Articles

Treaty shopping

The Tax Court of Canada rendered its much-anticipated decision in MIL (Investments) SA v. The Queen, 2006 TCC 460 on Aug 18, 2006. This is the first case to consider the application of the general anti-avoidance rule (GAAR) in Section 245 of the Income Tax Act to a "treaty shopping" transaction. The taxpayer was successful in convincing Justice R.D. Bell of the Tax Court of Canada that the GAAR did not apply. By way of background, the Canada Revenue Agency has consistently taken the position that the GAAR can be applied to deny a treaty benefit to a nonresident of Canada who enters into a series of transactions designed primarily to secure an exemption or reduction from Canadian tax under an income tax convention that Canada has with another country. The findings of the court in MIL continue to support treaty shopping as acceptable planning in the context of structuring crossborder investments. ...


Shopping.com: Analysis of a trend

Just three years ago, relatively minuscule numbers of shoppers were making purchases on the Internet. Electronic commerce (e-commerce) in 1996 amounted to only about $2.7 billion. Management Review reports that by 1998 the dollar amount had exploded to $73.9 billion, and the U.S. Department of Commerce expects e-commerce purchases to total $300 billion in the year 2002. ...


Albertsons offering Internet shopping

Albertsons had previously launched online shopping in several other markets, including Boise; Seattle; San Diego; Portland, Ore.; Las Vegas; Sacramento, Calif.; Philadelphia; Dallas-Ft. Worth; and the San Francisco Bay area. "We really don't think that this will ever be, at least not in the near future, our core business offering, obviously," said Danielle Killpack, Albertsons public affairs director for the Intermountain West. "But it's a service that we see has tremendous growth opportunity. We've had great success in doing it. The reason why we continue to expand is because we found a really successful model for us." ...


Genetic Algorithm for Web Information Query Optimization

To efficiently retrieve relevant documents from the rapid proliferation of large information collections, a novel query optimization algorithm based on genetic algorithm is proposed. The population is organized into query niches to explore potential document space. ...


Database Design for Web-Based Product Catalog

A Web-based product catalog is an online product database that requires easy access from anywhere in the world and uses the most efficient method for information retrieval. The database should support all products no matter what attributes the product has. ...


Web Site Design

Market research shows that there's no single `right' way to design a Web site, which is a good thing. Imagine how dull the Internet would be if it was made up of millions of identikit


Formalization of Web Design Patterns

Design patterns have been enthusiastically embraced in the software engineering community as well as in the Web community since they capture knowledge about how and when to apply ...


Towards Effective Web Site Designs: A Framework For Modeling, Design Evaluation And Enhancement

Effective Web site design is critical to the success of e-commerce. Therefore, the evaluation and enhancement of a Web site design is of great importance. ...



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The beginning of knowledge is the discovery of something we do not understand. Frank Herbert (1920 - 1986)