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Some of the main points of principle that remain unresolved in connection with the interpretation and application of bilateral tax treaty nondiscrimination provisions are identified. This is done from the perspective of a U.S. tax practitioner who has only an outsider's passing acquaintance with other countries' interpretations of bilateral tax treaty nondiscrimination provisions and with the ECJ case law on the tax issues under the EC Treaty. So this does not purport to be a thorough catalogue of technical issues of interpretation, nor a systematic comparison of tax treaty nondiscrimination rules and the EC Treaty provisions. Instead, the approach is one of reviewing the tax treaty rules and drawing some brief comparisons with their counterparts in the EC Treaty, critically analyzing s...
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ST. PETERSBURG, Fla. - A subplot to the 2011 Beef 'O' Brady's Bowl is the future status of Florida International Coach Mario Cristobal, who has been linked to the vacant head football coach position at the University of Pittsburgh.
Cristobal, a 41-year-old Miami native in his fifth season at FIU, reportedly interviewed at Pitt on Friday and is one of three candidates to do so. Cristobal and Ohio State Interim Coach Luke Fickell reportedly interviewed for the Panthers' job Friday, and Wisconsin offensive coordinator followed suit Saturday.
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Poor planning in the past means that Australia faces a shortage of doctors. International medical graduates (IMGs) have been brought in on temporary v...
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* Pursuant to 5 TH C IR .
R. 47.5, the Court has determined that this opinion should not be published and is not precedent except under the limited ...
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Introduction
Academic librarians are increasingly concerned about students' information literacy. The ability to effectively search academic resourc...
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CARSON CITY, Nev., Aug 3 /PRNewswire-USNewswire/ -- Nevada Lt. Gov. Brian Krolicki, who chairs the Nevada Commission on Economic Development, announced today that the commission is seeking proposals for professional services contractors to represent Nevada in Hong Kong and Beijing, China as a part of the commission's award- winning International Trade Representative Program.
(Logo: http://photos.prnewswire.com/prnh/20100614/DC20557LOGO)
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Sponsors welcome increased communication opportunities
SEATTLE -- At this fall's Localization World 2010, senior executives working in marketing, ma...
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ST. LOUIS -- Twelve amazing youth leaders from the United States, Canada, United Kingdom and France are being honored as Huggable Heroes([R]) for doin...
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By David Porter
The Associated Press