Within Arm S Length


Within Arm S Length
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Within Arm S Length


Within Arm S Length
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Author : Dan Emmett
language : en
Publisher: iUniverse
Release Date : 2012

Within Arm S Length written by Dan Emmett and has been published by iUniverse this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Biography & Autobiography categories.


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.



Within Arm S Length A Secret Service Agent S Definitive Inside Account Of Protecting The President


Within Arm S Length A Secret Service Agent S Definitive Inside Account Of Protecting The President
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Author : Dan Emmett
language : en
Publisher: Macmillan
Release Date : 2014-06-10

Within Arm S Length A Secret Service Agent S Definitive Inside Account Of Protecting The President written by Dan Emmett and has been published by Macmillan this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-06-10 with Biography & Autobiography categories.


An inside account by a Secret Service agent who provided protection for three Presidents describes stories of some of his more high-profile assignments and the personal and professional challenges faced by Secret Service agents and their families. 40,000 first printing.



Transfer Pricing And The Arm S Length Principle In International Tax Law


Transfer Pricing And The Arm S Length Principle In International Tax Law
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Author : Jens Wittendorff
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-01-01

Transfer Pricing And The Arm S Length Principle In International Tax Law written by Jens Wittendorff and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-01-01 with Law categories.


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.



Within Arm S Reach


Within Arm S Reach
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Author : Ann Napolitano
language : en
Publisher: Dial Press
Release Date : 2024-04-30

Within Arm S Reach written by Ann Napolitano and has been published by Dial Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-04-30 with Fiction categories.


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.



Transfer Pricing And The Arm S Length Principle After Beps


Transfer Pricing And The Arm S Length Principle After Beps
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Author : Richard S. Collier
language : en
Publisher: Oxford University Press, USA
Release Date : 2017

Transfer Pricing And The Arm S Length Principle After Beps written by Richard S. Collier and has been published by Oxford University Press, USA this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Law categories.


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.



Within Arm S Reach


Within Arm S Reach
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Author : Ann Napolitano
language : en
Publisher:
Release Date : 2021

Within Arm S Reach written by Ann Napolitano and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021 with categories.




Transfer Pricing In One Lesson


Transfer Pricing In One Lesson
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Author : Oliver Treidler
language : en
Publisher: Springer Nature
Release Date : 2019-09-12

Transfer Pricing In One Lesson written by Oliver Treidler and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-09-12 with Business & Economics categories.


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.



Transfer Pricing Aspects Of Intra Group Financing


Transfer Pricing Aspects Of Intra Group Financing
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Author : Raffaele Petruzzi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2013-10-20

Transfer Pricing Aspects Of Intra Group Financing written by Raffaele Petruzzi and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-10-20 with Law categories.


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.



Within Arm S Reach W A R


Within Arm S Reach W A R
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Author : Clifford W. Stewart
language : en
Publisher:
Release Date : 2001-07

Within Arm S Reach W A R written by Clifford W. Stewart and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001-07 with Sports & Recreation categories.


It's W.A.R. out there and there's no one better to have on your side than Cliff Stewart. A personal protection specialist to the world's rich and famous -- from Saudi Arabian sheiks and members of Royal Families to Muhammad All and Mr. T -- for more than 20 years, Stewart has distilled and crystallized the sum of his knowledge into a system called "Within Arms Reach" (W.A.R.). As a bodyguard who must rely on his instincts and skills to neutralize any attack, Stewart created a system which provides instant response with maximum effect. W.A.R. was created specifically for non-martial arts types -- professional protection specialists who had little time to learn the kinds of responses which could ultimately save the lives of their clients. W.A.R. gives you the tools to go into battle with the latest, most-innovative techniques known to man.



The Economics Of Organised Crime


The Economics Of Organised Crime
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Author : Gianluca Fiorentini
language : en
Publisher: Cambridge University Press
Release Date : 1997-08-14

The Economics Of Organised Crime written by Gianluca Fiorentini and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 1997-08-14 with Business & Economics categories.


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