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.

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.

This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.

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.

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