At Arms Length
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Author | : Dan Emmett |
Publisher | : Macmillan |
Total Pages | : 318 |
Release | : 2014-06-10 |
Genre | : Biography & Autobiography |
ISBN | : 1250044715 |
"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 the essential book on the Secret Service--a revealing and compelling inside look at the 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 challenges faced by Secret Service agents as well as the physical and emotional toll that can be inflicted on both agents and their families. Within Arm's Length also shares firsthand details about 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 and the inner workings of the White House"--
Author | : Jens Wittendorff |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 914 |
Release | : 2010-01-01 |
Genre | : Law |
ISBN | : 9041132708 |
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 |
Publisher | : Oxford University Press, USA |
Total Pages | : 336 |
Release | : 2017 |
Genre | : Law |
ISBN | : 9780198802914 |
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 | : Gianluca Fiorentini |
Publisher | : Cambridge University Press |
Total Pages | : 324 |
Release | : 1997-08-14 |
Genre | : Business & Economics |
ISBN | : 9780521629553 |
The first book to apply economic theory to the analysis of all aspects of organised crime.
Author | : Björn Heidecke |
Publisher | : Springer |
Total Pages | : 725 |
Release | : 2021-03-10 |
Genre | : Business & Economics |
ISBN | : 9783319733319 |
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 | : Maeve Losito |
Publisher | : |
Total Pages | : 286 |
Release | : 2013-06-26 |
Genre | : |
ISBN | : 9781481203531 |
Life would never be the same for Evelyn Desonierre. The life of a monster slayer is always hard, but when the only person who loved her is taken her entire world shatters. She is just a shell of a woman with walls built high and indestructible. That is until she is given an apprentice. Walls are meant to be impenetrable, however, there are those who test their climbing skills and conquer the barrier. Jason Hayes, Desonierre's new assistant, attempts just that.
Author | : Milton C. Cummings |
Publisher | : Americans for the Arts Books |
Total Pages | : 144 |
Release | : 1989 |
Genre | : Art |
ISBN | : |
Author | : Andrew Scobell |
Publisher | : DIANE Publishing |
Total Pages | : 51 |
Release | : 2004 |
Genre | : China |
ISBN | : 1428910255 |
Author | : Andrew Scobell |
Publisher | : Strategic Studies Institute |
Total Pages | : 72 |
Release | : 2006 |
Genre | : Korea (North) |
ISBN | : |
In the first decade of the 21st century, few national security challenges facing the United States is as vexing as that posed by North Korea. It is a paradox because it appears to be a very powerful state-possessing the world's fourth largest armed forces, a sizeable arsenal of ballistic missiles, and a worrying nuclear program-but it is also an economic basket case in terms of agricultural output, industrial production, and foreign trade exports. Virtually every aspect of the Pyongyang regime is mysterious and puzzling. In short, North Korea is difficult for Americans to understand and analyze, beginning with confusion about what kind of political system North Korea has and what kind of man leads it. The author explores Pyongyang's political dynamics and seeks to shed light on the political system of North Korea and its leader.
Author | : Eva Meijer |
Publisher | : Pushkin Press |
Total Pages | : 144 |
Release | : 2023-04-18 |
Genre | : Biography & Autobiography |
ISBN | : 1782276009 |
"Moving, poetic, cogent and honest." -- Andrew Solomon, author of The Noonday Demon An intimate study of depression that draws on personal experience and a deep knowledge of philosophy—perfect for fans of Maggie Nelson and Leslie Jamison The Limits of My Language is both a razor-sharp analysis of depression and a steadfast search for the things great and small -- from philosophy and art to walking a dog or sitting quietly with a cat -- that make our lives worth living. Much has been written about the treatment of depression, but relatively little about its meaning. In this strikingly original book, Eva Meijer weaves her own experiences and the insights of thinkers from Freud to Foucault and Woolf into a moving and incisive evocation of the condition. Depression is more than a chemical problem—the questions that occupy someone with depression are fundamentally human, and they touch on other philosophical questions that concern language, autonomy, power relations, loneliness, and the relationship between body and mind. But this book-length essay is also about the other side, such as animals, trees, others, art: about consolation, and hope, and the things that can give life meaning. The Limits of My Language explores how depression can make us grow out of shape over time, like a twisted tree, how we can sometimes remould ourselves in conversation with others, and how to move on from our darkest thoughts.