At Arm S Length

Author : Dan Emmett
Publisher : St. Martin's Press
Page : 318 pages
File Size : 55,8 Mb
Release : 2014-06-10
Category : Political Science
ISBN : 9781466843172

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Within Arm's Length: A Secret Service Agent's Definitive Inside Account of Protecting the President by Dan Emmett Pdf

A rare inside look at the Secret Service from an agent who provided protection worldwide for President George H. W. Bush, President William Clinton, and President George W. Bush Dan Emmett was just eight years old when President John F. Kennedy was assassinated. The events surrounding the President's death shaped the course of young Emmett's life as he set a goal of becoming a US Secret Service agent—one of a special group of people willing to trade their lives for that of the President, if necessary. Within Arm's Length is a revealing and compelling inside look at the Secret Service and the elite Presidential Protective Division (PPD). With stories from some of the author's more high-profile assignments in his twenty-one years of service, where he provided arm's length protection worldwide for Presidents George Herbert Walker Bush, William Jefferson Clinton, and George W. Bush, both as a member of the PPD and the Counter Assault Team, Dan Emmett describes the professional, physical and emotional challenges faced by Secret Service agents. Included are never before discussed topics such as the complicated relationship between presidents, first ladies and their agents, the inner workings of Secret Service protective operations as well as the seldom-mentioned challenges of the complex Secret Service cultural issues faced by an agent's family. Within Arm's Length also shares firsthand details about conducting presidential advances, dealing with the media, driving the President in a bullet-proof limousine, running alongside him through the streets of Washington, and flying with him on Air Force One. Within Arm's Length is the essential book on the United States Secret Service. This revealing and compelling inside look at the Presidential Protective Division, along with spellbinding stories from the author's career, gives the reader an unprecedented look in to the life and career of an agent in America's most elite law enforcement agency.

Author : Jens Wittendorff
Publisher : Kluwer Law International B.V.
Page : 914 pages
File Size : 54,8 Mb
Release : 2010-01-01
Category : Law
ISBN : 9789041132703

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Transfer Pricing and the Arm's Length Principle in International Tax Law by Jens Wittendorff Pdf

The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

Author : Richard S. Collier,Joseph L. Andrus
Publisher : Oxford University Press, USA
Page : 336 pages
File Size : 53,5 Mb
Release : 2017
Category : Law
ISBN : 0198802919

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Transfer Pricing and the Arm's Length Principle After BEPS by Richard S. Collier,Joseph L. Andrus Pdf

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic. This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

Author : Erle Stanley Gardner
Publisher : Unknown
Page : 128 pages
File Size : 46,8 Mb
Release : 2021
Category : Electronic
ISBN : 1479466476

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At Arm's Length by Erle Stanley Gardner Pdf

Author : Shirley Jordan
Publisher : Litfire Publishing, LLC
Page : 128 pages
File Size : 53,9 Mb
Release : 2016-10-22
Category : Electronic
ISBN : 1635244897

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At Arm's Length by Shirley Jordan Pdf

At some point in life you get fed up with the mishaps of life due to negative people in your life. So to keep peace and to stay out of confusion, you need to keep certain people at arm's length to have peace of mind.

Author : Terrence Guay
Publisher : Springer
Page : 233 pages
File Size : 49,6 Mb
Release : 2016-07-27
Category : Political Science
ISBN : 9781349267866

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At Arm’s Length by Terrence Guay Pdf

The author examines the extent to which the European Union and its policies influence Europe's defence industry. He suggests that the end of the Cold War and economic globalization are major factors pushing defence industrial issues to the regional level. The book describes institutional struggles between the European Commission, Council and Parliament in this policy area. The interdisciplinary approach addresses political economy, institution building, European security and defence, transatlantic relations, industrial restructuring, and the influence of defence sector interest groups.

Author : Oliver Treidler
Publisher : Springer Nature
Page : 145 pages
File Size : 52,8 Mb
Release : 2019-09-12
Category : Business & Economics
ISBN : 9783030250850

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Transfer Pricing in One Lesson by Oliver Treidler Pdf

This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.

Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher : World Bank Publications
Page : 388 pages
File Size : 45,7 Mb
Release : 2017-01-05
Category : Business & Economics
ISBN : 9781464809705

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Transfer Pricing and Developing Economies by Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra Pdf

Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.

Author : Björn Heidecke,Marc C. Hübscher,Richard Schmidtke,Martin Schmitt
Publisher : Springer
Page : 725 pages
File Size : 42,9 Mb
Release : 2021-03-10
Category : Business & Economics
ISBN : 3319733311

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Intangibles in the World of Transfer Pricing by Björn Heidecke,Marc C. Hübscher,Richard Schmidtke,Martin Schmitt Pdf

Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.

Author : Ann Napolitano
Publisher : Dial Press
Page : 353 pages
File Size : 48,9 Mb
Release : 2024-04-30
Category : Fiction
ISBN : 9780593732502

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Within Arm's Reach by Ann Napolitano Pdf

The tender and perceptive debut novel from the New York Times bestselling author of Hello Beautiful, about three generations of a large Catholic family jarred into crisis by an unexpected pregnancy “This stunning . . . exquisite, skillfully written gem addresses serious issues–e.g., guilt vs. loyalty, the past vs. the present—[but] remains hopeful and includes ample doses of humor and wit.”—Library Journal (starred review) No one in my mother’s family ever talks about anything that can be categorized as unpleasant or as having to do with emotions. . . . This spellbinding novel by bestselling author Ann Napolitano is a poignant reminder of how connected we are to those we love, even when we cannot find the words to say it. The unforgettable story of three generations of an Irish American family, Within Arm’s Reach is another rich and deeply satisfying novel from the author who captured the many dimensions of grief in Dear Edward and the unbreakable bonds of sisterhood in Hello Beautiful.

Author : Andreas Bullen
Publisher : IBFD
Page : 925 pages
File Size : 53,8 Mb
Release : 2011
Category : Corporations
ISBN : 9789087221171

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Arm’s Length Transaction Structures by Andreas Bullen Pdf

This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).

Author : Gianluca Fiorentini,Sam Peltzman
Publisher : Cambridge University Press
Page : 324 pages
File Size : 41,6 Mb
Release : 1997-08-14
Category : Business & Economics
ISBN : 0521629551

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The Economics of Organised Crime by Gianluca Fiorentini,Sam Peltzman Pdf

The first book to apply economic theory to the analysis of all aspects of organised crime.

Author : Milton C. Cummings,J. Mark Davidson Schuster
Publisher : Americans for the Arts Books
Page : 144 pages
File Size : 40,6 Mb
Release : 1989
Category : Art
ISBN : UVA:X001541855

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Who's to Pay for the Arts? by Milton C. Cummings,J. Mark Davidson Schuster Pdf

Author : Owen Batstone
Publisher : Christian Publishing House
Page : 49 pages
File Size : 52,8 Mb
Release : 2017-10-10
Category : Fiction
ISBN : 9781945757662

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THE DIARY OF JUDAS ISCARIOT by Owen Batstone Pdf

Author : Robert Danon,Vikram Chand,Guglielmo Maisto,Amanda Pletz
Publisher : Kluwer Law International B.V.
Page : 1053 pages
File Size : 45,8 Mb
Release : 2023-08-29
Category : Law
ISBN : 9789403540351

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Applying the Arm's Length Principle to Intra-group Financial Transactions by Robert Danon,Vikram Chand,Guglielmo Maisto,Amanda Pletz Pdf

It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.