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International Tax Planning and Prevention of Abuse
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Visceral and Ectopic Fat
While the health consequences and mechanisms by which visceral fat causes disease are well-studied, relatively less is known about ectopic fat, its patterns of deposition and its effects on the pathoetiology of type 2 diabetes, atherosclerosis, and cardiovascular disease. Visceral and Ectopic Fat: Risk Factors for Type 2 Diabetes, Atherosclerosis, and Cardiovascular Disease covers the wealth of literature that has been amassed over the past decade on this topic. This reference brings all the research and clinical data together in one volume and helps clinicians and academic researchers understand more thoroughly the underlying mechanisms and interrelation between fat depots and ectopic fat s...
The Interface of International Trade Law and Taxation
This book explores the ill-defined and oft-underestimated relationship between the World Trade Organization (WTO) and taxation. By adopting a two-pronged approach, the relationship is examined in terms of the extent to which the WTO legal framework exerts influence upon domestic tax law and international tax policy, and whether it is appropriate for the WTO to play a regulatory role in the field of taxation. The book begins with an examination of the historical development of international trade law and international tax law, and demonstrates that these two separate areas of law are closely linked in terms of their underlying principles and historical evolution. The work then goes on to offer a doctrinal analysis of the tax content found in the WTO legal texts and highlights ambiguities therein.
Taxation of Intercompany Dividends Under Tax Treaties and EU Law
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
A Companion to Crime, Harm and Victimisation
Succinct, accessible, and comprehensive, this book is the first to provide definitions and explanations of key terms and concepts from the expanding field of crime, harm, and victimization. Contributions from a wide range of experts investigate theories, ideas, and case studies relating to victims of conventional crime and victims outside the remit of criminal law. The book explores both the domestic and international nature, extent, and measurement of crime and harm as well as responses to victims and victimization in connection with conventional, corporate, and state crimes and harms. As part of Policy's Companions series, entries are presented in a user-friendly, quick-reference A‒Z format that clearly notes related sections and provides suggestions for further reading.
Global Perspectives in Ocular Oncology
Eye cancers vary in presentation depending upon geographic location and access to healthcare. Global Perspectives in Ocular Oncology offers an international platform for leading ocular oncologists and multidisciplinary specialists to highlight worldwide strengths and solutions to the challenges in treating eye cancer. The goal of the book is to provide a universal view on the management of adult and pediatric tumors affecting the eye and ocular adnexa. A range of topics pertinent to the global community have been included. Organized into seven distinct sections, this book covers international collaborations and initiatives, technology and innovations, and novel treatment strategies. In addition, it provides a glimpse into the future of the specialty. The emphasis on sharing perspectives as well as the global and multidisciplinary framework of the book are unique to the market. This work will appeal to a variety of audiences including ocular oncologists and ophthalmic subspecialists, oncologists and other specialists, optometrists, geneticists, allied medical professionals, and trainees entering these disciplines.
HIV-Associated Neurocognitive Disorders
HIV-Associated Neurocognitive Disorders: Molecular and Cellular Mechanisms and Clinical Manifestations is a comprehensive volume on the field of HIV-Associated Neurocognitive Disorders (HAND) as well as its associated comorbidities. Covering clinical manifestations as well as molecular and cellular mechanisms, this book discusses available macaque and rodent animal models of HAND, epigenetic regulation, and signaling pathways underlying symptoms. Chapters also cover prevention and therapeutic strategies, as well as diagnosis and biomarkers associated with disease outcomes. This volume is appropriate for basic research and clinical investigators working in the area of HIV-1 infection. - Provides an in-depth exploration of the clinical manifestations of HAND and its comorbidities - Includes detailed assessments of the molecular and cellular mechanisms underlying HAND symptoms - Examines animal models for studying HAND, including macaque and rodent models - Presents insights into epigenetic regulation and signaling pathways implicated in HAND - Covers prevention, therapeutic strategies, and diagnostic approaches
Beneficial Ownership in Tax Law and Tax Treaties
Introduction -- Beneficial Ownership : From Conscience to Liberalism and Law -- Beneficial Ownership in Tax Law -- From Domestic Tax Law to Tax Treaties : How Beneficial Ownership Jumped -- from US and UK Tax Treaty Policy into the Worldwide Tax Treaty Network -- Changing Skin in the OECD Model : What do Intermediaries in -- Continental Law and Common Law have in Common? -- Beneficial Ownership and EU Law -- Beneficial Ownership in Exchange of Information for Tax Matters -- Final Remarks.
Galectins
The comprehensive guide to the current understanding of galectins and their promising potential in drug design This is the first book focusing on galectins. It was inspired by topics discussed at the symposium "Galectins: Structures, Functions, and Therapeutic Targets" that was a part of the 234th American Chemical Society meeting in 2007. To help chemists, biochemists, and others understand the challenges inherent in the study of galectins and build on recent advances in the field, the editors have compiled articles from leading experts on galectins and their biomedical applications. Galectins includes: * An overview of early galectin research * An explanation of the nature of galectins * A...
