Download or read book The Missing Keystone of Income Tax Treaties written by Joanna Wheeler and published by IBFD. This book was released on 2012 with total page 449 pages. Available in PDF, EPUB and Kindle. Book excerpt: Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respect of the income for which treaty benefits are claimed. This "missing keystone" causes two major problems of interpretation. One problem arises if the contracting states attribute the income to different persons; the myriad ways in which such a conflict can occur is illustrated by an extensive comparison of the domestic law of the Netherlands and the United Kingdom in this respect. This missing keystone also causes a disconnection between the two principal conditions for treaty entitlement. The treaty residence of the claimant is based on a general liability to tax in a contracting state, whereas the distributive articles focus on the ownership of the income. Interpretation problems arise if domestic law imposes a tax liability on a person who is not the owner of the income, for example under anti-avoidance legislation or a corporate group regime. In order to eliminate this fundamental flaw, the thesis proposes a "new approach" in which the criterion for treaty entitlement is liability to tax on the income, backed up by substantial connections between the income and the treaty claimant and between the treaty claimant and the residence state. The new approach is tested in various situations, many of them decided cases, and proves to give appropriate policy results while respecting the tax sovereignty of states. The thesis includes a proposal for a re-draft of the OECD Model on this basis."
Download or read book Tiley s Revenue Law written by Glen Loutzenhiser and published by Bloomsbury Publishing. This book was released on 2019-08-22 with total page 1647 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf
Download or read book Tiley and Collison s UK Tax Guide 2010 11 written by Keith M. Gordon and published by . This book was released on 2010 with total page 2787 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tiley & Collison's UK Tax Guide adopts a practical approach to UK tax law providing essential guidance for the practitioner and is also ideally suited for students studying for the CIOT examination. It examines the workings of income tax, corporation tax, capital gains tax, inheritance tax, VAT, stamp duty and NIC. The thought-provoking commentary makes the complex subject of revenue law interesting and easy to understand.
Download or read book Comparative Income Taxation written by Brian J. Arnold and published by Kluwer Law International B.V.. This book was released on 2019-12-09 with total page 667 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comparative Income Taxation A Structural Analysis Fourth Edition Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries’ tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following: classification of business entities; taxation of corporations and their shareholders; corporate organization and restructuring; taxation of partnerships; residence and source taxation; controlled foreign company rules; restrictions on the deduction of interest; courts dealing with tax matters; and effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.
Download or read book Taxation Virtual Currency and Blockchain written by Aleksandra Bal and published by Kluwer Law International B.V.. This book was released on 2018-11-29 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: The emergence of convertible decentralized virtual currency schemes confronts tax authorities with unprecedented questions, among them are the status of virtual currency for tax purposes, which virtual transactions may bene?t from a VAT exemption and determining the most optimal method of tax regulation. This ?rst book-length treatment of this major current topic provides an in-depth and comprehensive analysis of the tax implications of virtual currency transactions. Seeking to ascertain whether virtual currency requires additional regulation or whether the law as it stands is adequate to administer its usage, the analysis not only thoroughly explains the nature of the underlying blockchain technology and its regulatory and judicial treatment so far but also identi?es best practices for virtual currency transactions and makes recommendations for the improvement of the existing tax systems. Among the aspects of the phenomenon covered are the following: – particular aspects of virtual currency use such as smart contracts and initial coin offerings; – comparative review of income tax consequences of virtual currency transactions in Germany, the Netherlands, the United Kingdom and the United States; – VAT/sales tax treatment of transactions involving virtual currency in the European Union and the United States; – methodology for creating an effective regulatory framework for the taxation of virtual currency; and – the future of blockchain. The book has three parts and an annex that describes tax regulations, administrative rulings and court decisions concerning virtual currency in twenty countries. In its in-depth analysis of tax implications of virtual currency transactions in major economies, detailed overview of recent tax developments that affect virtual currency transactions and evaluation of tax policies related to virtual currencies, this book has no peers. Especially in view of the OECD's examination of the tax challenges presented by the digital economy as part of its base erosion and pro?t shifting (BEPS) project, this clear and comprehensive explanation of the functioning of virtual currency and blockchain technology will be welcomed by tax administration of?cials and by persons mining and transacting in virtual currencies needing to know their compliance obligations.
Download or read book Advanced Topics in Revenue Law written by John Tiley and published by Bloomsbury Publishing. This book was released on 2013-01-07 with total page 532 pages. Available in PDF, EPUB and Kindle. Book excerpt: The last several years have seen fundamental changes to the UK tax system. Nearly the entirety of the UK corporation tax and international tax rules have been rewritten by three new statutes – the Corporation Tax Acts 2009 and 2010 and the Taxation (International and Other Provisions) Act 2010. The UK has also implemented major new policies affecting the taxation of pensions, charities, savings vehicles, 'non-doms' and the foreign profits of UK companies. In addition, European Union law, and especially the case law of the Court of Justice of the European Union, has had an increasingly important impact on UK corporation tax and international tax law in particular. This new book on advanced topics in UK tax law is derived from material previously found in John Tiley's major text on Revenue Law that has been expanded and comprehensively updated to take account of these developments. The book deals with Corporation Tax, International and European Tax, Savings and Charities, in a manageable and portable volume for law students and practitioners. It complements the material on UK Income Tax, Capital Gains Tax, and Inheritance Tax found in Revenue Law, 7th edition. Unlike other tax law books, this text explains the new rules found in CTA 2009, CTA 2010 and TIOPA 2010 in light of its legislative predecessors. The book contains extensive references to the new legislation and also to the former enactments in ICTA 1988 and elsewhere. Those familiar with the old law but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking advanced tax courses in the final year of their law degree course and for graduate students, but is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of or reference to the background material in terms of policy, history or other countries' tax systems.
Download or read book Revenue Law written by John Tiley and published by Bloomsbury Publishing. This book was released on 2012-10-11 with total page 821 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the 7th Edition of John Tiley's major text on revenue law, now massively restructured to focus upon the UK Tax system, Income Tax, Capital Gains Tax, and Inheritance Tax. What were previously sections dealing with Corporation Tax, International and European Tax, Savings and Charities have been spun-off to an entirely new book entitled Advanced Topics in Revenue Law. While this narrowing of the scope of Revenue Law means that it focuses on the most important UK taxes, its reduced size also makes it a more manageable and portable volume for law students and practitioners. As with previous editions, the text has been revised to incorporate changes wrought by new enactments in the past four years. This, however, remains the only book on tax law which continues to explain the new law found in ITEPA, ITTOIA and ITA in light of its legislative predecessors, with references to the former enactments still remaining where relevant. Those familiar with the old law of income tax but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking the subject in the final year of their law degree course or for more advanced courses and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems.
Download or read book Pentagon 9 11 written by Alfred Goldberg and published by Office of the Secretary, Historical Offi. This book was released on 2007-09-05 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: The most comprehensive account to date of the 9/11 attack on the Pentagon and aftermath, this volume includes unprecedented details on the impact on the Pentagon building and personnel and the scope of the rescue, recovery, and caregiving effort. It features 32 pages of photographs and more than a dozen diagrams and illustrations not previously available.
Download or read book In the Loop written by Office of Office of English Language Programs and published by Createspace Independent Publishing Platform. This book was released on 2015-02-17 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the Loop is divided into three parts: Part 1, "Idioms and Definitions"; Part 2, "Selected Idioms by Category"; and Part 3, "Classroom Activities." The idioms are listed alphabetically in Part 1. Part 2 highlights some of the most commonly used idioms, grouped into categories. Part 3 contains classroom suggestions to help teachers plan appropriate exercises for their students. There is also a complete index at the back of the book listing page numbers for both main entries and cross-references for each idiom.
Download or read book Landmark Cases in Revenue Law written by John Snape and published by Bloomsbury Publishing. This book was released on 2019-01-10 with total page 571 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an important addition to the series, this book tells the story of 20 leading revenue law cases. It goes well beyond technical analysis to explore questions of philosophical depth, historical context and constitutional significance. The editors have assembled a stellar team of tax scholars, including historians as well as lawyers, practitioners as well as academics, to provide a wide range of fresh perspectives on familiar and unfamiliar decisions. The whole collection is prefaced by the editors' extended introduction on the peculiar significance of case-law in revenue matters. This publication is a thought provoking and engaging showcase of tax writing that is accessible equally to specialists and non-specialists.
Download or read book Causes of War written by Jack S. Levy and published by John Wiley & Sons. This book was released on 2011-09-15 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by leading scholars in the field, Causes of War provides the first comprehensive analysis of the leading theories relating to the origins of both interstate and civil wars. Utilizes historical examples to illustrate individual theories throughout Includes an analysis of theories of civil wars as well as interstate wars -- one of the only texts to do both Written by two former International Studies Association Presidents
Download or read book Fundamentals of Electric Propulsion written by Dan M. Goebel and published by John Wiley & Sons. This book was released on 2008-12-22 with total page 528 pages. Available in PDF, EPUB and Kindle. Book excerpt: Throughout most of the twentieth century, electric propulsion was considered the technology of the future. Now, the future has arrived. This important new book explains the fundamentals of electric propulsion for spacecraft and describes in detail the physics and characteristics of the two major electric thrusters in use today, ion and Hall thrusters. The authors provide an introduction to plasma physics in order to allow readers to understand the models and derivations used in determining electric thruster performance. They then go on to present detailed explanations of: Thruster principles Ion thruster plasma generators and accelerator grids Hollow cathodes Hall thrusters Ion and Hall thruster plumes Flight ion and Hall thrusters Based largely on research and development performed at the Jet Propulsion Laboratory (JPL) and complemented with scores of tables, figures, homework problems, and references, Fundamentals of Electric Propulsion: Ion and Hall Thrusters is an indispensable textbook for advanced undergraduate and graduate students who are preparing to enter the aerospace industry. It also serves as an equally valuable resource for professional engineers already at work in the field.
Download or read book The Politics of Evidence written by Justin Parkhurst and published by Routledge. This book was released on 2016-10-04 with total page 287 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Open Access version of this book, available at http://www.tandfebooks.com/, has been made available under a Creative Commons Attribution-Non Commercial-No Derivatives 3.0 license. There has been an enormous increase in interest in the use of evidence for public policymaking, but the vast majority of work on the subject has failed to engage with the political nature of decision making and how this influences the ways in which evidence will be used (or misused) within political areas. This book provides new insights into the nature of political bias with regards to evidence and critically considers what an ‘improved’ use of evidence would look like from a policymaking perspective. Part I describes the great potential for evidence to help achieve social goals, as well as the challenges raised by the political nature of policymaking. It explores the concern of evidence advocates that political interests drive the misuse or manipulation of evidence, as well as counter-concerns of critical policy scholars about how appeals to ‘evidence-based policy’ can depoliticise political debates. Both concerns reflect forms of bias – the first representing technical bias, whereby evidence use violates principles of scientific best practice, and the second representing issue bias in how appeals to evidence can shift political debates to particular questions or marginalise policy-relevant social concerns. Part II then draws on the fields of policy studies and cognitive psychology to understand the origins and mechanisms of both forms of bias in relation to political interests and values. It illustrates how such biases are not only common, but can be much more predictable once we recognise their origins and manifestations in policy arenas. Finally, Part III discusses ways to move forward for those seeking to improve the use of evidence in public policymaking. It explores what constitutes ‘good evidence for policy’, as well as the ‘good use of evidence’ within policy processes, and considers how to build evidence-advisory institutions that embed key principles of both scientific good practice and democratic representation. Taken as a whole, the approach promoted is termed the ‘good governance of evidence’ – a concept that represents the use of rigorous, systematic and technically valid pieces of evidence within decision-making processes that are representative of, and accountable to, populations served.
Download or read book English as a Global Language written by David Crystal and published by Cambridge University Press. This book was released on 2012-03-29 with total page 227 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written in a detailed and fascinating manner, this book is ideal for general readers interested in the English language.
Download or read book Ecosystems and Human Well being written by Joseph Alcamo and published by . This book was released on 2003 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Ecosystems and Human Well-Being is the first product of the Millennium Ecosystem Assessment, a four-year international work program designed to meet the needs of decisionmakers for scientific information on the links between ecosystem change and human well-being. The book offers an overview of the project, describing the conceptual framework that is being used, defining its scope, and providing a baseline of understanding that all participants need to move forward. The Millennium Assessment focuses on how humans have altered ecosystems, and how changes in ecosystem services have affected human well-being, how ecosystem changes may affect people in future decades, and what types of responses can be adopted at local, national, or global scales to improve ecosystem management and thereby contribute to human well-being and poverty alleviation. The program was launched by United National Secretary-General Kofi Annan in June 2001, and the primary assessment reports will be released by Island Press in 2005. Leading scientists from more than 100 nations are conducting the assessment, which can aid countries, regions, or companies by: providing a clear, scientific picture of the current sta
Download or read book Handbook of Sports Medicine and Science written by Dennis J. Caine and published by John Wiley & Sons. This book was released on 2013-07-18 with total page 418 pages. Available in PDF, EPUB and Kindle. Book excerpt: This new volume in the Handbook of Sports Medicine and Science series, published in conjunction with the Medical Commission of the International Olympic Committee, offers comprehensive and practical guidance on the training and medical care of competitive gymnasts. Written and edited by leading trainers, team doctors, coaches and other professionals with unparalleled experience in elite gymnastics, this book covers all the key aspects of caring for gymnasts, minimizing the unique risks these athletes face, and treating injuries when they happen. The book is organized into 4 sections covering: The evolution of gymnastics Growth and development Training and performance Sports medicine Individual chapters cover key topics such as energy needs and body weight management; biomechanics; psychology; the epidemiology of gymnastic injuries; treatment and rehabilitation of common injuries; injury prevention; and more. Endorsed by the International Gymnastics Federation (FIG), no other book offers such an in-depth look at the unique considerations and challenges that affect the growth, performance, training, and medical care of athletes in this demanding sport.
Download or read book Autonomous Horizons written by Greg Zacharias and published by Independently Published. This book was released on 2019-04-05 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dr. Greg Zacharias, former Chief Scientist of the United States Air Force (2015-18), explores next steps in autonomous systems (AS) development, fielding, and training. Rapid advances in AS development and artificial intelligence (AI) research will change how we think about machines, whether they are individual vehicle platforms or networked enterprises. The payoff will be considerable, affording the US military significant protection for aviators, greater effectiveness in employment, and unlimited opportunities for novel and disruptive concepts of operations. Autonomous Horizons: The Way Forward identifies issues and makes recommendations for the Air Force to take full advantage of this transformational technology.