Download or read book Permanency in Building Construction written by Nathaniel Ellery and published by . This book was released on 1913 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanency in Building Construction written by Nathaniel Ellery and published by . This book was released on 1913 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Public Building written by Arthur Tappan North and published by . This book was released on 1928 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Design Standards for Construction of Permanent Family Housing for Federal Personnel written by United States. Housing and Home Finance Agency and published by . This book was released on 1957 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Fire Prevention and Fire Protection as Applied to Building Construction written by Joseph Kendall Freitag and published by . This book was released on 1921 with total page 1074 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Sweet s Indexed Catalogue of Building Construction written by and published by . This book was released on 1906 with total page 840 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Manual Covering Permanent Improvement Construction on Administrative Sites written by and published by . This book was released on 1914 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanent Builder written by and published by . This book was released on 1918 with total page 162 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Standards and Criteria for Construction of Permanent type Bachelor Officers Quarters written by United States. Army. Corps of Engineers and published by . This book was released on 1959 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Download or read book Sale of Permanent War Housing to Veterans Hearings Subcomm on Public Buildings and Grounds H R 5924 and S 2288 written by United States. Congress. House. Committee on Public Works and published by . This book was released on 1948 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanent WTC PATH Terminal written by and published by . This book was released on 2007 with total page 844 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Permanent Establishments written by Ekkehart Reimer and published by Kluwer Law International B.V.. This book was released on 2018-06-07 with total page 850 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
Download or read book Design Standards for Construction of Permanent Family Housing for Federal Personnel written by United States. Housing and Home Finance Agency and published by . This book was released on 1953 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Budget of the United States Government written by United States. Bureau of the Budget and published by . This book was released on 1955 with total page 1518 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Cross Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.
Download or read book Building Construction Before Mechanization written by John Fitchen and published by MIT Press. This book was released on 1989-04-03 with total page 345 pages. Available in PDF, EPUB and Kindle. Book excerpt: How were huge stones moved from quarries to the sites of Egyptian pyramids? How did the cathedral builders of the Middle Ages lift blocks to great heights by muscle power alone? In this intriguing book John Fitchen explains and illustrates the solutions to these and many other puzzles in preindustrial building construction. This is the first general survey of the practices and role of the builder (as opposed to the designer) in constructing an array of structures. Fitchen's approach gives a valuable hands-on feel for what it's like to work with ropes and ladders, wedges and slings; with crews engaged in well digging, bridge building, and the transporting of obelisks hundreds of miles by water and over land. The buildings discussed range from the tents, tepees, and igloos of nomadic tribes to the monumental pyramids of Egypt, the temples of Greece, the aqueducts of Rome, and the cathedrals of medieval Europe.
