How is 'permanent' defined with respect to the residence of individuals and the domicile test? Cite the key authority for this definition. Why do you believe the Court defined 'permanent' in this way? Jill Peach and her family, all of whom have Australian domiciles, moved from Adelaide to Fiji so that Jill could take a lecturer's position at The University of the South Pacific. She was given a contract for two years with an option to enter into a further contract after that period if the University was satisfied with her performance. Jill gave up her leased home in Adelaide, but stored some furniture with relatives in that city. She kept a bank account in Adelaide into which certain returns on Australian investments were paid and maintained her membership of an Australian medical benefits fund. She rented a house in Fiji and settled into her new duties. However, owing to illness, Jill had to resign from her job after only 18 months and return with her family to Australia. Would Jill be assessable in Australia on her salary from the university in Fiji? Fully justify your answer by providing a reasonably arguable position citing all relevant law. Ubique Ltd is incorporated in Xanadu but its business activities take place in Atlantis where it is involved in the mining and processing of minerals for export. These activities are managed by a resident of Atlantis who has power of attorney and appropriate managerial authority to carry out effectively his duties. All the directors of Ubique Ltd reside in Australia where the board meetings are held. However, given the global nature of the company, the directors rely heavily on advice from a large firm of accountants in the land of Lilliput. Finally, the managing director makes regular trips to Atlantis to inspect and review the company's operations. In terms of Australian tax law, is Ubique Ltd a resident of Australia? Fully justify your answer by providing a reasonably arguable position citing all relevant law.