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Author : Dan Emmett
Publisher : iUniverse
Page : 224 pages
File Size : 43,6 Mb
Release : 2012
Category : Biography & Autobiography
ISBN : 9781462070725
Narrates the story of Dae Emmett's journey in this coveted job, from the application process to his retirement as assistant to the special agent in charge on the elite Presidential Protective Division.
Author : Ann Napolitano
Publisher : Dial Press
Page : 353 pages
File Size : 51,8 Mb
Release : 2024-04-30
Category : Fiction
ISBN : 9780593732502
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 : Jens Wittendorff
Publisher : Kluwer Law International B.V.
Page : 914 pages
File Size : 50,7 Mb
Release : 2010-01-01
Category : Law
ISBN : 9789041132703
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 : 54,7 Mb
Release : 2017
Category : Law
ISBN : 0198802919
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 : Oliver Treidler
Publisher : Springer Nature
Page : 145 pages
File Size : 41,6 Mb
Release : 2019-09-12
Category : Business & Economics
ISBN : 9783030250850
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 : Dan Emmett,Charles Maynard
Publisher : St. Martin's Griffin
Page : 256 pages
File Size : 51,6 Mb
Release : 2017-06-06
Category : Young Adult Nonfiction
ISBN : 9781250130310
Dan Emmett was just eight years old when President John F. Kennedy was assassinated. From that moment forward, he knew he wanted to become a Secret Service agent, one of an elite group of highly trained men and women dedicated to preserving the life of the President of the United States at any cost, including sacrificing their own lives if necessary. Armed with single-minded determination and a never-quit attitude, he did just that. Selected over thousands of other highly qualified applicants to become an agent, he was eventually chosen to be one of the best of the best and provided protection worldwide for Presidents George Herbert Walker Bush, William Jefferson Clinton, and George W. Bush. I Am a Secret Service Agent skillfully describes the duties and challenges of 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. With fascinating anecdotes, Emmett weaves keen insight into the unique culture and history of the Secret Service with the inner workings of the White House. I Am A Secret Service Agent is a must read for young adults interested in a career in federal law enforcement.
Author : Gianluca Fiorentini,Sam Peltzman
Publisher : Cambridge University Press
Page : 324 pages
File Size : 45,7 Mb
Release : 1997-08-14
Category : Business & Economics
ISBN : 0521629551
The first book to apply economic theory to the analysis of all aspects of organised crime.
Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 338 pages
File Size : 42,7 Mb
Release : 2013-10-20
Category : Law
ISBN : 9789041167330
For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Author : Pegi Deitz Shea
Publisher : PM Press
Page : 143 pages
File Size : 54,8 Mb
Release : 2010-06-01
Category : Juvenile Fiction
ISBN : 9781604863857
A senior in high school, Abe's got a Division I track scholarship awaiting him, a hot girlfriend, and a loving and wealthy adoptive family, including a brother his age. But suddenly, horrific flashbacks and seizures rip him back five years ago to war-torn Africa, where he lost his mother, his sister, his friends, and almost his own life to torturous violence. In therapy for Post Traumatic Stress Disorder, Abe uncovers even darker moments that make him question why he's still alive. This contemporary young adult novel portrays the pressures of teens to live a normal life, let alone succeed at high levels; while facing mental illness and—in Abe's case—a past that no one could possibly understand… or survive. Pegi Deitz Shea has written a suspenseful, action-filled book that will open teens' eyes and hearts to the lives of young people exposed to violence around the world.
Author : George Cameron Stone
Publisher : Courier Corporation
Page : 705 pages
File Size : 41,7 Mb
Release : 2013-03-13
Category : Antiques & Collectibles
ISBN : 9780486131290
DIVIndispensable resource employs alphabetized, easy-to-use format. Arquebuses, flintlocks, and other antique guns appear here, along with German armor, Roman short swords, Turkish crossbows, much more. Over 4,500 individual photos and drawings, 875 detailed figures. /div
Author : Ann Napolitano
Publisher : Dial Press Trade Paperback
Page : 353 pages
File Size : 51,6 Mb
Release : 2024-04-30
Category : Fiction
ISBN : 9780593732496
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 : Ernest Hemingway
Publisher : Simon and Schuster
Page : 352 pages
File Size : 40,6 Mb
Release : 2014-07-08
Category : Fiction
ISBN : 9781476764528
Featuring a previously published author introduction, a personal foreword by his son and a new introduction by his grandson, a definitive edition of the lauded World War I classic collects all 39 of the Nobel Prize-winning author's alternate endings to offer new insights into his creative process. Reprint.
Author : Eduardo Baistrocchi,Ian Roxan
Publisher : Cambridge University Press
Page : 128 pages
File Size : 50,6 Mb
Release : 2012-12-06
Category : Law
ISBN : 9781139916288
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author : Elisabeth Elliot
Publisher : Revell
Page : 224 pages
File Size : 48,7 Mb
Release : 2021-03-16
Category : Religion
ISBN : 9781493434596
In a life filled with uncertainty, former missionary Elisabeth Elliot clung to the God who never left her side. Through the deaths of two husbands, a life of travel and danger, and raising her daughter as a single parent, God provided Elliot with a security that could not have come from relying on the world. In this handsomely repackaged edition of Secure in the Everlasting Arms, you are invited to join her as she recounts how she relied on God during some of the most amazing and difficult events of her life.
Author : Will Larson
Publisher : Stripe Press
Page : 281 pages
File Size : 51,7 Mb
Release : 2019-05-20
Category : Computers
ISBN : 9781953953339
A human-centric guide to solving complex problems in engineering management, from sizing teams to handling technical debt. There’s a saying that people don’t leave companies, they leave managers. Management is a key part of any organization, yet the discipline is often self-taught and unstructured. Getting to the good solutions for complex management challenges can make the difference between fulfillment and frustration for teams—and, ultimately, between the success and failure of companies. Will Larson’s An Elegant Puzzle focuses on the particular challenges of engineering management—from sizing teams to handling technical debt to performing succession planning—and provides a path to the good solutions. Drawing from his experience at Digg, Uber, and Stripe, Larson has developed a thoughtful approach to engineering management for leaders of all levels at companies of all sizes. An Elegant Puzzle balances structured principles and human-centric thinking to help any leader create more effective and rewarding organizations for engineers to thrive in.