The Israeli Palestinian Conflict A Long And Storied History

The Israeli-Palestinian conflict has a long and storied history. Israel was created in response to European anti-Semitism, with the ethno-nationalist vision of a Jewish territory of their own. By 1948, approximately 522,000 Jews had migrated to Palestine, most arriving during Hitler’s reign of terror that against Jews. Largely, Palestinians resented being expelled from their lands and bearing the burden of the persecution of European Jews. Consequently, the 1947 UN partition sparked aggression between Jewish and Palestinian militias, which escalated following Israel’s independence in 1948. This marks the beginning of conflict between two distinct populations seeking self-determination. Since then, numerous wars, uprisings and terrorist†¦show more content†¦Consequently, it is also these conflicting narratives that frame the security dilemma and climate of fear within which neither party feels secure without obvious dominance over the other. Culture, narrative and politics While theory may prescribe guidelines within which we may analyse and interact in the international system, in reality we cannot avoid the intersection between politics and cultural history. Even in non-democratic societies, public opinion plays a significant role in the maintenance of peace. Compelling narratives of nationalism and revolution, transmitted through media and the arts, rally people in support of rebel or terrorist groups, inciting uprisings and violent attacks that only escalate insecurities on both sides. Moreover, popular culture facilitates the entrance of these narratives into the international community, shaping public perceptions of the conflict and allowing Palestine and Israel to justify their actions or reaffirm their sovereignty. The Palestinian narrative is one of a stable society uprooted by European Jewish settlers and subsequently subject to unjustified Israeli violence, emphasising â€Å"the history of Palestine, the poignant testimonials of Palestinians living under grievous conditions of occupation or exile or imprisonment, [and] the betrayals by international and national leaders.† Take

Financial Aid Sap Appeal - 907 Words

Jaclyn Morrison XXX Mark Ave XXXXXXX, OK 00000 Financial Aid Services Buchanan Hall, RM 216 1000 Asp Avenue Norman, OK 73019-4078 RE: Financial Aid Satisfactory Academic Progress Appeal Fall 2013: Personal Difficulties Plan for Academic Success To Whom It May Concern, I am writing to appeal my current student aid suspension for the Fall 2013 semester. I understand that the release of financial aid to me is of concern of the college due to my GPA being a 1.7 overall and 1.43 for the Spring 2013 semester. However, I have taken the steps to remedy the errors on my academic transcript regarding the repeated classes. The severity of the lower grades on my transcript affected my acceptance into the College of Arts and†¦show more content†¦Barwick-Snell for future advisement. Ms. Thomas kindly reminded me to keep my grades up and we would not have to be in this situation again. My academic record remains far from perfect, and I know this. I’m determined to continue to repair the damage I’ve caused and obtain a degree and start a career, not only for myself, but for my new family as well. I am employed full time at the Canadian County Children’s Justice Center in El Reno, Oklahoma. I work Monday-Frida y, 8:00 a.m. to 5:00 p.m., as well as some overtime if it is required of me. Working this schedule prevents me from taking classes on campus as well as making necessary trips to campus if I should need to. I have been limited to email and phone correspondence. I would love to be able to attend school full time and not have to be employed full time as well. That however, is not a luxury my husband and I can afford. I have worked hard to remedy any time management issues I have, but there are instances where I do not have enough time to study for the assignments and prepare myself fully for exams. I have taken steps to incorporate more study time into my schedule, such as during lunch breaks as well as before and after work. 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Management Accounting Transfer Pricing

Question: Discuss about the Management Accounting for Transfer Pricing. Answer: Introduction: The transfer price is referred as the price at which various divisions of the company transact in business. It is considered to be a trade of labour and goods between departments of a company. The individual entity of a multi entity fund treats the price of the goods and of labour separately. In multi entity corporations different division of the entity is in charge of their own profit, and their calculation of ROIC. The division who are in charge of their profit need to transact among them, and the transfer price concept is used to measure up the price of the goods. The transfer price market acknowledged the market rate of the goods. The goods transferred or to be transferred from one entity to another entity shall fix their price no less than the market rate. If they set the price of the goods lower than market rate, one entity is going to lose its profit. There are regulations in place that guide the transfer pricing concept. There has to be fairness and accuracy in transfer pricing among the entities. In the matter of transfer pricing, the regulation of the arms length is followed and the entities should establish pricing policy based on the transactions done between partiesnot related to each other but at arms length (Investopedia, 2016). Documentation: Transfer pricing requires strict documentation. The transactions involved in the transfer pricing requires close monitoring by the department and by the auditor. It is expected that all the deals related to the transfer pricing would be viewed and monitored in various department; any kind of discrepancy can lead to higher tax payment, regulatory penalty and restatement fees. It has to be ensured that profit for every department is booked properly and the price at the arms length concept is applied in the transfer pricing. It is well known fact that 60% of the goods sold internationally are between related companies (ATO, 2016). Different transfer pricing: The transfer pricing (TP) landscape in Australia is evolving. The tax authorities in Australia are planning to approach the transfer pricing concept by reference to arms length conditions. There are respective treaties accepted by Australia in TP will be applied. It is expected that new TP concept will incorporate the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines. The new TP laws were introduced in Australia after loss of commissioner in Full Federal Court case of Commissioner of Taxation vs. SNF (Australia) Pty Ltd. The holistic view of TP rules on arms length conditions including cross border transactions is acknowledged by Government of Australia and the plan was to incorporate OECDS Base Erosion and Profit Shifting (BEPS) strategy (Kpmg, 2014). According to OECD transfer pricing assessment methods has evolved over the time. In international marketing five different transfers pricing methods are used by the industries. The TP methods are as following: Transfer At cost: The companies generally use the transfer at cost approach which contributes to the corporate profitability in domestic manufacturing industries. This policy also helps to keep duties at a minimum. The companies do not have any profit expectation from transfer price. Cost-Plus Pricing: The cost-Plus pricing method suggests that companies have taken the position that profit must be shown at every stage of movement of the goods through the corporate system. The cost-plus pricing method may imply that price of the goods become completely unrelated to competitive or demand conditions in the international market. It is often seen that most of the exporters use that method. Market based Transfer price: In the market based transfer price the price of the goods to be derived from the international market. There is however considerable degree of variation how profit is to be determined. To enter the new market at the market based price would not help new entrant in the market. Arms-Length Transfer Pricing: It is called the price which is reached between unrelated parties in a similar transaction and these kinds of transactions are called as arms-length transfer pricing. The arms-length price can be seen as not the single price but the range of price. Tax Regulations and Transfer Prices: It is often seen that high tax countries do use the policy of reallocation of income and expenses to maximize national tax revenues. The rates determined by the tax department are insensitive to the business and to the income of the companies (Chand, 2016). Conclusion: OECD is working overtime to set the principal of TP right among member countries. The assessment of the price of the goods transferred to one entity to another entity needs to be fixed based on some regulations and methods to be adopted by various countries. There are five methods being applied by OECD to ascertain the price of the goods to be transferred genuinely. One of such method is known as CUP method, according to this method price of the property or goods transferred under controlled transactions to be compared with the price of the product under uncontrolled transaction. This method can be applied for all types of transactions but it has to be applied in a reasonable and reliable manner. The resale price method is used by the entities which has purchased some product from the associated entity at some price and resold to another entity. The resale price is effectively reduced by the appropriate gross margin. The cost plus method can also be followed where appropriate mark up to be added to the cost of the product to determine the price of the goods. The transactional net margin method is based on the net profit methods. The net profit is to be compared from the uncontrolled transactions in the business entity. The arms length price is to be compared with the actual price at which the transactions have taken place (OECD, 2010). The transfer pricing is nothing but transfer of the goods to one entity to another entity at price. In large companies operate divisions for production of goods. If one division releases the goods at the manufactured price, the efficiency of the division cannot be understood at the cost price. It is also seen that individual entity treats the price of the goods and of labour separately. It is obvious that in multi entity corporations different division charge profit, and calculate ROIC independently. The division charge of their profit need to transact among them, the valuation concept of the price based on transfer price arms length concept is used to measure up the price of the goods. The transfer price market acknowledged the market rate of the goods. Transfer pricing requires strict documentation. The transactions involved in the transfer pricing requires close monitoring by the department and by the auditor. The burden of accounting and documentation is significant as all the deals related to the transfer pricing would be viewed and monitored. Any of the discrepancy of charging lower price to evade tax can lead to regulatory penalty and restatement fees. Each department would look to establish profit from the operation and decide the price at the arms length concept. In all such transactions 60% of the goods sold internationally are between related companies (ATO, 2016). Cleaning and Scraping Division Processing Division Sales 95 160 Units 400000 400000 Direct material 18 5 Direct labour 12 10 Manufacturing overhead 40 25 Variable Cost Direct material 18 5 Direct labour 12 10 Manufacturing overhead 30 10 Selling cost 5 Variable Cost 65 25 Fixed Cost 4000000 6000000 Contribution Margin Sales-Variable Cost 31.58% 84.38% Sales The target of the transfer pricing is to ensure that goods produced by one department reaches to other department at the market price. The help of the price of the unrelated divisions is to be accepted for that purpose. Each division would love to buy goods at the lowest cost so that it can maximize the return of the goods. The target of the divisions would be negotiating the lowest possible price. Here the cost of Cleaning and Scraping Division producing Cruden at $70. If the division decides to sell the Cruden in the open market, it can sell the product at $95 a unit. Processing Division would love to buy the goods at $70. The decision of the company is that Cleaning and Scraping Division produces 400,000 units per year and transfers it all to the Processing Division at total actual manufacturing cost plus 10%. If this proposition is acceptable to the Processing Division, then it would buy the goods at 10% mark up resulting into $77. The target would be negotiating the best deal for the processing division. If processing division is placed at low tax country then the management of the company may decide to sell that product at $70 to the processing division but that may not be acceptable to the tax authorities and they may seek that the sale price of the Cleaning and Scraping Division is listed not below $95, which is the market rate. According to the transfer pricing rules the goods can be sold to other department at the cost price or at cost plus mark up. It is often seen that large organization transfer goods to no tax processing department at the cost price. The reason for such transfer is to evade tax. If the nest department or any be the assembly department is situated in a low tax country, the goods are transferred to that department at cost price, which saves significant amount of tax for the company (Treasury, 2016). There are several methods used to assess the transfer price namely; at cost-plus price. The cost plus price is the added mark up with the cost. One department or the entity transfers goods at the cost plus mark up price which is already negotiated between two departments. The price at the arms length concept can be utilized by the departments also, where the goods is transferred to the price prevailing at the market under unrelated transactions. The better idea would be transfer the goods from Cleaning and Scraping Division to Processing Division at the negotiated price which will be cost plus mark up. Here in this case cost plus 10% would be a better concept. References: ATO, 2016. International transfer pricing - introduction to concepts and risk assessment. [Online] www.ato.gov.au Available at: https://www.ato.gov.au/print-publications/international-transfer-pricing---introduction-to-concepts-and-risk-assessment/ [Accessed 08 September 2016]. ATO, 2016. Simplifying transfer pricing record keeping. [Online] www.ato.gov.au Available at: https://www.ato.gov.au/Business/International-tax-for-business/In-detail/Transfer-pricing/Simplifying-transfer-pricing-record-keeping/ [Accessed 08 September 2016]. Chand, S., 2016. 5 Types of Transfer Pricing Methods used in International Marketing. [Online] www.yourarticlelibrary.com Available at: https://www.yourarticlelibrary.com/product-pricing/5-most-important-types-of-transfer-pricing-methods-used-in-international-marketing/5820/ [Accessed 08 September 2016]. Investopedia, 2016. Transfer Price. [Online] www.investopedia.com Available at: https://www.investopedia.com/terms/t/transferprice.asp [Accessed 08 September 2016]. Kpmg, 2014. Global Transfer Pricing Review. [Online] www.kpmg.com Available at: https://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/global-transfer-pricing-review/Documents/australia-2014.pdf [Accessed 08 September 2016]. OECD, 2010. TRANSFER PRICING METHODS. [Online] www.oecd.org Available at: https://www.oecd.org/ctp/transfer-pricing/45765701.pdf [Accessed 08 September 2016]. Treasury, 2016. Income Tax: cross-border profit allocation - review of transfer pricing rules. [Online] treasury.gov.au Available at: https://treasury.gov.au/~/media/Treasury/Consultations%20and%20Reviews/Consultations/2016/OECD%20BEPS%20Transfer%20Pricing%20Recomendations/Key%20Documents/PDF/Transfer%20Pricing%20Guidelines%20Public_Consultation.ashx [Accessed 08 September 2016].