anti-avoidance
International Experience with General Anti Avoidance Rules
... International Experience with General Anti Avoidance Rules SMU Law Review Volume 54 | Issue 1 Article 7 2001 International Experience with General Anti Avoidance Rules Graeme S Cooper Follow this and[.] ...
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Codifying Anti Avoidance Doctrines and Controlling Corporate Tax Shelters
... Codifying Anti Avoidance Doctrines and Controlling Corporate Tax Shelters SMU Law Review Volume 54 | Issue 1 Article 11 2001 Codif ying Anti Avoidance Doctrines and Controlling Corporate Tax Shelters[.] ...
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Does Croatia need a general anti-avoidance rule? Recommended changes to Croatia's current legislative framework
... general anti-avoidance ...developed avoidance doctrine required that a scheme must consist of a pre-ordained se- ries of transactions before it could be set ...
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The C.J.E.U. Case Law Relevant to the General Anti-Avoidance Rule (G.A.A.R.) Under the Anti-Tax Avoidance Directive (A.T.A.D.)
... 56/96, VT4 Ltd. v. Vlaamse, 1997 E.C.R. I-3143 and Case C-34/95, C-35/95 and C-36/95, Konsumentombudsmannen v. De Agostini and TV-Shop, 1997 E.C.R. I-03843; Case C- 115/78, Knoors v. Secretary of State, 1979 E.C.R. 399; ...
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Review of Anti-Avoidance Measures of General Nature and Scope-General Anti-Avoidance Rules and Other Measures
... analysis. 46 Intertax 1 (2018) pp. 18-44, Kluwer Law International; V. Chand, The Interaction of the Principal Purpose Test (and the Guiding Principle) with Treaty and Domestic Anti-Avoidance Rules, 46 ...
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UK Budget 2016: CGT, stamp duty, more anti-avoidance and a boost for entrepreneurs
... How is this all to be paid for? This is especially interesting given that tax policy decisions only generate revenue from 2019/20, and indeed cost £960m and £470m respectively over the 2017/18 and 2018/19 tax years. The ...
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Time to stop avoiding the tax avoidance issue in Croatia? A proposal based on recent developments in the European Union
... the anti- avoidance legislation – primarily the introduction of the new TAARs – mirror the general problem of the Croatian tax system ever since its comprehensive reform in 1994: the instability of the ...
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Tax Update A report on cross-border developments in Canadian tax law / September 2011
... new anti-avoidance rule that reclassifies certain amounts from exempt to taxable surplus where the amounts arise from transactions that are avoidance transactions, within the meaning of the GAAR ...
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The 2015/16 Federal Budget key Tax announcements for business 14 May 2015
... There are no budget estimates or forecasts of the revenue expected to be raised by these anti-avoidance rules. While it is stated that approximately 30 large multinational companies are suspected of ...
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Tax Base Erosion and Profit Shifting (BEPS) and International Economic Law*
... be caused by the inherent non-binding nature of soft law combined with the collective action problem stipulated above. Coherent and strong anti-abuse and anti-avoidance rules are necessary to prevent ...
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ACHIEVEMENT MOTIVATION TOWARD LEARNING ENGLISH LANGUAGE IN MODERN EDUCATIONAL CONTEXT OF GEORGIA
... The achievement goals construct from decades of research into the different motives people have in achievement settings (Elliot, 2005). Initially, the primary emphasis of achievement goal was on two types of achievement ...
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The Relationship Between Brain-Behavioral Systems and Negative and Positive Affect in Patients With Migraine
... As the results of Table 1 show, positive affect had a sig- nificant and positive relationship with active avoidance (P < 0.01 and r = 0.271), and there was a negative signifi- cant correlation with passive ...
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Association between Coping Strategies and Infertility Stress among a Group of Women with Fertility Problem in Shiraz, Iran
... passive avoidance coping, the participants looked for a miracle and wished for positive ...passive avoidance coping may be that participants of this study perceived less control over their infertility ...
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Relations between Teachers’ Goal Orientations, Their Instructional Practices and Students’ Motivation
... performance avoidance goals further enlightened the positive effects of teachers’ per- formance avoidance goals on perceived classroom performance goal ...performance avoidance goals, with which ...
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Soft Computing Approaches To Fault Tolerant Systems
... the anti-lock brake computer are both known to work properly and yet fail in operation because one computer interferes with the other when they are both ...
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Rational avoidance of accountability
... This paper has demonstrated that governments will endeavour to balance a public perception of being accountable with an actual unaccountable regime. Governments are composed of servants[r] ...
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Congestion Avoidance and Control
... The goal of this algorithm to send a signal to the endnodes as early as possible, but not so early that the gateway becomes starved for traffic. Since we plan to continue using packet drops as a congestion signal, ...
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Criminal Constitutional Avoidance
... the avoidance canon to vague statutes, it undermines the purposes of the canon itself in two ...the avoidance doctrine to vagueness statutes will often result in the Court rewriting the statute in the name ...
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Low Cost Autonomous Vehicle Control System by Using Neural Network
... from a demonstrating action and also suffer from a very slow convergence process and lack of generalization due to limited patterns to represent complicated environment. However, neural networks that can be implemented ...
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Analyzing Avoidance: Judicial Strategy in Comparative Perspective
... These avoidance tools—certiorari, DIGs, standing, ripeness, mootness—address timing: when can a particular claim be heard by the Court? A decision that a party bringing the claim lacks standing does not preclude a ...
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