Download or read book Tax Treaty Residence of Entities written by Jan Gooijer and published by Kluwer Law International B.V.. This book was released on 2019-09-13 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.
Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Download or read book Issues Concerning the Use of MTBE in Reformulated Gasoline written by United States. Congress. House. Committee on Energy and Commerce. Subcommittee on Oversight and Investigations and published by . This book was released on 2002 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Company Law written by Lee Roach and published by Oxford University Press. This book was released on 2022-03-11 with total page 832 pages. Available in PDF, EPUB and Kindle. Book excerpt: Lee Roach guides the reader through the intricacies of the subject with unrivalled clarity and expert analysis of the application of principles to real-life cases.
Download or read book International Commercial Tax written by Peter Harris and published by Cambridge University Press. This book was released on 2010-07-22 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.
Download or read book National Implementation of the Reformulated Gasoline Program written by United States. Congress. House. Committee on Commerce. Subcommittee on Health and the Environment and published by . This book was released on 2000 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Upper Steele Bayou Project Reformulation Study Supplemental EIS SEIS Flood Control Mississippi River and Tributaries Yazoo Basin written by and published by . This book was released on 1993 with total page 768 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Taxation of Dividends Reconsidered in Light of Corporate Tax Integration Proceedings of a Seminar Organised Jointly with OECD in Toronto in 1994 During the 48th Congress of the International Fiscal Association written by International Fiscal Association. Congress and published by Springer. This book was released on 1995-11-21 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proceedings of a seminar organised jointly with the OECD in Toronto in 1994 during the 48th congress of the International Fiscal Association.
Download or read book Cowanesque Lake Reformulation Study Cowanesque River written by and published by . This book was released on 1982 with total page 372 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Kellogg Unit Reformulation Study Planning Report written by and published by . This book was released on 1988 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Upper Yazoo Projects Reformulation Study Supplemental EIS SEIS Flood Control Mississippi River and Tributaries Yazoo Basin written by and published by . This book was released on 1994 with total page 526 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Redesigning Cities written by Jonathan Barnett and published by Routledge. This book was released on 2017-11-13 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is recommended reading for planners preparing to take the AICP exam. Too often, no one is happy with new development: Public officials must choose among unappealing alternatives, developers are frustrated and the public is angry. But growing political support for urban design, developers' interest in community building and successful examples of redesigned cities all over the U.S. are hopeful signs of change. The author explains how design can reshape suburban growth patterns, revitalize older cities, and retrofit metropolitan areas where earlier development decisions went wrong. The author describes in detail specific techniques, materials, and technologies that should be known (but often aren't) to planners, public officials, concerned citizens, and others involved in development.
Download or read book Corporations in Private International Law written by Stephan Rammeloo and published by Oxford University Press, USA. This book was released on 2001 with total page 404 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text provides discussion of the principle of freedom of establishment and focuses on the key issue of determining where a corporation has its 'seat' for legal purposes.
Download or read book Redeveloping China s Villages in the Twenty First Century written by Lior Rosenberg and published by ANU Press. This book was released on 2024-01-16 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: Implementing national policies is a crucial function of the local Chinese bureaucracy and an indispensable part of Beijing’s overall state capacity. Yet the specifics of how and why local officials interpret and implement such policies have so far escaped detailed attention. In Redeveloping China’s Villages in the Twenty-First Century, Lior Rosenberg fills this gap by examining the national Village Redevelopment Program, one of China’s most significant policies of recent decades to promote rural change. Based on Rosenberg’s on-site research, Redeveloping China’s Villages in the Twenty-First Century investigates the Village Redevelopment Program’s implementation in both the industrialised county of Chenggu, in Shandong province, and the predominantly agricultural county of Beian, in Anhui province. At the book’s heart is a puzzle: the program was supposed to prioritise poorer villages, but in both Chenggu and Beian—despite being carried out in surprisingly divergent ways—it has subsidised improved infrastructure and services in already industrialised and prosperous villages, while leaving behind poorer ones. In explaining this outcome, Rosenberg elaborates on the larger economic, political and social environment in which Chinese local officials operate, as well as the pressures they face from above. He analyses the dual role played by higher-level authorities, as both policy enablers and thwarters in a system that sanctifies commandism but where the distinction between principals and agents is blurred.
Download or read book Redesigning The American Dream Revised And Updated written by Dolores Hayden and published by W. W. Norton & Company. This book was released on 2002-09-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a provocative critique of American housing patterns that perpetuate Victorian stereotypes of the home as "woman's place" and the city as "man's world", urban historian and architect Dolores Hayden tallies the personal and social costs that an "architecture of gender" creates for the two-earner family, the single-parent family, and single people. She traces three models of home in historical perspective to document innovative alternatives for reconstructing neighborhoods.
Download or read book Redesigning Work written by Lynda Gratton and published by MIT Press. This book was released on 2022-05-03 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: How do we make the most of the greatest global shift in the world of work for a century and radically redesign the way we work—forever? Professor Lynda Gratton is the global thought-leader on the future of work. Drawing on thirty years of research into the technological, demographic, cultural, and societal trends that are shaping work and building on what we learned through our experiences of the pandemic, Gratton presents her innovative four-step framework for redesigning work that will help you: Understand your people and what drives performance Reimagine creative new ways to work Model and test these approaches within your organization Act and create to ensure your redesign has lasting benefits Gratton presents real-world case studies that show companies grappling with work challenges. These include the global bank HSBC, which built a multidisciplinary team to understand the employee experience; the Japanese technology company Fujitsu, which reimagined three kinds of “perfect” offices; and the Australian telecommunications company Telstra, which established new roles to coordinate work across the organization. Whether you’re working in a small team or running a multinational, Redesigning Work is the definitive book on how to transform your organization and make hybrid working work for you.
Download or read book Redeveloping Tehran written by Kiavash Soltani and published by Springer Nature. This book was released on 2022-03-13 with total page 201 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book compares two urban regeneration models, namely piecemeal and comprehensive redevelopments. Tehran, like many cities in the developing world, on the one hand faces extensive deterioration in its inner-city neighbourhoods and on the other hand, faces rapid population growth. Urban regeneration is adapted as a policy that not only accommodates urban growth within the city boundaries, but also tackles the deterioration problems. This book tries to understand how these two redevelopment models operate in run-down neighbourhoods of Tehran, with a specific focus on developers’ behaviour regarding these two models. Two neighbourhoods that have undergone redevelopments in Tehran, one piecemeal and one comprehensive, are chosen as case studies. Utilising institutional analysis as a qualitative methodological approach, this book improves our understanding of the process of built environment production, as well as the role of developers and state in the development process. The book demonstrates that the development decision-making cannot be solely understood as the result of economic rationality, as it occurs within institutional contexts structured by dynamic needs and concerns of actors. In advancing institutional analysis, the research demonstrates the different approaches taken by developers, development organisations and planners as they engaged differently with the wider structures set by the government through different policies.
