Global Transfer Pricing - Free Essay Example

Sample details Pages: 2 Words: 645 Downloads: 8 Date added: 2017/09/21 Category Economics Essay Type Argumentative essay Tags: Development Essay Did you like this example? 1. Global Transfer Pricing: A Practical Guide for Managers , Ralph Drtina, Jane L. Reimers, S. A. M. Advanced Management Journal, v74n2, Spring 2009. Transfer Pricing Article Summary The authors give a beneficial guide for managers for selecting and implementing a transfer pricing policy. According to the article, transfer pricing are the amounts charged for goods and services exchanged between divisions of the same company. In a multinational company strict international tax laws regulate the amounts charged for goods and services, tangible or intangible, which cross borders. The article advises a company with operations in more than one country to be cautious when setting transfer prices for goods or services sold between divisions. The managers can learn from this article that methods traditionally used to set prices between divisions in a single country may not be acceptable for international tax purposes. The article addresses two major types of transactions, intra-c ompany sales of products and intra-company licensing of intangible property. A multinational company can maximize the profits by shifting profits from divisions in high-tax to divisions in low-tax jurisdictions countries. A description of how global transfer pricing works is given along with transfer pricing effect on taxable income. In this global economy, the trend for countries is to strengthen their effort to collect tax revenues from transfer pricing. A company can mitigate tax conflicts by negotiations and price agreements. The article describes the arms-length principles used by most countries and standardized by IRS S428 and by OECD (Organization for Economic Co-operation and Development) rule. The article indicates what challenges need to be resolved when applying these standards. Under the arm’s length principle one compares the remunerations from cross-border controlled transactions within multinationals with the remuneration from transactions made between in dependent enterprises in similar circumstances. The arms-length principle has become the international norm for allocating the tax bases of multinational enterprises among the countries where they operate. Five transfer pricing methods for finding arm’s length price are presented along with the comparability issues related to selecting the method and determining the transfer price. The article illustrates the arms-length principle applied for transfer pricing for intangible assets. These assets include intellectual property, patents, formulas, copyrights, trademarks, brand names, licenses, or software. The article show numeric examples of approved ways to calculate transfer prices and explain how application differs between tangible goods and intellectual property. The article concludes with a series of guidelines for managers on how to be aware of the complexity of transfer pricing and how to minimize the risk associated with multinational intra-company transfers. Ever y multinational company should have a documented transfer policy that guides managers’ actions. A company should continue to update its transfer price policy whenever changes to its business affect the factors used to establish the arm length principle. In addition a company with many cross-border transactions should consider an advanced pricing agreement to ensure tax dispute will be kept to minimum. In order to avoid significant cost or penalties to their multinationals companies, managers should become familiar with the regulations of the countries involved, for example using OECD and IRS resources. Analysis and Opinion This article expands the information about transfer pricing from textbook, and emphasizes the aspect of international transfer pricing. Given the global and sometimes controversial nature of transfer pricing, it is important to develop internationally shared principles, as the arm’s length principle, to help each country fight abusive transfer of profit abroad, while at the same time limiting the risk of double taxation of those profits. This article has a lot of applicability to my job, since I work in a multinational company, in projects that develop products across borders and involve transfer pricing. Intellectual property issues (e. g. , valuations) can have significant implications on an organization’s taxes and financial performance. The intangible assets, tax valuation of intellectual property and transfer pricing are highlighted by the article. Don’t waste time! Our writers will create an original "Global Transfer Pricing" essay for you Create order

Kashmir ; A lost paradise Essay - 3104 Words

Kashmir — a beautiful mountain state with clear rivers, evergreen forests and one of the highest death rates in the world. It is at the center of an age-old dispute between Pakistan and India that has dragged on from the independence of both nations over fifty years ago to the present time, with no resolution in sight. The combined population of the two nation totals over a billion, so no conflict between them is of passing importance, especially when nuclear weapons are involved. Pakistan and India share a common heritage, language, and traditions, yet the subject of Kashmir can push them to the brink of annihilation. Fifty years of animosity have built up as a result. A proxy war still brews in Kashmir, claiming dozens of lives every†¦show more content†¦They removed the ruler of Junagarh and placed a â€Å"Provisional Government† in place, then used the excuse of â€Å"restoring law and order† to invade and hold a farcical plebiscite, which choose Ind ia. â€Å"India sought to justify its aggression†¦on the plea that the rulers of Junagarh and Hyderabad were acting against the wishes of their people† states the report on Kashmir released by the Pakistani Foreign Ministry. Keep this excuse in mind as you read on; the rulers of the states were acting against the will of the people, so India felt it had the moral right to interfere. In Kashmir, the roles were reversed. The ruler was Hindu with a Muslim majority. Anticipating that the ruler would chose India, the people rose against him, and with the support of Pakistani tribesmen, ousted the ruler and set up their own government. Now the irony of the situation is that while the Indians did the exact same thing in Junagarh, they could not accept the state of affairs in Kashmir. The provisional government of Kashmir chose Pakistan, and a few days later the ousted ruler of Kashmir signed over the state to India, despite no longer being technically in power. The Indian army then invaded, with the Pakistani army following suit, and war broke out between the fledgling nations. The United Nations intervened in 1948 and set up a shaky ceasefire temporarily splitting Kashmir into Indian-held and Pakistani held areas. As the countries were divided in AugustShow MoreRelatedKashmir Issue1534 Words   |  7 Pagesreturn home by the dusk. That’s the fear that the peop le of Kashmir are living with. Freedom, for Kashmir, is a search for the lost identity of its rich cultural religious class of medieval world. The issue of Kashmir is not as ordinary as most of the people in India think. People of Kashmir are dying dying for the future of their unborn. I just want to convey to the outer world the citizens of India that the common man in Kashmir is not a terrorist but a human being who has needs like anyoneRead MoreEthnic Tourism Essence of India7906 Words   |  32 Pageslet’s feel the experience and see how Ethnic tourism has helped promoting tourism and bringing world closer. Introduction India known as Visitor’s paradise derives her roots from a rich past both culturally and historically. This is manifest in the wealth of its cities and magnificent architecture. Starting from the tip of snowcapped mountains of Kashmir to beautiful landscapes allover to Kanyakumari there are enormous stories of cultural and ethnic wonders. There are scores of existing locations forRead MoreA Study on Role of Advertisement in Promotion of Tourism in India15524 Words   |  63 Pagesand Buddhist temples. Many  trekkingexpeditions also begin here. JAMMU AND KASHMIR Jammu amp; Kashmir  is known for its scenic landscape .Jammu and Kashmir  is the northernmost state of India.  It is also called as Paradise on Earth. ATTRACTIONS * Jammu  is noted for its scenic landscape, ancient temples and mosques, Hindu and Muslim shrines, castles, gardens and forts. * The Hindu holy shrines of Amarnath in  Kashmir Valley  attracts about   Vaishno Devi  also attract thousands of Hindu devoteesRead MoreHimachal Pradesh8795 Words   |  36 PagesHimachal Pradesh Himachal Pradesh is a state in Northern India. It is spread over 21,495 sq  mi (55,673  km ²)and is bordered by the Indian states of Jammu and Kashmir on the north, Punjab on the west and south-west, Haryana and Uttar Pradesh on the south, Uttarakhand on the south-east and by the Tibet Autonomous Region on the east. The literal meaning of Himachal Pradesh is Region of snowy mountains. Himachal Pradesh was anciently known as Dev Bhumi (The Abode of Gods) and is known to be abundant inRead MoreRise and Decline of the Muslim Ummah9373 Words   |  38 PagesEastern Europe until it reached the borders of Vienna. On the other side, it took upon itself, the responsibility of leadership and security of the entire Islamic world, including Northern Africa. It also revived the Caliphate, and in this way the lost splendour and grandeur of the Islamic world was once again restored. The important point to note here is that this task was performed by the Turks and not by the Arabs. Strange are the ways of Providence! The consolidation the Usmanian Caliphate producedRead MoreIndian English Novel17483 Words   |  70 Pagesanthologies, and in some instances bound compendiums of previously published comic book series). These novels are imbibed with life through both speech and images. Some of the popular graphic novels created in India comprise - The Believers, Corridor, Kashmir Pending and The Barn Owl`s Wondrous Capers by various novelists, likening themselves to the range of comic book popularisation. The contemporaneous Indian novels are widely sold and flying off the racks in overseas countries, besides just the native

Essay on Homer’s Odyssey Free Essays

In the tenth book of the Odyssey Odysseus and his companions find themselves trapped in the cave if the Cyclops Polyphemos. After their monstrous host has munched his way through several of his guests, the remainder take action. Odysseus makes a sharp, wooden stake, cutting it from the massive cudgel discovered in the cave; then together with four of his men he plunges the stake into the eye of the drunken, sleeping Polyphemos. We will write a custom essay sample on Essay on Homer’s Odyssey or any similar topic only for you Order Now Snodgrass, however, would dissent. His whole book is devoted to proving that not only did early Greek art rarely illustrate Homer, it was rarely even inspired by it. This theory is not a new one. Many other scholar have thought and pondered the same ideas. Snodgrass meticulously studies examples of scene often thought to be illustrations of Homer. Geometric art, he argues, offers nothing that can be identified as Homeric; indeed, there is only one Trojan war scene and that is Ajax’s rescue of the body of Achilles, a scene which occurs in neither the Odyssey nor the Iliad. One of the more bizarre apparitions of geometric art takes the form of a pair of Siamese twins, warriors with two heads, four legs, four arms and one torso and the subject of some fascinating pages in Snodgrass’s book. They were especially popular in early Greek art, but there is no clear Homeric influence here. Twice does the Iliad does refer to the twins, yet significantly he does not mention their rather striking deformity. It is preferable to understand both the artist and Homer as drawing on the same body of legendary material. By the mid seventh century figures on vases are beginning to be identified by captions. This at least makes it easier to determine whether the scene is from the Trojan war. Instead of two warriors fighting over a body we can be sure that we are looking at Menealos and Hektor fighting over the body of Euphorbos, as found on a famous Rhodian plate of the late seventh century, a picture that makes an impressive and appropriate cover for the book. This could very well be an illustration of the Iliad book where Menealos abandons his attempt to strip the corpse. Evidence for this tradition can be found in the shield of Euphorbos by Menealos himself. This is certainly plausible and helps to show that common subject matter is insufficient to prove influence. On the other hand, where a minor character is names, such as ‘Odios’ in the embassy to Achilles, then we can be more confident that the artist had Homer in mind. This is a book of enormous leaning and subtlety, and it conclusion is surely right, yet at the same time it seems something of a missed opportunity. It is devoted to a negative and tightly-argued thesis, that Homer’s epic poems had only minimal influence on early Greek at. Snodgrass is re-thinking early Greek art as he goes, but he is re-thinking it within the restrictions imposed by the very narrow focus of the book as a whole. Thus, the positive, for instance the illuminating chapter on synoptic narrative and on composition, can be rather swapped in the relentless negative arguments. Other will now need to work through the implications of his thesis, for example the role that must be assigned to oral tradition and all its local variations. Perhaps it is no conscience that his book should appear at a time when the literary culture of the recent past is being eroded by an increasing emphasis on the visual. How to cite Essay on Homer’s Odyssey, Essays

Yellow Raft In Blue Water Essay Research free essay sample

Yellow Raft In Blue Water Essay, Research Paper ? When authors write from a topographic point of penetration and existent lovingness about the truth, they have the ability to throw the visible radiations on for the reader. ? ( Anne Lamott ) When a reader can see a state of affairs in a distinguishable and realistic manner that entreaties to his emotion, he knows that the author has written with great penetration. With experience, authors can show the deeper significance of a clip or state of affairs. In A Yellow Raft in Blue Water, Michael Dorris exhibits this technique when he writes about Christine go forthing Rayona at Ida? s house. We will write a custom essay sample on Yellow Raft In Blue Water Essay Research or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The 1920? s is viewed as a comfortable and glamourous clip period, but F. Scott Fitzgerald tells us otherwise. In The Great Gatsby, Fitzgerald unveils the world of peoples? lives in the 1920? s by stating the narrative of Jay Gatsby. In A Yellow Raft in Blue Water, Christine is sick, and she leaves Rayona at Ida? s house. Dorris is able to? throw the visible radiations on for the reader? , because the reader views this state of affairs through two positions. Rayona thought that Christine was being selfish for go forthing her with Ida. She felt that her female parent was non looking out for her, and pretermiting her. However, when one views the fortunes through Christine? s eyes, the reader discovers that Christine left because she did non desire Rayona to see what she was traveling through. Christine besides did non desire Rayona to experience bad for her. Michael Dorris tells the narrative through two diffe rent positions, so the reader can feel the world and truth of what each character is experiencing indoors. In The Great Gatsby, F. Scott Fitzgerald does non portray the 1920? s as a clip of wealth, felicity, and excess like it is believed to be. Fitzgerald uses the character, Jay Gatsby, to demo the reader that this clip period was non all about felicity and joy. Gatsby is a adult male who did non cognize what existent love was. He had the fancy autos, and the beautiful house, but he did non hold Daisy. Fitzgerald is seeking to demo the reader that non everyone who had money in this clip period was happy. Fitzgerald writes the manner it truly was, leting the reader to understand what people were similar at this clip. Another realistic character in The Great Gatsby is Daisy Buchanan. Daisy? s hubby, Tom, was a really successful person, who had money, luxuries, and a large house. Daisy was still non happy and had an matter with Gatsby. The world was that everyone was non happy with their lives. Many people had jobs and Fitzgerald shows this in his work. Finally, when authors write with penetration, the reader is able to understand the truth about the state of affairs. Many plants of literature do non state the truth, and the reader is non able to experience what is traveling on in the book. Michael Dorris and F. Scott Fitzgerald do a phenomenal occupation in conveying the reader down to Earth. The authors use their cognition of the clip period to compose practically.

Secondhand Smoking Essay Example

Secondhand Smoking Essay Environmental tobacco smoke (ETS), mostly known as secondhand smoke, is the smoke from a burning cigarette and exhaled by the smoker that unwittingly inhaled by other people. This has always been the case, but the dangers of secondhand smoking were not really known until 1986, when the Surgeon General came out with his report that warned people about â€Å"involuntary smoking† and even about the possibility of smoking related diseases in healthy non-smokers who were exposed to secondhand smoke. The health professionals prefer to use the term second hand smoke instead of Environmental Tobacco Smoke because the two terms have highly differing definitions. ETS is used more as a definition of the way the environment reacts to the presence of tobacco smoke rather than the relationship of the smoke to the human health component.There are 2 types of second hand smoke that each individual is exposed to. The smoke that emanates from the lit tip of a cigarette, pipe, or cigar is known a s Side Stream Smoke. While the smoke blown by the smoker is known as Main Stream Smoke. Any person unwittingly exposed to the hazards of second hand smoke is termed as an Involuntary Smoker. As such, his body is exposed to and made to absorb the carcinogenic chemicals the same way the willing smokers do. This is why both smokers and non-smokers are at equal risk of developing a one of the many cancers that can be activated by the carcinogens in the cigarette.Something that most people exposed to second hand smoke do not realize is that second hand smoke exposes the non-smoker to   4000 or more various chemical mixes. At least 60 of these chemical components are well known carcinogens. Whether they realize it or not, primary smokers expose everyone around them to all the carcinogenic hazards stemming from mainstream and side stream smoke. In 2002, the International Agency for Research on Cancer conducted a monograph regarding tobacco and second hand smoke. The agency came to the co nclusion that second hand smoke can cause lung cancer in non smokers if the exposure to the smoke stream remains constant. Studies have proven that a smoker only inhales 15% of the smoke he puffs. A dangerously high 85% of the remaining smoke is diffused and absorbed by the environmental air causing it to be inhaled by the non- smokers. The report further states that:There is sufficient evidence that involuntary smoking (exposure to second-hand or environmental tobacco smoke) causes lung cancer in humans† and makes the overall evaluation that â€Å"Involuntary smoking (exposure to secondhand or environmental tobacco smoke) is carcinogenic to humans.Truly, secondhand smoke is a health risk and it can lead to lung cancer, sinus cancer, cervical, breast, and bladder cancer. Still, even if secondhand smoke does not lead to serious incurable diseases, it often leads to general health problems for both adults and children.Surveys have shown that as of June 2007, second hand smoking has been the cause of death for approximately 3,400 lung   cancer and 46,000 heart disease patients yearly   in the United States. Such a high rate of deaths stems from the increased level of second hand smoke in the places frequented by adults for social gatherings. A person who regularly goes to restaurants and bars is exposed to a smoke level 5 times higher than in their homes and offices. For married couples, the statistics are even more staggering. There is an estimated 35,000 non smokers deaths in households where one spouse is a non smoker. Lung cancer is usually diagnosed in about 3.400 adult patients. The list of recurring illnesses in people constantly exposed to second hand smoke lists like ordinary, negligible illnesses that should clear up on it’s own. Coughing, phlegm, chest discomfort and weak lungs, are only a partial listing of illnesses that beset adult non smokers.The most innocent victims of second hand smoke are the children. Mothers who constantly e xpose the unborn fetus to second hand smoke risk giving birth to low birth weight babies. It is estimated that about 67% of babies are born into a household with at least one smoker in the family. The exposure may also cause complications and health hazards in the development of an unborn child’s lungs and brain. A child’s exposure to second hand smoke also increases the risk of developing childhood asthma. Children who are prone to sinusitis and chronic respiratory problems (e.g. coughing and post nasal drip) will find that exposure to the smoke also causes chronic colds and coughing. The Environmental Protection Agency conducted a study in 1992 that confirms that exposure to second hand smoke causes lower respiratory tract infections in about 300,000 children ages 18 months and below.Although there has been no formal research as to whether cigarette odors can cause cancer, what has been proven is that the smoke sticks to anything and everything that lies in its path. The smell of the second hand smoke sticks to hair, clothes, and other surfaces. It is therefore believed that any cancer causing effects from such exposures will be highly minimal.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Furthermore, research in this area has shown that even exposure to small amounts of secondhand smoke is harmful to health and elimination of secondhand smoke from all indoor spaces is necessary to assure a healthy environment.   In fact, creating spaces for smokers, and separating smokers from non-smokers is a smart way to deal with secondhand smoke. It is something that the government has been able to institute and much progress has been made in this area. Today it is common to see â€Å"no smoking signs† in all public spaces, including, airports, hospitals, schools, office buildings, and other public institutions.   Proper ventilation of pubic spaces is another way to insure that everyone is protected from a hazardous breathing environment.   Clearly, o n an individual basis people can insure themselves and their families by eliminating secondhand smoke from their homes and cars.Of course, eradicating smoking from society is not easy, especially because it is such a big business. However, through education, and gentle, and not so gentle persuasion it is up to society to encourage the smokers to quit and the non-smokers to never pick up the habit. If we don’t turn a blind eye to an obvious problem it may save someone’s life in the long run. It is imperative that there is education in the schools that emphasizes the damaging effects of smoking on people.   Once people are aware of statistics about smoking and know the real story, they may think twice about picking up this bad habit.There are ways and means to avoid exposure to second hand smoke if one is really determined to quit smoking or limit his, her , or family exposure to the carcinogenic elements in the air they breath. For starters, a person who is still smok ing can choose to stop smoking. There was various ways and means available to quit smoking such as a nicotine patch of nicotine gum to help ease the toxin out of the body. When dealing with household companions who smoke, you must talk to them and convince them of the ill effects of smoking on both the smoker and non smokers. If they won’t listen to reason, the non smoker should demand that the smoking take place away from the person, if possible, outside of the home. Make the car a non smoking area and make sure that exposure to areas that have high second hand smoke content is limited or totally eliminated.In conclusion, I would like to mention that according to the American Lung Association, the move to ban smoking in public places in order to limit the public exposure to second hand smoke has begun to pick up steam in at least 15 states in the country. The ALA report indicates that:Fifteen states Arizona, California, Colorado, Connecticut, Delaware, Hawaii, Maine, Massac husetts, New Jersey, New Mexico, New York, Ohio, Rhode Island, Washington and Vermont as well as the District of Columbia and Puerto Rico prohibit smoking in almost all public places and workplaces, including restaurants and bars. Illinois, Maryland, Minnesota, Montana, New Hampshire, Oregon and Utah have passed legislation prohibiting smoking in almost all public places and workplaces, including restaurants and bars, but the laws have not taken full effect yetWork Citedâ€Å"Children and Second Hand Smoke†. American Academy of Pediatric Otolaryngology . 2007. 31 July 2007. http://www.entnet.org/healthinfo/tobacco/secondhand_smoke.cfm.â€Å"Second Hand Smoke â€Å".American Cancer Society. 2007. 29 July 2007. http://www.cancer.org/docroot/PED/content/PED_10_2X_Secondhand_Smoke-Clean_Indoor_Air.asp.â€Å"Second Hand Smoke†. Ontario Campaign for Action on Tobacco. 2007. 30 July 2007. http://www.ocat.org/healtheffects/index.html.â€Å"Second hand Smoke Fact Sheet†. American Lung Association . June 2007. 31 July 2007. http://www.lungusa.org/site/pp.asp?c=dvLUK9O0Eb=35422.â€Å"The Effects of Second Hand Smoke†.   essortment . 2002. 30 July 2007. http://mo.essortment.com/secondhandsmok_rxgs.htm.

Grandparents and an Online Degree Program Essays

Grandparents and an Online Degree Program Essays Grandparents and an Online Degree Program Essay Grandparents and an Online Degree Program Essay When many of us were young, our grandparents – in our estimation – could have been anywhere from 100 to 150 years old. We had no concept of ages; only that our grandparents were elderly people that hailed from another generation. With people living longer and much healthier lives, the grandparent of today does not resemble the grandparent of years’ past. In fact, grandparents are only grandparents in name and position only; many are young, vibrant, working people in the prime of their lives. Age no longer defines us as it once did, and many people – regardless of their age or their â€Å"place† in the family – are pursuing goals that were once reserved for the very young. A college education, as a matter of fact, was once something that most of us earned as young people in our twenties. In fact, there were some generations in which a college education was largely a male pursuit. That generation has now caught up with the generation where a college education is genderless and ageless; and they are jumping on the bandwagon to earn what is rightfully theirs to earn. While there may be little time in the day for a round trip to a campus that may be logistically inconvenient – as well as the time necessary to sit in class – there is the possibility for people of all ages to earn an online degree. The Internet has made all things possible; and a college education is no exception. Through an online degree program, people of all ages can simply login to complete all that is required in the class – reading, assignments, projects, and even quizzes and exams. All that is required to complete an online degree is acceptance into an accredited program, a computer with access to the Internet, and the desire to finally earn that college education. :

Why is the European Crisis So Much More Severe than the US Crisis and Essay

Why is the European Crisis So Much More Severe than the US Crisis and What Could Be Done to Fix It - Essay Example This crisis first manifested in late 2009 when the sovereign debt crisis was triggered by the increased levels of government debt around the world, and it was worsened by the downgrading of government debts for some European countries. Various causes of economic crises were seen for different European countries and all of these issues converged to form sovereign debts which were further increased by banking bailouts. In some other countries in Europe, their crisis was caused by private debts arising from the downturn of the property market. Greece was one of the countries which were significantly affected by this crisis. However, in general, the impact of the European crisis has been largely extensive. The impact of this crisis however seems to be larger and longer as compared to the US economic crisis as the US is now manifesting improvements in their economy. This paper shall discuss why the European crisis is so much more severe than the US crisis and what could be done to fix it. ... In effect, any economic decision and government solution imposed by the US federal government is a decision which is meant to affect the entire country, not just a particular state (Koba, 2012). For the European community however, the crisis stems from a variety of causes for different countries and any solution to be implemented by the European community would be difficult to implement to all countries (Nelson, et.al., 2012). The European crisis is taking much longer than the US crisis to resolve because it is caused by various issues. These causes seem to include the following or a combination of the following: globalized finance, flexible credit option from 2002 to 2008 which caused high-risk spending, 2007-2012 global financial crisis, global trade imbalance, real estate crisis, 2008-2012 international recession, and bailouts of banks and private bondholders (Kakutani, 2011). All of these elements combined form the European economic crisis. In the last two years, the European Zon e has carried out various considerations on how to handle their crisis. However, Greece, Ireland, Portugal, Spain, and even Italy have experienced a significant rating downgrade of their sovereign debt (Kakutani, 2011). This led to issues of default and a significant rise in borrowing costs. And, while this zone may be prompted to do whatever it would take to resolve the crisis, it would be unlikely for the situation to be resolved in the immediate foreseeable future. This crisis is not a classic currency issue (Sri Kumar, 2012). It is an issue which involves the management of economies in a currency zone, with their related economic and political issues arising from the fact that their citizens are doing