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Book Synopsis Within Arm's Length: A Secret Service Agent's Definitive Inside Account of Protecting the President by : Dan Emmett
Download or read book Within Arm's Length: A Secret Service Agent's Definitive Inside Account of Protecting the President written by Dan Emmett and published by Macmillan. This book was released on 2014-06-10 with total page 318 pages. Available in PDF, EPUB and Kindle. Book excerpt: An inside account by a Secret Service agent who provided protection for three Presidents describes stories of some of his more high-profile assignments and the personal and professional challenges faced by Secret Service agents and their families. 40,000 first printing.
Book Synopsis Priceless Passion by : V C Westbrook
Download or read book Priceless Passion written by V C Westbrook and published by . This book was released on 2013-01-09 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: When Nia Roge received the news that the business proposal she had submitted to the city council of Atlanta was approved, she was elated. She had dreamed of opening her own law firm in Atlanta with her best friend, Zoe. The women were well on their way to a new life, when everything they had dreamed of came crashing down. Between the betrayals from Nia's husband to the secrets that they both kept from each other, the ladies realized that life was a lot more complicated than they had bargained for. Nia soon found herself falling in love with one of her business associates, and it turned her world upside down. She was unsure as to what to do when he did not want the same things as she. He took her on a whirlwind ride, then left her wanting more. Feeling like she was being kept at arm's length, she vowed to move on with her life but found that she just kept on coming back. The ladies learned to adjust to what life had thrown at them and roll with the punches. In this novel, you will be on the edge of your seat from start to finish, wondering who will win in the end. Will Nia finally get the man she dreamed of? Will Zoe be content with being in Atlanta? All of these questions and more will be answered in this novel where love, romance, family, career and betrayal all meet at the same time.
Book Synopsis Transfer Pricing and the Arm's Length Principle in International Tax Law by : Jens Wittendorff
Download or read book Transfer Pricing and the Arm's Length Principle in International Tax Law written by Jens Wittendorff and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 914 pages. Available in PDF, EPUB and Kindle. Book excerpt: The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.
Book Synopsis Priceless Passion by : V.C. Westbrook
Download or read book Priceless Passion written by V.C. Westbrook and published by Xlibris Corporation. This book was released on 2013-01-18 with total page 197 pages. Available in PDF, EPUB and Kindle. Book excerpt: When Nia Roge received the news that the business proposal she had submitted to the city council of Atlanta was approved, she was elated. She had dreamed of opening her own law fi rm in Atlanta with her best friend, Zoe. The women were well on their way to a new life, when everything they had dreamed of came crashing down. Between the betrayals from Nias husband to the secrets that they both kept from each other, the ladies realized that life was a lot more complicated than they had bargained for. Nia soon found herself falling in love with one of her business associates, and it turned her world upside down. She was unsure as to what to do when he did not want the same things she did. He took her on a whirlwind ride, then left her wanting more. Feeling like she was being kept at arms length, she vowed to move on with her life but found that she kept on coming back. The ladies learned to adjust to what life had thrown at them and roll with the punches. In this novel, you will be on the edge of your seats from start to fi nish, wondering who will win in the end. Will Nia fi nally get the man she dreamed of? Will Zoe be content with being in Atlanta? All these questions and more will be answered in this novel, where love, romance, family, career, and betrayal all meet at the same time.
Book Synopsis Transfer Pricing and the Arm's Length Principle After BEPS by : Richard S. Collier
Download or read book Transfer Pricing and the Arm's Length Principle After BEPS written by Richard S. Collier and published by Oxford University Press, USA. This book was released on 2017 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic. This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.
Book Synopsis Arm’s Length Transaction Structures by : Andreas Bullen
Download or read book Arm’s Length Transaction Structures written by Andreas Bullen and published by IBFD. This book was released on 2011 with total page 925 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).
Download or read book At Arm's Length written by Shirley Jordan and published by AuthorHouse. This book was released on 2015-07-24 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt: At some point in life, you get fed up with the mishaps of life due to negative people in your life. So to keep peace and to stay out of confusion, you need to keep certain people at arms length to have peace of mind.
Book Synopsis Intangibles in the World of Transfer Pricing by : Björn Heidecke
Download or read book Intangibles in the World of Transfer Pricing written by Björn Heidecke and published by Springer. This book was released on 2021-03-10 with total page 725 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.
Download or read book At Arm’s Length written by Mike Cadden and published by Univ. Press of Mississippi. This book was released on 2021-06-28 with total page 116 pages. Available in PDF, EPUB and Kindle. Book excerpt: Literary critics and authors have long argued about the importance or unimportance of an author’s relationship to readers. What can be said about the rhetorical relationship that exists between author and reader? How do authors manipulate character, specifically, to modulate the emotional appeal of character so a reader will feel empathy, awe, even delight? In At Arm’s Length: A Rhetoric of Character in Children's and Young Adult Literature, Mike Cadden takes a rhetorical approach that complements structural, affective, and cognitive readings. The study offers a detailed examination of the ways authorial choice results in emotional invitation. Cadden sounds the modulation of characters along a continuum from those larger than life and awe inspiring to the life sized and empathetic, down to the pitiable and ridiculous, and all those spaces between. Cadden examines how authors alternate between holding the young reader at arm’s length from and drawing them into emotional intensity. This balance and modulation are key to a rhetorical understanding of character in literature, film, and television for the young. Written in accessible language and of interest and use to undergraduates and seasoned critics, At Arm’s Length provides a broad analysis of stories for the young child and young adult, in book, film, and television. Throughout, Cadden touches on important topics in children’s literature studies, including the role of safety in children’s media, as well as character in multicultural and diverse literature. In addition to treating “traditional” works, he analyzes special cases—forms, including picture books, verse novels, and graphic novels, and modes like comedy, romance, and tragedy.
Book Synopsis Applying the Arm's Length Principle to Intra-group Financial Transactions by : Robert Danon
Download or read book Applying the Arm's Length Principle to Intra-group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Download or read book Rough Ideas written by Stephen Hough and published by Farrar, Straus and Giroux. This book was released on 2020-02-04 with total page 464 pages. Available in PDF, EPUB and Kindle. Book excerpt: A collection of essays on music and life by the famed classical pianist and composer Stephen Hough is one of the world’s leading pianists, winning global acclaim and numerous awards, both for his concerts and his recordings. He is also a writer, composer, and painter, and has been described by The Economist as one of “Twenty Living Polymaths.” Hough writes informally and engagingly about music and the life of a musician, from the broader aspects of what it is to walk out onto a stage or to make a recording, to specialist tips from deep inside the practice room: how to trill, how to pedal, how to practice. He also writes vividly about people he’s known, places he’s traveled to, books he’s read, paintings he’s seen; and he touches on more controversial subjects, such as assisted suicide and abortion. Even religion is there—the possibility of the existence of God, problems with some biblical texts, and the challenges involved in being a gay Catholic. Rough Ideas is an illuminating, constantly surprising introduction to the life and mind of one of our great cultural figures.
Book Synopsis The Limits of My Language by : Eva Meijer
Download or read book The Limits of My Language written by Eva Meijer and published by Pushkin Press. This book was released on 2023-04-18 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Moving, poetic, cogent and honest." -- Andrew Solomon, author of The Noonday Demon An intimate study of depression that draws on personal experience and a deep knowledge of philosophy—perfect for fans of Maggie Nelson and Leslie Jamison The Limits of My Language is both a razor-sharp analysis of depression and a steadfast search for the things great and small -- from philosophy and art to walking a dog or sitting quietly with a cat -- that make our lives worth living. Much has been written about the treatment of depression, but relatively little about its meaning. In this strikingly original book, Eva Meijer weaves her own experiences and the insights of thinkers from Freud to Foucault and Woolf into a moving and incisive evocation of the condition. Depression is more than a chemical problem—the questions that occupy someone with depression are fundamentally human, and they touch on other philosophical questions that concern language, autonomy, power relations, loneliness, and the relationship between body and mind. But this book-length essay is also about the other side, such as animals, trees, others, art: about consolation, and hope, and the things that can give life meaning. The Limits of My Language explores how depression can make us grow out of shape over time, like a twisted tree, how we can sometimes remould ourselves in conversation with others, and how to move on from our darkest thoughts.
Book Synopsis Who's to Pay for the Arts? by : Milton C. Cummings
Download or read book Who's to Pay for the Arts? written by Milton C. Cummings and published by Americans for the Arts Books. This book was released on 1989 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Within Arm's Reach by : Ann Napolitano
Download or read book Within Arm's Reach written by Ann Napolitano and published by Dial Press. This book was released on 2024-04-30 with total page 353 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tender and perceptive debut novel from the New York Times bestselling author of Hello Beautiful, about three generations of a large Catholic family jarred into crisis by an unexpected pregnancy “This stunning . . . exquisite, skillfully written gem addresses serious issues–e.g., guilt vs. loyalty, the past vs. the present—[but] remains hopeful and includes ample doses of humor and wit.”—Library Journal (starred review) No one in my mother’s family ever talks about anything that can be categorized as unpleasant or as having to do with emotions. . . . This spellbinding novel by bestselling author Ann Napolitano is a poignant reminder of how connected we are to those we love, even when we cannot find the words to say it. The unforgettable story of three generations of an Irish American family, Within Arm’s Reach is another rich and deeply satisfying novel from the author who captured the many dimensions of grief in Dear Edward and the unbreakable bonds of sisterhood in Hello Beautiful.
Book Synopsis The Works of Ralph Waldo Emerson ... by : Ralph Waldo Emerson
Download or read book The Works of Ralph Waldo Emerson ... written by Ralph Waldo Emerson and published by . This book was released on 1911 with total page 714 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing Aspects of Intra-Group Financing by : Raffaele Petruzzi
Download or read book Transfer Pricing Aspects of Intra-Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Book Synopsis The Economics of Organised Crime by : Gianluca Fiorentini
Download or read book The Economics of Organised Crime written by Gianluca Fiorentini and published by Cambridge University Press. This book was released on 1997-08-14 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first book to apply economic theory to the analysis of all aspects of organised crime.
