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Source as a Solution to Residence

Source as a Solution to Residence
Author: Adam H. Rosenzweig
Publisher:
Total Pages: 63
Release: 2015
Genre:
ISBN:

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The choice between source-based and residence-based taxation has defined the terms of the debate for the international tax regime since its inception in the early 1900's. The thesis of this Article is that the construct of source and residence as two competing and irreconcilable doctrines is largely incorrect as a legal matter. Rather, both source rules and residence rules can and should be thought of solely as instrumental tools to divide taxing authority in a globalized world with mobile capital. Under this approach, there is no reason why “source” rules as a doctrinal matter need to be used only for “source” taxation as an economic matter, or that “residence” rules as a doctrinal matter need be used for “residence” taxation as an economic matter. Instead, the source rules as a doctrinal matter can actually be used to solve the problems of the residence rules as a doctrinal matter. Put differently, source and residence as doctrinal rules can converge into a single concept in the modern global economy.If it is true that residence as a conceptual matter has become increasingly meaningless in the globalized world, tying the doctrinal rules of residence to the doctrinal rules for source can better effectuate the ultimate goals of the international tax regime. This Article introduces a proposal to define the residence of entities as domestic for purposes of US tax law based on the source of the income of such entities. In its most simplistic form - an entity would be a US Person if it earns over a threshold amount of US Source income. Of course, such an approach would prove more complex than such a simple statement, but the basic premise holds. The Article then demonstrates how such an approach could be used to resolve two of the most difficult and pressing issues confronting the modern US international tax regime: corporate inversions and offshore hedge funds.


Facing Segregation

Facing Segregation
Author: Molly W. Metzger
Publisher: Oxford University Press
Total Pages: 288
Release: 2018-11-19
Genre: Political Science
ISBN: 0190862327

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Evidence for the negative effects of segregation and concentrated poverty in America's cities now exists in abundance; poor and underrepresented communities in segregated urban housing markets suffer diminished outcomes in education, economic mobility, political participation, and physical and psychological health. Though many of the aggravating factors underlying this inequity have persisted or even grown worse in recent decades, the level of energy and attention devoted to them by local and national policymakers has ebbed significantly from that which inspired the landmark civil rights legislation of the 1960s. Marking 50 years since the passage of the Fair Housing and Civil Rights Acts, Facing Segregation both builds on and departs from two generations of scholarship on urban development and inequality. Authors provide historical context for patterns of segregation in the United States and present arguments for bold new policy actions ranging from local innovations to national initiatives. The volume refocuses attention on achievable solutions by providing not only an overview of this timely subject, but a roadmap forward as the twenty-first century assesses the successes and failures of the housing policies inherited from the twentieth. Rather than introducing new theories or empirical data sets describing the urban landscape, Metzger and Webber have gathered the field's first collection of prescriptions for what ought to be done.


Drawdown

Drawdown
Author: Paul Hawken
Publisher: Penguin
Total Pages: 258
Release: 2017-04-18
Genre: Science
ISBN: 1524704652

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• New York Times bestseller • The 100 most substantive solutions to reverse global warming, based on meticulous research by leading scientists and policymakers around the world “At this point in time, the Drawdown book is exactly what is needed; a credible, conservative solution-by-solution narrative that we can do it. Reading it is an effective inoculation against the widespread perception of doom that humanity cannot and will not solve the climate crisis. Reported by-effects include increased determination and a sense of grounded hope.” —Per Espen Stoknes, Author, What We Think About When We Try Not To Think About Global Warming “There’s been no real way for ordinary people to get an understanding of what they can do and what impact it can have. There remains no single, comprehensive, reliable compendium of carbon-reduction solutions across sectors. At least until now. . . . The public is hungry for this kind of practical wisdom.” —David Roberts, Vox “This is the ideal environmental sciences textbook—only it is too interesting and inspiring to be called a textbook.” —Peter Kareiva, Director of the Institute of the Environment and Sustainability, UCLA In the face of widespread fear and apathy, an international coalition of researchers, professionals, and scientists have come together to offer a set of realistic and bold solutions to climate change. One hundred techniques and practices are described here—some are well known; some you may have never heard of. They range from clean energy to educating girls in lower-income countries to land use practices that pull carbon out of the air. The solutions exist, are economically viable, and communities throughout the world are currently enacting them with skill and determination. If deployed collectively on a global scale over the next thirty years, they represent a credible path forward, not just to slow the earth’s warming but to reach drawdown, that point in time when greenhouse gases in the atmosphere peak and begin to decline. These measures promise cascading benefits to human health, security, prosperity, and well-being—giving us every reason to see this planetary crisis as an opportunity to create a just and livable world.


Solar Assisted Ground Source Heat Pump Solutions

Solar Assisted Ground Source Heat Pump Solutions
Author: Francesco Reda
Publisher: Springer
Total Pages: 73
Release: 2016-12-09
Genre: Technology & Engineering
ISBN: 3319496980

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This book analyses solar-assisted ground-source heat pump systems, a technology meant for producing heating and cooling energy for buildings. It focuses on ground source heat pump, reversible central heating and cooling system that transfer heat from or to the ground, applications which use solar thermal collectors. Providing deep insights into energy-saving, solar thermal system operating strategies, it illustrates examples of useful configurations and controlling approach for different climates for different vertical ground heat exchanger depths. Offering an overview of solar assisted ground source heat pump systems, including design principles and energy-performance data for different climates, it is a valuable resource for designers and scientists who focus on building heating and cooling technologies.


Global Perspectives on E-Commerce Taxation Law

Global Perspectives on E-Commerce Taxation Law
Author: Subhajit Basu
Publisher: Ashgate Publishing, Ltd.
Total Pages: 344
Release: 2007
Genre: Business & Economics
ISBN: 0754684970

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This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field.


A Guide to the Home Electric System

A Guide to the Home Electric System
Author: Paul R. Wonning
Publisher: Mossy Feet Books
Total Pages: 91
Release: 2021-05-12
Genre: House & Home
ISBN:

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The A Guide to the Home Electric System provides readers with a complete handbook to the home electric system. Understanding the fundamentals of how a residential electrical wiring system helps the home owner understand the electrical wiring components in a home as well as a guide to how a house is wired. This is not an instructional manual on how to wire a home, however it is an invaluable guide as to how the electric system is configured and how the power company supplies electric power to the home. A glossary of electric wiring terms and a guide to home batteries is included, as well. Residential electric, house electrical, electric power system fundamentals, electrical wiring residential, basic home electrical wiring, electrical wiring residential, home wiring guide


Residential Real Estate

Residential Real Estate
Author: Anupam Nanda
Publisher: Routledge
Total Pages: 230
Release: 2019-03-20
Genre: Business & Economics
ISBN: 1317483480

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Residential Real Estate introduces readers to the economic fundamentals and emerging issues in housing markets. The book investigates housing market issues within local, regional, national and international contexts in order to provide students with an understanding of the economic principles that underpin residential property markets. Key topics covered include: Location choice in urban areas Housing supply and demand Housing finance and housing as an asset class Demographic shifts and implications for housing Sustainable homes and digitalisation in housing Drawing on market-level information, readers are encouraged to recognise the supply and demand drivers and modelling of dynamic housing markets at various spatial scales and the implications of trends within an urban and regional context, e.g. urbanisation, ageing population, migration, digitalisation. With research-based discussions and coverage of relevant literature, this is an ideal textbook for students of residential real estate, property and related business studies courses at UG and PG levels, as well as a reference book with research topics for researchers. This book will also be of interest to professionals and policymakers.


Bioclimatic Housing

Bioclimatic Housing
Author: Richard Hyde
Publisher: Routledge
Total Pages: 458
Release: 2012-04-27
Genre: Architecture
ISBN: 1136571140

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In the search for sustainable architecture, there is growing interest in the relationship between nature and design. In this vital new book, the termbioclimatic relating to the dynamic between climate and living organisms, is applied by the authors in focusing on countries where housing requires cooling for a significant part of the year. In this context, Bioclimatic Housing covers creative, vernacular architecture to present both the theory and practice of innovative, low-energy architecture. The book interweaves the themes of social progress, technological fixes and industry transformation within a discussion of global and country trends, climate types, solutions and technologies. Prepared under the auspices of a 5-year International Energy Agency (IEA) project, and with case studies from Iran, Malaysia, Australia, Japan, Sri Lanka and Italy, this is a truly international and authoritative work, providing an essential primer for building designers, builders, developers and advanced students in architecture and engineering.


Fundamentals of Risk Analysis and Risk Management

Fundamentals of Risk Analysis and Risk Management
Author: Vlasta Molak
Publisher: CRC Press
Total Pages: 496
Release: 1996-11-26
Genre: Law
ISBN: 1439821976

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This book bridges the gap between the many different disciplines used in applications of risk analysis to real world problems. Contributed by some of the world's leading experts, it creates a common information base and language for all risk analysis practitioners, risk managers, and decision makers. Valuable as both a reference for practitioners and a comprehensive textbook for students, Fundamentals of Risk Analysis and Risk Management is a unique contribution to the field. Its broad coverage ranges from basic theory of risk analysis to practical applications, risk perception, legal and political issues, and risk management.