The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
This is the first monograph dedicated to the site of Socoh in the Judean Shephelah. Our research was initiated in 2010 as an intensive survey by the Institute of Archaeology, Southern Adventist University, and the Institute of Archaeology, The Hebrew University of Jerusalem. The study incorporates historical sources that are listed and analyzed, including the Bible, ancient Near Eastern, Byzantine, and Medieval records. A history of the research conducted over the past 190 years by explorers, geographers, and archaeologists is compiled, before providing the full report on the results of an intensive site survey conducted at Socoh in 2010. Finally, specialized studies of the finds and a report of recent salvage excavations of burial caves, looted by antiquity robbers nearby, give a state-of-the-art presentation of the latest information known about this important biblical site in southern Judah.
WTO Law and Direct Taxation are linked in numerous ways. The WTO Agreements, thereof especially the GATT and GATS Agreements, contain several explicit provisions on the subject of direct taxes or even on its delimitation from Tax Treaty Law. To some extent, the scope of application of WTO Law has been broadened by case law to comprise also direct taxes. This entails overlappings particularly with regard to the law of subsidies, prohibitions of discrimination, and most-favoured-nation obligations. This book highlights increasingly relevant interdependencies between WTO Law and Direct Taxation from the viewpoint of 21 States. Special emphasis is placed on the conformity of national taxes on profits with WTO Law as well as on specifics of interpretation in several Member States. 21 National Reports from nearly all EU countries as well as Colombia, Israel, New Zealand, Norway and the USA dealt with this topic and were compiled and published in this volume. Additionally, a General Report prepared by Servatius van Thiel summarises the results of the National Reports. Moreover, experts in this field joining the Conference among them Reuven Avi-Yonah, Michael Lennard and Raymond Luja have volunteered contributions dealing with specific problems of WTO and Direct Taxation.
The results of recent archaeological excavation, systematic rural survey and detailed studies of pottery distributions have revealed the extent and complexities of the economy in the eastern empire. The eight papers in this volume demonstrate this complexity and prosperity, examining several types of product and how the economy evolved over time. Contents: New Rome, new theories on Inter-regional exchange: East Mediterranean economy in Late Antiquity ( Sean Kingsley and Michael Decker ); Urban Economies of Late Antique Cyrenaica ( Andrew Wilson ); The economic impact of the Palestinian wine trade in Late Antiquity ( Sean Kingsley ); Food for an empire: wine and oil production in North Syria ( Michael Decker ); Beyond the amphora: non-ceramic evidence for Late Antique industry and trade ( Marlia Mundell Mango ); The economy of Late Antique Cyprus ( Tassos Papacostas ); LR2: a container for the military annona on the Danubian border? ( Olga Karagiorgou ); Specialization, trade and prosperity: an overview of the economy of the Late Antique Eastern Mediterranean ( Bryan Ward-Perkins ).
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
The Alien Tort Statute (also referred to as the Alien Tort Claims Act) is a US statute that provides a cause of action for violations of international law. While originally used against former dictators and military officials who fled to the U.S. after the respective governments in their home countries have been removed, human rights activists are now targeting transnational corporations or multinational enterprises for human rights violations in connection with their investments made outside the United States. This book examines and analyzes corporate liability under the Alien Tort Statute.
The Taxation of Trusts in South Africa is the first book to exclusively cover the direct and indirect taxation of trusts in South Africa, including a look at the application of the exchange control regulations to both onshore and offshore trusts.
Proposes a reconstruction of the Temple, which differs from conventional descriptions in Jewish literary sources during the First and Second Temple eras. This book examines the individual descriptions of the Temple and considers the influence of the descriptions on subsequent ones.
This paper assesses the landmark Tax Cuts and Jobs Act (TCJA), from the perspective of both the U.S. itself and the wider world. The reform has many positive aspects including steps to broaden the base of, and reduce marginal rates under, the personal income tax (PIT), reduce distortions to investment and financing decisions, and mitigate outward profit shifting. But the TCJA has a large fiscal price tag and leaves significant uncertainty as to how the U.S. tax system will develop. The PIT changes could have better targeted relief at low earners, and there is scope to more fully address distortions in business taxation. The novel international provisions create a complex array of both positive and negative international spillovers, and have the potential to significantly reshape the wider international tax system.
These volumes comprise a collection of papers by Michael E. Stone, written over a period of 35 years. Stone is a leading scholar in two different fields of research, the Jewish literature of the Second Temple period including the Dead Sea Scrolls, and Armenian Studies. So this collection includes essays relating to the origins and nature of the Apocryphal literature and its relationship with the Dead Sea Scrolls, as well as more specific studies devoted to themes that have interested Stone throughout his career, including Messianism, 4 Ezra, Adam and Eve, and Aramaic Levi Document. His Armenian interests have embraced the Armenian Biblical text, Armenian pilgrimage to and presence in the Holy Land and Armenian paleography and epigraphy. Papers included in the volumes, some of which were originally published in obscure venues, touch on all these themes. A number of previously unpublished papers are included.
The World and the Word is a fresh introduction to the Old Testament driven largely by the fact that so much Christian preaching and teaching today increasingly ignores what is eighty percent of the Bible. Authors Eugene Merrill, Mark Rooker, and Michael Grisanti work through the world and text of the Old Testament always making three major points: • The Old Testament is a rich source of theology and doctrine that is presupposed by the New Testament. Without it, Christian theology would be seriously deficient. • Mastery of the Old Testament is crucial to an understanding of the New Testament. • The Old Testament offers, by teaching and example, practical principles of belief and behavior for contemporary times. Who God was and what He did then can be replicated in the lives of men and women today. Separating the verifiable biblical and extra-biblical data from the various interpretations of that same information, the book further shows how the Old Testament forms the platform and matrix from which sprang the life, ministry, and teachings of Jesus and the church. The World and the Word will help students see an entry point into the very heart and design of God who loves them and wishes to make them the special object of His grace.
The purpose of this book is to help postmodern Westerners understand what the Bible has to say about wealth and possessions, its acquisition and protection, deprivation and slavery, corruption and hedonism, and even relations between management and labor. Focusing on Torah (the Pentateuch), it interprets this "great text" against other "great texts" in its literary-historical environment, including some epic poems from Mesopotamia, some Jewish texts from Syro-Palestine, and some Nazarene parables from the Greek New Testament.
This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.
In this thoroughly revised and updated second edition, Mariana Mota Prado and Michael J. Trebilcock offer a succinct and readable introduction to the main concepts and debates in the field of law and development. They examine the role of legal systems and institutions, investigate perceptions around what laws and legal arrangements encourage and facilitate development, and probe the issues arising in both private law and public law as well as in international economic relations. Written with the insight of two top experts in the field, this Advanced Introduction covers the most recent trends in law and development research and highlights areas that remain underexplored.
The authors of this commentary take a canonical-historical approach to the books of Joshua, Judges, and Ruth, three books that are diverse, yet share the common historical context of the tribal settlement of Canaan. They examine Joshua, Judges, and Ruth as narratives with dynamic theological messages about the dynamic relationship between God's people and the powerful God who gives land and provides deliverers for the people.
This book shows how, in unearthing biblical cities, archaeology transformed nineteenth-century thinking on the truth of Christianity and its role in modern cities.
Provides a short, accessible, and lively introduction to Jerusalem Jerusalem - A Brief History shows how Jewish, Christian, and Islamic scriptures confer providential meaning to the fate of the city and how modern Jerusalem is haunted by waves of biblical fantasy aiming at mutually exclusive status-quo rectification. It presents the major epochs of the history of Jerusalem’s urban transformation, inviting readers to imagine Jerusalem as a city that is not just sacred to the many groups of people who hold it dear, but as a united, unharmed place that is, in this sense, holy. Jerusalem - A Brief History starts in modern Jerusalem—giving readers a look at the city as it exists today. It goes on to tell of its emergence as a holy city in three different ways, focusing each time on another aspect of the biblical past. Next, it discusses the transformation of Jerusalem from a formerly Jewish temple city, condemned to oblivion by its Roman destroyers, into an imperially sponsored Christian theme park, and the afterlife of that same city under later Byzantine and Muslim rulers. Lastly, the book returns to present day Jerusalem to examine the development of the modern city under the Ottomans and the British, the history of division and reunification, and the ongoing jostling over access to, and sovereignty over, Jerusalem’s contested holy places. Offers a unique integration of approaches, including urban history, the rhetoric of power, the history of art and architecture, biblical hermeneutics, and modern Middle Eastern Studies Places great emphasis on how Jerusalem is a real city where different people live and coexist Examines the urban transformation that has taken place since late Ottoman times Utilizes numerous line drawings to demonstrate how its monumental buildings, created to illustrate an alliance of divine and human power, are in fact quite ephemeral, transient, and fragile Jerusalem - A Brief History is a comprehensive and thoughtful introduction to the Holy City that will appeal to any student of religion and/or history.
This comprehensive exploration of language and literacy in the multi-lingual environment of Roman Palestine (c. 63 B.C.E. to 136 C.E.) is based on Michael Wise's extensive study of 145 Hebrew, Aramaic, Greek, and Nabataean contracts and letters preserved among the Bar Kokhba texts, a valuable cache of ancient Middle Eastern artifacts. His investigation of Judean documentary and epistolary culture derives for the first time numerical data concerning literacy rates, language choices, and writing fluency during the two-century span between Pompey's conquest and Hadrian's rule. He explores questions of who could read in these ancient times of Jesus and Hillel, what they read, and how language worked in this complex multi-tongued milieu. Included also is an analysis of the ways these documents were written and the interplay among authors, secretaries, and scribes. Additional analysis provides readers with a detailed picture of the people, families, and lives behind the texts.
Informed by world-systems analysis, this book examines the shifting patterns of accommodation and resistance to the offshore world, with a particular focus on Mauritius as a critical but underappreciated offshore node mediating foreign investment into India and Africa. Drawing on a large pool of financial data and elite interviews, the authors present the first detailed comparative study of the Mauritius–India and Mauritius–Africa offshore relationships. These relationships serve as indicative test cases of the contemporary global tax reform agenda and its promise to rein in offshore finance. Whereas India’s economic power and multilateral track record have enabled it to actively shape this agenda and implement it in a robust manner, most African countries have found themselves either unable to meet its stringent criteria or unwilling to do so out of fear that it might discourage investment. Its impact on offshore financial centers has likewise been limited. A few of the least sophisticated ones appear to have fallen by the wayside, but the rest have either remained largely unaffected, or, like Mauritius, succeeded in consolidating their operations and surviving the current round of regulatory headwinds. The findings suggest that the contemporary global tax reform agenda has thus far not only failed to make good on its promise but also actually reinforced numerous existing power hierarchies. The Uneven Offshore World is written in an accessible style and aimed at readers without specialized knowledge of tax issues.
The financial crisis exposed unsavory results of interactions between low- and moderate-income households and alternative and mainstream financial institutions: overleveraged incomes, high cost for financial services, and lack of access to useful financial products that can cushion against economic instability. It revealed a financial services system that is not well designed to serve these households, leaving them without financial slack. Pivotal analysis, focusing on metropolitan Detroit's low- and moderate-income neighborhoods, examines household decision making processes, behaviors, and attitudes toward a full range of financial transactions during the subprime lending boom. The author advocates helping families seek financial stability in three primary ways: enhancing individuals' financial capability, using technology to promote access to financial products and services that meet their needs, and establishing strong protections for consumers.
From attacks on oil infrastructure in post-war reconstruction Iraq to the laying of gas pipelines in the Amazon Rainforest through indigenous community villages, infrastructure projects are sites of intense human rights struggles. Many state and non-state actors have proposed solutions for handling human rights problems in the context of specific infrastructure projects. Solutions have been admired for being lofty in principle; however, they have been judged wanting in practice. This book analyzes how human rights are handled in varied contexts and then assesses the feasibility of a common international institutional solution under the auspices of the United Nations to the alleged problem of the inability to translate human rights into practice.
Private sector action provides one of the most promising opportunities to reduce the risks of climate change, buying time while governments move slowly or even oppose climate mitigation. Starting with the insight that much of the resistance to climate mitigation is grounded in concern about the role of government, this books draws on law, policy, social science, and climate science to demonstrate how private initiatives are already bypassing government inaction in the US and around the globe. It makes a persuasive case that private governance can reduce global carbon emissions by a billion tons per year over the next decade. Combining an examination of the growth of private climate initiatives over the last decade, a theory of why private actors are motivated to reduce emissions, and a review of viable next steps, this book speaks to scholars, business and advocacy group managers, philanthropists, policymakers, and anyone interested in climate change.
It is, thus, an important witness to Eusebius' thinking on the Bible, the Church, and the empire at a critical moment in his life and in the history of Christianity. The present book is the first comprehensive assessment of the Commentary's methods and ideas.
Explaining the Cosmos analyses the philosophical and theological writings relating to the creation and eternity of the world of three Gazan thinkers, Aeneas, Zacharias and Procopius. It sheds light on Neoplatonic and Christian debates, and maps distinctive cultural characteristics of Gaza, including its schools and monasteries, in Late Antiquity.
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