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Barnes and Noble

Tax Treaty Residence of Entities

Current price: $145.00
Tax Treaty Residence of Entities
Tax Treaty Residence of Entities

Barnes and Noble

Tax Treaty Residence of Entities

Current price: $145.00
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In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.

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Barnes & Noble does business -- big business -- by the book. As the #1 bookseller in the US, it operates about 720 Barnes & Noble superstores (selling books, music, movies, and gifts) throughout all 50 US states and Washington, DC. The stores are typically 10,000 to 60,000 sq. ft. and stock between 60,000 and 200,000 book titles. Many of its locations contain Starbucks cafes, as well as music departments that carry more than 30,000 titles.

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