Download or read book Certainty in Law written by Humberto Ávila and published by Springer. This book was released on 2016-07-20 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Instead of the usual apologetic treatment found in legal doctrine, linked to the determinacy, immutability or predictability of norms, this book treats legal certainty innovatively, holistically and in depth. Using a method at once analytical and functional, Professor Ávila examines the structural elements of legal certainty, from its definition and foundations to its various dimensions, normative forces and efficacies, citing a wealth of examples from case law to support each of the theses defended. No subject is more important and topical than legal certainty. Problems relating to lack of understanding, instability and unpredictability of law intensify day by day everywhere, in civil law and common law countries alike. Normative sources are increasingly diverse in origin (national, international, community) and multiple in nature (legal, contractual, jurisprudential). They change constantly, and present increasingly frequent problems of ambiguity and vagueness that significantly hinder their comprehension. This state of affairs, which to a greater or lesser extent is true of any legal order, justifies a return to the subject of legal certainty. In this book, essential questions are answered such as: Legal certainty in what sense? Certainty of what, for whom, in whose vision and by whom? When, to what extent, and to what end? “(...) it is probably the most comprehensive and systematic study ever produced on this subject using the analytical method.” (Riccardo Guastini, Professor of Jurisprudence, University of Genoa, Italy)

Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

Download or read book JUSTI A E DEMOCRACIA as novas perspectivas da hermen utica constitucional written by Renata Furtado de Barros and published by Lulu.com. This book was released on 2012-12-10 with total page 501 pages. Available in PDF, EPUB and Kindle. Book excerpt: A ABPJD (Academia Brasileira de Produção Jurídica Discente) apresenta seu terceiro livro produzido com a colaboração de diversos profissionais da área jurídica, intitulado: "JUSTIÇA E DEMOCRACIA: as novas perspectivas da hermenêutica constitucional". Essa obra é fruto de inúmeras pesquisas dos alunos do curso de Pós-Graduação em Direito da PUC Minas, tendo contado com a colaboração de diversos docentes e discentes de outras instituições espalhadas por todo o Brasil. Com o objetivo de facilitar a leitura, a obra foi dividida em dois volumes, sendo este o primeiro volume. O que se busca a todo momento é crer em um ordenamento jurídico mais justo e democrático, para tanto, entendemos que a hermenêutica é um caminho seguro para reflexão da aplicação das normas no Estado Democrático de Direito brasileiro. Esperamos que esse livro seja uma reflexão da hermenêutica constitucional e de seu papel na manutenção de ideais mais sólidos de Justiça e Democracia. As Organizadoras.

Download or read book International Trade Subsidy Rules and Tax and Financial Export Incentives written by Paulo Penteado Neto and published by AuthorHouse. This book was released on 2012 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study researches interrelations between international trade subsidy rules and the use of tax and financial export incentives by developing countries. The author proclaims that developing countries should be allowed to adopt certain incentives without violating the WTO rules concerning subsidies. After a discussion about the right to development and the fair/just trade the author analyses the WTO concept of subsidy and its categories in light of the US-Foreign Sales Corporations (US-FSC) WTO case decision.

Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

Download or read book Tax Treaty Case Law around the Globe 2017 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2018-02-20 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided in 2016 around the world.

Download or read book Tax Treaty Case Law around the Globe 2019 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-07-22 with total page 412 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

Download or read book ABUSO DE TRATADOS INTERNACIONAIS E A REGRA DO PRINCIPAL PURPOSE TEST written by Melody Araújo Pinto Furman and published by Arraes Editores. This book was released on 2022-09-06 with total page 159 pages. Available in PDF, EPUB and Kindle. Book excerpt: O livro estuda a regra do Principal Purpose Test (PPT), uma regra geral antiabuso que lida com planejamentos tributários internacionais. Essa regra foi proposta no âmbito do Projeto BEPS (Base Erosion and Profit Shifting) como fruto da Ação 6 do Projeto. Após uma introdução sobre os planejamentos tributários internacionais e de regras propostas ao longo dos anos para lidar com essa prática, estuda-se a regra PPT. Avalia-se o conceito, os objetivos, o alcance e os elementos estruturantes da regra PPT, bem como o status atual de adoção dessa regra nos tratados internacionais celebrados pelo Brasil.

Download or read book Welcome to the United States written by and published by . This book was released on 2007 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Free Speech A Very Short Introduction written by Nigel Warburton and published by OUP Oxford. This book was released on 2009-02-26 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'I disapprove of what you say, but I will defend to the death your right to say it' This slogan, attributed to Voltaire, is frequently quoted by defenders of free speech. Yet it is rare to find anyone prepared to defend all expression in every circumstance, especially if the views expressed incite violence. So where do the limits lie? What is the real value of free speech? Here, Nigel Warburton offers a concise guide to important questions facing modern society about the value and limits of free speech: Where should a civilized society draw the line? Should we be free to offend other people's religion? Are there good grounds for censoring pornography? Has the Internet changed everything? This Very Short Introduction is a thought-provoking, accessible, and up-to-date examination of the liberal assumption that free speech is worth preserving at any cost. ABOUT THE SERIES: The Very Short Introductions series from Oxford University Press contains hundreds of titles in almost every subject area. These pocket-sized books are the perfect way to get ahead in a new subject quickly. Our expert authors combine facts, analysis, perspective, new ideas, and enthusiasm to make interesting and challenging topics highly readable.

Download or read book CyberBRICS written by Luca Belli and published by Springer Nature. This book was released on 2021-01-04 with total page 289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book stems from the CyberBRICS project, which is the first major attempt to produce a comparative analysis of Internet regulations in the BRICS countries – namely, Brazil, Russia, India, China, and South Africa. The project has three main objectives: 1) to map existing regulations; 2) to identify best practices; and 3) to develop policy recommendations in the various areas that compose cybersecurity governance, with a particular focus on the strategies adopted by the BRICS countries to date. Each study covers five essential dimensions of cybersecurity: data protection, consumer protection, cybercrime, the preservation of public order, and cyberdefense. The BRICS countries were selected not only for their size and growing economic and geopolitical relevance but also because, over the next decade, projected Internet growth is expected to occur predominantly in these countries. Consequently, the technology, policy and governance arrangements defined by the BRICS countries are likely to impact not only the 3.2 billion people living in them, but also the individuals and businesses that choose to utilize increasingly popular applications and services developed in BRICS countries according to BRICS standards. Researchers, regulators, start-up innovators and other Internet stakeholders will find this book a valuable guide to the inner workings of key cyber policies in this rapidly growing region.

Download or read book The BRICS and the Future of Global Order written by Oliver Stuenkel and published by Rowman & Littlefield. This book was released on 2020-02-03 with total page 273 pages. Available in PDF, EPUB and Kindle. Book excerpt: The transformation of the BRIC acronym from an investment term into a household name of international politics and into a semi-institutionalized political outfit (called BRICS, with a capital ‘S’), is one of the defining developments in international politics in the past decades. While the concept is now commonly used in the general public debate and international media, there has not yet been a comprehensive and scholarly analysis of the history of the BRICS term. The BRICS and the Future of Global Order, Second Edition offers a definitive reference history of the BRICS as a term and as an institution—a chronological narrative and analytical account of the BRICS concept from its inception in 2001 to the political grouping it is today. In addition, it analyzes what the rise of powers like Brazil, Russia, India, China, and South Africa means for the future of global order. Will the BRICS countries seek to establish a parallel system with its own distinctive set of rules, institutions, and currencies of power, rejecting key tenets of liberal internationalism, are will they seek to embrace the rules and norms that define today’s Western-led order?

Download or read book Principles for Building Resilience written by Reinette Biggs and published by Cambridge University Press. This book was released on 2015-04-02 with total page 317 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reflecting the very latest research, this book provides an in-depth review of the role of resilience in the management of social-ecological systems and the ecosystem services they provide. Leaders in the field outline seven principles for building resilience in social-ecological systems, examining how these can be applied to advance sustainability.

Download or read book Crude Existence written by Kristin Reed and published by Univ of California Press. This book was released on 2009-11-15 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: After decades of civil war and instability, the African country of Angola is experiencing a spectacular economic boom thanks to its most valuable natural resource: oil. Focusing on the everyday realities of people living in the extraction zones, Reed explores the exclusion, degradation, and violence that are the fruits of petrocapitalism in Angola.

Download or read book The Takeover of Social Policy by Financialization written by Lena Lavinas and published by Springer. This book was released on 2017-03-25 with total page 233 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book critically addresses the model of social inclusion that prevailed in Brazil under the rule of the Workers Party from the early 2000s until 2015. It examines how the emergence of a mass consumer society proved insufficient, not only to overcome underdevelopment, but also to consolidate the comprehensive social protection system inherited from Brazil’s 1988 Constitution. By juxtaposing different theoretical frameworks, this book scrutinizes how the current finance-dominated capitalism has reshaped the role of social policy, away from rights-based decommodified benefits and towards further commodification. This constitutes the Brazilian paradox: how a center-left government has promoted and boosted financialization through a market incorporation strategy using credit as a lever for expanding financial inclusion. In so doing, it has pushed the subjection of social policy further into the logic of financial markets.

Download or read book Mean Baby written by Selma Blair and published by Vintage. This book was released on 2023-05-09 with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt: Selma Blair has played many roles: Ingenue in Cruel Intentions. Preppy ice queen in Legally Blonde. Muse to Karl Lagerfeld. Advocate for the multiple sclerosis community. But before all of that, Selma was known best as … a mean baby. In a memoir that is as wildly funny as it is emotionally shattering, Blair tells the captivating story of growing up and finding her truth. "Blair is a rebel, an artist, and it turns out: a writer."—Glennon Doyle, Author of the #1 New York Times Bestseller Untamed and Founder of Together Rising The first story Selma Blair Beitner ever heard about herself is that she was a mean, mean baby. With her mouth pulled in a perpetual snarl and a head so furry it had to be rubbed to make way for her forehead, Selma spent years living up to her terrible reputation: biting her sisters, lying spontaneously, getting drunk from Passover wine at the age of seven, and behaving dramatically so that she would be the center of attention. Although Selma went on to become a celebrated Hollywood actress and model, she could never quite shake the periods of darkness that overtook her, the certainty that there was a great mystery at the heart of her life. She often felt like her arms might be on fire, a sensation not unlike electric shocks, and she secretly drank to escape. Over the course of this beautiful and, at times, devasting memoir, Selma lays bare her addiction to alcohol, her devotion to her brilliant and complicated mother, and the moments she flirted with death. There is brutal violence, passionate love, true friendship, the gift of motherhood, and, finally, the surprising salvation of a multiple sclerosis diagnosis. In a voice that is powerfully original, fiercely intelligent, and full of hard-won wisdom, Selma Blair’s Mean Baby is a deeply human memoir and a true literary achievement.

Download or read book Fiscal Federalism in Theory and Practice written by Mrs.Teresa Ter-Minassian and published by International Monetary Fund. This book was released on 1997-09-10 with total page 1146 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past few decades, a clear trend has emerged worldwide toward the devolution of spending and, to a lesser extent, revenue-raising responsibilities to state and local levels of government. One view is that the decentralization of spending responsibilities can entail substantial gains in terms of distributed equity and macroeconomic management. The papers in this volume, edited by Teresa Ter-Minassian, examine the validity of these views in light of theoretical considerations, as well as the experience of a number of countries.