Download or read book The Hybrid Rule written by Quinn Loftis and published by Quinn Loftis Books, LLC. This book was released on 2023-03-28 with total page 313 pages. Available in PDF, EPUB and Kindle. Book excerpt: So many impossibly powerful foes have opposed the wolves and their allies over the years. Evil witches, warlocks, fae, elves, and alphas, just to name a few. And all have found the pack too strong to break. But the foe hellbent on taking down the pack now—the vampire king, Cain—has a plan that might finally tip the balance of power away from the wolves. In the middle of the desert, Cain works desperately to find a way to mix the blood of wolves and vampires. While most find the idea reprehensible, Cain believes it is the key to his victory. He imagines an army of unstoppable hybrids with the combined power of the vampires and the Canis lupus. Such a force would be unstoppable, even for the powerful of alpha of alphas, Fane Lupei. And Cain just might have found the secret ingredient necessary to bring his plans to fruition.
Download or read book Hybrid Entities in Tax Treaty Law written by Sriram Govind and published by Linde Verlag GmbH. This book was released on 2020-09-03 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
Download or read book Combination of beliefs on hybrid DSm models written by Jean Dezert and published by Infinite Study. This book was released on with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter presents a general method for combining uncertain and paradoxical (i.e. highly conflicting) sources of evidence for a wide class of fusion problems. From the foundations of the DSmT we show how the DSm rule of combination can be extended to take into account all possible integrity constraints (if any) of the problem under consideration due to the true nature of elements/concepts involved into it.
Download or read book Hybrid Financial Instruments Double Non Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Download or read book Addressing hybrid mismatch arrangements written by Policy and Stratgey, Inland Revenue, New Zealand and published by Policy and Strategy, Inland Revenue, New Zealand. This book was released on 2016-09-06 with total page 87 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.
Download or read book Double non taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
Download or read book Managing Hybrid Organizations written by Susanna Alexius and published by Springer. This book was released on 2018-12-05 with total page 374 pages. Available in PDF, EPUB and Kindle. Book excerpt: A much-needed addition to literature, this timely edited collection aims to provide clarity and understanding on how modern organizations work. The authors explore the characteristics of hybrid organizations in contemporary society, taking into account the complex societal challenges that face businesses today. Arguing that hybrid organizations are in fact not a new phenomenon, this thought-provoking collection goes beyond existing research and re-evaluates our traditional understanding of this concept. Scholars of organization, management and innovation will find this book an insightful read, as it sheds light on the fundamental aspects that shape today’s hybrid organizations.
Download or read book Columbia Law Review written by and published by . This book was released on 1928 with total page 1192 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Applications and Science in Soft Computing written by Ahmad Lotfi and published by Springer Science & Business Media. This book was released on 2004-01-22 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book covers the theory and application of soft computing techniques namely; neural networks, fuzzy logic, evolutionary computing and complex systems. The book is a collection of selected, edited papers presented at the 4th conference RACS Recent Advances in Soft Computing held in Nottingham, December 2002. It provides the latest developments in applications of soft computing techniques as well as advances in theoretical aspects of soft computing.
Download or read book Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and published by . This book was released on 1998 with total page 1370 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Corporate and Organizational Identities written by Bertrand Moingeon and published by Routledge. This book was released on 2002-07-18 with total page 222 pages. Available in PDF, EPUB and Kindle. Book excerpt: Using a five-facet framework, this book furthers understanding about collective identities by bringing together contributions from various management disciplines.
Download or read book California Court of Appeal 2nd Appellate District Records and Briefs written by California (State). and published by . This book was released on with total page 518 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book SEC Docket written by United States. Securities and Exchange Commission and published by . This book was released on 1999 with total page 1184 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Artificial Evolution written by El-ghazali Talbi and published by . This book was released on 2006-04-18 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is based on the best papers presented at the 7th Conference on Artificial Evolution, EA 2005, held in Lille (France).
Download or read book The Ashgate Research Companion to International Criminal Law written by Yvonne McDermott and published by Routledge. This book was released on 2016-03-23 with total page 600 pages. Available in PDF, EPUB and Kindle. Book excerpt: International criminal law is at a crucial point in its history and development, and the time is right for practitioners, academics and students to take stock of the lessons learnt from the past fifteen years, as the international community moves towards an increasingly uni-polar international criminal legal order, with the International Criminal Court (ICC) at the helm. This unique Research Companion takes a critical approach to a wide variety of theoretical, practical, legal and policy issues surrounding and underpinning the operation of international criminal law as applied by international criminal tribunals. The book is divided into four main parts. The first part analyses international crimes and modes of liability, with a view to identifying areas which have been inconsistently or misguidedly interpreted, overlooked to date or are likely to be increasingly significant in future. The second part examines international criminal processes and procedures, and here the authors discuss issues such as victim participation and the rights of the accused. The third part is a discussion of complementarity and sentencing, while the final part of the book looks at international criminal justice in context. The authors raise issues which are likely to provide the most significant challenges and most promising opportunities for the continuing development of this body of law. As international criminal law becomes more established as a distinct discipline, it becomes imperative for international criminal scholarship to provide a degree of critical analysis, both of individual legal issues and of the international criminal project as a whole. This book represents an important collective effort to introduce an element of legal realism or critical legal studies into the academic discourse.
Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1570 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Download or read book Code of Federal Regulations written by and published by . This book was released on 2005 with total page 702 pages. Available in PDF, EPUB and Kindle. Book excerpt:
