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Vulnerable Transactions in Corporate Insolvency
by John Armour Howard BennettThis book examines powers and remedies available to a liquidator or administrator that render 'vulnerable' the company's prior contractual commitments or proprietary dispositions so as to enhance the asset pool available to creditors. In the process,the book does two things. First, it offers comprehensive accounts of the relevant causes of action: undervalue transactions, preferences, late floating charges, unregistered charges, transactions defrauding creditors, gratuitous corporate transactions and post-petition dispositions in liquidation. Secondly, it seeks to raise issues about the context and purpose of these causes of action, many of which have not yet been fully explored in the case law or academic literature. These are considered through a discussion of their relationship to the pari passu principle; a restitutionary analysis of the remedial provisions; and issues arising specifically in cross-border and international insolvency proceedings. The book is thus a source of reference both for insolvency litigators and for transactional lawyers seeking advice on potential vulnerability. The thematic approach and rigorous analysis will also make it of interest to an academic readership.
After Enron: Improving Corporate Law and Modernising Securities Regulation in Europe and the US
by John Armour Joseph A McCaheryAt the end of the twentieth century it was thought by many that the Anglo-American system of corporate governance was performing effectively and some observers claimed to see an international trend towards convergence around this model. There can be no denying that the recent corporate governance crisis in the US has caused many to question their faith in this view. This collection of essays provides a comprehensive attempt to answer the following questions: firstly, what went wrong - when and why do markets misprice the value of firms, and what was wrong with the incentives set by Enron? Secondly, what has been done in response, and how well will it work - including essays on the Sarbanes-Oxley Act in the US, UK company law reform and European company law and auditor liability reform, along with a consideration of corporate governance reforms in historical perspective. Three approaches emerge. The first two share the premise that the system is fundamentally sound, but part ways over whether a regulatory response is required. The third view, in contrast, argues that the various scandals demonstrate fundamental weaknesses in the Anglo-American system itself, which cannot hope to be repaired by the sort of reforms that have taken place. "This collection of papers by leading US and European corporate law scholars provides fresh and rigorous analyses of the recent corporate governance scandals and the strategies devised by regulators to guard against future governance failures."Randall Thomas, John Beasley Professor of Law and Business, Vanderbilt University School of Law, Vanderbilt University.
Nursing Ethics: A Virtue-Based Approach
by A. ArmstrongThis book proposes a 'strong' (action-guiding) account of a virtue-based approach to moral decision-making within contemporary nursing practice. Merits and criticisms of obligation and virtue-based approaches to morality are explored. The author argues that in order to deliver morally good care, it is necessary to examine one's moral character.
Routledge Handbook Of International Law
by David ArmstrongThe Routledge Handbook of International Law provides a definitive global survey of the interaction of international politics and international law. Each chapter is written by a leading expert and provides a state of the art overview of the most significant areas within the field. This highly topical collection of specially commissioned papers from both established authorities and rising stars is split into four key sections: The Nature of International Law including the interaction between the disciplines of International Law and International Relations The Evolution of International Law progressing from the ancient world to present day. Law and Power in International Society discussing topical issues such as the war in Iraq and the international criminal court Key Issues in International Law including international refugee law, indigenous rights, intellectual property, trade and the challenges presented by "new terrorism". A comprehensive survey of the state of the discipline, The Routledge Handbook of International Law is an essential work of reference for scholars and practitioners of international Law.
Routledge Handbook Of International Law
by David ArmstrongThe Routledge Handbook of International Law provides a definitive global survey of the interaction of international politics and international law. Each chapter is written by a leading expert and provides a state of the art overview of the most significant areas within the field. This highly topical collection of specially commissioned papers from both established authorities and rising stars is split into four key sections: The Nature of International Law including the interaction between the disciplines of International Law and International Relations The Evolution of International Law progressing from the ancient world to present day. Law and Power in International Society discussing topical issues such as the war in Iraq and the international criminal court Key Issues in International Law including international refugee law, indigenous rights, intellectual property, trade and the challenges presented by "new terrorism". A comprehensive survey of the state of the discipline, The Routledge Handbook of International Law is an essential work of reference for scholars and practitioners of international Law.
International Law And International Relations (PDF)
by David Armstrong Theo Farrell Hélène LambertIn this fully updated and revised edition, the authors explore the evolution, nature and function of international law in world politics and situate international law in its historical and political context. They propose three interdisciplinary 'lenses' (realist, liberal and constructivist) through which to view the role of international law in world politics and suggest that the concept of an international society provides the overall context within which international legal developments occur. These theoretical perspectives offer different ways of looking at international law in terms of what it is, how it works and how it changes. Topics covered include the use of force, international crimes, human rights, international trade and the environment. The new edition also contains more material on non-western perspectives, international institutions and non-state actors and a new bibliography. Each chapter features discussion questions and guides to further reading.
Crime and the Justice System in America: An Encyclopedia (Non-ser.)
by Gordon M. Armstrong Frank SchmallegerAn inter-disciplinary survey of crime and violence in America with historical perspective, but primary entry emphasis focused on the 20th century. Addressing specifically the period from 1960 to the present, this reference also projects into the 21st century with contemporary terminology covering aspects of violent crime, DNA evidence, terrorism, riots, gangs, guns and gun control, AIDS, drug and drug related crime, and corporate and political crime. A Bibliographic Essay, Table of Cases, and Index enrich this work designed for students, scholars, and professionals in criminal justice and related fields.
The Lost Art of Scripture: Rescuing The Sacred Texts
by Karen Armstrong'KAREN ARMSTRONG IS A GENIUS' A.N. Wilson'One of our best living writers on religion' Financial Times'Karen Armstrong is one of the handful of wise and supremely intelligent commentators on religion' Alain De BottonIn our increasingly secular world, holy texts are at best seen as irrelevant, and at worst as an excuse to incite violence, hatred and division. So what value, if any, can scripture hold for us today? And if our world no longer seems compatible with scripture, is it perhaps because its original purpose has become lost?Today we see the Quran being used by some to justify war and terrorism, the Torah to deny Palestinians the right to live in the Land of Israel, and the Bible to condemn homosexuality and contraception. The holy texts at the centre of all religious traditions are often employed selectively to underwrite arbitrary and subjective views. They are believed to be divinely ordained; they are claimed to contain eternal truths.But as Karen Armstrong, a world authority on religious affairs, shows in this fascinating journey through millennia of history, this narrow reading of scripture is a relatively recent phenomenon. For hundreds of years these texts were instead viewed as spiritual tools: scripture was a means for the individual to connect with the divine, to transcend their physical existence, and to experience a higher level of consciousness. Holy texts were seen as fluid and adaptable, rather than a set of binding archaic rules or a ‘truth’ that has to be ‘believed’.Armstrong argues that only by rediscovering an open engagement with their holy texts will the world’s religions be able to curtail arrogance, intolerance and violence. And if scripture is used to engage with the world in more meaningful and compassionate ways, we will find that it still has a great deal to teach us.
Life After Life: A Guildford Four Memoir
by Paddy Armstrong Mary-Elaine TynanPaddy Armstrong was one of four people falsely convicted of The Guildford Bombing in 1975. He spent fifteen years in prison for a crime he did not commit.Today, as a husband and father, life is wonderfully ordinary, but the memory of his ordeal lives on. Here, for the first time and with unflinching candour, he lays bare the experiences of those years and their aftermath.Life after Life is a testament to the resilience of the human spirit and the power of forgiveness. It reminds us of the privilege of freedom, and how the balm of love, family and everyday life can restore us and mend the scars of even the most savage injustice.'This book captures the sweet soul of Paddy. Beautifully written. For lovers of freedom everywhere.' Jim Sheridan
Kostendruck und Standard: Zu den Auswirkungen finanzieller Zwänge auf den Standard sozialversicherungsrechtlicher Leistungen und den haftungsrechtlichen Behandlungsstandard (Kölner Schriften zum Medizinrecht #5)
by Johannes ArnadeDas Gesundheitswesen leidet an Ressourcenknappheit, die Diskrepanz zwischen dem medizinisch Machbaren und dem tatsächlich Finanzierbaren wächst. Der Band behandelt zwei der zentralen rechtlichen Problemfelder, die sich daraus ergeben: die Möglichkeiten der Rationierung medizinischer Leistungen sowie die Konfliktlinien zwischen Arzthaftungs- und Sozialversicherungsrecht. Ziel der Studie ist es, einen verfassungskonformen Ansatz für die Zuteilung knapper Ressourcen zu entwickeln und eine Harmonisierung der verschiedenen Teildisziplinen zu erreichen.
Collection of ICC Arbitral Awards 2012 – 2015
by Jean-Jacques Arnaldez Yves Derains Dominique HascherThe Collection of ICC Arbitral Awards 2012-2015 contains extracts of cases handled by the ICC Court of Arbitration, one of the world's most respected arbitral institutions. This most recent collection supplements six previous and successful volumes containing awards from the periods 1974-1985, 1986-1990, 1991-1995, 1996-2000, 2001-2007 and 2008-2011. This collection is a practical reference tool, containing three types of useful indexes incorporating information from all three volumes: – a consolidated analytical table, in both English and French, contains extensive cross-references based on the terminology used in awards and case notes; – a chronological index lists the awards; – a key word index, also provided in both languages, allows the reader to locate the material of interest quickly and easily. In addition to providing a wealth of information in a highly accessible manner, this book includes case notes end expert commentaries on the awards. This publication is an indispensable reference work for anyone interested in international arbitration and in the reasoning of international arbitrators on the interpretation and application of contractual clauses, international conventions, and the law of international trade. It is invaluable to both scholars and practitioners involved in the drafting and negotiation of international commercial contracts and the resolution of international commercial disputes.
Collection of ICC Arbitral Awards 2016-2020 (Collection of ICC Arbitral Awards #8)
by Jean-Jacques Arnaldez Yves Derains Dominique T. Hascher<span style="font-size:12.0pt;font-family: "Times New Roman",serif;mso-fareast-font-family:"Times New Roman";color:black; mso-fareast-language:EN-IN">The<span style="font-size:12.0pt;font-family: "Times New Roman",serif;mso-fareast-font-family:"Times New Roman";color:black; mso-fareast-language:EN-IN"> Collection of ICC Arbitral Awards 2016¿2020<span style="font-size:12.0pt;font-family: "Times New Roman",serif;mso-fareast-font-family:"Times New Roman";color:black; mso-fareast-language:EN-IN"> contains extracts of cases handled by the ICC Court of Arbitration, one of the world’s most respected arbitral institutions. This most recent collection supplements seven previous and successful volumes containing awards from the period 1974 to 2015. This collection is a practical reference tool, containing three types of useful indexes incorporating information from all three volumes: <p style="margin-bottom:0in;margin-bottom:.0001pt;line-height: normal;background:white" class="MsoNormal"> <p style="margin-top:0in;margin-right:0in;margin-bottom:0in; margin-left:.25in;margin-bottom:.0001pt;line-height:normal;background:white" class="MsoNormal"><span style="font-size:12.0pt;font-family:"Times New Roman",serif;mso-fareast-font-family: "Times New Roman";color:black;mso-fareast-language:EN-IN">a consolidated analytical table, in both English and French, contains extensive cross-references based on the terminology used in awards and case notes; <p style="margin-top:0in;margin-right:0in;margin-bottom:0in; margin-left:.25in;margin-bottom:.0001pt;line-height:normal;background:white" class="MsoNormal"><span style="font-size:12.0pt;font-family:"Times New Roman",serif;mso-fareast-font-family: "Times New Roman";color:black;mso-fareast-language:EN-IN">a chronological index lists the awards; <p style="margin-top:0in;margin-right:0in;margin-bottom:0in; margin-left:.25in;margin-bottom:.0001pt;line-height:normal;background:white" class="MsoNormal"><span style="font-size:12.0pt;font-family:"Times New Roman",serif;mso-fareast-font-family: "Times New Roman";color:black;mso-fareast-language:EN-IN">a keyword index, also provided in both languages, allows the reader to locate the material of interest quickly and easily. <p style="margin-bottom:0in;margin-bottom:.0001pt;line-height: normal;background:white" class="MsoNormal"><span style="font-size:12.0pt;font-family: "Times New Roman",serif;mso-fareast-font-family:"Times New Roman";color:black; mso-fareast-language:EN-IN"> In addition to providing a wealth of information in a highly accessible manner, this book includes case notes end expert commentaries on the awards. This publication is an indispensable reference work for anyone interested in international arbitration and in the reasoning of international arbitrators on the interpretation and application of contractual clauses, international conventions, and the law of international trade. It is invaluable to both scholars and practitioners involved in the drafting and negotiation of international commercial contracts and the resolution of international commercial disputes.
Responsibility in Science and Technology: Elements of a Social Theory (Technikzukünfte, Wissenschaft und Gesellschaft / Futures of Technology, Science and Society)
by Simone Arnaldi Luca BianchiThe present volume elucidates the scope of responsibility in science and technology governance by way of assimilating insights gleaned from sociological theory and STS and by investigating the ways in which responsibility unfolds in social processes. Drawing on these theoretical perspectives, the volume goes on to review a ‘heuristic model’ of responsibility. Such a model provides a simple, tentative, though no less coherent analytical framework for further examining the idea of responsibility, its transformations, configurations and contradictions.
Responsibility in Nanotechnology Development (The International Library of Ethics, Law and Technology #13)
by Simone Arnaldi Arianna Ferrari Paolo Magaudda Francesca MarinThis book disentangles the complex meanings of responsibility in nanotechnology development by focusing on its theoretical and empirical dimensions. The notion of responsibility is extremely diversified in the public discourse of nanoscale technologies. Addressed are major disciplinary perspectives working on nanotechnology, e.g. philosophy, sociology, and political science, as well as the major multidisciplinary areas relevant to the innovation process, e.g. technology assessment and ethics. Furthermore, the interplay between such expertises, disciplines, and research programmes in providing a multidisciplinary understanding of responsibility is emphasized.
Governance and Risk Management in Taxation (Accounting, Finance, Sustainability, Governance & Fraud: Theory and Application)
by Arnaldo Marques de Oliveira NetoThis book provides insights into identifying and dealing with possible corporate tax risks. It also elaborates on how enterprises can avoid possible issuance of notices of violation, fines and default interest, and ensure reduced tax responsibility of enterprises and their administrators when dealing with tax issues, thereby bringing about increased efficiency and productivity.Conducted in collaboration with the Brazilian Enterprises Group of Advertising and Publicity Services, it also includes managerial information resources and procedures for tax risks that enterprises may encounter. Additionally, it presents findings that allow the academic community and enterprises (not only advertising and publicity services) alike to benefit from the results derived from the Model of Corporate Risk Management (GRCorp) and the Specific Model of Tax Risk Management (GRTrib) frameworks developed by the author. The book serves as a valuable resource for academic researchers and practitioners in businesses.
Shifting Centres of Gravity in Human Rights Protection: Rethinking Relations between the ECHR, EU, and National Legal Orders (Routledge Research in Human Rights Law)
by Oddný Mjöll Arnardóttir Antoine BuyseThis book brings together researchers from the fields of international human rights law, EU law and constitutional law to reflect on the tug-of-war over the positioning of the centre of gravity of human rights protection in Europe. It addresses both the position of the Convention system vis-à-vis the Contracting States, and its positioning with respect to fundamental rights protection in the European Union. The first part of the book focuses on interactions in this triangle from an institutional and constitutional point of view and reflects on how the key actors are trying to define their relationship with one another in a never-ending process. Having thus set the scene, the second part takes a critical look at the tools that have been developed at European level for navigating these complex relationships, in order to identify whether they are capable of responding effectively to the complexities of emerging realities in the triangular relationship between the EHCR, EU law and national law. Chapter 10 of this book is freely available as a downloadable Open Access PDF under a Creative Commons Attribution-Non Commercial-No Derivatives 3.0 license. https://s3-us-west-2.amazonaws.com/tandfbis/rt-files/docs/Open+Access+Chapters/9781138121249_oachapter10.pdf
Securing Private Communications: Protecting Private Communications Security in EU Law – Fundamental Rights, Functional Value Chains, and Market Incentives (Information Law Series Set)
by Axel M. ArnbakIt has become glaringly clear that any communicative act online is subject to breach by intelligence agencies, cybercriminals, advertising networks, employers, and corporate data miners, to mention the most obvious intruders. Internet users, seeing no other choice than to hop onto the web-based bandwagon, have come to depend on a networked communications environment that is fundamentally insecure. Now lawmakers worldwide are gearing up to intervene. Arguing for a stricter stance on protecting private communications security, this groundbreaking study offers a conceptual and legislative toolkit leading to a step-by-step regulatory model in EU law. The proposed model is tested in two detailed case studies on HTTPS and cloud communications. From the interlocking perspectives of fundamental rights, systems design, and political organization, the regulatory model proposed is tested on HTTPS, which covers the user-provider relationship in web browsing, and on "cloud" communications that affect interdomain and intradomain communications. The case studies are based on the infamous DigiNotar breach and the MUSCULAR programme disclosed by whistle-blower Edward Snowden and contain original legal, security economics, and computer science research, conducted jointly with scholars trained in these disciplines. Responding to a general positive human right to communications security that is emerging from European fundamental rights law, this book not only provides one of the first interdisciplinary studies to appear in the academic literature on EU communications security law, but also offers broad recommendations to the EU lawmaker and gives directions for future research. It is sure to become a first point of discussion, reference, and legislative action for policymakers and practitioners in Europe and beyond.
Metals and Society: An Introduction to Economic Geology (Springer Geochemistry/Mineralogy #2)
by Nicholas Arndt Clément GaninoIn the second edition Steve Kesler (University of Michigan) has been added as an author to rewrite some chapters. The motivation for this revised edition is to more intensively address economic issues that surround the exploitation of mineral resources. This emphasis gives the book a unique character. With these sections Metals and Society deals with issues that pervade much of current science reporting – the rate of exploitation of natural resources, the question of when or if these resources will be exhausted, the pollution and social disturbance that accompanies mining, the compromises and challenges that arise from the explosion of demand from China, India and other rapidly developing countries, and the moral issues that surround mining of metals in lesser developed countries for consumption in the “first-world” countries. With its dual character, the book will be useful as an introductory text for students in the earth sciences and a reference volume for students, teachers and researchers of geography, economics and the social sciences.
Sexual Justice / Cultural Justice: Critical Perspectives In Political Theory And Practice (PDF)
by Barbara Arneil Monique Deveaux Rita Dhamoon Avigail EisenbergThis key volume explores the relationship between cultural justice and sexual justice in multicultural societies in a new light. The authors challenge the framing of ‘feminism and multiculturalism’ as one of inevitable conflict, as well as the portrayal of liberal sexual equality and cultural rights as irreconcilable, moving the debate beyond the culture/gender impasse. Sexual Justice / Cultural Justice will be of strong interest to students and researchers working in the areas of gender and feminist theory, politics, law, philosophy and sociology.
Sexual Justice / Cultural Justice: Critical Perspectives In Political Theory And Practice
by Barbara Arneil Monique Deveaux Rita Dhamoon Avigail EisenbergThis key volume explores the relationship between cultural justice and sexual justice in multicultural societies in a new light. The authors challenge the framing of ‘feminism and multiculturalism’ as one of inevitable conflict, as well as the portrayal of liberal sexual equality and cultural rights as irreconcilable, moving the debate beyond the culture/gender impasse. Focusing on three theoretical themes from a feminist perspective: the meaning and role of culture and identity in politics the problem of autonomy in relation to culture and identity the crucial role of democracy in addressing the theoretical and practical problems raised by this set of issues. The diverse contributors break new theoretical ground by providing detailed engagement with the concrete experiences of women and minorities who are caught in the dilemmas of gender and cultural justice. The collected chapters address sexual/cultural justice in a range of different countries, offering illuminating case studies on Britain, South Africa, Canada, the Netherlands, Australia, Mexico, and the United States. Sexual Justice / Cultural Justice will be of strong interest to students and researchers working in the areas of gender and feminist theory, politics, law, philosophy and sociology.
Financial Markets in Hong Kong (Oxford Legal Research Library Online)
by Douglas W Arner Berry Hsu Say H Goo Syren Johnstone Paul LejotSince the publication of the first edition in 2006, financial regulation around the world has changed dramatically as a result of the 2008 global financial crisis. As one of the world's leading financial centres, international regulatory reforms have had a significant impact on the legal and regulatory system in Hong Kong. This new second edition provides a comprehensive and authoritative single-volume guide to the main areas of financial regulation and financial law in Hong Kong. Given the massive changes in financial regulation globally and in Hong Kong, the second edition has been substantially rewritten and revised to address changes in markets and their legal and regulatory frameworks, as well as the implications of these changes to future market development. The book is in five parts: The first part considers the evolution of Hong Kong's role as a financial centre and the development of its financial regulatory structure, one that is perhaps unusually complex given the size of the jurisdiction. The second part discusses the regulation of the banking, securities, insurance sectors, including the regulatory powers of the Hong Kong Monetary Authority (HKMA), the Securities and Futures Commission of Hong Kong (SFC), the Office of the Commissioner of Insurance (OCI), and the forthcoming Independent Insurance Authority (IIA). The third part covers regulation of financial products and services, including securities offerings and listings, investment products and asset management, financial derivatives, and takeovers and mergers. The fourth part addresses market conduct and misconduct, including corporate governance, market abuse and financial crime. Finally, the fifth part examines the international context, focusing on the relationship between Hong Kong's financial markets and regulation and mainland China as well as key issues for Hong Kong's role as a major global financial centre.
U.S. Constitution For Dummies: 2nd Edition
by Michael ArnheimAn in-depth look at the defining document of America Want to make sense of the U.S. Constitution? This plain-English guide walks you through this revered document, explaining how the articles and amendments came to be and how they have guided legislators, judges, and presidents and sparked ongoing debates. You'll understand all the big issues — from separation of church and state to impeachment to civil rights — that continue to affect Americans' daily lives. Get started with Constitution basics — explore the main concepts and their origins, the different approaches to interpretation, and how the document has changed over the past 200+ years Know who has the power — see how the public, the President, Congress, and the Supreme Court share in the ruling of America Balance the branches of government — discover what it means to be Commander in Chief, the functions of the House and Senate, and how Supreme Court justices are appointed Break down the Bill of Rights — from freedom of religion to the prohibition of "cruel and unusual punishments," understand what the first ten amendments mean Make sense of the modifications — see how amendments have reformed presidential elections, abolished slavery, given voting rights to women, and more Open the book and find: The text of the Constitution and its ammendments Discussion of controversial issues including the death penalty, abortion, and gay marriage Why the word "democracy" doesn't appear in the Constitution What the Electoral College is and how it elects a President Details on recent Supreme Court decisions The Founding Fathers' intentions for balancing power in Washington
U.S. Constitution For Dummies
by Michael ArnheimAn in-depth look at the defining document of America Want to make sense of the U.S. Constitution? This plain-English guide walks you through this revered document, explaining how the articles and amendments came to be and how they have guided legislators, judges, and presidents and sparked ongoing debates. You'll understand all the big issues — from separation of church and state to impeachment to civil rights — that continue to affect Americans' daily lives. Get started with Constitution basics — explore the main concepts and their origins, the different approaches to interpretation, and how the document has changed over the past 200+ years Know who has the power — see how the public, the President, Congress, and the Supreme Court share in the ruling of America Balance the branches of government — discover what it means to be Commander in Chief, the functions of the House and Senate, and how Supreme Court justices are appointed Break down the Bill of Rights — from freedom of religion to the prohibition of "cruel and unusual punishments," understand what the first ten amendments mean Make sense of the modifications — see how amendments have reformed presidential elections, abolished slavery, given voting rights to women, and more Open the book and find: The text of the Constitution and its ammendments Discussion of controversial issues including the death penalty, abortion, and gay marriage Why the word "democracy" doesn't appear in the Constitution What the Electoral College is and how it elects a President Details on recent Supreme Court decisions The Founding Fathers' intentions for balancing power in Washington
International Tax Primer
by Brian J. ArnoldInternational Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. This third edition has been expanded substantially, due to the major developments that have occurred since the second edition of this indispensable resource appeared in 2004 – not least the fact that innumerable smalland medium-sized firms, as well as individuals, now engage in cross-border transactions that cause them and their tax advisers to confront international tax issues on a regular basis. Moreover, as the countries of the world have become increasingly integrated economically, the importance of the major issues that a country must confront in designing its international tax rules and in coordinating those rules with the tax systems of its trading partners has mushroomed. The book strikes a balance between the specific and the general by illustrating the funda mental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of non-residents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN • Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. New material in the third edition includes analysis of the OECD’s initiative against base erosion and profit shifting (BEPS), tax aspects of hybrid entities and financial instruments, and taxation of fees for technical services as proposed under the UN Model Treaty. Although of greatest value to tax practitioners and government officials confronting interna tional tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
International Tax Primer
by Brian J. ArnoldTax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.