Descriptive Essay My Unforgettable Travels - 1245 Words

My Unforgettable Travels Visualizing a picture in your head can be so captivating and it can bring back memories you’d never thought you would remember. I visualized a picture of a love lock bridge in Paris, France because it is something that stood out to me when I was traveling. Everything about this area was amazing and breathtaking. I will always remember traveling to France and Spain because of how different other countries are than the United States. Going to these places really made me love exploring and learning new things about the world. When going to France, I really depicted it as a different place than it was. I thought it was going to be just like New York City with a little touch of different people. I was so incredibly wrong. I went there in February of this year and ever since then I can’t wait to go back to different countries. The lifestyle there was so serene and mesmerizing all at once. You felt this almost joy of just walking into certain places. I went to multiple different places there. For example, I went to the Palace of Versailles, Hotel Des Invalides, the Eiffel Tower and then art museums with painting like the Mona Lisa and much more. These places were spectacular and so different. The work of every building was hand crafted and made me wish I could live in Paris. The people there were a little rude to Americans, but that didn’t stop me from trying to converse with them as much as I could. I would always look up differentShow MoreRelatedArt as an Embodied Imagination22095 Words   |  89 Pagesbecomes more prominent depending on the context. They argue that feelings play a central role in consumer decision making and merit serious investigation, which, for this study, means that intertwining mind and body is crucial for creating an unforgettable consumer experience. The effort afoot to restore embodied realism to social scientiï ¬ c inquiry (Johnson 1999; Lakoff and Johnson 1999) has generated some of the m ost exciting research into consumer behavior. In this article, we address the linksRead MoreArt as an Embodied Imagination22095 Words   |  89 Pagesbecomes more prominent depending on the context. They argue that feelings play a central role in consumer decision making and merit serious investigation, which, for this study, means that intertwining mind and body is crucial for creating an unforgettable consumer experience. The effort afoot to restore embodied realism to social scientiï ¬ c inquiry (Johnson 1999; Lakoff and Johnson 1999) has generated some of the most exciting research into consumer behavior. In this article, we address the links

Essay about Henry David Thoreaus Enlightenment and Ideas

Civil Disobedience is one of Henry David Thoreaus most famous essays. One of the major problems most critics see with this essay deals with Thoreaus seemingly contradictory statements about society from the beginning to the end. Barry Wood, a well-known critical writer, attributes this change in beliefs to the enlightenment of Thoreau in jail. While I agree with Wood that Thoreau does achieve a form of enlightenment, I will show that Thoreaus views regarding the society he lived in never actually changed throughout the essay: the only aspect of the essay that changed was Thoreaus means of attacking his society. Thoreau uses his enlightened state to shift from an overt, blatant form of attack to a more subtle, psychological one.†¦show more content†¦It is the quality of using ones mind that Thoreau designates as key to being human; therefore, the mass of men Thoreau describes earlier in the essay are sub-human because they lack this quality. Thoreau does not hint around his opinions in this first section, he makes sure the reader knows his views on society. However, at the end of the essay Thoreaus opinions become disguised. In order to understand why this occurs, we must explain briefly about the narrative and its significance in terms of Thoreaus views on society. The narrative section of Thoreaus essay gives perhaps the most insight into his life and the reasons for his changing ideas. Barry Wood describes the narrative as a key portion of the essay that brings about the awakening of vision, and spiritual renewal of Thoreau as he leaves the prison (Wood 421). As he is locked into a small cell, Thoreau reflects that he still did not once feel confined within the walls of stone and mortar that made up the jail he was forced to inhabit. He even goes so far as to say he believes the societal wall his townsmen would have to climb to be free is still a more difficult to one to climb or break through, before they could get to be as free as ThoreauShow MoreRelatedWalden and Transcendentalism Essay1545 Words   |  7 Pages Henry Thoreau’s masterpiece, Walden or a Life in the Woods, shows the impact transcendentalism had on Thoreau’s worldview. Transcendentalism is a philosophy that asserts the primacy of the spiritual over the material. Transcendentalism puts the emphasis on spiritual growth and understanding as opposed to worldly pleasures. Thoreau’s idea of transcendentalism stressed the importance of nature and being close to nature. He believed that nature was a metaphor for spiritual enlightenment. A walkRead MoreEssay The Incredible Henry David Thoreau1081 Words   |  5 Pagesthe integrity of their government. Henry David Thoreau was one such man. Henry Thoreau was born in Concord, Massachusetts to a successful pencil manufacturer John Thoreau and a strong-willed, quick-witted mother, Cynthia. Early on Henry enjoyed reading books and observing nature in solitude. He inherited the gift of gab and intellectual inquiry from his mother as well as both Puritan and abolitionist ideals. In 1837 he graduated from Harvard. In 1841 Henry moved into Ralph Waldo Emersons homeRead MoreThe True Transcendentalist: Thoreau and Emerson775 Words   |  3 Pages Throughout the years there has been multiple different types of American literary movements. Like the Puritan which was a time of when people wrote personal poems, journals, and their personal diaries. The next is Enlightenment period was a time in which it was mostly about science and logic also it included political writings. Another wonderful literary movement is the Romanticism which was filled with emotion, individuality, and nature. But one of the greatest literary movements the one that willRead MoreAnalysis Of Henry David Thoreau s Walden861 Words   |  4 Pagessits on their shoulder and tells them whether or not they are going to live or die each day; no one knows when he or she is going to die. If you knew you were going to die tomorrow would you live differently? Henry David Thoreau in an excerpt of his book Walden addresses complex philosophical ideas including death, simplifying everyday life and religion using: carefully chosen, meditative word choice, comparisons and other philosophies and stories intended for the audience of Concord during the 1800’sRead MoreThoreau And Transcendentalism1518 Words   |  7 Pages Henry David Thoreau’s words that â€Å"disobedience is the true foundation of liberty† and that â€Å"the obedient must be slaves† is a political statement that never lost its topicality during the Romantic era. Thoreau served as an important contributor to the philosophical and American literary movement known as New England Transcendentalism. Nature and the conduct of life are two central themes that are often weaved together in his essays and books that were published in the Romantic era of literatureRead MoreHenry David Thoreau, Walden, and Transcendental Values for Education1000 Words   |  4 PagesHenry David Thoreau was testing transcendental values when he took up residence at Walden Pond in 1845. During his time of simple living at the pond, he studied nature and applied those observations to h umans and everyday life. He was always learning from the woods, pond, meadows and animals in the natural world around him. Nature was his classroom and everything was an opportunity to learn. In Thoreau’s book, Walden , written at the pond, he theorized that education could come through an intimacyRead MoreHenry David Thoreau : A Transcendentalist1438 Words   |  6 PagesHenry David Thoreau: A Transcendentalist Religion and politics are perhaps the most important topics of discussion, and paradoxically, the ones least discussed. Our differences cause us to shy away from such depth in our conversations with others and it is a remarkable human being who can share her opinion honestly on the subjects, and even more so, transcend the current popular opinions of the time. Henry David Thoreau was a man such as this. He spoke out against an unjust society and challengedRead MoreDavid Thoreau s Life And The Early Works Of The Poet2145 Words   |  9 PagesDivinity School, his first wife’s death, his travels abroad, his study of Hinduism, and the works of the poet William Blake all have tremendous importance to the development of Transcendentalism. These ideas and his contributions to the movement would also influence most markedly Henry David Thoreau’s short life and the early works of the poet Walt Whitman. Ralph Waldo Emerson was born on May 25th, 1803, in Boston, Massachusetts to William Emerson and his wife Ruth Haskins Emerson. Emerson attendedRead MoreTranscendentalism Essay1866 Words   |  8 Pagesuniverse†. This led to Emerson resigning from his position and setting off to europe in 1832; attempting to learn some of what their philosophers thought. The English romantics had ideas that attracted Emerson with his newfound thoughts. Around this time, Emerson met with a man studying Immanuel Kant’s works named Frederick Henry Hedge. This allowed Emerson to learn of Kant and his transcendental idealism. While discussing Kant, Emerson only took certain pieces back to America with him. In 1833, EmersonRead MoreEarly American Literature Essay1511 Words   |  7 Pagesyears of development throughout American before it produced the first great generation of American writers such as, Washington Irving, Ralph Waldo Emerson, Nathaniel Hawthorne, Herman Melville, Henry David T horeau, Edgar Allan Poe and Emily Dickinson, just to name a few. There was a sense of enlightenment that spread over America in the 18th century. Many of the stories reflected the sense of freedom that came with the revolution. Consider Washington Irving, he was among the first American writers

The Acoustics of Speech in Individuals Who Stutter Free Essays

The Acoustics of Speech in Individuals who Stutter: Literature The Acoustics of Speech in Individuals who Stutter Introduction Research concerning acoustics in children who stutter, who have recovered from stuttering and adult stutterers shows that there is a lack of coherency in the data collected and reforms need to be made to the methods involved. The research that has been conducted on stuttering pertains mostly to the condition in children; stuttering is most prevalent in younger children and in most cases will be corrected by the later years of youth. Researchers working within the field are confronted by many problematic factors when both conducting their research and specifically in analysing data. We will write a custom essay sample on The Acoustics of Speech in Individuals Who Stutter or any similar topic only for you Order Now Diverse methods of data compilation and independent methods of interpretation mean that what one scientists concludes from an experiment may not support established theories and existing information on the subject. It can be assumed that analysis of acoustics in stuttering needs to be done with a specific framework that all researchers can work from. Issues like the diagnosis of stuttering complexes from mild, moderate and severe; the focus on frequency changes; and subtyping have all been encountered and brought up for review by researchers who wish to have a more fully rounded database from which to study stuttering in all its forms. A review of literature on the subject exposes many difficulties within the field of research and offers suggestions on how these might be addressed and overcome. Once a basic premise for observation, study and analysis is reached, the database will be much more comprehensive and useful to future research. Literature Review Acoustic analysis is the foundation to stuttering research conducted by many different scientists and scholars; the ways in which this research is conducted vary, however, and therefore can produce subsequently varied results and different ways of looking at stuttering itself. Some researchers are of the opinion that stuttering is heavily influenced by the actual perception of listeners, and that though analysis of reaction and perception of acoustics in stutterers it is possible to more fully comprehend those characteristics of speech that are a part of the disorder (Amir, Yairi). Through analysis of speech patterns in preschool aged children, the researchers concluded that interval duration in speech patterns must exceed 70 ms to be considered normal speech; under 50 ms interval duration was therefore attributed to stutterers. Some researchers have taken acoustic analysis to a new level with the use of the computer as a more failsafe analytical tool; due to a lack of specific acoustic parameters by which to classify stuttering the computer offers a more solid foundation for diagnosis and treatment (Brosch, Hage, Johannsen). Research conducted by these authors was inconclusive because of a lack of cohesive data on the subject, however it is their belief that with further study one might better understand the correlations between specific acoustics and the different stages of stuttering. The primary factor thought to be attributed to stuttering in different stages is age. Chang, Ohde and Conture believe that it is a disorganization of specific factors of speech, in particular the transition rate of speech formation, that can be cited as a precursor to stuttering. This research is key to the development of tuttering studies because currently there are very little data or theoretical models to explain the conditions that lead to stuttering in children. Through acoustic analysis not only of children and adults who currently stutter, but the acoustic analysis of children who will later develop a stutter, these researchers believe that more will be understood about the progression of the disorder and subsequen tly the treatment methods themselves. Given the generalities of much stuttering data, it has been concluded that subtyping of the disorder would help greatly with further research and the uture specialization of treatments and diagnoses (Yairi). In this case, the acoustic analysis carried out by researchers would be made very specific and varied: attention would be paid to transition rates, vowel duration, particularities of speech disfluency and other inconsistencies attributed to stuttering. Yairi’s research has yet to lead to subtypes of the disorder, however the belief remains that through more acoustic analysis, enough data will be gathered to start separating the disorder into more than one general field. Frequency changes and second formant transitions in reschool children who stutter persistently and who have recovered from the condition show general differences in speech patterns between the two groups. Most poignant was the fact that the research showed frequency ch anges in persistent stutterers were discreet while the recovery group showed marked frequency changes (Subramanian, Yairi, Amir). Research such as this helps to support Yairi’s theory that subtyping may be useful in the field. Along these lines, Armson and Kalinowski pointed out the difficulties in performing acoustic analysis on stutterers when the condition itself may be changing the data. These researchers feel that to properly assess acoustic data they must learn how to separate those factors out which cause stuttering, and which are inherent in individuals only after one has begun to stutter. The acoustics of one individual in a pre-stuttering state might show related frequencies and vowel duration, as well as the same speech rate and consonant-vowel repetitions to that of a stutterer; the researchers maintain, however, that the cognitive functions of one who stutters might be significantly different that that of an individual who does not stutter but will later develop the disorder. Cognitive and acoustic factors of stuttering are currently inextricable from those of the prestutterer, and until these can be separated the data gathered on the subject will remain generalized and of less value than it might be. As well as this, information on acoustics must be analyzed both during the stutter and during normal speech in the same individual. Paden, Abrose and Yairi studied the phonological acoustics of stutterers and non-stutterers to ascertain whether there were any significant differences between the two groups. Through the observation of children over a two-year span, attention was paid to not only current differences in the phonological skills of the children but the changes in those skill levels over time. They found that the phonological skill level of children who had recovered from stuttering were markedly higher than that of children who currently stutter; over the course of two years, however, the skill levels were developed and no significant difference could be shown. Flipsen Jr. , Hammer and Yost point out that perhaps the major flaw in the field is the fact that Clinicians are esponsible for identifying stuttering cases and labelling them either mild, moderate or severe. This means that Clinicians must rely on their own individual acoustic analysis to interpret the severity of stuttering case by case, and in doing so are likely to be inconsistent. Personal analysis of the acoustics of several different individuals who stutter means that although analysis is based on regimented di sfluency factors, such as vowel duration and frequency, relying solely on acoustic interpretation though listening cannot be scientifically sound. The researchers propose that a better method must be contrived in a study that supports Brosch, Hage and Johanssen’s computer analysis theory. In keeping with the idea that research on stuttering must be more specialized, Louis, Myers, Faragasso, Townsend and Gallagher have studied a particular disorder that is often attributed to stutterers but which they insist is a different disorder. Cluttering is an irregularity that has to do with the rate of speech: people with this condition will either speak more rapidly than normal or they will have inconsistencies in the rate of speech. While many researchers will have cluttering placed in the same field as stuttering, Louis (et al) believes that it is generalizations like this that cripple the scientific community. Acoustic analysis of cluttered speakers shows clearly that the condition is not the same as stuttering: while stuttering has a more clustered effect on the phonemes of speech, cluttering is less specific to certain vowel and consonant groups. Gohinho, Ingham, Davidow and Cotton have discovered that in treatment of stuttering, the reduction of short-deviation phonetic intervals has a direct affect on the condition. Acoustic analysis of normal stuttering and manipulated speech in normal stutterers suggested that phonetic interval distribution in the two speech groups were generally different; this theory was inconclusive. In terms of treatment, however, it has been useful and is thought to offer new possibilities in treatment procedures. Ingham, Fox, Ingham, Xiong, Zamarripa, Hardies and Lancaster conducted their own research based on gender differences between stutterers. Data were collected in terms both of acoustics and of cerebral blood flow in adults. While females are more likely to recover from stuttering in childhood and males are generally more susceptible to the condition, this research found that the stages of recovery were not significantly different between the gender groups. The researchers concluded that chronic stuttering was related to abnormal speech-motor and auditory region interactions. Healey and Ramig conducted research into stuttering that was specific to treatment, specifically treatment length and its effect on differing severities of the condition. Acoustic analysis of patients undergoing treatment showed that the severity of each case made no significant difference to recovery and the transition from one level to another; similarly treatment time made no difference in the progression and recovery of stutterers. Max and Caruso also explored treatment options, finding that fluency adaptation through the process of repeating specific readings was improved over other methods of treatment. With specific phonological aspects in the readings, designed to ontain certain phrases and vowel-consonant groups that give stutterers trouble normally, these were given to treatment patients to repeat until any changes were observed in speech patterns. Repetition treatments have traditionally very popular and due to their superiority over many other methods these treatments continue to dominate in the field. Specific study of the different aspects of language and acoustics means that a scenario for stuttering can be pieced together slowly and fo rmed of many different speech parts as well as cerebral and other physical data (Natke, Grosser, Sandrieser, Kalveram). Research into the effect of stressed syllables within speech and stuttering was conducted with reference to the length of such syllables. Natke and his colleagues hypothesized that stressed syllables were responsible for stuttering in many individuals, and studies proved that these were indeed catalysts for stuttering in most cases. Whether or not duration of stressed syllables has anything to do with disfluency is not yet apparent. Currently, Yaruss believes, no correlation can be drawn between utterance rates and response time latency. His own research explored these and consequently still was not supportive of the theory that conversational speaking rates were actually related to response time latency. He does believe that if more research were conducted into this area, a correlation would indeed be found; inadequate methods of acoustic analysis are cited as the reason why hypotheses such as these remain unproven. In Yairi’s response to the criticisms of Wingate on his theories of diversity in the field of acoustic study, he asserts that there are many different ways to study stuttering and that these varying methods should be valued. Wingate proposes, like many scholars, that there should only be one method of study so that subsequent data compilations are relevant to one another and more easily formed into future subdivisions of the disorder. While Yairi does not dispute the value of specialization within the field for the sake of greater knowledge and better treatment plans, he does maintain that a fundamental diversity among researchers is a positive attribute. In terms of acoustic analysis, this means that the lack of cohesion between existing research would persist. Evaluation of Published Research and Conclusions Overwhelmingly, researchers in the specific linguistic field that study stuttering and its related conditions are asking for continuity in research methods and data organization. While independent researchers and study groups might be able to find their own way of cultivating date, studying acoustics of stutterers, non-stutterers and recovering stutterers and interpreting this data, it is essentially of no use to the rest of the field unless aspects of the study can be repeated. Researchers like Brosche, Hage and Johanssen are particularly forward thinking in their approach to acoustic analysis, because unlike so many of their colleagues they are not continuing to rely on what they believe to be inferior techniques. The use of computer analysis in terms of stuttering acoustics not only means that a discrepancy between professionals can be ruled out in the future but that further information can be gathered concerning speech patterns that are undistinguishable to the unaided ear. Yairi is also correct when he says that there is more than one way to study stuttering. If all researchers relied on exactly the same techniques then no breakthroughs could be expected in the field; despite this fact most acoustic analysts who wish to better understand stuttering simply want a basic framework upon which to base their own studies and interpret the results of others. If a certain degree of flexibility could be maintained in acoustic analysis while certain fundamental factors were incorporated, researchers would be in a better position to interpret and present their own results in relation to the work of colleagues. Factors that might feature in each research project might nclude vowel duration, second formant transition, conversational speed and other specific disfluency forms. By using these factors in all research related to stuttering, whether the study is based on such factors or not, will mean that although two research projects might be based on completely different theories the results can still be comparatively put together. If one research projec t focuses on brain activity and blood flow during stuttered speech, and another focuses on frequency, results may still have relevance to one another because of the use of basic acoustic analysis. Coherency is needed in this field of research so that results and future treatments are made clearer. Implementing basic acoustic analyses in every research project will help to form a stuttering database that can be referenced by every researcher. Reference List Amir, O. , Yairi, E. (2002). The effect of temporal manipulation on the perception of disfluencies as normal or stuttering. Journal of Communication Disorders, vol. 35, 63-82. Armson, J. , Kalinowski, J. (1994). Interpreting results of the fluency speech paradigm in stuttering research: Difficulties in separating cause from effect. Journal of Speech and Hearing Research, vol. 37, 69-82. Brosch, S. , Hage, A. , Johanseen, H. (2002). Prognostic indicators for stuttering: the value of computer-based speech analysis. Brain and Language, vol. 82, 75-86. Chang, S. , Ohde, R. , Conture, E. , (2002). Coarticulation and Formant Transition Rate in Children who Stutter. Vanderbilt University. Flipsen Jr. , P. , Hammer, J. , Yost, K. (2005). Measuring Severity of Involvement in Speech Delay: Segmental and Whole Word Measures. American Journal of Speech-Language Pathology, vol. 14, 298-312. Godinho, T. , Ingham, R. , Davidow, J. , Cotton, J. (2006). The Distribution of Phonated Intervals in Individuals who Stutter. Journal of Speech, Language and Hearing Research, vol. 49, 161- 171. Healey, E. , Ramig, P. (1989). The Relationship of Stuttering Severity and Treatment Length to Temporal Measures of Stutterers’ Perceptually Fluent Speech. Journal of Speech and Hearing Disorders, vol. 54, 313-319. Ingham, R. , Fox, P. , Ingham, J. , Xiong, J. , Zamarippa, F. , Hardies, L. , Lancaster, J. (2004). Brain Correlates of Stuttering and Syllable Production: Gender Comparisons and Replication. Journal of Speech, Language and Hearing Research, vol. 47, 321- 341. Louis, K. Myers, F. , Faragosso, K. , Townsend, P. , Gallaher, A. (2004). Perceptual Aspects of Cluttered Speech. Journal of Fluency Disorders, vol. 29, 213-235. Max, L. , Caruso, A. , (1998). Adaptation of Stuttering Frequency During Repeated Readings: Associated Changes in Acoustic Parameters of Perceptually Fluent Speech. Journal of Speech, Language and Hearing Research, vo l. 41, 1265-1281. Natke, U. , Grosser, J. , Sandrieser, P. , Kalveram, K. (2002). The Duration Effect of the Stress Component in Stuttering. Journal of Fluency Disorders, vol. 27, 305-318. TermPaper? Blog. com Paden, E. Ambrose, N. , Yairi, E. (2001). Phonological progress during the first 2 years of stuttering. University of Illinois at Urbana-Champaign. Subramanian, A. , Yairi, E. , Amir, O. (2003). Second formant transitions in fluent speech of persistent and recovered preschool children who stutter. Journal of Communication Disorders, vol. 36, 59-75. Yairi, E. (2001). Letters to the Editor. Journal of Speech, Language and Hearing Research, vol. 44, 585-597. Yairi, E. (2007). Subtyping Stuttering I: A Review. Journal of Fluency Disorders, vol. 32, 165-196. Yaruss, J. (1997). Utterance Timing and Childhood Stuttering. Elsevier Science. How to cite The Acoustics of Speech in Individuals Who Stutter, Papers

Tax Competition and BEPS of Globalization †MyAssignmenthelp.com

Question: Discuss about the Tax Competition and BEPS of Globalization. Answer: Introduction: The Dutch authority in a taxation ruling concluded that the amount paid by the Starbucks in Netherland for coffee roasting activity is an arm length transaction. The European Commission examined the ruling of the Dutch authority. The remuneration paid by the Starbucks is determined based on the report of transfer pricing that applied the TNMM. This amount is calculated based on the fixed percentage of cost base that includes all the cost to which star buck manufacturing has added value. The profit earned in excess of the taxable remuneration by the star buck manufacturing is transferred to a group outside Netherland as a tax deductible royalty expenses. This policy of the star bucks was criticized by the commission the two grounds. The first criticism was for inflated price that Starbucks manufacturing paid to the Switzerland Starbucks for the coffee beans. The second criticism was that the royalty paid for the Roasting of coffee beans does not reflect the current market value (Gorms en, 2016). The arm's length principle is applied based on the comparing the situation of transaction between two independent companies and intra group transactions. The comparison can be useful if the economic entities compared is sufficiently comparable. As per Article 8b of Dutch Corporate Income Tax Act 1969 and in accordance with international standards, the APS should be used in determining the arm's length remuneration for the purpose of transfer pricing. It is assumed that Starbucks manufacturing will use the arm's length transfer prices in conducting transactions with the related distributors. It should be noted that there is a need to test whether the company in incomparable situations are actually and legally hand equally (Gunn Luts, 2015). In the system the commission does not apply the noncommissioned OECD convention for model tax but focuses is on the general principles of equal fiscal treatment under the European law. The methodology that has been adopted for providing the report regarding Transfer pricing does not provide an approach that is reliable in determining the market result. Therefore, it can be said that the arm's length principle has not been fulfilled. In the court of Justice, it was confirmed that if in the case of intergroup transfers the method of tax does not comply with the arm's length principle then this would mean that selective advantage is given to the concerned company (Thomson Hardwick, 2017). Application of OECD and BEPS guidelines In this case, OECD guidelines are used for recommending the method for determining the arm's length pricing. There are wide range of OECD guidelines and the application of different guidelines will result in wide range of amount for taxable basis. It has been seen that based on the facts and circumstances of the individual taxpayers not all the approximations made are correct. The OECD guideline in paragraph 6.1 provides that royalty is a recurring payment based on the output of the user and in some cases based on Profit. In this case, the payment of royalty is not based on output, sale or profit. It has been saying that royalty fluctuates from year to year but the sales have not shown the same the fluctuations. Therefore, in this case it can be said that the OECD guidelines has not been followed in this case (Gonzlez, 2017). In this case, the European Commission scrutinizes the ruling of the Luxembourg tax authorities. The ruling confirmed the taxable income of the entity Fiat that is based in Luxembourg and the financial services that is provided by entity to other group companies. The company determines the taxable income based on the principle of transactional net margin method. In this case of Fiat taxable income is ascertained by determining the required rate of return on the risk capital by using the method of Capital Asset pricing model (Lyal, 2015). It was argued by the commission that the complex and artificial method used for calculating the taxable profit does not reflect the existing market conditions. The Commissioner further argued that certain unjustifiable assumptions was made in determining the capital base. The estimated remuneration that is used for determining the taxable income is very low compared to the market rate. Therefore, it was concluded that fiat has paid tax only on small p ortion of their earnings. The policy followed by the company resulted in taxable profit that is 20 times lower than the existing market conditions (Wattel, 2016). Consideration of ECJ in determining the arms length transaction In the case of Fiat, it is the opinion of the European Commission that due to the unjustifiable economic assumptions in the application of transfer pricing method the capital base is lower than the actual capital. In addition to this in the Fiat case, it is the opinion of the European commission that the remuneration applied to the lower capital base does not reflect the actual market rate (Mason, 2017). The Fiat finance and trade provided financial services to intragroup car companies. As a result, the company was engaged in different activities which many fiat companies across Europe. On comparing the activities of the Fiat finance with other banks, the income of the Fiat finance could have been determined. However, the ruling suggested a more complex method of determining income. In accordance with the OECD transfer, pricing guidelines transfer price should be set at the market rate. In this case Fiat Finance services has provided loan to inter group companies at a lower rate. Therefore, it can be said that transfer-pricing guideline of OECD has been violated. In this case, the organization for economic cooperation and development guideline has been be misapplied (Chisholm, 2017). The OECD transfer pricing guidelines for the multinational companies was first drafted on June 27 1995. This guideline have been developed continuously and updated regularly resulting in the current guideline. In the OECD Guidelines the guidance relating to the implementation of the arm's length principle that is used for valuation for the tax purpose in the cross border transactions are provided. In the globalized economy, it is the responsibility of the governments to ensure that the multinational enterprises does not transfers the profit artificially to other jurisdictions. The government should ensure that the tax base reported by the multinational enterprise should reflect the economic activity undertaken by the enterprise in that country. From the taxpayers prospective the transfer pricing guideline is important to eliminate the double taxation in the cross border transaction between the associated enterprises (Cachia, 2017). The transactional method is given priority by the OE CD guidelines as it is considered the most direct method of determining comparability. In case the transactional method is not applicable then transactional net margin method or profit split method is used for establishing comparability. In the OECD guidelines, the CUP is not given priority in the transactional method. If the results of the transactions are comparable then according to the OECD rule, business strategies are considered (Mason, 2017). The strategies includes expansion of market, market penetration, savings of cost and others. In the transactional net margin method, the profitability of a state of transaction is compared with other transactions. This is used to determine whether transfer between inter group companies are in par with other unrelated companies. The BEPS report suggested transfer pricing guidelines this amendments was implemented in the OECD guidelines. On analyzing the cases, it can be seen that the European Commission has found that advance pricing agre ement provided by Netherland to Starbucks and Luxembourg to Fiat subsidiaries are illegal state aids. In the preliminary decision, the commission concluded that selective tax advantage was granted by Luxembourg to fiat financing company. In Netherland, selective tax advantage was given to Starbuck coffee roasting company star buck manufacturing. In the case of Starbucks, it was the opinion of the European Commissioner that advance-pricing agreement has sanctioned wrongly the accessories payments made to be related parties. The commission found that because of this sanction most of the profit of the company was shifted abroad where it was not taxed. The Commissioner held that the service provided by the Fiat finance to other subsidiaries is similar to that of a bank. Therefore, it was unacceptable to calculate the taxable profit based on percentage return on capital employed for the financing activity. Therefore, it can be seen that the commission has considered and implemented the O ECD guidelines and BEPS recommendation for determining the arm's length transaction for intra group services (Douma Kardachaki, 2016). The Article 107 (1) of the Treaty functioning of the European Union provides that if a member states provides any aid through the resources of the state that distorts the competition among the member states is considered as illegal and incompatible in the trade between inter member states. In determining the state aid the concept of advantage and selectivity are distinctly important (Douma Kardachaki, 2016). However, in the recent cases of the commission it can be seen that the focus has been the examination of "selective advantage" rather than separately analyzing the requirements. It can be seen that the Commissioner has deviated from its earlier practice where it consistently assessed the presence of selectivity and advantage in a separate manner. In the earlier state aid investigations, the commission did not challenge the application of its own transfer-pricing rule by the member states for specific transfer pricing agreements. It has been seen that the new approach of the comm ission has immensely affected the practical applications. In the transfer pricing cases, it can be seen that the commission has disagreed with the application of the principle of arm's length transactions. It should be noted that the commission has not challenged the transfer pricing law that have been implemented on the involved countries instead (Evertsson, 2016). However, the commission has challenged the transfer prices that have been agreed on the tax ruling that are not in consistent with commissions interpretation of the arms length transaction. In these cases, the Commission has arrived at different conclusions that the tax officials and the commission regarded it the absolute truth. The commission concluded that the decision of the tax officials have provided selective tax advantages without considering the fact that weather similar advantages would have been granted to comparable circumstances. The consequences of this conclusion is that any administrative decisions relati ng to tax is a subject to 10 years uncertainty. The State aid is not a suitable tool to deal with complex transfer price in situation that are covered in the text rulings. Therefore, number of concern is raised in the investigation of the commission (Bauckloh et al., 2017). The fundamental principle of a tax law is that changes are not applied retrospectively but in future. It is necessary that the companies should be able to reliably estimate the tax obligation so that they can appropriately structure their investment. The tax rulings only deals with domestic tax laws and treaty law for specific business activity or investment structure. The changing of the tax rule with retrospective effect for unpaid taxes for up to 10 years questions the certainty of the laws and rules. The BEPS action plan concluded that the premises on which the loopholes in the Global tax system is address is through adoption of legal changes in the Global coherence. It is done by providing the business predi ctability and certainty. The commission did not respect these basic premises as the decision lacks Global coherence and have increased uncertainty (Morgan, 2016). In the European Union the members sovereign Nations and has the right to design their own tax rules. It can be said that state aid cannot be used as a tool to undermine the sovereignty of the member states. The investigation of the commission currently seems to be violating the sovereignty of the member states. The organization for economic cooperation and development has voice concerned in its BEPS Action Plan. The concern was that the consensus-based framework is replaced with the unilateral measures. This could lead to chaos and uncertainty in the Global tax system. In addition to this, it could also lead to the emergence of double taxation system. In providing its recommendations, OECD adheres to ambitious schedule in order to combat the perception of tax avoidance by the multinational Enterprises. The action of the co mmission undermine the effort of the organization for economic cooperation and development for establishing a conscious based framework post BEPS. In selecting the appropriate method for transfer, pricing the OECD guideline has provided five methods to approximate the arm's length transaction between two companies of the same group. These methods are comparable uncontrolled price method, cost plus method, the transaction net margin method, the resale minus method and the transactional profit split method. In the OECD guidelines, there is a distinction between transactional profit method and traditional transaction methods (Campbell Helleloid, 2016). The guidelines have declared a preference for traditional method of transactions like CUP over the transactional methods such as TNMM. It is explain in the guideline that multinational corporations should retain the freedom to apply the method that is described in the guidelines for establishing the transfer price if the methods satisfies the consulate principal. The European Court of Justice has earlier examined the issue of transfer pricing rule in the cases of direct taxation. In recent years, the European Court of Justice provides a more substantial judicial discussion on the applicability and liability of transfer pricing rules particularly the arms length transactions. The cases have shown that European Court of Justice wants more reconciliation between the traditional Transfer pricing rule and the requirements related to fundamental freedoms (Hassan, 2016). The decisions of the European court of Justice has shown that the concept of arm's length transaction is applied in a more general way in the cases. In this background, it can be said that a reconciliation between the European tax law and treaty law is possible. The analysis if the recent decision have shown that European Court of Justice has moved the transfer pricing control in a state that the arm's length standard will gradually be eroded and a new model has to be developed for its replacement. The main reason for the replacement will be that the court does not give importance to the economic consideration of the multinational corporations. Therefore, it can be said that OECD guideline is more desirable than the guideline provided by the European court of Justice (Kavanagh Robins, 2015). The decision of case of the commission has huge implications. It is predicted that because of the decision of the commission it has become more troublesome for the European Union States to give favorable tax rulings to the companies. The example of the recent cases are the state aid that is given to Apple by Ireland. In particular, these decisions have shown that any favorable tax rulings is regarded as an illegal favorable benefit to the company (Haslehner, 2016). The European court of Justice by the decision of these cases is sending a clear message that any favorable benefits given to a multinational enterprise by remember state through tax ruling is illegal state aid. It is because this hampers the competition among the markets of the member states. The European Court of Justice argues that justifiable basis should be used for collecting tax. The European Court of Justice states that unjustifiable and complex process should not be used for computing tax that is payable. Therefore , it can be said that European court of Justice have ensured that the tax collection system becomes less Complex and is based on a justifiable ground. Based on this it can be concluded that the above cases and the decision of the European Court of Justice has simplified or improved the taxation system currently prevalent (Honore, 2015). The European Commission has highlighted the need for supporting the developing countries for utilizing the domestic resources by encouraging development in line with good system of taxation. In this section the transfer pricing as adopted by the developing countries are discussed. The initiative taken by the European Commission has a very favorable outcome in the development and overall business environment of the developing countries. The ECJ has argued that the transfer pricing and the arms length principle helps in maintaining the fair market value and thus encourages competition. This has a positive impact on the activities related to international trade and multinational Enterprises. The globalization has encouraged cross border transactions between the related entities as a result the transfer pricing has become important agenda. It can be estimated that among all the business transaction worldwide the two third of them is between inter group companies. It is more important for the developing countries because the economies have recently opened up (Law, 2014). This process of opening the economy have attracted investment from the large multinational enterprises as foreign direct investment. In the absence of any Transfer pricing guideline, it will not be possible for tax administration and the multinational Enterprise to refer to a proper guideline. However, it has been seen that the developing countries face is a lot of trouble dealing with Transfer pricing. The main problem is that the local administration is largely inexperienced with regard to transfer pricing. The organization for economic cooperation and development has initiated many efforts for establishing common grounds in the transfer pricing matters (Blockx, 2016). In order to provide sound recommendations relating to transfer pricing the generally the considerations should be made about the economic and political conditions. The sound recommendations can be made after assessing the legal prec onditions and preconditions related to the tax matters. Therefore, it can be said that the consideration of the European Court of Justice has helped the nonmember states or developing countries in understanding the meaning of transfer pricing. The considerations has helped the developed countries to develop a regulation that will not encourage complex on unjustifiable basis for calculating tax. The decision will promote a more simple and justifiable basis of taxation in the developing countries. It is expected that multinational Enterprises operating in the developing countries will transfer products to related enterprises at the market price and not add discount price. Hence, it will help to maintain the competition in the market. Based on the above discussion it can be said that the consideration of the European Court of Justice has helped the developing countries to maintain a more competitive market (Cerioni, 2016). Reference Bauckloh, T., Hardeck, I., Wittenstein, P. U., Zwergel, B. (2017). Do Some Multinational Firms Benefit from Competitive Tax Advantages in Europe? Evidence from Stock Price Reactions to EU State Aid Investigations. Blockx, J. (2016). The Belgian Excess Profit Exemption: Tax Incentives for Multinational Groups as State Aid.Journal of European Competition Law Practice. Cachia, F. (2017). Analysing the European Commissions Final Decisions on Apple, Starbucks, Amazon and Fiat Finance Trade.EC Tax Review,26(1), 23-35. Campbell, K., Helleloid, D. (2016). Starbucks: Social responsibility and tax avoidance.Journal of Accounting Education,37, 38-60. Cerioni, L. (2016). Book Review: Advanced Issues in International and European Tax Law.Intertax,44(3), 284-287. Chisholm, B. C. (2017). ICRICT Looking to a Future of Actual Tax Reform: An Organizational Analysis of the Independent Commission for the Reform of International Corporate Taxation.U. Cin. L. Rev.,85, 231-319. DeNovio, N. J., Righini, E., Gibbs, N. N. (2016). State Aid: What It Is, and How It May Affect Multinationals and Tax Departments.Tax Executive,68, 15. Douma, S., Kardachaki, A. (2016). The Impact of European Union Law on the Possibilities of European Union Member States to Adapt International Tax Rules to the Business Models of Multinational Enterprises.Intertax,44(10), 746-754. Evertsson, N. (2016). Corporate tax avoidance: a crime of globalization.Crime, law and social change,66(2), 199-216. Gonzlez, S. M. (2017). State Aid, Tax Competition and BEPS: Comments on the European Commission's Decisions on Transfer Pricing Rulings. Gormsen, L. L. (2016). EU State Aid Law and Transfer Pricing: A Critical Introduction to a New Saga.Journal of European Competition Law Practice,7(6), 369-382. Gunn, A., Luts, J. (2015). Tax Rulings, APAs and State Aid: Legal Issue.EC Tax Review,24(2), 119-125. Haslehner, W. (2016). Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law. InState Aid Law and Business Taxation(pp. 133-161). Springer Berlin Heidelberg. Hassan, M. (2016). Global Tax news.TAXtalk,2016(57), 14-17. Honore, M. (2015). State Aid and Taxation-All Clear. Kavanagh, J., Robins, N. (2015). Corporate Tax Arrangements Under EU State Aid Scrutiny.Eur. St. Aid LQ, 358. Law, B. V. (2014). Transfer pricing: A step forward for Albania.changes. Lyal, R. (2015). Transfer pricing rules and state aid.Fordham Int'l LJ,38, 1017. Mason, R. (2017). State Aid Special ReportPart 2: Legitimate Expectations. Mason, R. (2017). Tax Rulings as State Aid FAQ. Morgan, J. (2016). Corporation tax as a problem of MNC organisational circuits: The case for unitary taxation.The British Journal of Politics and International Relations,18(2), 463-481. Thomson, A., Hardwick, E. (2017). The European Commission's Application of the State Aid Rules to Tax: Where Are We Now?.Journal of Taxation of Investments,34(3). Wattel, P. J. (2016). Stateless Income, State Aid and the (Which?) Arms Length Principle.Intertax,44(11), 791-801. Wattel, P. J. (2016). The Cat and the Pigeons: Some General Comments on (TP) Tax Rulings and State Aid After the Starbucks and Fiat Decisions. InState Aid Law and Business Taxation(pp. 185-194). Springer Berlin Heidelberg.

Tax Competition and BEPS of Globalization †MyAssignmenthelp.com

Question: Discuss about the Tax Competition and BEPS of Globalization. Answer: Introduction: The Dutch authority in a taxation ruling concluded that the amount paid by the Starbucks in Netherland for coffee roasting activity is an arm length transaction. The European Commission examined the ruling of the Dutch authority. The remuneration paid by the Starbucks is determined based on the report of transfer pricing that applied the TNMM. This amount is calculated based on the fixed percentage of cost base that includes all the cost to which star buck manufacturing has added value. The profit earned in excess of the taxable remuneration by the star buck manufacturing is transferred to a group outside Netherland as a tax deductible royalty expenses. This policy of the star bucks was criticized by the commission the two grounds. The first criticism was for inflated price that Starbucks manufacturing paid to the Switzerland Starbucks for the coffee beans. The second criticism was that the royalty paid for the Roasting of coffee beans does not reflect the current market value (Gorms en, 2016). The arm's length principle is applied based on the comparing the situation of transaction between two independent companies and intra group transactions. The comparison can be useful if the economic entities compared is sufficiently comparable. As per Article 8b of Dutch Corporate Income Tax Act 1969 and in accordance with international standards, the APS should be used in determining the arm's length remuneration for the purpose of transfer pricing. It is assumed that Starbucks manufacturing will use the arm's length transfer prices in conducting transactions with the related distributors. It should be noted that there is a need to test whether the company in incomparable situations are actually and legally hand equally (Gunn Luts, 2015). In the system the commission does not apply the noncommissioned OECD convention for model tax but focuses is on the general principles of equal fiscal treatment under the European law. The methodology that has been adopted for providing the report regarding Transfer pricing does not provide an approach that is reliable in determining the market result. Therefore, it can be said that the arm's length principle has not been fulfilled. In the court of Justice, it was confirmed that if in the case of intergroup transfers the method of tax does not comply with the arm's length principle then this would mean that selective advantage is given to the concerned company (Thomson Hardwick, 2017). Application of OECD and BEPS guidelines In this case, OECD guidelines are used for recommending the method for determining the arm's length pricing. There are wide range of OECD guidelines and the application of different guidelines will result in wide range of amount for taxable basis. It has been seen that based on the facts and circumstances of the individual taxpayers not all the approximations made are correct. The OECD guideline in paragraph 6.1 provides that royalty is a recurring payment based on the output of the user and in some cases based on Profit. In this case, the payment of royalty is not based on output, sale or profit. It has been saying that royalty fluctuates from year to year but the sales have not shown the same the fluctuations. Therefore, in this case it can be said that the OECD guidelines has not been followed in this case (Gonzlez, 2017). In this case, the European Commission scrutinizes the ruling of the Luxembourg tax authorities. The ruling confirmed the taxable income of the entity Fiat that is based in Luxembourg and the financial services that is provided by entity to other group companies. The company determines the taxable income based on the principle of transactional net margin method. In this case of Fiat taxable income is ascertained by determining the required rate of return on the risk capital by using the method of Capital Asset pricing model (Lyal, 2015). It was argued by the commission that the complex and artificial method used for calculating the taxable profit does not reflect the existing market conditions. The Commissioner further argued that certain unjustifiable assumptions was made in determining the capital base. The estimated remuneration that is used for determining the taxable income is very low compared to the market rate. Therefore, it was concluded that fiat has paid tax only on small p ortion of their earnings. The policy followed by the company resulted in taxable profit that is 20 times lower than the existing market conditions (Wattel, 2016). Consideration of ECJ in determining the arms length transaction In the case of Fiat, it is the opinion of the European Commission that due to the unjustifiable economic assumptions in the application of transfer pricing method the capital base is lower than the actual capital. In addition to this in the Fiat case, it is the opinion of the European commission that the remuneration applied to the lower capital base does not reflect the actual market rate (Mason, 2017). The Fiat finance and trade provided financial services to intragroup car companies. As a result, the company was engaged in different activities which many fiat companies across Europe. On comparing the activities of the Fiat finance with other banks, the income of the Fiat finance could have been determined. However, the ruling suggested a more complex method of determining income. In accordance with the OECD transfer, pricing guidelines transfer price should be set at the market rate. In this case Fiat Finance services has provided loan to inter group companies at a lower rate. Therefore, it can be said that transfer-pricing guideline of OECD has been violated. In this case, the organization for economic cooperation and development guideline has been be misapplied (Chisholm, 2017). The OECD transfer pricing guidelines for the multinational companies was first drafted on June 27 1995. This guideline have been developed continuously and updated regularly resulting in the current guideline. In the OECD Guidelines the guidance relating to the implementation of the arm's length principle that is used for valuation for the tax purpose in the cross border transactions are provided. In the globalized economy, it is the responsibility of the governments to ensure that the multinational enterprises does not transfers the profit artificially to other jurisdictions. The government should ensure that the tax base reported by the multinational enterprise should reflect the economic activity undertaken by the enterprise in that country. From the taxpayers prospective the transfer pricing guideline is important to eliminate the double taxation in the cross border transaction between the associated enterprises (Cachia, 2017). The transactional method is given priority by the OE CD guidelines as it is considered the most direct method of determining comparability. In case the transactional method is not applicable then transactional net margin method or profit split method is used for establishing comparability. In the OECD guidelines, the CUP is not given priority in the transactional method. If the results of the transactions are comparable then according to the OECD rule, business strategies are considered (Mason, 2017). The strategies includes expansion of market, market penetration, savings of cost and others. In the transactional net margin method, the profitability of a state of transaction is compared with other transactions. This is used to determine whether transfer between inter group companies are in par with other unrelated companies. The BEPS report suggested transfer pricing guidelines this amendments was implemented in the OECD guidelines. On analyzing the cases, it can be seen that the European Commission has found that advance pricing agre ement provided by Netherland to Starbucks and Luxembourg to Fiat subsidiaries are illegal state aids. In the preliminary decision, the commission concluded that selective tax advantage was granted by Luxembourg to fiat financing company. In Netherland, selective tax advantage was given to Starbuck coffee roasting company star buck manufacturing. In the case of Starbucks, it was the opinion of the European Commissioner that advance-pricing agreement has sanctioned wrongly the accessories payments made to be related parties. The commission found that because of this sanction most of the profit of the company was shifted abroad where it was not taxed. The Commissioner held that the service provided by the Fiat finance to other subsidiaries is similar to that of a bank. Therefore, it was unacceptable to calculate the taxable profit based on percentage return on capital employed for the financing activity. Therefore, it can be seen that the commission has considered and implemented the O ECD guidelines and BEPS recommendation for determining the arm's length transaction for intra group services (Douma Kardachaki, 2016). The Article 107 (1) of the Treaty functioning of the European Union provides that if a member states provides any aid through the resources of the state that distorts the competition among the member states is considered as illegal and incompatible in the trade between inter member states. In determining the state aid the concept of advantage and selectivity are distinctly important (Douma Kardachaki, 2016). However, in the recent cases of the commission it can be seen that the focus has been the examination of "selective advantage" rather than separately analyzing the requirements. It can be seen that the Commissioner has deviated from its earlier practice where it consistently assessed the presence of selectivity and advantage in a separate manner. In the earlier state aid investigations, the commission did not challenge the application of its own transfer-pricing rule by the member states for specific transfer pricing agreements. It has been seen that the new approach of the comm ission has immensely affected the practical applications. In the transfer pricing cases, it can be seen that the commission has disagreed with the application of the principle of arm's length transactions. It should be noted that the commission has not challenged the transfer pricing law that have been implemented on the involved countries instead (Evertsson, 2016). However, the commission has challenged the transfer prices that have been agreed on the tax ruling that are not in consistent with commissions interpretation of the arms length transaction. In these cases, the Commission has arrived at different conclusions that the tax officials and the commission regarded it the absolute truth. The commission concluded that the decision of the tax officials have provided selective tax advantages without considering the fact that weather similar advantages would have been granted to comparable circumstances. The consequences of this conclusion is that any administrative decisions relati ng to tax is a subject to 10 years uncertainty. The State aid is not a suitable tool to deal with complex transfer price in situation that are covered in the text rulings. Therefore, number of concern is raised in the investigation of the commission (Bauckloh et al., 2017). The fundamental principle of a tax law is that changes are not applied retrospectively but in future. It is necessary that the companies should be able to reliably estimate the tax obligation so that they can appropriately structure their investment. The tax rulings only deals with domestic tax laws and treaty law for specific business activity or investment structure. The changing of the tax rule with retrospective effect for unpaid taxes for up to 10 years questions the certainty of the laws and rules. The BEPS action plan concluded that the premises on which the loopholes in the Global tax system is address is through adoption of legal changes in the Global coherence. It is done by providing the business predi ctability and certainty. The commission did not respect these basic premises as the decision lacks Global coherence and have increased uncertainty (Morgan, 2016). In the European Union the members sovereign Nations and has the right to design their own tax rules. It can be said that state aid cannot be used as a tool to undermine the sovereignty of the member states. The investigation of the commission currently seems to be violating the sovereignty of the member states. The organization for economic cooperation and development has voice concerned in its BEPS Action Plan. The concern was that the consensus-based framework is replaced with the unilateral measures. This could lead to chaos and uncertainty in the Global tax system. In addition to this, it could also lead to the emergence of double taxation system. In providing its recommendations, OECD adheres to ambitious schedule in order to combat the perception of tax avoidance by the multinational Enterprises. The action of the co mmission undermine the effort of the organization for economic cooperation and development for establishing a conscious based framework post BEPS. In selecting the appropriate method for transfer, pricing the OECD guideline has provided five methods to approximate the arm's length transaction between two companies of the same group. These methods are comparable uncontrolled price method, cost plus method, the transaction net margin method, the resale minus method and the transactional profit split method. In the OECD guidelines, there is a distinction between transactional profit method and traditional transaction methods (Campbell Helleloid, 2016). The guidelines have declared a preference for traditional method of transactions like CUP over the transactional methods such as TNMM. It is explain in the guideline that multinational corporations should retain the freedom to apply the method that is described in the guidelines for establishing the transfer price if the methods satisfies the consulate principal. The European Court of Justice has earlier examined the issue of transfer pricing rule in the cases of direct taxation. In recent years, the European Court of Justice provides a more substantial judicial discussion on the applicability and liability of transfer pricing rules particularly the arms length transactions. The cases have shown that European Court of Justice wants more reconciliation between the traditional Transfer pricing rule and the requirements related to fundamental freedoms (Hassan, 2016). The decisions of the European court of Justice has shown that the concept of arm's length transaction is applied in a more general way in the cases. In this background, it can be said that a reconciliation between the European tax law and treaty law is possible. The analysis if the recent decision have shown that European Court of Justice has moved the transfer pricing control in a state that the arm's length standard will gradually be eroded and a new model has to be developed for its replacement. The main reason for the replacement will be that the court does not give importance to the economic consideration of the multinational corporations. Therefore, it can be said that OECD guideline is more desirable than the guideline provided by the European court of Justice (Kavanagh Robins, 2015). The decision of case of the commission has huge implications. It is predicted that because of the decision of the commission it has become more troublesome for the European Union States to give favorable tax rulings to the companies. The example of the recent cases are the state aid that is given to Apple by Ireland. In particular, these decisions have shown that any favorable tax rulings is regarded as an illegal favorable benefit to the company (Haslehner, 2016). The European court of Justice by the decision of these cases is sending a clear message that any favorable benefits given to a multinational enterprise by remember state through tax ruling is illegal state aid. It is because this hampers the competition among the markets of the member states. The European Court of Justice argues that justifiable basis should be used for collecting tax. The European Court of Justice states that unjustifiable and complex process should not be used for computing tax that is payable. Therefore , it can be said that European court of Justice have ensured that the tax collection system becomes less Complex and is based on a justifiable ground. Based on this it can be concluded that the above cases and the decision of the European Court of Justice has simplified or improved the taxation system currently prevalent (Honore, 2015). The European Commission has highlighted the need for supporting the developing countries for utilizing the domestic resources by encouraging development in line with good system of taxation. In this section the transfer pricing as adopted by the developing countries are discussed. The initiative taken by the European Commission has a very favorable outcome in the development and overall business environment of the developing countries. The ECJ has argued that the transfer pricing and the arms length principle helps in maintaining the fair market value and thus encourages competition. This has a positive impact on the activities related to international trade and multinational Enterprises. The globalization has encouraged cross border transactions between the related entities as a result the transfer pricing has become important agenda. It can be estimated that among all the business transaction worldwide the two third of them is between inter group companies. It is more important for the developing countries because the economies have recently opened up (Law, 2014). This process of opening the economy have attracted investment from the large multinational enterprises as foreign direct investment. In the absence of any Transfer pricing guideline, it will not be possible for tax administration and the multinational Enterprise to refer to a proper guideline. However, it has been seen that the developing countries face is a lot of trouble dealing with Transfer pricing. The main problem is that the local administration is largely inexperienced with regard to transfer pricing. The organization for economic cooperation and development has initiated many efforts for establishing common grounds in the transfer pricing matters (Blockx, 2016). In order to provide sound recommendations relating to transfer pricing the generally the considerations should be made about the economic and political conditions. The sound recommendations can be made after assessing the legal prec onditions and preconditions related to the tax matters. Therefore, it can be said that the consideration of the European Court of Justice has helped the nonmember states or developing countries in understanding the meaning of transfer pricing. The considerations has helped the developed countries to develop a regulation that will not encourage complex on unjustifiable basis for calculating tax. The decision will promote a more simple and justifiable basis of taxation in the developing countries. It is expected that multinational Enterprises operating in the developing countries will transfer products to related enterprises at the market price and not add discount price. Hence, it will help to maintain the competition in the market. Based on the above discussion it can be said that the consideration of the European Court of Justice has helped the developing countries to maintain a more competitive market (Cerioni, 2016). Reference Bauckloh, T., Hardeck, I., Wittenstein, P. U., Zwergel, B. (2017). Do Some Multinational Firms Benefit from Competitive Tax Advantages in Europe? Evidence from Stock Price Reactions to EU State Aid Investigations. Blockx, J. (2016). The Belgian Excess Profit Exemption: Tax Incentives for Multinational Groups as State Aid.Journal of European Competition Law Practice. Cachia, F. (2017). Analysing the European Commissions Final Decisions on Apple, Starbucks, Amazon and Fiat Finance Trade.EC Tax Review,26(1), 23-35. Campbell, K., Helleloid, D. (2016). Starbucks: Social responsibility and tax avoidance.Journal of Accounting Education,37, 38-60. Cerioni, L. (2016). Book Review: Advanced Issues in International and European Tax Law.Intertax,44(3), 284-287. Chisholm, B. C. (2017). ICRICT Looking to a Future of Actual Tax Reform: An Organizational Analysis of the Independent Commission for the Reform of International Corporate Taxation.U. Cin. L. Rev.,85, 231-319. DeNovio, N. J., Righini, E., Gibbs, N. N. (2016). State Aid: What It Is, and How It May Affect Multinationals and Tax Departments.Tax Executive,68, 15. Douma, S., Kardachaki, A. (2016). The Impact of European Union Law on the Possibilities of European Union Member States to Adapt International Tax Rules to the Business Models of Multinational Enterprises.Intertax,44(10), 746-754. Evertsson, N. (2016). Corporate tax avoidance: a crime of globalization.Crime, law and social change,66(2), 199-216. Gonzlez, S. M. (2017). State Aid, Tax Competition and BEPS: Comments on the European Commission's Decisions on Transfer Pricing Rulings. Gormsen, L. L. (2016). EU State Aid Law and Transfer Pricing: A Critical Introduction to a New Saga.Journal of European Competition Law Practice,7(6), 369-382. Gunn, A., Luts, J. (2015). Tax Rulings, APAs and State Aid: Legal Issue.EC Tax Review,24(2), 119-125. Haslehner, W. (2016). Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law. InState Aid Law and Business Taxation(pp. 133-161). Springer Berlin Heidelberg. Hassan, M. (2016). Global Tax news.TAXtalk,2016(57), 14-17. Honore, M. (2015). State Aid and Taxation-All Clear. Kavanagh, J., Robins, N. (2015). Corporate Tax Arrangements Under EU State Aid Scrutiny.Eur. St. Aid LQ, 358. Law, B. V. (2014). Transfer pricing: A step forward for Albania.changes. Lyal, R. (2015). Transfer pricing rules and state aid.Fordham Int'l LJ,38, 1017. Mason, R. (2017). State Aid Special ReportPart 2: Legitimate Expectations. Mason, R. (2017). Tax Rulings as State Aid FAQ. Morgan, J. (2016). Corporation tax as a problem of MNC organisational circuits: The case for unitary taxation.The British Journal of Politics and International Relations,18(2), 463-481. Thomson, A., Hardwick, E. (2017). The European Commission's Application of the State Aid Rules to Tax: Where Are We Now?.Journal of Taxation of Investments,34(3). Wattel, P. J. (2016). Stateless Income, State Aid and the (Which?) Arms Length Principle.Intertax,44(11), 791-801. Wattel, P. J. (2016). The Cat and the Pigeons: Some General Comments on (TP) Tax Rulings and State Aid After the Starbucks and Fiat Decisions. InState Aid Law and Business Taxation(pp. 185-194). Springer Berlin Heidelberg.

Unknown Citizen VS The enormous radio Essay Example

Unknown Citizen VS The enormous radio Essay The Unknown citizen by W.H. Auden and The enormous radio by John Cheever both share the same idea about society. Both the poem and the short story are hypocritical and show how individuals hide behind the shield of conformity. In the Unknown Citizen Auden describes the perfect man, yet in whos eyes does he meet perfection? Thefirst time I read the poem I interpreted it differently than I do now. Ifirst thought that the character was the ideal person who reached ultimate perfection yet as I read it a second time I realized I was wrong. In all of the lines that I thought were complimentary, as I reread them I found them very impersonal and vague. In line nine Auden says he wasnt odd in h is ways, In lines fourteen -fifteen he bought the paper everydayreactions were normal in every way, and also in line twenty-three he held proper opinions for this time of year. I read all of these as very general, like the speaker is rewarding him for being a perfect clone of what every one else is. The speaker in this poem is always referred to aswe therefor the speaker must be society. In the conclusion of the poem the speaker questions wether the man was happy and free and answers it himself by saying the question is absurd and if he was not okay, they would know. Yet Im sure everything was not perfect in this mans life, but they didnt know. I also interpreted the title differently, the unknown citizen this also contributed to my idea of this man being just like everyone else. Because he is unknown for his accomplishment because it is the norm, he did nothing more and nothing less than what was expected of him. He didnt get fired and noone complained about him yet the speaker doesnt go on to explain the important role he played. The speaker identifies the man as JS/07/m/378.

Angiosperms and Gymnosperms essays

Angiosperms and Gymnosperms essays Angiosperms are flowering plants. Angiosperms are the biggest group in the plant kingdom. They have true roots, stems, leaves and flowers. They also have seeds. The seeds are formed when an egg is fertilized by pollen in the ovary. The ovary is within the flower. The flower contains the male or female parts of the plant. Fruits are frequently produced from these ripened ovaries. Angiosperms are more highly evolved that the algae, mosses, fungi and ferns. Their advanced structures allow them to live on land. They have roots that hold the plant in place and take in needed minerals and water. They have leaves that are the major food makers for the plant. They have stems that hold the plants up and move the nutrients and water about the plant. Angiosperms are the primary food source for animals and provide oxygen for us to breathe. They provide lumber for buildings and other objects, fibers for clothes, are the basis for many drugs. Gymnosperms are a type of plant that reproduces by a seed that is not enclosed. They are not like the angiosperms that have seeds contained flowers. Many of these plants are cone-bearing plants. Gymnosperms are found throughout the world. They have roots and stems. Their leaves are in the form of needles in conifers. At the time of pollination, the pollen grains fall among the cone scales until they fall on to the ovules. As the cone grows up, it gets bigger and the seeds that are created by the male pollen and female parts are seen. Most conifers are always green and they do not shed their leaves as deciduous plants do but retain their needles for quite a while. When the needles fall off, they are quickly replaced. Other groups within the gymnosperms include the gingkos and cycads. ...

Strategic Hospitality Management Essay Example | Topics and Well Written Essays - 750 words

Strategic Hospitality Management - Essay Example The year 2007 saw a major restructuring for the Accor group with regard to its hotel businesses. The Sofitel group which was classified under the up-market luxury category repositioned itself as a hotel with a French touch. This could be because Sofitel's origins were in France. (Pouillat and Chabrot). The concept now is that each hotel in the chain will be unique in design and architecture that will be suited to the region where it is run. Two sister brands will be introduced in 2009 namely, Sofitel Legend and So by Sofitel. During the years 2006 Sofitel sold one French hotel and six hotels in the USA to streamline its operations and to improve cash flow. The US hotels were sold off for 370 million USD. In 2007 two more hotels in the US were sold for 225 million USD to a GEM Realty Capital of which Accor was a joint venture partner. (Press Release: Accor Announces Sale and Management Back of Sofitel Hotels in New York and Philadelphia). Earlier that year, thirty Accor properties in UK were sold off for 11 million Euros. "Financially, the transaction will enable Accor to reduce its adjusted net debt by '584 million, of which '172 million will be added to the Group's cash reserves. It will have no impact on EBITDA but will add '7 million to 2007 profit before tax." (Press Release: Accor Sells 30 Hotel Properties in the United Kingdom for '711 Million and Signs a Development Partnership with Land Securities, p.1). These are just examples of the selling spree set about by Accor to decrease its net debt and for its major restructuring strategies for the whole group including Sofitel. Human resources challenge: The major restructuring done at Sofitel has created some challenges in the human resources department. Because the hotel chain has reinvented itself under a French image, the staff will now have to be trained or hired accordingly to suit the tastes of lovers of French cuisine and style. As mentioned earlier the new image will result in each hotel having its unique style and architecture, depending on its location and will be blended with its French image. This will create challenges for employees because of the lack standardization and uniformity across its hotels. As a result the group has revamped its strategies to be brand specific. This will entail in creation of a diversified training program that will fit the needs of each of its hotels. The detailed human resources plan was presented to the Geneva based European Works Council as a part of discussion and approval. In order to support these changes at Sofitel and also other strategic changes in the groups the Accor group had started and training school for its employees called the Accor Academy. Apart from general and on the job training, the groups also have three certification programs for its employees. The first one is a skills certification process which it has just introduced and plans to expand worldwide by the year 2010. The success of any organization depends on its top and middle level leadership. With a long term vision in mind the group has started a program called the "GM Pass personalized career development program to train future hotel general managers." (Intensified Training Initiatives. 2007). The third initiative is a advanced training program for managers and future managers with high potential so that they can be developed further. They also have t he potential to become part of the top management of the company later. There have been two key area of challenge for Sofitel and

Classical Image of Education Essay Example | Topics and Well Written Essays - 1000 words

Classical Image of Education - Essay Example Though it defies description and is not easily defined, we know it when we see it as our imagination offers us a clue to its possibilities. Our classical image of education and its definition falls short of the true meaning when it is applied to a lifetime of learning. Typically, an education has been thought of as a specified period of time in which certain subjects are learned to a pre-determined level. Education is sometimes mistaken for the Bachelor's or Master's degree that indicates we have attended school, but it is not an education. Albert Einstein once said, "Imagination is more important than knowledge. Knowledge is limited. Imagination encircles the world". The spark that ignites our imagination is education. The subjects taught in pursuit of these goals give us information and provides us with a key to further learning, but this is not education. Learning to appreciate art, perform logical operations, or the history of rock and roll are interesting to know, but they do not qualify as education. All of these activities and endeavors are simply the tools required to begin to mine an education. Yet, listing all the tools and components involved in making an education would be of no more relevance than calling a list of ingredients a cake. The traditional view of 120 credits, electives, and compulsory courses fails to completely define education. Education is the creation of a task, concept, or belief that we find useful in our life and defines us as a human being. The formal learning that was required to obtain a degree becomes useful as we enter the workplace and begin to assimilate with the culture of our livelihood. Here we learn what is expected of us, what is needed to make progress on a task, and how to complete a workplace function. Logic and art may help us temper the new environment and give us a sense of deeper understanding of the world around us, but the education takes place when we learn to undertake a project and develop the confidence that gives us our self-identity. Information needs to be put to use and contribute to our sense of self-worth to be considered education. In essence, we define education by how education defines us and the way that we define ourselves. Education is part and parcel of the human spirit that drives us to imagine, create, inspire, innovate, and invent. We may have an intricate knowledge of calculus, but in its dormant state it adds nothing to our education. Education is an action word that demands that we act and react to the facts and information we gained from attending school. When we encounter a new situation that requires us to solve a problem we create a solution from the tools we gained from our classroom experience. The innovative experience that we create out of our limited knowledge is the true meaning of education. It is not simply the information or the knowledge that defines us. Education is the inspiration we receive when we put our knowledge into action. When we integrate several fields of knowledge, while we stretch to invent a new process or concept, we can then say that the experience was 'a real education'.

Unit 3 DB Acct310 Essay Example | Topics and Well Written Essays - 250 words

Unit 3 DB Acct310 - Essay Example rder costing system is mainly used in service industries including hospitals, movie studios, law firms and even repair shops as well as in cases where individual non-homogeneous goods are produced by an organization. When it comes to this type of system, record keeping and cost problems can be very complex to handle especially where different products and services are available, compared to when dealing with single products and services. Since the products available are different, the cost will relatively be different hence a cost record for each product. Therefore, job order costing needs a lot of effort and concentration as compared to process costing system. Process costing involves tracing and accumulation of direct costs, and the allocation of indirect costs of manufacturing processes (Hansen & Mowen, 2006). Process costing is much applicable when the products in question are naturally homogeneous. Costs are in this case assigned to products which are produced en mass as noted by Hansen and Mowen (2006). This method is mostly suitable for industries such as chemical manufacturing companies since the process flow is continuous. In this system a production report is prepared to summarize the totals and cost of units. In the case of a company that deals with chemicals, cement, electrical parts, textiles and pharmaceuticals products, process costing method is advisable. This is because their production process is continuous and order costing method may not be appropriate for this kind of companies. Job order costing is applicable in companies that manufacture many different products for example clothing factory and service industries (Hansen & Mowen, 2006). Each product has its own price hence this system is appropriate to use and follow. Records of each and every order and its cost are stored separately for easy understanding and follow up. Records in a process order costing system are much easier to follow and less complicated as compared to job order

Advantages of Learning Organization

Advantages of Learning Organization Due to impacts of the international financial crisis and the notable slowdown of the economy, Bank co has encountered more challenges. Accordingly, Bank co is transforming from an operational company to a sales-oriented one, in a bid to enhance their competitiveness. As the customer services centers are established and original branch institutes are shut down, the structure change influences 7 percent of the workforce. The board doesnt think a young management can handle the shift and further reforms; therefore, a great emphasis is put on staff learning approaches. As the staff capabilities are core resource to an organizations competitive advantage, all the management focuses on the planning and implementing of strategies. This essay not only elaborates Bank cos successful integration its HRM strategy with the overall business strategy, but also discusses the problems in the policy implementation. Some coherent solutions for these problems are also discussed in this essay. 2.0 Bank cos Objective as a Learning Organization 2.1 Definition of Learning Organization Peter (1990) proposed that any organizational thought a learning organization can be conducted by teams led by managers that facilitate a communication that values reflective thought, new patterns of thinking and a suspension of assumptions. In generally speaking, a learning organization has the following characteristics. First, the staff has a shared vision as their daily guideline and considers all organizational processes, functions, activities, and interactions with the overall environment as a member of the system. Second, each staff can air their own opinions to each other without fear of criticism or punishment. Third, staff sacrifices their personal self-interest and integrates department interest to cooperate to achieve the organizations shared vision. 2.2 Advantages of Learning Organization Brandt (2003) proposed that a learning organization is just like a school, a flexible and responsive organization should change in accord with changing circumstances. A learning organization has the following advantages. First, learning organization can promote continuous improvement. Whether project outcomes satisfy customers needs or not relies on how managers assess and narrow the gap between the two. Levine (2001) found that improve managers concentration span to organizational learning is a great potential to establish cooperation and continuous improvement that promote organizational performance. Second, learning organization can promote innovation. Although this statement is obviously true, but there is no quantitative study based on parallels between the characteristics of learning organization and the statement in literature that supports innovation and employee creativity can improve the performance of learning organization (Ramous and Steger, 2000). Third, learning organiz ation can foster community building. As learning community can break through stereotype routines and cultivate effective learning environment. Digenetic (1998) claimed that a learning community should be a mechanism for creating the learning organization. 2.3 Evaluation of Bank cos Objective With the financial crisis wreaking havoc on nations across all continents, the sense of living in a globalized age has become more acute. To cope with profound changes, Bank co made a strategic shift which focuses on four main units. First, human resource planning is long-term programs of Bank co. Due to the resignation of skilled and veteran managers, Bank co supports staff development by offering investment of  ¿Ã‚ ¡17 million. It allocates about 25,000 training days for the staff each year. The training and development (TD) department has finished the training programs for more than 5,600 managers until nowadays. And the training programs coherently focus on five units, such as, resourcing and development, HR quality, training design and delivery, equal opportunities and residential training. Second, training and development should be implemented to management staffs at all levels. Since a survey indicates that 60% employees considered that the training programs are just attending courses, the TD department decided to implement a wider range of flexible training methods, such as, self-directed learning, coaching, job rotation, secondments, etc. As a result, staff at all levels start to self-study in learning resource center without the reliance on training courses. Their hobbies and interests have been explored by a large margin. Thats to say, Bank co cultivates a learning atmosphere within the company, and ushers staff to take the responsibility of self-development. Third, employee relations are another focus of Bankco. The employee relations are cooperative instead of competitive, because staff at all levels share the same goal of the organization. It coincides with the policy of a harmonious society. It is an opportunity for staff to realize themselves, while it is a challenge for the managers who provide opportunities within which the staff can learn and develop. According to Maslows hierarchy of needs, self-actualization is the highest need on the pyramid of needs, self-actualization must produce an attraction and stimulant for staff to find themselves (Maslow, 2008). Fourth, personnel operation is important. As HR department had considerable power, Bank co established a belief that a learning organization would remain competitive and successful. The shift causes an unprecedented series of efforts and initiatives intended to learn from diverse source, because the line managers are responsible for ensuring that proper action will be good for individuals who keep a partnership with their mangers. During the establishment of learning organization, Bankco has achieved good financial performance as a reward. 2.4 The Achievement of Learning Shift The shift from being operational to becoming sales oriented has brought significant changes in the performance of Bank co. First, as a learning organization, Bankco retains knowledge workers. Bank cos shift causes some of middle-aged managers to leave, when the company is in desperate need of talent to rebuild itself. Therefore, the management had to give top priority to learning programs to cultivate talent as fast as possible. Second, the learning center collects public recording which is unobtrusive and useful in the execution of decision-making and work process. The data on management and information about staff behaviors to certain jobs are useful for researches to analyze Bank cos operation and set down the appropriate management policies. As learning is applied to innovate or modify individual dispositions, processes, policies, and procedures, the staff can further develop their interests and hobbies, Bankco can improve its management experience as well. 5.0 Conclusion In our uncertain world, the only thing that appears to be certain is that social computer-base communication technologies are rapidly becoming online hot spots and changing the way we communicate and information. It is convenient to express social relationships on the IM and blog through links and comments. But we should take advantage of these technologies and overcome their challenges. The best approach is to develop good habits to use computer-based communication technologies, even the link is from friends, they need verify to friends again.

Modern Industrial Economy :: essays research papers

The Modern Industrial Economy   Ã‚  Ã‚  Ã‚  Ã‚  Before the beginning of the eighteenth century, Europe was in dire need of a transformation. One that would change their style of life, not only for the well being of the countries, but for the people as well. This transformation could mean the development of nations into world powers. This need was fulfilled by one word, industrialization. Perhaps the biggest change in history was the Industrial Revolution of the 18th century. This was not only carrying economic changes, but social changes as well. This extensive mechanization from home manufacturing to large-scale factory production was without doubt, the largest conversion for labor fabrication.   Ã‚  Ã‚  Ã‚  Ã‚  Let’s take a look at some necessities for a country to industrialize. First of all, raw materials would be needed in whatever industry you would want to develop. Without a source of power or materials, the product would not be able to be produced at a large factory. Surplus of food is another necessity for industrialization. Without this extensive food supply, laborers would not be fed properly which could result in catastrophic losses. Another major element in the development of industry is entrepreneurs. Since Britain had a sizable middle-class with entrepreneur ideas, they seemed to fit more and more into this equation. Labor Force is also a large contributor to this cause. With an ability of laborers to leave their homes and go into factories, people started realizing the positive effects of big business. One distinct feature that was possessed by Britain was wealth. At the time, Great Britain was one of the wealthiest nations and could afford to dump l arge sums of money into buildings and export. Finally, one of the last things that were needed that could limit all the other elements is the possession of a government that was open to new ideas. If people in a nation could not get their government to back the ideas, they would have nothing. It was up to the entrepreneurs to convince the government officials that money could be made and power could be established.   Ã‚  Ã‚  Ã‚  Ã‚  But why did Britain industrialize first? In the beginning of the 18th century, these qualities were not that noticeable. Actually, the Netherlands and France were just as wealthy at the time, had equally skilled populations, and had just as powerful of an empire. The French government truly was seen as more quick to respond, especially in the area of transportation and communication.

Justification By Faith

The subject of â€Å"Justification by Faith† is an argument, proposed by the Apostle Paul in Romans 1:17 where he starts by introducing God’s revelation to humankind concerning unrighteousness: That this was a God-given revelation in the beginning and throughout man’s history (faith to faith) within the â€Å"Gentile’s law of nature and the Jews law of Moses. However, Paul further exclaims, â€Å"that neither of them could be justified by their obedience to the respective laws under which they were, but that they both stood in need of the righteousness of God.† [1] As Paul is strictly a preacher of the Gospel of salvation through Christ Jesus, there is no doubt he had to find another style of presenting the Good News to factions in opposition to one another.His method of preaching in Romans catches the undivided attention of both the Jew and the Gentile Christian. Justification in the sight of God comes by faith in Christ Jesus alone, by which we c an also avoid the wrath of God that is consequential to the ungodliness and unrighteousness of men. Certain cults, like the Jehovah’s Witnesses seek gratification by including their works to implement salvation and only adhere to particular scripture verses to defend their position.They twist the interpretation of James 2:18, 20, and 26 by ignoring Ephesians 2:8-9, which is contrary to the analogy of faith and does not agree with the biblical map. Works are only what we offer out of thanks for the sacrifice Christ made for us but they search for every excuse and alternative possible and refuse abandon their false doctrine, which is a matter of their own â€Å"free choice†. In actuality, there is no â€Å"free choice† because not accepting Christ Jesus as our personal savior accounts as a sin, in the eyes of God. (John 5:26-29)â€Å"Justification† and â€Å"Faith† DefinedSince we are speaking of â€Å"Justification by Faith†, this is where it is appropriate to throw in the explanation of the two words, â€Å"justification† and â€Å"faith†.Let Us Define â€Å"Justification†According to Verlyn D. Verbrugge’s New International Dictionary of New Testament Theology†, the Greek word â€Å"justification† (dikaiÃ… sis), defines a vindication or an acquittal (p. 147), a dismissal of criminal charges. We can best explain â€Å"justification† by encountering someone having a traffic citation for speeding and that either he gets the infraction dismissed or he pays the fine. The driver may appear in court to dispute the citation but if found guilty the punishment for these charges remain impending. He is no longer guilty if the charges are dropped and they will be forgotten. If the fine remains and is not paid, penalty charges will be added and compounded until the driver pays the full amount incurred, is arrested, or is jailed and serves time as payment; or serves time and still pay s for the infraction.At this point, his license to drive can be suspended or revoked. The driver is no longer considered criminal once the fine is paid but this is where sin and the traffic citation divide. We cannot pay for our sin, our infractions against heaven. Our depravity is a spiritual matter that cannot be handled by physical means. Only a divine spiritual source can take care of both our spiritual, physical needs simultaneously, and that comes through blood sacrifice only. Christ Jesus, â€Å" In whom we have redemption through his blood, the forgiveness of sins, according to the riches of his grace;† (Eph. 1:7)Definition of â€Å"Faith†Now â€Å"faith† (πΠ¯ÃÆ'tÃŽ ¹Ãâ€š), as defined by Verbrugge, offers another method of having that traffic ticket expunged. It â€Å"denotes the trust that someone may place in other people or in the gods, credibility, and credit in business, guarantees, or something entrusted† (p. 462). Again, in this cas e it is Christ Jesus, because he paid every debt of man’s criminal activity. So here, we put our trust (â€Å"faith†) in Jesus to pay the penalty for our crime much like a father might pull out his credit card to pay for his child’s driving infringement; least the child ends up in jail for reoccurring and additional fees applied to that summons.What, or Who, is God’s RighteousnessIn Romans 1:17 we encounter the phrase â€Å"the righteousness of God†. This phrase does not necessarily refer to God’s uprightness, holiness, or purity, or His faithfulness in keeping His promises, nor the justice He will serve at the judgment but the means by which He provides salvation for humankind. Therefore, â€Å"the righteousness of God† refers to Christ Jesus for he obediently fulfilled all the prophecies of the Old Testament, which began in Genesis 3:15, and faithfully accomplished the Father’s promises.â€Å"And I will put enmity between yo u and the woman, and between your offspring and hers; he will crush your head, and you will strike his heel.† NIV Our faith in Christ Jesus, as our personal savior, justifies us in the sight of the Father because we testify to the pure, holy, and righteous blood that he shed to save us from sin, hell, the grave and eternal death. Here â€Å"the righteousness of God† and â€Å"the revelation of the wrath of God† compare to having a significant relationship.The Apostle Paul is actually teaching us that without receiving Christ and becoming a â€Å"son of God† (John 1:12) we remain criminals to the heavenly government of God and â€Å"the wrath of God†, which is eternal separation from the Father becomes the reward (in this case, punishment) for our unrighteousness. We cannot save ourselves and anything we claim good enough to make us free from sin and afford us â€Å"safe passage† into heaven is far and wide from what God sees as righteous (Isa iah 64:6). Besides, if man could provide his own salvation, there would not have been a need for Jesus to give his life at Calvary and his doing so would have been in vain. (Acts 4:12)Paul’s Theological TeachingsIn Romans 6:23, Paul teaches, â€Å"the wages of sin is death; but the gift of God is eternal life through Jesus Christ our Lord† which means our salvation is a perfect salvation and could only be provided by God in the flesh (Emmanuel – God with us). We are saved from the stain of Adam’s disobedience in the garden, the murderous character of our tainted blood, the captivity of the enemy of God (Satan) and from eternal death, which is a result of all that  encompasses our sinful nature.All of this describes â€Å"the righteousness of God† but Paul goes one-step further when he turns to â€Å"the revelation of the wrath of God† in 1:18-32. In verse 19 Paul explains how the knowledge of right and wrong is revealed to man when he stat es, â€Å"Because that which may be known of God is manifest in them; for God hath shewed it unto them.† The knowledge of right and wrong, good and evil, righteousness and wickedness is made manifest within the heart of man even though â€Å"the imagination of man's heart is evil from his youth† (Genesis 8:21). The Spirit of God in man (that is the remnant spirit of God in man) plants this innate knowledge, of good and evil, and no matter how we cut it, this is proof that God created man, for this is His trademark, benchmark or ISBN.By the knowledge of good and evil in man, the homosexual knows his or her lifestyle is an â€Å"abomination† (Leviticus 18:22; 20:13; Deuteronomy 22:5; 1 Corinthians 6:9) to God as well as the reason why the thief escapes being caught. (Exodus 20:15; Leviticus 19:11; Jeremiah 2:26) From this point, we can understand how both â€Å"the righteousness of God† and â€Å"the revelation of the wrath of God† are related to one another. Jesus Christ is God’s righteousness and provides the only payment to expunge our criminality against heaven. God has created in man (revealed in man) the inborn knowledge of the difference between sin and righteousness.Paul Refutes Jewish IdeologyPaul was a Pharisee within Judaism and understood all the ins-and-outs of their doctrine, which became a plus for Christians of his day and has become a major advantage for us today because it leads to the defense of Christianity against Judaism, as well as, other belief systems. In Judaism, â€Å"justification by faith† was national pride and was a form of idolatry because they idolized the fact they were Jews. They further believed that the sect with the most righteous form of living (by keeping the law), of all the Jewish communities (Scribes, Pharisees, Essenes, etc.), would enter into heaven. In this, they believed the gentile would not qualify for salvation, seeing the Jews were the only chosen nation of God an d possessed the Laws of God. They, the Jews, did not extend the blessing to other nations and held them as cursed of God, the products of eternal damnation. [2]However,  Paul refutes this ideology in Romans 10:1-13, bringing into reason â€Å"Since they did not know the righteousness of God and sought to establish their own, they did not submit to God's righteousness. Christ is the culmination of the law so that there may be righteousness for everyone who believes.† (Romans 10:3-4) Paul repeats this same doctrine to the Galatians, using different words: â€Å"Is the law then against the promises of God? God forbid: for if there had been a law given which could have given life, verily righteousness should have been by the law.† (Gal. 3:21) Reading deeper into these two statements, Paul is expressing that the attitude, of the Jews, was nothing more than legalistic prejudiced against other nationalities and cultures but Paul corrects this in the second sentence of Roman s 10:3-4, where he refers to the â€Å"culmination†.This â€Å"culmination† breaks down the barriers of selectivity and makes â€Å"faith† inclusive â€Å"for everyone who believes.† The use of the word â€Å"culmination† concludes that Christ has fulfilled every requirement needed to save humankind, which then makes everyone (Jew and Gentile, alike) with faith in Christ Jesus, an inclusive entity. â€Å"Justification by Faith† in Christ Jesus is â€Å"the only way, the only truth, and the only life. And No man comes to the Father but by him† (John 14:6) is what the Apostle Paul’s argument is all about. Paul leaves no doubt in the minds of Christians or the ungodly, unchurched peoples how salvation is attained. That it only comes through being â€Å"justified† through our â€Å"faith† in what Christ has done on the Cross of Calvary for all humankind.That he will return, looking to find a church without â€Å"spot or wrinkle† (Ephesians 5:27). â€Å"But without faith it is impossible to please him: for he that cometh to God must believe that he is, and that he is a rewarder of them that diligently seek him.† (Hebrews 11:6) We are â€Å"rewarded† the â€Å"justification† needed to become right in the sight of God. It is this writer’s opinion that Christ has already cleansed us of the â€Å"spot†, the sin we inherited from Adam’s disobedience when we accepted him as our personal savior but our â€Å"wrinkles†, our personal sins, still need ironing out. The final change will be â€Å"ironed out† on the day of rewards, the rapture because (as for now) we can only strive for the perfection but Christ will do the ultimate perfecting.God’s Wrath in Paul’s Concept of SalvationAccording to the â€Å"Evangelical Dictionary of Theology† by Baker House, there are six words to describe the emotions associated with God†™s wrath. â€Å"These terms, all of which express varied shades or degrees of wrath, anger, displeasure, or vexation, are the following: anph (to be angry); zaaph and derivatives (to be wroth, displeased, sad); hemah (indignation, anger, wrath); kaas (to be angry, wrathful, indignant, vexed, grieved); ebrah (rage, wrath); qasaph (to be displeased, angry, wroth); saneh (to hate). In the New Testament, there are more than twenty references to the anger, wrath, or vengeance (orge) of God and a few references to indignation and displeasure (achthos).† [3]Although there may appear to be varying degrees of God’s wrath, I must go along with Paul’s theology that â€Å"If you’ve committed one sin, you’ve committed them all.† Let us return to Romans 6:23, â€Å"For the wages of sin is death†¦Ã¢â‚¬  All sin leads to death and eternal condemnation. There is no leeway for what the secular world may deem, i.e., â€Å"a little white lie†; a lie is a lie and holds no degree of sensitivity in God’s righteousness. Nevertheless, salvation is explained by Paul in Romans 5:18, â€Å"Therefore as by the offence of one judgment came upon all men to condemnation; even so by the righteousness of one the free gift came upon all men unto justification of life.† That gift is Christ Jesus as the apostle previously proclaimed, â€Å"For by grace are ye saved through faith; and that not of yourselves: it is the gift of God: Not of works, lest any man should boast.† (Ephesians 2:8, 9)A Door with Two SidesDr. Elmer Towns, in his book â€Å"Core Christianity†, compares â€Å"conversion to a door with two sides.† â€Å"Human activity is on one side of the door, while God’s activity is on the other side.† When we convert to Christianity, we are pushing on the door to heaven and God, on the other side, regenerates us into new life. We are then born again and the world, God, sin, and ourselve s appear to us in a different and opposing light of understanding. [4] If we are â€Å"pushing on heaven’s door† then we have accepted Jesus because he states, â€Å"I am the door: by me if any man enter in, he shall be saved, and shall go in and out, and find pasture.† In the case of the  Apostle Paul, however, I interpret it as God opened the door and dragged him inside. His encounter with Jesus Christ made a life changing impact that not only altered Paul’s way of thinking and his mission but also rearranged the course of human and church history.He, Paul, admittedly states this in Romans 1:1, â€Å"Paul, a servant of Jesus Christ, called to be an apostle, separated unto the gospel of God†. He was definitely â€Å"called and separated†, made a â€Å"prisoner† (Ephesians 3:1; 4:1) of Christ Jesus in a fashion that no other apostle had experienced. The reason I have used the verb â€Å"had† is because there were only thirtee n apostles; the thirteenth being Paul, replacing the rebellious Judas. By biblical standards, an apostle is a person who was a Jew, had seen Jesus face-to-face, planted churches, and had authority over the church, in various regions. There are people today, using the title â€Å"apostle† unjustifiably because they do not fit all the requirements but may have an â€Å"apostolic anointing†. Therefore, if they are given a title, perhaps it should be â€Å"anointed one† and not â€Å"apostle†.Paul on FaithPaul has written many epistles, containing verses, about â€Å"faith†. â€Å"Now faith is the substance of things hoped for†¦Ã¢â‚¬  (Heb. 11:1); â€Å"But without faith it is impossible to please him:† (Heb. 11:6). These are just a few examples, outside of the letter to the Romans, in which Paul speaks on â€Å"justification†. â€Å"Is the law then against the promises of God? God forbid: for if there had been a law given which c ould have given life, verily righteousness should have been by the law.† (Gal. 3:21) This was also another argument against the Jews, concerning their belief in salvation by the law.ConclusionI praise God for giving us the Apostle Paul, for through him we have an in depth analysis of what â€Å"justification by faith† truly is, as long as we stick to verifying scripture with scripture and not take it upon ourselves to explain these things out of selfishness and ignorance. As I have tried to prove, there is no contention between Paul’s writings on faith and that of the Apostle James because James is not purporting that salvation comes by works. We must all come to the understanding that good deeds are what we do as a gesture of good will and appreciation for the blood sacrifice that Jesus Christ made to save us from sin, death, the grave and the eternal tortures of hell. The Apostle Paul also teaches, in 2 Timothy 4:3, that â€Å"†¦the time will come when th ey will not endure sound doctrine; but after their own lusts shall they heap to themselves teachers, having itching ears;†The time is here and now because we find these false doctrines just about everywhere we turn. Paul charges us to, â€Å"Preach the word; be instant in season, out of season; reprove, rebuke, exhort with all longsuffering and doctrine.† (2 Timothy 4:2) We must also consider that, â€Å"whosoever shall call upon the name of the Lord shall be saved. How then shall they call on him in whom they have not believed? and how shall they believe in him of whom they have not heard? and how shall they hear without a preacher? And how shall they preach, except they be sent? as it is written, How beautiful are the feet of them that preach the gospel of peace, and bring glad tidings of good things!† (Romans 10:13-15)Paul teaches, in this verse, that it is our obligation to correct those who have not received the true doctrine of Christ. This charge is an ext ension to the Great Commission. Just as well as there are those who have not the gospel, there are those that have not the true gospel. The apostle further warns, â€Å"Whosoever transgresseth, and abideth not in the doctrine of Christ, hath not God. He that abideth in the doctrine of Christ, he hath both the Father and the Son. If there come any unto you, and bring not this doctrine, receive him not into your house, neither bid him God speed: For he that biddeth him God speed is partaker of his evil deeds.† (2 John 1:9-11)