Double taxation treaty

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  • Chapter 11 - International taxation. Taxes and international business decisions; differences in national corporate tax and withholding tax regimes; overlapping tax jurisdictions and double taxation; foreign tax credits; controlled foreign corporations, subpart f income, and foreign tax credit baskets; tax treaties; foreign currency translation for tax purposes; tax incentives.

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  • The U.S. newspaper industry is in the midst of a historic restructuring, buffeted by a deep recession that has battered crucial advertising revenues, long-term structural challenges as readers turn to free news and entertainment on the Internet, and heavy debt burdens weighing down some major media companies. Eight major U.S. newspaper companies filed for bankruptcy between 2008 and early 2010 (though nearly all have since emerged as reorganized companies), while hundreds of smaller papers went out of business or moved to Web-only publications.

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  • Bloom Energy’s product is proving an increasingly popular choice for data centres and in March 2012 the company launched its ‘Mission Critical Practice’, a service that aims to secure the energy supply for critical government and business IT systems. By providing highly reliable power independently of the electricity grid, fuel cell systems help to improve data security and minimise the effect of grid disruptions (for more information on this application please refer to the Special Feature on page 30).

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  • When motion capture is used on line, it is possible to create applications based on a full 3-D interaction metaphor in which the specifications of deformations or motion are given in real-time. This new concept drastically changes the way of designing animation sequences. Thalmann [1993] calls all techniques based on this new way of specifying animation VR-based animation techniques. He also calls VR devices all interactive devices allowing to communicate with virtual worlds.

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  • Suppose that you've nally made your model as simple as possible. At this point your model is probably too simple to be of much interest: it's likely just an example or a special case. But if you have made your model as simple as possible, it will now be much easier to see how to generalize it since you know what the key pieces are that make the model work. Here is where your education can be helpful. At last you can use all those techniques you learned in graduate school. Most of the time you were a student you probably stud- ied various canonical models: things...

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  • On placing before the public this account of my escape from Germany and some episodes from my life in two prison camps, I feel that I must make clear that it was only due to the fact that I had two definite supplementary objects to attain, that I succeeded in making myself launch out in the following pages. The first of these objects is to add my quota to the information before the public relating to the treatment and existence of those who, in prisons in Germany, have suffered and are suffering for their country. My second object is to try to throw a little...

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  • Given the new unusual and usual event models, both adapted from the general usual event model, the HMM topology is changed with one more state. Hence the cur- rent HMM has 2 states, one representing the usual events and one representing the first detected unusual event. The Viterbi algorithm is then used to find the best possible state sequence which could have emitted the observation sequence, according to the maximum likelihood (ML) cri- terion (Figure 2, step 3). Transition points, which define new segments, are detected using the current HMM topol- ogy and parameters.

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  • Finally, we refine the accuracy of the computed per- formance model through experimental sampling. We use statistical interpolation between computed and ex- perimental sample points in order to re-approximate the per-application performance models, thus dynamically refining the model. We experimentally show that, by us- ing this method, convergence towards near-optimal con- figurations can be achieved in mere minutes, while an exhaustive exploration of the multi-dimensional search space, representing all possible partitioning configura- tions, would take weeks, or even months.

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  • It would be tactless in a foreword to propose answers to the puzzle of bilateral investment treaties (BITs) and double taxation treaties (DTTs). Perhaps, though, it is not inappropriate to pose some questions that may whet the appetite of the reader. Although many questions about the diffusion and implications of these bilateral treaties are relevant to both BITs and DTTs, I focus on BITs, a topic on which many academic and policy discussions have centered.

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  • Our study of nearly 150 organisations iv , of which 70% had PMOs*, showed that, overall, those organisations with PMOs did not have higher project success rates, but somewhat counter- intuitively, they had lower levels of management satisfaction with the level of project performance and value delivered.

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  • Take for example an investment contract with an annuitisation option where the annuity factor is the same as new annuities offered by the insurer at the time the option is executed. Since the insurer is free to determine the annuity factor, the annuitisation is in substance the formation of a new contract, the terms of which are agreed at the date the option is exercised. The contract cannot therefore be classified as an insurance contract at inception.

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  • Audit committees of public companies and registered investment companies have direct responsibility to oversee the integrity of a company’s financial statements and to hire, compensate and oversee the external auditor. Public focus on how audit committees discharge their responsibilities, including their oversight of the external auditor, has increased significantly. Each year, audit committees should evaluate the external auditor in fulfilling their duty to make an informed recommendation to the Board whether to retain the auditor.

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  • The need for a money market arises because receipts of economic units do not coincide with their expenditures. These units can hold money balances—that is, transactions balances in the form of currency, demand deposits, or NOW accounts—to insure that planned expenditures can be maintained independently of cash receipts. Holding these balances, however, involves a cost in the form of foregone interest. To minimize this cost, economic units usually seek to hold the minimum money balances required for day-to- day transactions.

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  • The ESBG is of the opinion that, in general, the universal banking model coped much better with the financial crisis than the separate banking system. We would like also to stress the relevance of the retail and savings banks model for the provision of lending to the economic activity in Europe. We consider that those institutions and business models that have proved long-term to be involved in the provision of banking services to the economic activity should be treated in a more favourable way.

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  • The importance of human-animal bonds has been documented throughout history, across cultures, and in recent research. However, attachments with companion animals have been undervalued and even pathologized in the field of mental health. This article briefly surveys the evolution of human-animal bonds, reviews research on their health and mental health benefits, and examines their profound relational significance across the life course.

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  • The birth of  the  interne  takes place  in 1969 when  Advanced  Research  Projects  Agency  Network  (ARPANet)  is  commissioned  by  the  department  of  defense (DOD) for research in networking.     The ARPANET is a success from the very beginning.  Although  originally  designed  to  allow  scientists  to  share  data  and  access  remote  computers,  e‐mail  quickly becomes the most popular application. The  ARPANET becomes a high‐speed digital post office  as people use it to collaborate on research projects  and  discuss  topics  of  various  interests.

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  • Sperm cells are highly specialized cells that are able to move. Each sperm cell must be able to deliver a haploid set of chromosomes from the male to an egg cell in the female reproductive tract. The structure of a mature sperm cell is well adapted to its function. Almost the entire head of the sperm is the haploid nucleus, the all-important genetic information that is delivered to the egg. Attached to the head of the sperm is a long tail that propels the sperm along.

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  • The UK Programme Board identified five key workstre each of which were led by one of the four countries and which are outlined on Page 14 (Box 1). A full list members of each of the workstreams and national steering groups is given at Appendix 2 and we acknowledge the tremendous commitment shown by members and chairs. Underpinning the work of the workstreams were the principles of user involvement, professional education, leadership, and the provision of safe, emotionally satisfying, effective and evidence-based maternity care to meet user needs.

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  • In the United States, women who are HIV positive and are aware of that fact are advised not to breast-feed their infants. Chemicals present in breast milk act together, with time and cold temperatures, to destroy the HIV present in expressed breast milk. The risk to childcare providers who feed children bottles of expressed breast milk is extremely low because the risk of transmission from skin/mucous membrane exposures to HIV is extremely low (probably much lower than...

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  • The second area of related work is feature modeling and design assembly. The two projects described here are reminiscent of the feature-based modeling and design for assembly or design for manufacturability research prevalent in the late 1980s and 1990s in the AI and Design community (Dixon et al., 1987, Shah, 1991, Shah and Mantyla, 1996). Jung and Nousch (2000) describe a system for designing and fabrication of furniture using computer graphics modeling.

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