The List Is Not Exhaustive

"Taxes Covered"

"The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.

Technology Strategy Patterns

Technologists who want their ideas heard, understood, and funded are often told to speak the language of businessâ??without really knowing what that is. This bookâ??s toolkit provides architects, product managers, technology managers, and executives with a shared languageâ??in the form of repeatable, practical patterns and templatesâ??to produce great technology strategies. Author Eben Hewitt developed 39 patterns over the course of a decade in his work as CTO, CIO, and chief architect for several global tech companies. With these proven tools, you can define, create, elaborate, refine, and communicate your architecture goals, plans, and approach in a way that executives can readily understand, approve, and execute. This book covers: Architecture and strategy: Adopt a strategic architectural mindset to make a meaningful material impact Creating your strategy: Define the components of your technology strategy using proven patterns Communicating the strategy: Convey your technology strategy in a compelling way to a variety of audiences Bringing it all together: Employ patterns individually or in clusters for specific problems; use the complete framework for a comprehensive strategy

Journal of the Royal Asiatic Society of Great Britain and Ireland