It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.
This book provides an overview of the current state-of-the-art of nonlinear time series analysis, richly illustrated with examples, pseudocode algorithms and real-world applications. Avoiding a “theorem-proof” format, it shows concrete applications on a variety of empirical time series. The book can be used in graduate courses in nonlinear time series and at the same time also includes interesting material for more advanced readers. Though it is largely self-contained, readers require an understanding of basic linear time series concepts, Markov chains and Monte Carlo simulation methods. The book covers time-domain and frequency-domain methods for the analysis of both univariate and multivariate (vector) time series. It makes a clear distinction between parametric models on the one hand, and semi- and nonparametric models/methods on the other. This offers the reader the option of concentrating exclusively on one of these nonlinear time series analysis methods. To make the book as user friendly as possible, major supporting concepts and specialized tables are appended at the end of every chapter. In addition, each chapter concludes with a set of key terms and concepts, as well as a summary of the main findings. Lastly, the book offers numerous theoretical and empirical exercises, with answers provided by the author in an extensive solutions manual.
The Power of Design offers an introduction and a practical guide to product innovation, integrating the key topics that are necessary for the design of sustainable and energy-efficient products using sustainable energy technologies. Product innovation in sustainable energy technologies is an interdisciplinary field. In response to its growing importance and the need for an integrated view on the development of solutions, this text addresses the functional principles of various energy technologies next to the latest design processes and innovation methods. From the perspective of product applications, the book provides clear explanations of technologies that are significant for product integration, such as batteries, photovoltaic solar energy, fuel cells, small wind turbines, human power, energy saving lighting, thermal energy technologies in buildings, and piezoelectric energy conversions. The design processes and innovation methods presented in this book include various approaches ranging from technical, societal and creative methods that can be applied in different stages of the design process. Other features include: a methodological approach, enabling readers to easily apply the theory to their research projects and to the actual design of sustainable products with energy technologies discussion on interaction design and smart grid interventions colour photographs that illustrate the final products numerous case studies of product development projects and concepts in practice, enabling readers to understand and design energy-efficient products in several different markets a companion website containing useful information about the cases and an additional design cases with sustainable energy technologies The Power of Design provides a comprehensive and visually-appealing opening into the subject for third and fourth year students, postgraduates, and professionals in the areas of energy, environment, product design and engineering
Believing "high-risk equals high-reward" is holding your portfolio hostage High Returns from Low Risk proves that low-volatility, low-risk portfolios beat high-volatility portfolios hands down, and shows you how to take advantage of this paradox to dramatically improve your returns. Investors traditionally view low-risk stocks as safe but unprofitable, but this old canard is based on a flawed premise; it fails to see beyond the monthly horizon, and ignores compounding returns. This book updates the thinking and brings reality to modelling to show how low-risk stocks actually outperform high-risk stocks by an order of magnitude. Easy to read and easy to implement, the plan presented here will help you construct a portfolio that delivers higher returns per unit of risk, and explains how to achieve excellent investment results over the long term. Do you still believe that investors are rewarded for bearing risk, and that the higher the risk, the greater the reward? That old axiom is holding you back, and it is time to start seeing the whole picture. This book shows you, through deep historical simulation, how to reap the rewards of smarter investing. Learn how and why low-risk, low-volatility stocks beat the market Discover the formula that outperforms Greenblatt's Construct your own low-risk portfolio Select the right ETF or low-risk fund to manage your money Great returns and lower risk sound like a winning combination — what happens once everyone is doing it? The beauty of the low-risk strategy is that it continues to work even after the paradox is widely known; long-term investment success is possible for anyone who can shake off the entrenched wisdom and go low-risk. High Returns from Low Risk provides the proof, model and strategy to reign in your exposure while raking in the profit.
Living on the Edge' examines the function of the Sahel region of Africa as an important wintering area for long-distance migrant birds. It describes the challenges the birds have to cope with – climate change, of course, and rapid man-made habitat changes related to deforestation, irrigation and reclamation of wetlands. How have all these changes affected the birds, and have birds adapted to these changes? Can we explain the changing numbers of breeding birds in Europe by changes in the Sahel, or vice versa? Winner of the BB/BTO Best Bird Book Award 2010 The Jury commented: "It is a tremendous book in every department. It marks a step-change in our knowledge of the ecology of this critically important region in the European-African migration system and of the many species (familiar to us on their breeding grounds) that winter there. The authors combine the latest scientific information with vivid descriptions of landscapes and animals. Their book is richly illustrated with large numbers of drawings, maps and photographs by acclaimed experts. The wealth of coloured graphics has been particularly well thought out and encourages readers to delve into the figures and learn more about the region, rather than having the (all-too-common) opposite effect. Summing up, the jury praises not just the high quality of the texts, the information and the illustrations, but also the sheer pleasure of reading the book: "One of the key attributes of a good book is to be able to grip the reader's attention and transport him or her to another place. We feel confident that [Living on the edge] will have that effect.
Contains an outline of the principles and characteristics of relevant instrumental techniques, provides an overview of various aspects of direct additive analysis by focusing on an array of applications in R ampD, production, quality control, and technical service.
Beginning with classification, nomenclature, and structures, this reference discussesphysicochemical properties of alkaloids relevant to the chromatographic process.Chromatographic Analysis of Alkaloids explores the main experimental factors affectingthe separation and detection of alkaloids in gas (GC), liquid (LC), and thinlayer(1LC) chromatography ... illustrates separation conditions described in recentliterature ... provides, for a given compound, the GC, LC, and 1LC techniquesavailable within the same paragraph ... surveys, in tabular form, the methods forsample preparation for chromatographic analysis ... contains over 1,200 up-to-datereferences covering the majority of papers on the chromatography of alkaloids... and more.Serving as a rich resource of practical information, Chromatographic Analysis ofAlkaloids is essential reading for analytical, organic, natural products, and forensicchemists and biochemists, pharmacologists, and graduate-level students in thesedisciplines.
Research Management: Europe and Beyond addresses the myriad responsibilities related to research management and administration. The book incorporates narratives from those working in the field to provide insight into the profession. The book also offers a unique perspective on the topic by incorporating global perspectives to address the growing interdisciplinary nature of research collaboration. The book outlines practical advice for those in the research management and administration profession at all levels of experience. It is also a useful tool that research institutions and research groups can use to assist in planning and streamlining their research support. - Offers a deeper understanding of the research management and administrative landscape through single and collective definitions and experiences - Provides an overview of the research environment and explores the international research arena - Discusses some of the most complex issues in research management and administration by covering topics such as ethics, innovation, research impact, organizational structures, and processes for the project life cycle
Himalayan Phytochemicals: Sustainable Options for Sourcing and Developing Bioactive Compounds provides a detailed review of the important medicinal plants which have already been discovered in the Himalayan region, outlining their discovery, activity and underlying chemistry. In addition, it supports a global shift towards sustainable sourcing of natural products from delicate ecosystems. Across the world, environmental destruction and overharvesting of medicinal plants are reducing and destroying multiple important sources and potential leads before researchers have the chance to discover, explore or synthesize them effectively. By identifying this problem and discussing its impact on the Himalayan region, Himalayan Phytochemicals: Sustainable Options for Sourcing and Developing Bioactive Compounds frames the ongoing global struggle and highlights the key factors that must be considered and addressed when working with phytochemicals from endemic plant sources. - Reviews both well-known and recently discovered plants of this region - Highlights methods for phytochemical extraction and analysis - Provides context to support a shift towards sustainable sourcing of natural products
Offshore Risk Assessment was the first book to deal with quantified risk assessment (QRA) as applied specifically to offshore installations and operations. Risk assessment techniques have been used for more than three decades in the offshore oil and gas industry, and their use is set to expand increasingly as the industry moves into new areas and faces new challenges in older regions. This updated and expanded third edition has been informed by a major R&D program on offshore risk assessment in Norway and summarizes research from 2006 to the present day. Rooted with a thorough discussion of risk metrics and risk analysis methodology, subsequent chapters are devoted to analytical approaches to escalation, escape, evacuation and rescue analysis of safety and emergency systems. Separate chapters analyze the main hazards of offshore structures: fire, explosion, collision, and falling objects as well as structural and marine hazards. Risk mitigation and control are discussed, as well as an illustration of how the results from quantitative risk assessment studies should be presented. The third second edition has a stronger focus on the use of risk assessment techniques in the operation of offshore installations. Also decommissioning of installations is covered. Not only does Offshore Risk Assessment describe the state of the art of QRA, it also identifies weaknesses and areas that need further development. This new edition also illustrates applications or quantitative risk analysis methodology to offshore petroleum applications. A comprehensive reference for academics and students of marine/offshore risk assessment and management, the book should also be owned by professionals in the industry, contractors, suppliers, consultants and regulatory authorities.
Seasonality in economic time series can "obscure" movements of other components in a series that are operationally more important for economic and econometric analyses. In practice, one often prefers to work with seasonally adjusted data to assess the current state of the economy and its future course. This book presents a seasonal adjustment program called CAMPLET, an acronym of its tuning parameters, which consists of a simple adaptive procedure to extract the seasonal and the non-seasonal component from an observed series. Once this process is carried out, there will be no need to revise these components at a later stage when new observations become available. The authors describe the main features of CAMPLET, evaluate the outcomes of CAMPLET and X-13ARIMA-SEATS in a controlled simulation framework using a variety of data generating processes, and illustrate CAMPLET and X-13ARIMA-SEATS with three time series: US non-farm payroll employment, operational income of Ahold and real GDP in the Netherlands. Furthermore they show how CAMPLET performs under the COVID-19 crisis, and its attractiveness in dealing with daily data. This book appeals to scholars and students of econometrics and statistics, interested in the application of statistical methods for empirical economic modeling.
This industrially relevant resource covers all established and emerging analytical methods for the deformulation of polymeric materials, with emphasis on the non-polymeric components. Each technique is evaluated on its technical and industrial merits. Emphasis is on understanding (principles and characteristics) and industrial applicability. Extensively illustrated throughout with over 200 figures, 400 tables, and 3,000 references.
Living on the Edge' examines the function of the Sahel region of Africa as an important wintering area for long-distance migrant birds. It describes the challenges the birds have to cope with – climate change, of course, and rapid man-made habitat changes related to deforestation, irrigation and reclamation of wetlands. How have all these changes affected the birds, and have birds adapted to these changes? Can we explain the changing numbers of breeding birds in Europe by changes in the Sahel, or vice versa? Winner of the BB/BTO Best Bird Book Award 2010 The Jury commented: "It is a tremendous book in every department. It marks a step-change in our knowledge of the ecology of this critically important region in the European-African migration system and of the many species (familiar to us on their breeding grounds) that winter there. The authors combine the latest scientific information with vivid descriptions of landscapes and animals. Their book is richly illustrated with large numbers of drawings, maps and photographs by acclaimed experts. The wealth of coloured graphics has been particularly well thought out and encourages readers to delve into the figures and learn more about the region, rather than having the (all-too-common) opposite effect. Summing up, the jury praises not just the high quality of the texts, the information and the illustrations, but also the sheer pleasure of reading the book: "One of the key attributes of a good book is to be able to grip the reader's attention and transport him or her to another place. We feel confident that [Living on the edge] will have that effect.
This book provides an overview of the current state-of-the-art of nonlinear time series analysis, richly illustrated with examples, pseudocode algorithms and real-world applications. Avoiding a “theorem-proof” format, it shows concrete applications on a variety of empirical time series. The book can be used in graduate courses in nonlinear time series and at the same time also includes interesting material for more advanced readers. Though it is largely self-contained, readers require an understanding of basic linear time series concepts, Markov chains and Monte Carlo simulation methods. The book covers time-domain and frequency-domain methods for the analysis of both univariate and multivariate (vector) time series. It makes a clear distinction between parametric models on the one hand, and semi- and nonparametric models/methods on the other. This offers the reader the option of concentrating exclusively on one of these nonlinear time series analysis methods. To make the book as user friendly as possible, major supporting concepts and specialized tables are appended at the end of every chapter. In addition, each chapter concludes with a set of key terms and concepts, as well as a summary of the main findings. Lastly, the book offers numerous theoretical and empirical exercises, with answers provided by the author in an extensive solutions manual.
It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.
This will help us customize your experience to showcase the most relevant content to your age group
Please select from below
Login
Not registered?
Sign up
Already registered?
Success – Your message will goes here
We'd love to hear from you!
Thank you for visiting our website. Would you like to provide feedback on how we could improve your experience?
This site does not use any third party cookies with one exception — it uses cookies from Google to deliver its services and to analyze traffic.Learn More.