lnternational transfer pricing strategies for minimizing global income taxes

Optimal financiai strategies are criticai for long term survival in competitive international markets. Financial strategies pertaining to transfer pricing have become increasingly important as income tax authorities seek additional revenues through increased monitoring of company practices. In this first of two articles, optimal tax strategies are presented after reviewing the transfer pricing concept and the rationale underlying governments' increased focus on transfer pricing. In the second forthcoming article, we analyze the effect of government restrictions on optimal pricing strategies.

INTERNATIONALIZATION OF STATE-OWNED ENTERPRISES THROUGH FOREIGN DIRECT INVESTMENT

ABSTRACT State-owned enterprises (SOEs) are created to focus on domestic needs, and yet recent evidence points to increasing outward foreign direct investment by SOEs. Existing International Business (IB) theories focus on efficiency-based motives for internationalization; therefore, they do not fully capture SOEs' internalization dynamics, which are driven largely by political factors and social welfare considerations. We integrate public management and IB theories to develop propositions that combine these questions: why SOEs internationalize; what are their motivations; and what are the main managerial outcomes of SOEs' internationalization. Our findings suggest that SOEs display little hesitancy in entering international markets, and that SOE international expansion is not contradictory with the goals of state-ownership if the purpose is to adjust the company to changing institutional environments both in the domestic and international markets. Our propositions about SOE internationalization are based on an in-depth case study of the outward foreign direct investment conducted by Brazil's Petrobras over the past three decades.

Quality of Canned mandarin as affected by preservation liquid

This study is integrated within a research line dedicated to evaluate different options to introduce mandarin in Spanish agro-food industries and in both national and international markets. The effects of different preservation liquids (sucrose solution, sucrose and ascorbic acid solution, grape, and grapefruit juices), soluble solids (10, 12, 14 ºBrix), and thermal processing (30 seconds at 98 ºC) on vitamin C, color, carotenoids and sensory quality of canned Satsuma mandarin segments were studied. The liquid preservation that presented the best results was grapefruit juice, which provided the highest vitamin C (323 mg.L-1) and total carotenoids (16.4 mg.L-1) contents (the main carotenoid found was β-cryptoxanthin), intense orange color, high thermal stability, and very good sensory quality (e.g. intense floral and fresh-mandarin aromas and low levels of off-flavors).

Emerging markets and the international financial architecture: a blueprint for reform

If emerging markets are to achieve their objective of joining the ranks of industrialized, developed countries, they must use their economic and political influence to support radical change in the international financial system. This working paper recommends John Maynard Keynes's "clearing union" as a blueprint for reform of the international financial architecture that could address emerging market grievances more effectively than current approaches. Keynes's proposal for the postwar international system sought to remedy some of the same problems currently facing emerging market economies. It was based on the idea that financial stability was predicated on a balance between imports and exports over time, with any divergence from balance providing automatic financing of the debit countries by the creditor countries via a global clearinghouse or settlement system for trade and payments on current account. This eliminated national currency payments for imports and exports; countries received credits or debits in a notional unit of account fixed to national currency. Since the unit of account could not be traded, bought, or sold, it would not be an international reserve currency. The credits with the clearinghouse could only be used to offset debits by buying imports, and if not used for this purpose they would eventually be extinguished; hence the burden of adjustment would be shared equally - credit generated by surpluses would have to be used to buy imports from the countries with debit balances. Emerging market economies could improve upon current schemes for regionally governed financial institutions by using this proposal as a template for the creation of regional clearing unions using a notional unit of account.

The concept of emerging power in international politics and economy

ABSTRACT This paper aims to analyze the concept of emerging power established to the understanding of international affairs. The work observes that the use of the lexicon emerging - regarding to markets, countries or powers - as qualifier for a range of international relations phenomena became a constituent part of the matter. In spite of that, the empirical denotation of the predicate is ahead of the amount of efforts on its theoretical contextualization. Our methodological hypothesis is that the rational denial of the concepts prevailing connotative spectrum by acknowledging the embedded wisdom about cognate phenomena synthesizes a theoretical framework on its accurate use.

Uprootedness and the protection of migrants in the International Law of Human Rights

The article attempt to demonstrate the evolution of international law in connected to the subject of the forced immigrants'. The author supported by several texts, cases and resolutions of the regional level, through interamerican court and European court, and the global level, through the international court. It's shown the evolution that occurred in international law in millennium turn over, which recognize the immigrants' rights. However, it's stressed the necessity of the development of those laws connected to the theme e the recognition, from the States; the importance of law's that effort to ensure the respect to human rights relative to the immigrants and their families.

Brazil: an emerging military power? The problem of the use of force in Brazilian international relations in the 21st century

The central goal of this paper is thinking about the Brazilian military power and its linking to the international ambitions of the country in the 21st century. After a comparative analysis to other BRICs and with a historical one about Brazil's strategic irrelevance, we aim to establish what the minimum military capacity Brazil would need in order to meet the country's latest international interests. Similarly, it will be discussed if the National Strategy of Defense, approved in 2008, and the recent strategic agreements signed with France represent one more step toward this minimum military capacity.

Brazil's rise on the international scene: Brazil and the World

Since Cardoso and during Lula's Administration, the international order has undergone significant changes. These changes have allowed the Brazilian foreign policy to mitigate internal effects of an order established by others and, at the same time, to become an active participant in the formulation of the new order. To democratize globalization became the mainspring of Brazilian foreign policy. In the scope, President Lula has maintained the tradition of formulating and programming foreign policy as a State policy, and also has fostered the logistic strategy of incorporation of Brazil into the international scene.

International thought in the Lula era

In the last fifty years, Brazil began a rapid process of structural transformation, following the first stage of industrial development in the 1930s. Currently the country integrates the small group of countries which evolved from an initial peripheral and subordinate insertion dating back to the nineteenth century, part of the most dynamic segment of the semiperiphery. But this category, intermediate between the "maturity" and "backwardness", according Modernization theorists, or between the "center" and "periphery", as theorists of the Dependence defend, has undergone a process of overcoming considerable positive progress in the direction of the group of states that dominate the current world system. In this way, during the years 2003-2010, foreign policy, along with the formulation of a new regionalism as a strategy of global integration and a new ideal model of State, has been a key factor

Climate governance in an international system under conservative hegemony: the role of major powers

In the last five years, climate change has been established as a central civilizational driver of our time. As a result of this development, the most diversified social processes - as well as the fields of science which study them - have had their dynamics altered. In International Relations, this double challenge could be explained as follows: 1) in empirical terms, climate change imposes a deepening of cooperation levels on the international community, considering the global common character of the atmosphere; and 2) to International Relations as a discipline, climate change demands from the scientific community a conceptual review of the categories designed to approach the development of global climate governance. The goal of this article is to discuss in both conceptual and empirical terms the structure of global climate change governance, through an exploratory research, aiming at identifying the key elements that allow understanding its dynamics. To do so, we rely on the concept of climate powers. This discussion is grounded in the following framework: we now live in an international system under conservative hegemony that is unable to properly respond to the problems of interdependence, among which - and mainly -, the climate issue.

An outline of military technological dynamics as restraints for acquisition, international cooperation and domestic technological development

The expectation that technological returns from defense expenditure through acquisition, international cooperation and domestic research would further national development underappreciates the different technological dynamic of the armed services. This paper outlines the technological dynamic the stems from fighting in the air, at sea and on land, exemplifying consequences for the case of acquisition.

The international implications of the Chinese model of development in the Global South: Asian Consensus as a network power

This paper analyzes People's Republic of China (PRC) economic and political ascendance in the 21st century focusing on the evolution of the sui generis economic development model and its significances of the evolution of relationship between China and the developing countries in the peripheral "Global South." The objective of this article is to analyze the relationship between China and the Global South (Africa and South America) in the 21st century, characterized as a new Center-periphery global network power based on trade and investment that we call as "Asian Consensus."