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Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade a...
Transnational Commercial Law is a textbook that deals predominantly with substantive legal contract rules that apply across borders and are designed to govern cross-border business transactions. This is an emerging field of research, teaching and practical interest in international trade and commercial law, requiring reference to multiple areas of law, including both private and public international law, the law of specific commercial transactions and arbitration. For the first time Transnational Commercial Law combines all these relevant issues in one book, and provides a basis for further study as well as detailed, cutting edge academic analyses. It provides a compact yet accessible guide to the most important cornerstones of this evolving legal discipline. Transnational Commercial Law is aimed primarily for use on LLM courses and master's programmes in commercial law. Students are presented with the actual contractual rules in the wider context of the general legal framework, and situates it within the theoretical debate, providing a truly international perspective on transnational commercial law in a globalised world.
For nearly 30 years, this work has provided authoritative, in-depth guidance on the law of residence, including most recently the Statutory Residence Test. Since the previous 19th Edition, the proposed changes to domicile and deemed domicile legislation, due to be enacted in April 2017, were omitted from the first Finance Bill of 2017 but then re-introduced and backdated in the Finance 2017-19 Bill, published in September 2017. This edition provides detailed analysis of this legislation, with regard to the deemed domicile rules, changes to remittance basis and overseas companies with UK residential property which now come under scope of IHT. It also includes further amendments to deemed domi...
This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).
This book provides an analysis of residence, domicile and UK taxation and examines the residence and other fiscal connections for individuals, companies and trusts. It unravels the tax residence of companies and the resolution of dual residence including specialised residence rules applied to controlled foreign companies, dual resident investing companies and transfer pricing.
In honor of Sinatra's 100th birthday, Pete Hamill's classic tribute returns with a new introduction by the author. In this unique homage to an American icon, journalist and award-winning author Pete Hamill evokes the essence of Sinatra--examining his art and his legend from the inside, as only a friend of many years could do. Shaped by Prohibition, the Depression, and war, Francis Albert Sinatra became the troubadour of urban loneliness. With his songs, he enabled millions of others to tell their own stories, providing an entire generation with a sense of tradition and pride belonging distinctly to them. With a new look and a new introduction by Hamill, this is a rich and touching portrait that lingers like a beautiful song.
An uproarious, irreverent, unauthorized parody of the Christian bestseller, Heaven Is A Deal tells the story of an unscrupulous Iowa couple's bungling attempts to send a preschooler to Heaven to meet Jesus--then use the kid's memories to gain fame and fortune. The perfect antidote to fundamentalist claptrap, for believers and non-believers alike. You don't have to be rational to love this spoof...but it helps!
In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.