using the [Australian Guide to Legal Citation (AGLC 4th ed)](https://drive.google.com/file/d/1TGvYqdqQnOU-GtSV3I25ft6EyYIx_w4U/edit). Footnotes apply when adopting the AGLC style. Examples are provided in the AGLC guide. **Submission Process Summary** * The first page of the article should contain only the title with no acknowledgements, footnote or any other information identifying authors or their institutional affiliations. * The electronic file name should follow the format of “author-TITLE.doc” or docx. The TITLE may be abbreviated to the first few key words. * The article must be a Microsoft Word. Graphics must be scalable. * Microsoft Office documents should be submitted in MS file versions no earlier than Office 2007. * Include keywords to describe the paper. * Include acknowledgements. # _Copyright and Publication Policy_ This policy sets out the terms under which the Author/s agree to permit the Revenue Law Journal (RLJ) to (1) publish and reproduce the Manuscript, and (2) permit others to publish and reproduce the Manuscript. **Copyright of the Author/s** Copyright in the Manuscript is owned by the Author and RLJ jointly. All publications are made available under a [Creative Commons CC-BY-NC-ND licence](https://creativecommons.org/licenses/). **Authorship** The Editorial Committee of the RLJ regards the Manuscript as the original work of the Author/s. The Author/s therefore warrant that the Manuscript: * Is an original work created solely by the Author/s, is not plagiarised, and no part of the Manuscript infringes the copyright of another person; * Properly attributes any material contained in it not created solely by the Author/s; * Does not contain any material that is defamatory; and * Does not infringe any of the rights of any third party. **Ethics Approval** The Editorial Committee of the RLJ aims to ensure that all articles published in the RLJ report on work that is morally acceptable. The Author/s therefore warrant that they sought and obtained appropriate ethical approval for any research reported in the Manuscript, and that they have obtained the informed consent of research subjects or interviewees wherever necessary. **Sole Submission for Publication** A Manuscript submitted for publication in the RLJ must not have been published elsewhere, or have been submitted for publication with another journal. The Author/s therefore warrant that the Manuscript: * Has not been published in whole or in part elsewhere; * Will not be submitted for publication elsewhere whilst it is under consideration by the RLJ; and * If related to material presented at a conference, has either not been published in conference proceedings or is substantially different to what has been published in the conference proceedings. **Copyright Royalties** The RLJ is registered with the Copyright Agency (Australia) which is a non-profit organisation offering centralised licencing arrangements for reproduction of works. The Author/s agree that any income received through these arrangements will be used by the RLJ to further the interests of the RLJ. # Review of the Manuscript In submitting the Manuscript for publication in the RLJ, the Author/s agree to be bound by the decisions of the Editorial Committee. All decisions of the Editorial Committee about whether or not to publish the Manuscript in the RLJ shall be final. The Manuscript may be: * Rejected by the Editorial Committee before being sent to referees; * Returned to the Author/s for revision prior to being sent to referees; * Rejected after refereeing, or if requested changes are not made in a timely manner; and/or * Returned to the Author/s for revision at any time after refereeing, after proofing, and/or after typesetting. The Author/s acknowledge that the above process is to ensure a high quality production with full compliant references. The Editorial Committee reserves the right to edit the Manuscript to ensure that it conforms to accepted grammatical, presentation and in-house style guidelines and to enhance clarity of expression. While the Editorial Committee will endeavour to consult the Author/s before making such changes, there may be occasions when due to time constraints this will not possible. The Author/s approval of the final draft of the Manuscript will be sought prior to publication, unless the Author/s indicate in writing that they do not wish this to occur. # Publication and Reproduction The RLJ has relationships with online databases and will make the article available via them, in order to increase the rate of circulation and citation of articles. The Author/s agree not to make the Manuscript available for third party reproduction in any format including online media and University e-prints databases until one calendar year after publication in the RLJ. After that time, where the article is reproduced, the Author/s will ensure that the reproduction will be made under the terms of the Creative Commons licence stated: [CC-BY-NC-ND](https://creativecommons.org/licenses/by-nc-nd/4.0/). # Contact For all general enquiries please contact the RLJ editorial office at the Bond University Law Faculty: Email: RLJ@bond.edu.au

A Critical Analysis of the Foreign Tax Credit in Australia and its Relationship to the Imputation and Controlled Foreign Entities Legislation