Evolution of APA Regime

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535520
Total Pages : 252 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Evolution of APA Regime by : Kuldeep Sharma

Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.

Guide to International Transfer Pricing

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501715
Total Pages : 1074 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Guide to International Transfer Pricing by : Dr A. Michael Heimert

Download or read book Guide to International Transfer Pricing written by Dr A. Michael Heimert and published by Kluwer Law International B.V.. This book was released on 2018-10-26 with total page 1074 pages. Available in PDF, EPUB and Kindle. Book excerpt: The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14

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Publisher : OECD Publishing
ISBN 13 : 9264539395
Total Pages : 95 pages
Book Rating : 4.2/5 (645 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-04-15 with total page 95 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Ireland.

Visualizing Social Science Research

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Publisher : SAGE
ISBN 13 : 145223955X
Total Pages : 225 pages
Book Rating : 4.4/5 (522 download)

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Book Synopsis Visualizing Social Science Research by : Johannes Wheeldon

Download or read book Visualizing Social Science Research written by Johannes Wheeldon and published by SAGE. This book was released on 2011-07-12 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: This introductory text presents basic principles of social science research through maps, graphs, and diagrams. The authors show how concept maps and mind maps can be used in quantitative, qualitative, and mixed methods research, using student-friendly examples and classroom-based activities. Integrating theory and practice, chapters show how to use these tools to plan research projects, "see" analysis strategies, and assist in the development and writing of research reports.

OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14

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Publisher : OECD Publishing
ISBN 13 : 9264304193
Total Pages : 84 pages
Book Rating : 4.2/5 (643 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14 written by OECD and published by OECD Publishing. This book was released on 2018-08-30 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to ...

Fundamentals of Transfer Pricing

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Publisher : Kluwer Law International B.V.
ISBN 13 : 904119021X
Total Pages : 469 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang

Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-01-03 with total page 469 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.

Basics of Qualitative Research

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Publisher : SAGE Publications, Incorporated
ISBN 13 : 9780803959392
Total Pages : 336 pages
Book Rating : 4.9/5 (593 download)

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Book Synopsis Basics of Qualitative Research by : Anselm Strauss

Download or read book Basics of Qualitative Research written by Anselm Strauss and published by SAGE Publications, Incorporated. This book was released on 1998-09-29 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Second Edition of this best-selling textbook continues to offer immensely practical advice and technical expertise that will aid researchers in analyzing and interpreting their collected data, and ultimately build theory from it. The authors provide a step-by-step guide to the research act. Full of definitions and illustrative examples, the book presents criteria for evaluating a study as well as responses to common questions posed by students of qualitative research.

Berlitz: Ireland Pocket Guide

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Publisher : Apa Publications (UK) Limited
ISBN 13 : 178004738X
Total Pages : 225 pages
Book Rating : 4.7/5 (8 download)

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Book Synopsis Berlitz: Ireland Pocket Guide by : Berlitz

Download or read book Berlitz: Ireland Pocket Guide written by Berlitz and published by Apa Publications (UK) Limited. This book was released on 2012-09-26 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: Berlitz Pocket Guide Ireland combines snappy text with full-colour photography to highlight the very best that this charming country has to offer. The Where To Go chapter details all the key sights that you will not want to miss; from vibrant and intoxicating capital city Dublin, to the stunning scenery of the south and the historical intrigue of Northern Ireland. The What to Do chapter explores Ireland's musical and sporting scene and opportunities to sample its famed craic, whilst the Eating Out chapter investigates the local cuisine and provides a list of recommended restaurants for you to try. Top 10 Attractions and A Perfect Tour itinerary present inspiration for experiencing the very best of Ireland. Background information about the turbulent history of the country and the character of its people is also provided to help you really understand the culture you have come to experience. Clear and detailed maps plot all the major sights, and the Travel Tips section offers practical advice on how to get there and where to stay.

Transfer Pricing Developments Around the World 2020

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Publisher : Kluwer Law International B.V.
ISBN 13 : 940352393X
Total Pages : 312 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Transfer Pricing Developments Around the World 2020 by : Michael Lang

Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

Mixed Methods in Health Sciences Research

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Publisher : SAGE Publications
ISBN 13 : 1483347141
Total Pages : 376 pages
Book Rating : 4.4/5 (833 download)

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Book Synopsis Mixed Methods in Health Sciences Research by : Leslie Curry

Download or read book Mixed Methods in Health Sciences Research written by Leslie Curry and published by SAGE Publications. This book was released on 2014-09-30 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Mixed Methods in Health Sciences Research: A Practical Primer, by Leslie Curry and Marcella Nunez-Smith, presents key theories, concepts, and approaches in an accessible way. Packed with illustrations from the health sciences literature, this ready-to-use guidebook shows readers how to design, conduct, review, and use mixed methods research findings. Helpful checklists, figures, tables, templates, and much more give readers examples that will elevate the quality of their research, facilitate communication about their methods, and improve efficiency over the course of their projects. Real-world examples and insights from mixed methods researchers provide unique perspectives on every aspect of mixed methods research. This book successfully pulls together foundational mixed methods principles, synthesizes the knowledge base in the field, and translates it for a health science researcher audience. “The content is highly applicable to real life research teams in the areas of clinical research, health services research, and implementation science, providing sound content and practical advice. The authors have synthesized and pull key concepts from a variety of sources to provide a concise resource.” —Linda M. Herrick, South Dakota State University “Everything from the references, to the topics, checklists, conceptual graphic representations, and organizers, interviews, and resources, all contribute to the content and aid with understanding and/or application. … It addresses specific MM research as it pertains to health sciences in a way that other texts just do not even attempt.” —Denise L. Winsor, University of Memphis “[This text is] a very pragmatic approach to mixed methods research; excellent resources, tables, and figures [are] provided, along with cases and examples of value to researchers and grant reviewers. Its relevance to practice, education, and research, as well as to potential policy implications, is a strong focus that would make this a valued textbook for any researcher!” ? —Karen Devereaux Melillo, University of Massachusetts Lowell “The text is cutting edge. It leads the way with its focus on team dynamics. [The authors] succeed in making the book relevant and practical. They also articulate a number of key insights in the area of mixed methods that rarely get addressed, such as teams and conflict. Great read with a lot of good, practical information for mixed methods researchers at all levels. The practical approach of this text makes it an innovative and valuable resource.” —John G. Schumacher, University of Maryland

Forgiveness Is a Choice

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Publisher : American Psychological Association
ISBN 13 : 1433804808
Total Pages : 225 pages
Book Rating : 4.4/5 (338 download)

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Book Synopsis Forgiveness Is a Choice by : Robert D. Enright

Download or read book Forgiveness Is a Choice written by Robert D. Enright and published by American Psychological Association. This book was released on 2019-06-11 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: By demonstrating how forgiveness, approached in the correct manner, benefits the forgiver far more than the forgiven this self-help book benefits people who have been deeply hurt by another and caught in a vortex of anger, depression, and resentment.

Advances in Mixed Methods Research

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Publisher : SAGE
ISBN 13 : 1446241211
Total Pages : 202 pages
Book Rating : 4.4/5 (462 download)

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Book Synopsis Advances in Mixed Methods Research by : Manfred Max Bergman

Download or read book Advances in Mixed Methods Research written by Manfred Max Bergman and published by SAGE. This book was released on 2008-05-06 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advances in Mixed Methods Research provides an essential introduction to the fast-growing field of mixed methods research. Bergman′s book examines the current state of mixed-methods research, exploring exciting new ways of conceptualizing and conducting empirical research in the social and health sciences. Contributions from the world′s leading experts in qualitative, quantitative, and mixed methods approaches are brought together, clearing the way for a more constructive approach to social research. These contributions cover the main practical and methodological issues and include a number of different visions of what mixed methods research is. The discussion also covers the use of mixed methods in a diverse range of fields, including sociology, education, politics, psychology, computational science and methodology. This book represents an important contribution to the ongoing debate surrounding the use of mixed methods in the social sciences and health research, and presents a convincing argument that the conventional, paradigmatic view of qualitative and quantitative research is outdated and in need of replacement. It will be essential reading for anyone actively engaged in qualitative, quantitative and mixed methods research and for students of social research methods. Manfred Max Bergman is Chair of Methodology and Political Sociology at the University of Basel.

OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

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Publisher : OECD Publishing
ISBN 13 : 9264840893
Total Pages : 442 pages
Book Rating : 4.2/5 (648 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023 written by OECD and published by OECD Publishing. This book was released on 2023-11-14 with total page 442 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report provides stakeholders with an overview of each jurisdiction’s Mutual Agreement Procedure (MAP) policy and practices in a clear and simple manner.

Research Methods for the Social Sciences

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Publisher : A&C Black
ISBN 13 : 1441140867
Total Pages : 175 pages
Book Rating : 4.4/5 (411 download)

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Book Synopsis Research Methods for the Social Sciences by : Jerry Wellington

Download or read book Research Methods for the Social Sciences written by Jerry Wellington and published by A&C Black. This book was released on 2007-10-18 with total page 175 pages. Available in PDF, EPUB and Kindle. Book excerpt: The aim of this book is to provide an introductory but not simplistic guide to research in the social and behavioural sciences. The book sets out to tackle difficult issues and concepts in a scholarly but accessible manner, providing ample guidance and signposts to further reading. We explore a wide range of questions about research and research methods, including: * What counts as 'good research'? * Research approaches, paradigms, methods and methodology: what are they and what is the difference? * What is the so-called 'qualitative/ quantitative'? * When and where is quantitative research indispensable? * If one suggests that research should be 'scientific' what does that mean? * What methods and methodologies are used in social research? * What is the role of statistics in social and behavioural research? How should statistical evidence be interpreted? * What are the ways in which research can, and should, be disseminated and presented? This book is aimed as much at the reflective, researching professional as for the professional researcher.

The Bowland Shale Formation, UK: Processes and Resources

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Publisher : Geological Society of London
ISBN 13 : 1786205904
Total Pages : 311 pages
Book Rating : 4.7/5 (862 download)

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Book Synopsis The Bowland Shale Formation, UK: Processes and Resources by : J.F. Emmings

Download or read book The Bowland Shale Formation, UK: Processes and Resources written by J.F. Emmings and published by Geological Society of London. This book was released on 2024-07-02 with total page 311 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume showcases recent geological, geophysical and geochemical research on the Carboniferous Bowland Shale Formation. The volume focuses on the key Carboniferous basins in the Midlands, northern England and North Wales. The Bowland Shale is perhaps the most controversial black shale unit in the UK. In the mid-2000s, attention turned to the Bowland Shale as a target for unconventional hydrocarbon exploration in the UK following success in the USA. This placed the Bowland Shale at the centre of a series of interconnected controversies and debates from the local to national scale. The geological credibility of the purported shale gas resource in the UK was – and continues to be – highly contentious. This volume contributes to a more updated view of the Bowland Shale, covering topics such as sedimentary, geochemical and physical properties and processes, basin-forming events, hydrocarbon prospectivity, mineralization and heat and fluid flow in the subsurface. The volume also includes a field guide to some of the key localities in the UK.

The Myth of Closure: Ambiguous Loss in a Time of Pandemic and Change

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Publisher : W. W. Norton & Company
ISBN 13 : 1324016825
Total Pages : 158 pages
Book Rating : 4.3/5 (24 download)

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Book Synopsis The Myth of Closure: Ambiguous Loss in a Time of Pandemic and Change by : Pauline Boss

Download or read book The Myth of Closure: Ambiguous Loss in a Time of Pandemic and Change written by Pauline Boss and published by W. W. Norton & Company. This book was released on 2021-12-14 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: How do we begin to cope with loss that cannot be resolved? The COVID-19 pandemic has left many of us haunted by feelings of anxiety, despair, and even anger. In this book, pioneering therapist Pauline Boss identifies these vague feelings of distress as caused by ambiguous loss, losses that remain unclear and hard to pin down, and thus have no closure. Collectively the world is grieving as the pandemic continues to change our everyday lives. With a loss of trust in the world as a safe place, a loss of certainty about health care, education, employment, lingering anxieties plague many of us, even as parts of the world are opening back up again. Yet after so much loss, our search must be for a sense of meaning, and not something as elusive and impossible as "closure." This book provides many strategies for coping: encouraging us to increase our tolerance of ambiguity and acknowledging our resilience as we express a normal grief, and still look to the future with hope and possibility.

PAIS International in Print

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Publisher :
ISBN 13 : 9781877874284
Total Pages : 2046 pages
Book Rating : 4.8/5 (742 download)

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Book Synopsis PAIS International in Print by : Catherine Korvin

Download or read book PAIS International in Print written by Catherine Korvin and published by . This book was released on 2003-05 with total page 2046 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains bibliographic references with abstracts and subject headings to public and social policy literature and to world politics published in print and electronic formats; international focus.