Download or read book The DEMPE Concept and Intangibles written by Karol Dziwinski and published by Kluwer Law International B.V.. This book was released on 2022-06-06 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.

Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 471 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.

Download or read book Boundary Boss written by Terri Cole, MSW, LCSW and published by Sounds True. This book was released on 2021-04-20 with total page 204 pages. Available in PDF, EPUB and Kindle. Book excerpt: Break Free From Over-Functioning, Over-Delivering, People-Pleasing, and Ignoring Your Own Needs So You Can Finally Live the Life You Deserve! Most of us were never taught how to effectively express our preferences, desires or deal-breakers. Instead, we hide our feelings behind passive-aggressive behavior, deny our own truths, or push our emotions down until we get depressed or so frustrated that we explode, potentially destroying hard-won trust and relationships. The most successful and satisfied people on the planet have one thing in common: the ability to create and communicate clear, healthy boundaries. This ability is, hands down, the biggest game changer when it comes to creating a healthy, happy, self-determined life. In Boundary Boss, psychotherapist Terri Cole reveals a specific set of skills that can help you stop abandoning yourself for the sake of others (without guilt or drama) and get empowered to consciously take control of every aspect of your emotional, spiritual, physical, personal, and professional life. Since becoming a Boundary Boss is a process, Cole also offers actionable strategies, scripts, and techniques that can be used in the moment, whenever you need them. You will learn: • How to recognize when your boundaries have been violated and what to do next • How your unique “Boundary Blueprint” is unconsciously driving your boundary behaviors, and strategies to redesign it • Powerful boundary scripts so in the moment you will know what to say • How to manage “Boundary Destroyers”—including emotional manipulators, narcissists, and other toxic personalities • Where you fall on the spectrum of codependency and how to create healthy, balanced relationships This book is for women who are exhausted from over-giving, overdoing, and even over-feeling. If you’re getting it all done but at the expense of yourself, give yourself the gift of Boundary Boss.

Download or read book The Inner Child Journal written by Rachel Havekost and published by . This book was released on 2020-12 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Inner Child Journal is a 90-day guided journal designed to heal and re-parent your Inner Child. The prompts in this journal will connect you to your Inner Child, facilitate meaningful healing, and teach you to cultivate your wise Inner Parent so that you can find peace and wholeness in your daily life.This journal can be used as a supplement to your Inner Child work in therapy, or as a means to access this healing process if therapy is inaccessible to you.Intended to be part of your morning routine, every guided entry is different and contains prompts on topics like: mindfulness, affirmations, identifying needs, dialogue between Inner Parent and Inner Child, and letters to your Inner Child.All you need to get started is a cozy nook, your favorite pen, and a commitment to showing yourself grace, love, and compassion.WHAT'S INSIDE:Description of the Inner Child and Inner ParentExplanation of Inner Child healing, Intergenerational trauma, and Re-Parenting90 pages of journaling with specific prompts and categoriesMindfulness, affirmations, and needs identificationInner Child & Inner Parent dialogues and letters to your inner childDaily entries with specific prompts and instructions to help you dive deep9 Categories of promptsOver 50 unique questions that are recycled daily, so no two days are the sameInstructions and descriptions so you can really understand how to get started with the journalingExample of a daily journal for comprehensionIntention-setting and frequent reflections so you can chart your growthTips and tricks for if you get stuckQuotes and daily encouragement to keep you motivatedThis journal is infused with love and the hopes that when you open its pages you feel held, supported, and guided through the entire journey.All you have to do is begin.*Please note this journal is not intended to be a replacement for therapy, nor is it meant to be used as a diagnostic tool.

Download or read book World War Z written by Max Brooks and published by Broadway Books. This book was released on 2013 with total page 434 pages. Available in PDF, EPUB and Kindle. Book excerpt: An account of the decade-long conflict between humankind and hordes of the predatory undead is told from the perspective of dozens of survivors who describe in their own words the epic human battle for survival, in a novel that is the basis for the June 2013 film starring Brad Pitt. Reissue. Movie Tie-In.

Download or read book Investigating Iwo written by Breanne Robertson and published by . This book was released on 2019 with total page 371 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Investigating Iwo encourages us to explore the connection between American visual culture and World War II, particularly how the image inspired Marines, servicemembers, and civilians to carry on with the war and to remember those who made the ultimate sacrifice to ensure victory over the Axis Powers. Chapters shed light on the processes through which history becomes memory and gains meaning over time. The contributors ask only that we be willing to take a closer look, to remain open to new perspectives that can deepen our understanding of familiar topics related to the flag raising, including Rosenthal's famous picture, that continue to mean so much to us today"--

Download or read book Aviation in the U S Army 1919 1939 written by Maurer Maurer and published by . This book was released on 1987 with total page 706 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book From One Leader to Another written by Combat Studies Institute Press and published by Military Bookshop. This book was released on 2013-05 with total page 398 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work is a collection of observations, insights, and advice from over 50 serving and retired Senior Non-Commissioned Officers. These experienced Army leaders have provided for the reader, outstanding mentorship on leadership skills, tasks, and responsibilities relevant to our Army today. There is much wisdom and advice "from one leader to another" in the following pages.

Download or read book Defending Air Bases in an Age of Insurgency written by Shannon Caudill and published by Military Bookshop. This book was released on 2014-08 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: This anthology discusses the converging operational issues of air base defense and counterinsurgency. It explores the diverse challenges associated with defending air assets and joint personnel in a counterinsurgency environment. The authors are primarily Air Force officers from security forces, intelligence, and the office of special investigations, but works are included from a US Air Force pilot and a Canadian air force officer. The authors examine lessons from Vietnam, Iraq, Afghanistan, and other conflicts as they relate to securing air bases and sustaining air operations in a high-threat counterinsurgency environment. The essays review the capabilities, doctrine, tactics, and training needed in base defense operations and recommend ways in which to build a strong, synchronized ground defense partnership with joint and combined forces. The authors offer recommendations on the development of combat leaders with the depth of knowledge, tactical and operational skill sets, and counterinsurgency mind set necessary to be effective in the modern asymmetric battlefield.

Download or read book The New Public Diplomacy written by J. Melissen and published by Springer. This book was released on 2005-11-22 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: After 9/11, which triggered a global debate on public diplomacy, 'PD' has become an issue in most countries. This book joins the debate. Experts from different countries and from a variety of fields analyze the theory and practice of public diplomacy. They also evaluate how public diplomacy can be successfully used to support foreign policy.

Download or read book The Infinite Game written by Simon Sinek and published by Penguin. This book was released on 2019-10-15 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the New York Times bestselling author of Start With Why and Leaders Eat Last, a bold framework for leadership in today’s ever-changing world. How do we win a game that has no end? Finite games, like football or chess, have known players, fixed rules and a clear endpoint. The winners and losers are easily identified. Infinite games, games with no finish line, like business or politics, or life itself, have players who come and go. The rules of an infinite game are changeable while infinite games have no defined endpoint. There are no winners or losers—only ahead and behind. The question is, how do we play to succeed in the game we’re in? In this revelatory new book, Simon Sinek offers a framework for leading with an infinite mindset. On one hand, none of us can resist the fleeting thrills of a promotion earned or a tournament won, yet these rewards fade quickly. In pursuit of a Just Cause, we will commit to a vision of a future world so appealing that we will build it week after week, month after month, year after year. Although we do not know the exact form this world will take, working toward it gives our work and our life meaning. Leaders who embrace an infinite mindset build stronger, more innovative, more inspiring organizations. Ultimately, they are the ones who lead us into the future.

Download or read book Beyond the North Wind written by Darra Goldstein and published by Ten Speed Press. This book was released on 2020-02-04 with total page 322 pages. Available in PDF, EPUB and Kindle. Book excerpt: 100 traditional yet surprisingly modern recipes from the far northern corners of Russia, featuring ingredients and dishes that young Russians are rediscovering as part of their heritage. IACP AWARD FINALIST • LONGLISTED FOR THE ART OF EATING PRIZE • NAMED ONE OF THE BEST COOKBOOKS OF THE YEAR BY THE WASHINGTON POST AND FORBES “A necessary resource for food writers and for eaters, a fascinating read and good excuse to make fermented oatmeal.”—Bon Appétit Russian cookbooks tend to focus on the food that was imported from France in the nineteenth century or the impoverished food of the Soviet era. Beyond the North Wind explores the true heart of Russian food, a cuisine that celebrates whole grains, preserved and fermented foods, and straightforward but robust flavors. Recipes for a dazzling array of pickles and preserves, infused vodkas, homemade dairy products such as farmers cheese and cultured butter, puff pastry hand pies stuffed with mushrooms and fish, and seasonal vegetable soups showcase Russian foods that are organic and honest--many of them old dishes that feel new again in their elegant minimalism. Despite the country's harsh climate, this surprisingly sophisticated cuisine has an incredible depth of flavor to offer in dishes like Braised Cod with Horseradish, Roast Lamb with Kasha, Black Currant Cheesecake, and so many more. This home-style cookbook with a strong sense of place and evocative storytelling brings to life a rarely seen portrait of Russia, its people, and its palate—with 100 recipes, gorgeous photography, and essays on the little-known culinary history of this fascinating and wild part of the world.

Download or read book White Trash written by Nancy Isenberg and published by Penguin. This book was released on 2016-06-21 with total page 482 pages. Available in PDF, EPUB and Kindle. Book excerpt: The New York Times bestseller A New York Times Notable and Critics’ Top Book of 2016 Longlisted for the PEN/John Kenneth Galbraith Award for Nonfiction One of NPR's 10 Best Books Of 2016 Faced Tough Topics Head On NPR's Book Concierge Guide To 2016’s Great Reads San Francisco Chronicle's Best of 2016: 100 recommended books A Washington Post Notable Nonfiction Book of 2016 Globe & Mail 100 Best of 2016 “Formidable and truth-dealing . . . necessary.” —The New York Times “This eye-opening investigation into our country’s entrenched social hierarchy is acutely relevant.” —O Magazine In her groundbreaking bestselling history of the class system in America, Nancy Isenberg upends history as we know it by taking on our comforting myths about equality and uncovering the crucial legacy of the ever-present, always embarrassing—if occasionally entertaining—poor white trash. “When you turn an election into a three-ring circus, there’s always a chance that the dancing bear will win,” says Isenberg of the political climate surrounding Sarah Palin. And we recognize how right she is today. Yet the voters who boosted Trump all the way to the White House have been a permanent part of our American fabric, argues Isenberg. The wretched and landless poor have existed from the time of the earliest British colonial settlement to today's hillbillies. They were alternately known as “waste people,” “offals,” “rubbish,” “lazy lubbers,” and “crackers.” By the 1850s, the downtrodden included so-called “clay eaters” and “sandhillers,” known for prematurely aged children distinguished by their yellowish skin, ragged clothing, and listless minds. Surveying political rhetoric and policy, popular literature and scientific theories over four hundred years, Isenberg upends assumptions about America’s supposedly class-free society––where liberty and hard work were meant to ensure real social mobility. Poor whites were central to the rise of the Republican Party in the early nineteenth century, and the Civil War itself was fought over class issues nearly as much as it was fought over slavery. Reconstruction pitted poor white trash against newly freed slaves, which factored in the rise of eugenics–-a widely popular movement embraced by Theodore Roosevelt that targeted poor whites for sterilization. These poor were at the heart of New Deal reforms and LBJ’s Great Society; they haunt us in reality TV shows like Here Comes Honey Boo Boo and Duck Dynasty. Marginalized as a class, white trash have always been at or near the center of major political debates over the character of the American identity. We acknowledge racial injustice as an ugly stain on our nation’s history. With Isenberg’s landmark book, we will have to face the truth about the enduring, malevolent nature of class as well.

Download or read book Seeds of Redemption written by Andy White and published by Wipf and Stock Publishers. This book was released on 2021-05-24 with total page 187 pages. Available in PDF, EPUB and Kindle. Book excerpt: Struggle--of both the small and staggering sort--is woven throughout all our lives. It can erode our faith, strip us of hope, rob us of joy, extinguish our vitality, and diminish our capacity to love. But because God is always present and at work, seeds of redemption lie as hidden treasure buried in the ground of struggle. By taking a deeply human look at various figures in the lineage of Jesus in Matthew 1, Andy White shows us that the people we once may have considered unlike us because of thousands of years of separation suddenly come close in their pain, loss, and failures. He, too, comes close as a man who has faced hardships, to offer others a hand when their feet are unsteady. By digging into the lives of these biblical sojourners, White unearths hidden treasures, guides readers on a journey of self-discovery, and points the way forward, showing us ways to cultivate tenacious hope, stronger faith, and greater capacity to live and love as participants in God's ongoing redemption story.

Download or read book Public Opinion written by Walter Lippmann and published by . This book was released on 1922 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: In what is widely considered the most influential book ever written by Walter Lippmann, the late journalist and social critic provides a fundamental treatise on the nature of human information and communication. The work is divided into eight parts, covering such varied issues as stereotypes, image making, and organized intelligence. The study begins with an analysis of "the world outside and the pictures in our heads", a leitmotif that starts with issues of censorship and privacy, speed, words, and clarity, and ends with a careful survey of the modern newspaper. Lippmann's conclusions are as meaningful in a world of television and computers as in the earlier period when newspapers were dominant. Public Opinion is of enduring significance for communications scholars, historians, sociologists, and political scientists. Copyright © Libri GmbH. All rights reserved.

Download or read book Lethal and Non Lethal Fires written by Army University Press and published by . This book was released on 2018-09 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: Lethal and Non-Lethal Fires: Historical Case Studies of Converging Cross-Domain Fires in Large Scale Combat Operations, provides a collection of ten historical case studies from World War I through Desert Storm. The case studies detail the use of lethal and non-lethal fires conducted by US, British, Canadian, and Israeli forces against peer or near-peer threats. The case studies span the major wars of the twentieth-century and present the doctrine the various organizations used, together with the challenges the leaders encountered with the doctrine and the operational environment, as well as the leaders' actions and decisions during the conduct of operations. Most importantly, each chapter highlights the lessons learned from those large scale combat operations, how they were applied or ignored and how they remain relevant today and in the future.

Download or read book Congress and the Nation 2013 2016 Volume XIV written by David Hosansky and published by CQ Press. This book was released on 2019-10-29 with total page 745 pages. Available in PDF, EPUB and Kindle. Book excerpt: Chronicling the polarized partisan environment during the President Barack Obama’s second term, Congress and the Nation 2013-2016, Vol. XIV is the most authoritative reference on congressional lawmaking and trends during the 113th and 114th Congresses. The newest edition in this award-winning series documents the most fiercely debated issues during this period, including: The unprecedented federal government shutdown, The strike down of the Defense of Marriage Act as unconstitutional, End of the filibuster for most executive and judicial branch nominees, Changes to the Dodd–Frank Act, Israeli Prime Minister Netanyahu and Pope Francis address joint sessions, Sexual Assault Survivors′ Rights Act passed, overhauling rape kit processing and establishment of victim bill of rights, SPACE Act passed, allowing commercial exploration of space. No other source guides readers seamlessly through the policy output of the national legislature with the breadth, depth, and authority of Congress and the Nation. This is a landmark series is a must-have reference for all academic libraries and meets the needs of the full spectrum of users, from lower-level undergraduates through researchers and faculty.