When an eight year old boy goes missing in the middle of a hurricane a small town detective named Daniel Kennedy must put together pieces of a complex puzzle to solve the crime. And time is running out. What he encounters along the way will have you on the edge of your seat until the very last page. The Storm is the first of three books about Detective Daniel Kennedy.
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When an eight year old boy goes missing in the middle of a hurricane a small town detective named Daniel Kennedy must put together pieces of a complex puzzle to solve the crime. And time is running out. What he encounters along the way will have you on the edge of your seat until the very last page. The Storm is the first of three books about Detective Daniel Kennedy.
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Johann Gottfried Herder initiated the modern disciplines of philosophical anthropology and cultural history, including the study of popular culture. He is also remembered as a sharp critic of colonialism and imperialism. But what types of social, economic and political arrangements did Herder envision for modern European societies? Herder and Enlightenment Politics provides a radically new interpretation of Herder's political thought, situating his ideas in Enlightenment debates on modern patriotism, commerce and peace. By reconstructing Herder's engagement with Rousseau, Montesquieu, Abbt, Ferguson, Möser, Kant and many other contemporary authors, Eva Piirimäe shows that Herder was deeply interested in the potential for cultural, moral and political reform in Russia, Germany and Europe. Herder probed the foundations of modern liberty, community and peace, developing a distinctive understanding of human self-determination, natural sociability and modern patriotism as well as advocating a vision of Europe as a commercially and culturally interconnected community of peoples.
Focuses on the possibility of creating serious security risks by housing wiretapping within communication infrastructure and whether widespread communications surveillance enhances or endangers national security. Landau explains that understanding whether building wiretapping into communication infrastructure keeps us safe requires that we understand the technology, economics, law, and policy issues of communication surveillance technologies. She offers a set of principles to govern wiretapping policy that will allow us to protect our national security as well as our freedom.
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