Michael Lang

The Road to Woodstock

Holly George-Warren

A fortieth anniversary tribute to the first Woodstock event, written by its co-creator, describes the events of the historical three-day performance, in an account that features rare photographs and recollections by such artists as the Grateful Dead, Crosby Stills & Nash, and The Who. 75,000 first printing.

“[A] vivid and lively account of those hectic and historic three days….The best fly-on-the-wall account, tantamount to having had a backstage pass to an iconic event.” —New York Post The Woodstock music festival of 1969 is an American cultural touchstone, and no book captures the sights, sounds, and behind-the-scenes machinations of the historic gathering better than Michael Lang’s New York Times bestseller, The Road to Woodstock. USA Today calls this fascinating, entertaining, and blissfully nostalgic look back, “Invaluable.” In The Road to Woodstock, Michael Lang recaptures the magic for the generation that was there…and for the generations that followed.

Stefan Scherber

Kundenwünsche und Produkte, ja ganze Märkte ändern sich heutzutage rasend schnell: Kleine, agile Unternehmen sind hier im Vorteil – sie sind flexibel und können am schnellsten auf Veränderungen reagieren. Der Druck auf die Produktentwicklung größerer Unternehmen steigt. Wie gelingt es Organisationen mit ihren manchmal eingefahrenen und unflexiblen Prozessen und Vorgehensweisen in diesem Wettbewerb zu bestehen? Mit den bestehenden Strukturen ist das fast nicht möglich. Welche Veränderungen sind also nötig, damit ein Unternehmen – ganz gleich welcher Größe – wirklich agil werden kann? Und wie geht man eine solche Veränderung an? Autoren aus acht namhaften Unternehmen (Telefonica, Telekom, Fiducia, Otto, Jimdo, Autoscout24, Bison, Xing) lassen uns in diesem Band an ihren Erfahrungen, Erfolgen und Erkenntnissen teilhaben. Sie beschreiben unter anderem, was ihre Unternehmen dazu bewogen hat, sich auf das Abenteuer „Agile Transition“ einzulassen, wie diese Transition jeweils angegangen wurde, ob und warum es sinnvoll ist, agiles Vorgehen auch außerhalb der Softwareentwicklung zu etablieren, welche Erfolgsfaktoren sich aus ihren Erfahrungen ableiten lassen und wie die Arbeit mit verteilten Teams in einem agilen Umfeld funktionieren kann.

Erfahrungsberichte aus der Praxis

Erfolgsfaktoren wirklich agiler Unternehmen

Pope Benedict XVI has made the liturgy a central theme of his pontificate, and he has paid special attention to the vitally important role of language in prayer. This historical and theological study of the changing role of Latin in the Roman Catholic Church sheds light on some of the Holy Father's concerns and some of his recent decisions about the liturgy. The Fathers of the Second Vatican Council allowed for extended use of the vernacular at Mass, but they maintained that Latin deserved pride of place in the Roman Rite. The outcome, however, was that modern translations of the prayers of the Mass replaced the Latin prayers. What was the reason for the Council's decision and why is there now a desire for greater use of Latin in Catholic worship? Why have some post-conciliar English translations of the prayers of the Mass been replaced? Fr. Lang answers these questions by first analyzing the nature of sacred language. He then traces the beginnings of Christian prayer to the Scriptures and the Greek spoken at the time of the apostles. Next he recounts the slow and gradual development of Latin into the sacred language of the Western Church and its continuing use throughout the Middle Ages. Finally, he addresses the rise of modern languages and the ongoing question of whether the participation of the laity at Mass is either helped or hindered by the use of Latin.

Reflections on Liturgy and Language

The Voice of the Church at Prayer

Reinhard Wagner

Der Weg zum projektorientierten Unternehmen - Wissen für Entscheider

Raffaele Petruzzi

Transfer pricing and business restructurings: issues and developments In the ever-evolving global landscape, the ability of businesses to swiftly adapt is crucial for maintaining relevance and competitiveness. This imperative holds true for multinationals, which frequently engage in strategic restructuring of their operations, assets, and resources to realign with the dynamic shifts in market conditions. This dynamic approach enhances operational efficiency, cuts costs, and optimizes financial performance. However, the intricacies of restructuring, especially in the context of transfer pricing, pose considerable challenges. Despite elaborate guidance from the OECD and UN, transfer pricing considerations in business restructuring remain complex. Determining appropriate transfer pricing methodologies, finding comparable transactions, and ensuring accurate documentation present hurdles for both multinationals and tax administrations. This publication discusses the most important issues and recent developments related to this theme. It attempts to cover various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, that took place in October 2022 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.

Current Developments, Relevant Issues and Possible Solutions

Transfer Pricing and Business Restructurings

Peter Haunold

Auswirkungen des automatischen Informationsaustauschs in der Praxis Stand Bankauskünften in Österreich, Schweiz, Liechtenstein und in anderen Staaten bisher noch das Bankgeheimnis entgegen, entwickelte sich der automatische Informationsaustausch im Bereich der Einkünfte aus Kapitalvermögen zum international anerkannten Standard. Österreich, die Schweiz, Liechtenstein und Luxemburg werden ab 2016 dem automatischen Informationsaustausch, der mit dem FATCA der USA seinen Ausgang nahm, beitreten. Die Auswirkungen des automatischen Informationsaustauschs werden in diesem Buch sowohl aus wissenschaftlicher Sicht als auch hinsichtlich der Auswirkungen auf die Praxis behandelt. Im Fokus stehen dabei:FATCA und seine Umsetzung in ÖsterreichNeue automatische Informationsaustausch nach dem Meldestandard der OECDZusammenspiel von Informationsaustausch und GeldwäschevorschriftenZukunft der Rubik-Abkommen mit Schweiz und LiechtensteinBankgeheimnis nach dem Bankenpaket 2015

Schriftenreihe IStR Band 96

Transparenz - Eine neue Ära im Steuerrecht

Tax rules in non-tax agreements is a topic of great relevance in practice. Yet, up to now, this area of tax law has been generally neglected by researchers. The aim of this book is to close this gap in tax law research and to analyse the provisions of international agreements and similar legal instruments under international law which provide for a special domestic law tax treatment for specific individuals and international organizations. Twenty-four national reports from countries across the globe have been compiled and are published in this volume. Seventy experts, including the authors of the national reports, convened for a joint conference on "Tax Rules in Non-Tax Agreements" in Rust (Austria) from 7-9 July 2011. The national reports focus on the interaction of tax rules in non-tax agreements with the corresponding tax treaty rules. Moreover, possible matters of dispute regarding the justification of these tax rules within the legal and political frameworks of the different states are given much attention. The objective of this book is to show the relevance of tax rules in non-tax agreements, to highlight problematic issues and to encourage future research in this important field of tax law

Tax Rules in Non-tax Agreements

Henry Linger

Wita Wojtkowski

Jaroslav Pokorny

Chris Barry

Vaclav Repa

Karel Richta

Information Systems Development: Business Systems and Services: Modeling and Development, is the collected proceedings of the 19th International Conference on Information Systems Development held in Prague, Czech Republic, August 25 - 27, 2010. It follows in the tradition of previous conferences in the series in exploring the connections between industry, research and education. These proceedings represent ongoing reflections within the academic community on established information systems topics and emerging concepts, approaches and ideas. It is hoped that the papers herein contribute towards disseminating research and improving practice.

Business Systems and Services: Modeling and Development

Information Systems Development

Russet Lederman

Olga Yatskevich

How We See: Photobooks by Women is a comprehensive 'book on books" reference and resource that presents a global range of one hundred 21st-century photobooks by female photographers. Also included are one hundred historical books by women photographers, an annotated chronology, visual and author indexes, and three essays on the history and practice of photobooks by women.

Photobooks by Women

How We See

Pasquale Pistone

Alexander Rust

Josef Schuch

Claus Staringer

Jeffrey Owens

Alfred Storck

Eric Kemmeren

Peter Essers

Daniel S. Smit

Global overview of international tax disputes on DTC This e-book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 39 most important tax treaty cases which were decided in 2013 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2014 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.

Schriftenreihe IStR Band 89

Tax Treaty Case Law around the Globe 2014

Christoph Schneider

Rob Pooley

Jennifer Coady

Information Systems Development: Reflections, Challenges and New Directions, is the collected proceedings of the 20th International Conference on Information Systems Development held in Edinburgh, Scotland, August 24 - 26, 2011. It follows in the tradition of previous conferences in the series in exploring the connections between industry, research and education. These proceedings represent ongoing reflections within the academic community on established information systems topics and emerging concepts, approaches and ideas. It is hoped that the papers herein contribute towards disseminating research and improving practice

Reflections, Challenges and New Directions

Donato Raponi

Value Added Tax – a thorough analysis Given the ever increasing importance of indirect taxation as a source of revenue for governments, and the increasing complexity of legal framework as well as the increasing number of countries adopting indirect taxation, it is highly important to closely watch how the law is actually applied in practice. The main driving force in this area is undoubtedly the European Court of Justice. This book offers a thorough analysis but also keeps track of the ongoing developments in this area. It analyses selected topics (e.g. abuse and anti-avoidance measures, taxable base and rates, treatment of Public Bodies, exemptions, and deductions) by looking at the most important and recent judgments of the Court of Justice of the European Union. Experts from all over the world, not just from academia but also government representatives and tax practitioners, have given their input and helped to put together what is an informative and worthy read for anyone dealing with indirect taxation on a professional basis.

Schriftenreihe IStR Band 84

ECJ - Recent Developments in Value Added Tax

Giammarco Cottani

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Industries, Regions, New Technologies, and Other Topics

Fundamentals of Transfer Pricing

Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.

Tax Treaty Interpretation

María José Escalona

Gustavo Aragón

Information System Development—Improving Enterprise Communication are the collected proceedings of the 22nd International Conference on Information Systems Development: Improving Enterprise Communication—ISD 2013 Conference, held in Seville, Spain. It follows in the tradition of previous conferences in the series in exploring the connections between industry, research and education. These proceedings represent ongoing reflections within the academic community on established information systems topics and emerging concepts, approaches and ideas. It is hoped that the papers herein contribute towards disseminating research and improving practice. The conference tracks highlighted at the 22nd International Conference on Information Systems Development (ISD 2013) were: Applications Data and Ontologies End Users Enterprise Evolution Industrial cases in ISD Intelligent Business Process Management Model Driven Engineering in ISD New Technologies Process Management Quality

Improving Enterprise Communication

Information System Development

CJEU - The most important cases in the field of direct taxation A great number of cases pending before the Court of Justice of the European Union (CJEU) concern the fundamental freedoms and direct taxation. In particular, the number of infringement procedures brought before the CJEU by the European Commission has been increasing year on year. The CJEU is still in the driver’s seat in the area of direct taxation. All judgements and pending cases, therefore, have to be carefully analyzed by academics as well as practitioners. This book discusses the most important cases in the field of direct taxation pending before or recently decided by the CJEU. Moreover, the national background of these cases is discussed and possible infringements of the fundamental freedoms and secondary EU law are analyzed. The analyses are presented by esteemed national and European tax law experts. By examining the preliminary questions, the arguments brought forward by the parties and existing CJEU case law, the authors provide insight into the possible reasoning of the Court. Moreover, this book goes to the heart of the national tax systems, exposing hidden obstacles to the fundamental freedoms.

Schriftenreihe IStR Band 110

CJEU - Recent Developments in Direct Taxation 2017

Peter ESSERS

Daniel Smit

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided in 2016 around the world.

Schriftenreihe IStR Band 108

Tax Treaty Case Law around the Globe 2017

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.

Michael Lang

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