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Download or read book Problems and Materials on the Sale and Lease of Goods written by Douglas J. Whaley and published by Aspen Publishers. This book was released on 1990 with total page 440 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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Download or read book The Allocation of Multinational Business Income Reassessing the Formulary Apportionment Option written by Richard Krever and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 314 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
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Download or read book Enterprise Liability in Commercial Relationships written by Phillip I. Blumberg and published by Aspen Publishers. This book was released on 1998 with total page 1012 pages. Available in PDF, EPUB and Kindle. Book excerpt: Traditional corporation law (or "entity" law) no longer covers the challenges presented by today's multinational corporate integration and control. Now, Blumberg's ground-breaking analysis of the law of corporate groups (or "enterprise" law) brings current trends in business law into sharp focus, with detailed examination of thousands of cases. This unique addition to The Law of Corporate Groups library provides in-depth coverage of statutory and judicial law, federal and state, that affects companies engaged in enterprises linked by franchise, license, or contract rather than by corporate stock. It explains and analyzes in detail the issues facing such entities as franchisers and franchisees, licensor and licensees, contractors and subcontractors, hospitals and other health care institutions, medical personnel in independent practice, and many others.
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Download or read book Shepard s Discovery Proceedings in Federal Practice written by and published by McGraw-Hill Companies. This book was released on 1983 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: This guidebook to federal discovery rules & their applications in federal practice provides quick practice points, a discussion of function & scope of discovery, & an analysis of discovery procedure. Extensive coverage of local rule provisions for each federal district court is included in the work.