Within Arm S Length

Narrates the story of Dae Emmett's journey in this coveted job, from the application process to his retirement as assistant to the special agent in charge on the elite Presidential Protective Division.

The tender and perceptive debut novel from the New York Times bestselling author of Hello Beautiful, about three generations of a large Catholic family jarred into crisis by an unexpected pregnancy “This stunning . . . exquisite, skillfully written gem addresses serious issues–e.g., guilt vs. loyalty, the past vs. the present—[but] remains hopeful and includes ample doses of humor and wit.”—Library Journal (starred review) No one in my mother’s family ever talks about anything that can be categorized as unpleasant or as having to do with emotions. . . . This spellbinding novel by bestselling author Ann Napolitano is a poignant reminder of how connected we are to those we love, even when we cannot find the words to say it. The unforgettable story of three generations of an Irish American family, Within Arm’s Reach is another rich and deeply satisfying novel from the author who captured the many dimensions of grief in Dear Edward and the unbreakable bonds of sisterhood in Hello Beautiful.

The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic. This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

From the New York Times bestselling author of Hello Beautiful and Dear Edward, a novel set in Flannery O'Connor's hometown of Milledgeville, and a tragedy that forever alters the town and the author herself "A wholly believable world shaped by duty, small pleasures, and fateful choices."—O, The Oprah Magazine Forced by illness to leave behind a successful life in New York, literary icon Flannery O'Connor has returned to her family farm in the small town of Milledgeville, Georgia. With her health and time both limited, all she wants is to be left alone to write. But Flannery's plans are soon upended by Melvin Whiteson, a banker from Manhattan who has recently married the town belle. Melvin is at loose ends with his new life; though he has every opportunity, he's not sure where to begin. Flannery knows exactly what she wants, but is running out of time. Through their unusual and clandestine friendship, both will come to reflect on the decisions they have made and the paths they have chosen. Literary history and fiction gracefully intersect in this emotionally charged novel of small town Southern life, which asks us all to consider how we can live our lives to the fullest.

It's W.A.R. out there and there's no one better to have on your side than Cliff Stewart. A personal protection specialist to the world's rich and famous -- from Saudi Arabian sheiks and members of Royal Families to Muhammad All and Mr. T -- for more than 20 years, Stewart has distilled and crystallized the sum of his knowledge into a system called "Within Arms Reach" (W.A.R.). As a bodyguard who must rely on his instincts and skills to neutralize any attack, Stewart created a system which provides instant response with maximum effect. W.A.R. was created specifically for non-martial arts types -- professional protection specialists who had little time to learn the kinds of responses which could ultimately save the lives of their clients. W.A.R. gives you the tools to go into battle with the latest, most-innovative techniques known to man.

Adapted from Within Arm'’s Length for a younger audience, a rare inside look at the Secret Service from an agent who protected Presidents George H. W. Bush, Bill Clinton, and George W. Bush. Dan Emmett was just eight years old when President John F. Kennedy was assassinated. From that moment forward, he knew he wanted to become a Secret Service agent, one of an elite group of highly trained men and women dedicated to preserving the life of the President of the United States at any cost, including sacrificing their own lives if necessary. Armed with single-minded determination and a never-quit attitude, he did just that. Selected over thousands of other highly qualified applicants to become an agent, he was eventually chosen to be one of the best of the best and provided protection worldwide for Presidents George Herbert Walker Bush, William Jefferson Clinton, and George W. Bush. I Am a Secret Service Agent skillfully describes the duties and challenges of conducting presidential advances, dealing with the media, driving the President in a bullet-proof limousine, running alongside him through the streets of Washington, and flying with him on Air Force One. With fascinating anecdotes, Emmett weaves keen insight into the unique culture and history of the Secret Service with the inner workings of the White House. I Am A Secret Service Agent is a must read for young adults interested in a career in federal law enforcement.

For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.