New Releases by C.J. Taylor

As a response to base erosion and profit shifting (BEPS) issues, Australia has introduced a diverted profits tax modelled on, but different from, part of the United Kingdom''s diverted profits tax. The Australian diverted profits tax became law on 4 April 2017. The article describes the basic conditions for operation of the diverted profits tax and analyses three tests limiting the application of the diverted profits tax to multinationals. It lists entities excluded from the operation of the diverted profits tax and explains the factors for determining the principal purpose. Furthermore, the article explains the relation between the diverted profits tax and CFC rules, thin capitalization rules, transfer pricing matters and tax treaties.

This article examines the influence of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project, prior Australian tax treaty practice, the OECD Model and German tax treaty practice on the 2015 Australia-Germany Tax Treaty (the 2015 Treaty). Reference is made in this article to the Explanatory Memorandum to International Tax Agreements Amendment Bill 2016 in ascertaining the influence of the BEPS recommendations, German tax treaty practice and prior Australian treaty practice on the treaty. Provisions in the 2015 Treaty were compared with recommendations and discussions in the various reports issued by the OECD as part of the BEPS project to determine the extent to which the treaty provisions reflected the BEPS recommendations. To determine whether particular provisions showed the influence of German tax treaty practice, they were compared with the German Model Tax Treaty as published by the German Ministry of Finance. To determine whether particular provisions were consistent with past idiosyncratic features of Australian tax treaty practice, they were compared with provisions in prior Australian tax treaties, with archival records of Australian tax treaty negotiations and with the results of prior investigations of Australian tax treaty practice. The article argues that in future Australia should make further adjustments to its tax treaty practice in a post-BEPS and Multilateral Instrument environment.

In this article, the author discusses the 2010, 2013 and 2016 amendments to Hong Kong''s Inland Revenue Ordinance, to bring Hong Kong into line with the OECD''s international standards on exchange of information. The author outlines the objectives of the amendments and comments on the changes made in each of those years.

The heavens — the sun, the stars, and the moon — have inspired, intrigued, and mystified us from the beginning of time. We’ve always searched for ways to comprehend their beauty and their meaning. Mohawk artist and author C. J. Taylor has drawn from First Nations legends from across North America to present a fascinating collection of stories inspired by the night skies. The legends — Salish, Onondaga, Blackfoot, Netsilik (Inuit), Wasco, Ojibwa, and Cherokee — are by turns funny, beautiful, tragic, and frightening, but each one is infused with a sense of awe. From the Ojibwa legend of the great hunter, White Hawk, and his love for an unattainable maiden, or the Salish legend of a magical lake that is threatened when human beings turn greedy and lose their respect for its gifts and for the sun’s power, to the delightful Cherokee legend of Grandmother Spider who brought light to the world, this is an important collection that is enhanced by Taylor’s glorious paintings.

From the heartbreaking Mi’kmaq story of Minnow, a mermaid in the Atlantic who must choose between two worlds to that of Water Lily and her five brothers, told by the Coos in British Columbia, creatures that inhabit fantastic realms appear in many First Nation stories. C. J. Taylor draws from those stories and from her own Mohawk heritage in this collection of haunting tales about some of the powerful spirits who touch the lives of human folk. The spirits of heaven and earth from the Ute help bring an understanding of the stars in the sky. The Cree story, “Souls in the Fog,” presents the battle between the good and the evil-minded. The Ojibwa “Fairy Village” is a unique and touching love story. Illustrated with her own powerful oil paintings, this is a collection to read and an excellent story-teller’s resource.

Nine legends which give us insight into how North America was seen by its first inhabitants.