Richard Krever Fundamental Principles Of Taxation Pdf
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Interactive Qualitative Analysis
Author: Norvell Northcutt
language: en
Publisher: SAGE Publications
Release Date: 2024-05-21
"The authors take a ′user friendly′ systematic approach to qualitative research, something that has long been missing in the field. I consider this to be a groundbreaking work, one that will hit home with students and faculty alike." —Justin M. Laird, SUNY Brockport "This book does an excellent job of integrating design, methods, and analysis. . . . The real beauty of the book is that it overturns many of the age-old assumptions about how ′good′ research should be done. . . . The authors′ pleasant and refreshing style, coupled with subtle irreverence for outmoded or constraining paradigms of inquiry, makes for highly enjoyable reading." —Roger Rennekamp, University of Kentucky Interactive Qualitative Analysis: A Systems Method for Qualitative Research aims to help students unscramble the mysteries of qualitative data collection, coding, and analysis by showing how to use a systematic, qualitative technique: interactive qualitative analysis. The authors synthesize ideas from grounded theory, path and factor analysis, quality management theory, Foucauldian concepts of power and knowledge, and systems theory. A dialectical revision of Guba and Lincoln′s theory of rigor is offered which, combined with systems theory, offers new insights into the meaning of reliability and validity in qualitative research. Unlike many theoretical works, Interactive Qualitative Analysis develops the theory into a complete and transparent set of protocols for research design, observation, analysis, and interpretation. The construction, interpretation, and comparison of recursive systems of meaning, or mindmaps, is articulated in detail. The book is organized so that those not interested in theory can skip to the applied chapters. Case studies illustrate each stage of the research process with an emphasis on interpretation. The combination of theory and practice perfectly suits the book for advanced qualitative research courses across the social sciences, especially those that address epistemology. Professional researchers and evaluators will also find this an invaluable guide to qualitative analysis. Key Features * Advice boxes alert readers to potential pitfalls in qualitative research, and offer the appropriate steps to take in order to avoid such issues * Sidebars provide clear and concise snapshots of the theoretical basis for research decisions * Interactive CD contains sample data and exercises to provide students with effective practice as well as reinforce and clarify principles explained in the book * Provides a "road map" to using interactive qualitative inquiry in dissertation writing
Legal Interpretation of Tax Law
This book deals comparatively with tax law interpretation in economies engaged in cross-border investment at a global level. Authors from eleven jurisdictions provide detailed analysis and commentary on various tax law topics and issues, such as: methods of tax law interpretation; how the judiciary is organized as regards tax law; the role, if any, of the central goverment's high court in providing precedent and guidelines for interpretation; external sources a court can consider when interpreting legislation; constitutional restrictions on interpretation of legislation; prevalence of the general anti-avoidance rule (GAAR); "transplanted" categories (an undefined term is clarified through the meaning of that same term in another law); the concept of "ordinary income"; the concept of "capital" expenses; interpretation of tax treaties; and interrelation of judicial interpretation and administrative interpretation
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option
Author: Richard Krever
language: en
Publisher: Kluwer Law International B.V.
Release Date: 2020-02-20
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246