So many impossibly powerful foes have opposed the wolves and their allies over the years. Evil witches, warlocks, fae, elves, and alphas, just to name a few. And all have found the pack too strong to break. But the foe hellbent on taking down the pack now—the vampire king, Cain—has a plan that might finally tip the balance of power away from the wolves. In the middle of the desert, Cain works desperately to find a way to mix the blood of wolves and vampires. While most find the idea reprehensible, Cain believes it is the key to his victory. He imagines an army of unstoppable hybrids with the combined power of the vampires and the Canis lupus. Such a force would be unstoppable, even for the powerful of alpha of alphas, Fane Lupei. And Cain just might have found the secret ingredient necessary to bring his plans to fruition.

Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

This chapter presents a general method for combining uncertain and paradoxical (i.e. highly conflicting) sources of evidence for a wide class of fusion problems. From the foundations of the DSmT we show how the DSm rule of combination can be extended to take into account all possible integrity constraints (if any) of the problem under consideration due to the true nature of elements/concepts involved into it.

Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.

"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

This book constitutes the proceedings of the International Joint Conference on Rules and Reasoning, RuleML+RR 2018, held in Luxembourg during September 2018. This is the second conference of a new series, joining the efforts of two existing conference series, namely “RuleML” (International Web Rule Symposium) and “RR” (Web Reasoning and Rule Systems). The 10 full research papers presented together with 5 long technical communications and 7 short papers were carefully reviewed and selected from 33 submissions.

A much-needed addition to literature, this timely edited collection aims to provide clarity and understanding on how modern organizations work. The authors explore the characteristics of hybrid organizations in contemporary society, taking into account the complex societal challenges that face businesses today. Arguing that hybrid organizations are in fact not a new phenomenon, this thought-provoking collection goes beyond existing research and re-evaluates our traditional understanding of this concept. Scholars of organization, management and innovation will find this book an insightful read, as it sheds light on the fundamental aspects that shape today’s hybrid organizations.

If you do more than one thing for work, then you are more than one thing. If this describes you, then you may be a hybrid professional. Until recently, hybrids have been hidden in the workforce. But today and moving forward, the secret is out. In today's world, professional identity is no longer just about being an expert or a generalist. Now, workers can be both. These hybrid professionals have unique talents that defy conventional labels because they work at the intersections of their multiple identities. Discover how hybrid professionals are revolutionizing the workforce and leading exciting, one-of-a-kind work. If you're a jack-of-all-trades or trying to figure out what differentiates you from others, give yourself permission to become a hybrid professional and be more than your title.