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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 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 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 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 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.
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 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 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 and Customs Valuation by : Anuschka Bakker
Download or read book Transfer Pricing and Customs Valuation written by Anuschka Bakker and published by IBFD. This book was released on 2009 with total page 695 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.
Book Synopsis Clean Your Inner House by : Mary Schulze Michener
Download or read book Clean Your Inner House written by Mary Schulze Michener and published by Gazelle Press. This book was released on 2013-08-01 with total page 129 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
Book Synopsis Partners in deterrence by : Stephan Frühling
Download or read book Partners in deterrence written by Stephan Frühling and published by Manchester University Press. This book was released on 2021-08-03 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the dawn of the atomic age to today, nuclear weapons have been central to the internal dynamics of US alliances in Europe and Asia. But nuclear weapons cooperation in US alliances has varied significantly between allies and over time. This book explores the history of America’s nuclear posture worldwide, delving into alliance structures and interaction during and since the end of the Cold War to uncover the underlying dynamics of nuclear weapons cooperation between the US and its allies. Combining in-depth empirical analysis with an accessible theoretical lens, the book reveals that US allies have wielded significant influence in shaping nuclear weapons cooperation with the US in ways that reflect their own, often idiosyncratic, objectives. Alliances are ecosystems of exchange rather than mere tools of external balancing, the book argues, and institutional perspectives can offer an unprecedented insight into how structured cooperation can promote policy convergence.
Book Synopsis Clockwork Prince by : Cassandra Clare
Download or read book Clockwork Prince written by Cassandra Clare and published by Simon and Schuster. This book was released on 2013-03-19 with total page 528 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the Council attempts to strip Charlotte of her power, shapechanger Tessa Gray works with the London Shadowhunters to find the Magister and destroy his clockwork army, learning the secret of her own identity while investigating his past.
