Download or read book A Reflection on the Future of Corporate Tax Residency in the Age of Remote Work and Mobility of Individuals written by Eva Escribano and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The normalization and popularization of remote work in the post pandemic era is prone to trigger several consequences in the application of tax rules. In particular, the increasing mobility of individuals is expected to generate changes on the outcome of corporate tax residence rules based on where the entity is governed (both at the domestic and the treaty level) and give rise to new tax planning opportunities. The present paper intends to analyze the troubling coexistence between mobility of individuals and these residence rules and further reflect on how corporate tax residency should look like in the future.
Download or read book Corporate Tax Residence and Mobility written by Edoardo Traversa and published by . This book was released on 2018 with total page 731 pages. Available in PDF, EPUB and Kindle. Book excerpt: The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject resident corporate taxpayers to full tax liability, usually on a worldwide basis. In tax treaties, residence plays a fundamental role in the allocation of taxing powers between states. Moreover, within the European Union, it gives access to the legal protection granted to companies by internal market rules, whether contained in EU treaties (fundamental freedoms) or in tax directives. Today, however, the globalization and the digitalization of the economy are putting residence under heavy pressure. Within multinational enterprises, the geographical dislocation of the functions performed by people and entities within the multinational group makes it harder to identify a central place of decision or management in cases where this place is not the same as the place where the company was incorporated. Moreover, tax planning strategies involving location or the transfer of residence to low-tax jurisdictions have come under the spotlight of international organizations, such as the OECD and the European Union. Against this background, this book examines the notion of residence from a comparative, EU and international law perspective. It is divided into two parts. Part one comprises a general introductory report, as well as five thematic reports on key present and future issues concerning the tax residence of companies. Part two comprises the national reports of 14 EU Member States and 6 non-EU Member States (Norway, Russia, Serbia, Turkey, Ukraine and the United States). Those reports contain an extensive analysis of the definition and function of corporate tax residence on the basis of a questionnaire (which is included as an appendix in this book). With contributions from renowned academics from Europe and beyond, this book offers an insightful and multifaceted perspective on a fundamental concept of domestic and international taxation.
Download or read book Corporate Residence and International Taxation written by Robert Couzin and published by IBFD. This book was released on 2002 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.
Download or read book Corporate Tax Residence and Mobility written by Edoardo Traversa and published by . This book was released on 2018 with total page 764 pages. Available in PDF, EPUB and Kindle. Book excerpt: The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject resident corporate taxpayers to full tax liability, usually on a worldwide basis. In tax treaties, residence plays a fundamental role in the allocation of taxing powers between states. Moreover, within the European Union, it gives access to the legal protection granted to companies by internal market rules, whether contained in EU treaties (fundamental freedoms) or in tax directives. Today, however, the globalization and the digitalization of the economy are putting residence under heavy pressure. Within multinational enterprises, the geographical dislocation of the functions performed by people and entities within the multinational group makes it harder to identify a central place of decision or management in cases where this place is not the same as the place where the company was incorporated. Moreover, tax planning strategies involving location or the transfer of residence to low-tax jurisdictions have come under the spotlight of international organizations, such as the OECD and the European Union. Against this background, this book examines the notion of residence from a comparative, EU and international law perspective. It is divided into two parts. Part one comprises a general introductory report, as well as five thematic reports on key present and future issues concerning the tax residence of companies. Part two comprises the national reports of 14 EU Member States and 6 non-EU Member States (Norway, Russia, Serbia, Turkey, Ukraine and the United States). Those reports contain an extensive analysis of the definition and function of corporate tax residence on the basis of a questionnaire (which is included as an appendix in this book). With contributions from renowned academics from Europe and beyond, this book offers an insightful and multifaceted perspective on a fundamental concept of domestic and international taxation.
Download or read book The Future of Corporate Residency written by Tsilly Dagan and published by . This book was released on 2018 with total page 33 pages. Available in PDF, EPUB and Kindle. Book excerpt: Globalization and tax competition challenge residence base taxation of corporations, by pushing states to offer competitive “deals” in order to attract corporate-residents. This paper will describe this process and ask whether states could regain their power to tax corporations on a residence-basis through multilateral cooperation. It will argue that the history of cooperation on international tax among states raises some serious doubts, not only regarding the attainability and sustainability of such cooperation, but also regarding its desirability. The paper will start with a very brief review of the process of corporations gaining independence from the state turning them from chartered organizations reigned by the political institutions of the state into independent market actors. It will then consider the seemingly inverse process of the rationale for income taxation shifting from a market based logic of benefit taxation to a political rationale of taxation based on membership in (and commitment to) a political community. Both these processes burden the ability of states to benefit from the profits of corporations. Globalization and tax competition, the paper goes on to argue, present further challenges for the taxation of corporations. Tax competition not only marketizes the relationships between states and their corporate-taxpayers, but also fragmentizes it -- allowing taxpayers to pick and choose among various features of the different jurisdictions, thus seriously undermining the ability of states to collect taxes from such MNEs. The paper will conclude by discussing whether cooperation among states could offer a solution, arguing that such cooperation is not only extremely hard to attain and sustain, but also not necessarily desirable.
Download or read book Corporate Residency in Australia Back to the Future written by K. Sadiq and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors consider the possible impact of recent proposed changes to Australia's definition of corporate tax residency.
Download or read book Mobility of Individuals and Workforces written by Svetislav V. Kostić and published by . This book was released on 2024 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Occupational Therapy Practice Framework Domain and Process written by Aota and published by AOTA Press. This book was released on 2014 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: As occupational therapy celebrates its centennial in 2017, attention returns to the profession's founding belief in the value of therapeutic occupations as a way to remediate illness and maintain health. The founders emphasized the importance of establishing a therapeutic relationship with each client and designing an intervention plan based on the knowledge about a client's context and environment, values, goals, and needs. Using today's lexicon, the profession's founders proposed a vision for the profession that was occupation based, client centered, and evidence based--the vision articulated in the third edition of the Occupational Therapy Practice Framework: Domain and Process. The Framework is a must-have official document from the American Occupational Therapy Association. Intended for occupational therapy practitioners and students, other health care professionals, educators, researchers, payers, and consumers, the Framework summarizes the interrelated constructs that describe occupational therapy practice. In addition to the creation of a new preface to set the tone for the work, this new edition includes the following highlights: a redefinition of the overarching statement describing occupational therapy's domain; a new definition of clients that includes persons, groups, and populations; further delineation of the profession's relationship to organizations; inclusion of activity demands as part of the process; and even more up-to-date analysis and guidance for today's occupational therapy practitioners. Achieving health, well-being, and participation in life through engagement in occupation is the overarching statement that describes the domain and process of occupational therapy in the fullest sense. The Framework can provide the structure and guidance that practitioners can use to meet this important goal.
Download or read book The Structuring of Organizations written by Henry Mintzberg and published by . This book was released on 2009 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Synthesizes the empirical literature on organizationalstructuring to answer the question of how organizations structure themselves --how they resolve needed coordination and division of labor. Organizationalstructuring is defined as the sum total of the ways in which an organizationdivides and coordinates its labor into distinct tasks. Further analysis of theresearch literature is neededin order to builda conceptualframework that will fill in the significant gap left by not connecting adescription of structure to its context: how an organization actuallyfunctions. The results of the synthesis are five basic configurations (the SimpleStructure, the Machine Bureaucracy, the Professional Bureaucracy, theDivisionalized Form, and the Adhocracy) that serve as the fundamental elementsof structure in an organization. Five basic parts of the contemporaryorganization (the operating core, the strategic apex, the middle line, thetechnostructure, and the support staff), and five theories of how it functions(i.e., as a system characterized by formal authority, regulated flows, informalcommunication, work constellations, and ad hoc decision processes) aretheorized. Organizations function in complex and varying ways, due to differing flows -including flows of authority, work material, information, and decisionprocesses. These flows depend on the age, size, and environment of theorganization; additionally, technology plays a key role because of itsimportance in structuring the operating core. Finally, design parameters aredescribed - based on the above five basic parts and five theories - that areused as a means of coordination and division of labor in designingorganizational structures, in order to establish stable patterns of behavior.(CJC).
Download or read book Imagining the Internet written by Janna Quitney Anderson and published by Rowman & Littlefield Publishers. This book was released on 2005-07-21 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the early 1990s, people predicted the death of privacy, an end to the current concept of 'property,' a paperless society, 500 channels of high-definition interactive television, world peace, and the extinction of the human race after a takeover engineered by intelligent machines. Imagining the Internet zeroes in on predictions about the Internet's future and revisits past predictions—and how they turned out. It gives the history of communications in a nutshell, illustrating the serious impact of pervasive networks and how they will change our lives over the next century.
Download or read book Global Age friendly Cities written by World Health Organization and published by World Health Organization. This book was released on 2007 with total page 83 pages. Available in PDF, EPUB and Kindle. Book excerpt: The guide is aimed primarily at urban planners, but older citizens can use it to monitor progress towards more age-friendly cities. At its heart is a checklist of age-friendly features. For example, an age-friendly city has sufficient public benches that are well-situated, well-maintained and safe, as well as sufficient public toilets that are clean, secure, accessible by people with disabilities and well-indicated. Other key features of an age-friendly city include: well-maintained and well-lit sidewalks; public buildings that are fully accessible to people with disabilities; city bus drivers who wait until older people are seated before starting off and priority seating on buses; enough reserved parking spots for people with disabilities; housing integrated in the community that accommodates changing needs and abilities as people grow older; friendly, personalized service and information instead of automated answering services; easy-to-read written information in plain language; public and commercial services and stores in neighbourhoods close to where people live, rather than concentrated outside the city; and a civic culture that respects and includes older persons.
Download or read book Imagine Boston 2030 written by City Of Boston and published by . This book was released on 2017-09-08 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Today, Boston is in a uniquely powerful position to make our city more affordable, equitable, connected, and resilient. We will seize this moment to guide our growth to support our dynamic economy, connect more residents to opportunity, create vibrant neighborhoods, and continue our legacy as a thriving waterfront city.Mayor Martin J. Walsh's Imagine Boston 2030 is the first citywide plan in more than 50 years. This vision was shaped by more than 15,000 Boston voices.
Download or read book The Digital Person written by Daniel J Solove and published by NYU Press. This book was released on 2004 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Daniel Solove presents a startling revelation of how digital dossiers are created, usually without the knowledge of the subject, & argues that we must rethink our understanding of what privacy is & what it means in the digital age before addressing the need to reform the laws that regulate it.
Download or read book Ask a Manager written by Alison Green and published by Ballantine Books. This book was released on 2018-05-01 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the creator of the popular website Ask a Manager and New York’s work-advice columnist comes a witty, practical guide to 200 difficult professional conversations—featuring all-new advice! There’s a reason Alison Green has been called “the Dear Abby of the work world.” Ten years as a workplace-advice columnist have taught her that people avoid awkward conversations in the office because they simply don’t know what to say. Thankfully, Green does—and in this incredibly helpful book, she tackles the tough discussions you may need to have during your career. You’ll learn what to say when • coworkers push their work on you—then take credit for it • you accidentally trash-talk someone in an email then hit “reply all” • you’re being micromanaged—or not being managed at all • you catch a colleague in a lie • your boss seems unhappy with your work • your cubemate’s loud speakerphone is making you homicidal • you got drunk at the holiday party Praise for Ask a Manager “A must-read for anyone who works . . . [Alison Green’s] advice boils down to the idea that you should be professional (even when others are not) and that communicating in a straightforward manner with candor and kindness will get you far, no matter where you work.”—Booklist (starred review) “The author’s friendly, warm, no-nonsense writing is a pleasure to read, and her advice can be widely applied to relationships in all areas of readers’ lives. Ideal for anyone new to the job market or new to management, or anyone hoping to improve their work experience.”—Library Journal (starred review) “I am a huge fan of Alison Green’s Ask a Manager column. This book is even better. It teaches us how to deal with many of the most vexing big and little problems in our workplaces—and to do so with grace, confidence, and a sense of humor.”—Robert Sutton, Stanford professor and author of The No Asshole Rule and The Asshole Survival Guide “Ask a Manager is the ultimate playbook for navigating the traditional workforce in a diplomatic but firm way.”—Erin Lowry, author of Broke Millennial: Stop Scraping By and Get Your Financial Life Together
Download or read book Engineering written by Unesco and published by UNESCO. This book was released on 2010-01-01 with total page 392 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reviews engineering's importance to human, economic, social and cultural development and in addressing the UN Millennium Development Goals. Engineering tends to be viewed as a national issue, but engineering knowledge, companies, conferences and journals, all demonstrate that it is as international as science. The report reviews the role of engineering in development, and covers issues including poverty reduction, sustainable development, climate change mitigation and adaptation. It presents the various fields of engineering around the world and is intended to identify issues and challenges facing engineering, promote better understanding of engineering and its role, and highlight ways of making engineering more attractive to young people, especially women.--Publisher's description.
Download or read book Moving Out of Poverty written by Deepa Narayan and published by World Bank Publications. This book was released on 2009-12-09 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is no peace with hunger. Only promises and promises and no fulfillment. If there is no job, there is no peace. If there is nothing to cook in the pot, there is no peace. - Oscar, a 57-year-old man, El Gorri n, Colombia They want to construct their houses near the road, and they cannot do that if they do not have peace with their enemies. So peace and the road have developed a symbiotic relation. One cannot live without the other. . . . - A community leader from a conflict-affected community on the island of Mindanao, Philippines Most conflict studies focus on the national level, but this volume focuses on the community level. It explores how communities experience and recover from violent conflict, and the surprising opportunities that can emerge for poor people to move out of poverty in these harsh contexts. 'Rising from the Ashes of Conflict' reveals how poor people s mobility is shaped by local democracy, people s associations, aid strategies, and the local economic environment in over 100 communities in seven conflict-affected countries, including Afghanistan. The findings suggest the need to rethink postconflict development assistance. This is the fourth volume in a series derived from the Moving Out of Poverty study, which explores mobility from the perspectives of poor people in more than 500 communities across 15 countries.
Download or read book The Challenge of Crime in a Free Society written by United States. President's Commission on Law Enforcement and Administration of Justice and published by . This book was released on 1967 with total page 368 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report of the President's Commission on Law Enforcement and Administration of Justice -- established by President Lyndon Johnson on July 23, 1965 -- addresses the causes of crime and delinquency and recommends how to prevent crime and delinquency and improve law enforcement and the administration of criminal justice. In developing its findings and recommendations, the Commission held three national conferences, conducted five national surveys, held hundreds of meetings, and interviewed tens of thousands of individuals. Separate chapters of this report discuss crime in America, juvenile delinquency, the police, the courts, corrections, organized crime, narcotics and drug abuse, drunkenness offenses, gun control, science and technology, and research as an instrument for reform. Significant data were generated by the Commission's National Survey of Criminal Victims, the first of its kind conducted on such a scope. The survey found that not only do Americans experience far more crime than they report to the police, but they talk about crime and the reports of crime engender such fear among citizens that the basic quality of life of many Americans has eroded. The core conclusion of the Commission, however, is that a significant reduction in crime can be achieved if the Commission's recommendations (some 200) are implemented. The recommendations call for a cooperative attack on crime by the Federal Government, the States, the counties, the cities, civic organizations, religious institutions, business groups, and individual citizens. They propose basic changes in the operations of police, schools, prosecutors, employment agencies, defenders, social workers, prisons, housing authorities, and probation and parole officers.
