Search results for: old testament taxation

Authors: Dario Rajmilovich

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The tax system represents a multidisciplinary cosmos whose main purpose is to provide financial resources to the government of a given political jurisdiction in order to apply them to the public purposes outlined by that government. Not withstanding this basic external configuration of a finalistic order, its internal structure essentially responds to a series of principles or axes whose roots can be traced in the Old Testament (written Torah) and in oral sources (especially the KaBaLáh or Cábala compiled in the second century of the Common era in the book called "the Zóhar" (Book of Splendor) attributed to Rabi Shimón bar Iojái). The purpose of this work is to outline a general theory of taxation based on the biblical principles inherent to taxation and to project its effects in the configuration of a just tax system designated as "Virtuous Taxation".

Keywords: principles of taxation, kabaláh and taxation, old testament taxation, virtuous taxation

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Authors: Maciej Dudek, Robert Kruszewski, Janusz Kudla, Konrad Walczyk

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In this paper, we study how taxation of bequests affects human capital formation in the long term and short term horizon. Our underlying model is an overlapping generation model (OLG) with some degree of altruism on the part of the ancestors' generation towards their descendants. We ask the question in three separate frameworks. First, we study a simple one-sector model where a proxy of human capital is wage income. It the steady-state -for CRRA utility function and human capital produced with non-decreasing returns -the taxation of bequests is neutral to the accumulation of human capital. In the second framework, neutrality applies to the growth rates of human capital, physical capital, and consumption. In this case, taxation increases the level of bequests, leading to a lower value of current consumption. Finally in we consider two periods model instead of infinite horizon model as long as the tax revenue is at least partially rebated back to the public, the fraction of human capital engaged in the process of formation of human capital increases with the tax rate on bequests. In other words, taxation of bequests is partially offset by an increase in human capital formation. Higher human capital allows the future generation to earn higher wages, and today's generation can find it optimal to endow the future generation with more human capital when taxation is imposed on physical capital transferred to the next generation.

Keywords: taxation, bequests, policy, human capital

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Authors: Theresia Simatupang dan Rahmayanti

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Tax Law is a legal product and therefore should be subject to the legal norms, both about this actions, implementation, and about the material. Law has always aimed at providing justice, and besides that the law as a tool used to organize the order or rule of law. tax classification of a crime in this is very necessary, because the crime of taxation is very detrimental to the country and is still very high in society and socialization associated with punishment in sentencing that would have to provide a deterrent for the perpetrators, so refer to the this, these criminal offenses can endanger the stability of the nation's economy and the country that require special snacks. The application of legal sanctions against the perpetrators of the crime of taxation already has a strong legal basis, namely UU KUP. UU KUP have loaded threat (sanctions) severe punishment for tax payers who commit offenses and crimes in the field of taxation, which is contained in Article 38, and Article 39, Article 41, Article 41 A, and 41 B as well as Article 43 of Law and Law No. 12 KUP about 1985 Land Tax and Building. Criminal sanctions against violators of the tax provision are important because tax payers sanctions for violating tax laws.

Keywords: accountability, tax crime, criminal liability, taxation

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Authors: Marny S. Menkes Lemmel

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Upon hearing or reading the term agape love in a Christian context, one typically thinks of God's love for people and the type of love people should have for God and others. While C.S. Lewis, a significant propagator of this view, and others with a similar opinion are correct in their knowledge of agape in the New Testament in most occurrences, nonetheless, examples of this term appear in the New Testament having quite a different sense. The New World Encyclopedia, regarding the verb form of agape, 'agapao,' comments that it is occasionally used also in a negative sense, but here and elsewhere, there is no elaboration on the significance of these negative instances. If intensity and sacrifice are the crucial constituents of God's agape love and that of his followers, who are commanded to love as God does, the negative instances of this term in the New Testament conceivably indicate that a person's love for improper recipients is likewise intense and sacrificial. This is significant because one who has chosen to direct such love neither to God nor his "neighbors," but to inanimate things or status, clearly shows his priorities, having decided to put all his energy and resources into them while demeaning those for whom God has required such love, including God himself. It is not merely a matter of a person dividing his agape love among several proper objects of that love, but of directing it toward improper targets. Not to heed God's commands regarding whom to love is to break God's entire law, and not to love whom one should, but to love what one should not, is not merely a matter of indifference, but is disloyalty and loathing. An example of such use of the term agape occurs in Luke 11:43 where the Pharisees do not and cannot love God at the same time as loving a place of honor in the synagogues and greetings in the public arena. The exclamation of their dire peril because of their love for the latter reveals that the previously mentioned love objects are not in God's gamut of proper recipients. Furthermore, it appears to be a logical conclusion that since the Pharisees love the latter, they likewise despise God and those whom God requires his people to love. Conversely, the objects of the Pharisees' love in this verse should be what followers of God ought to despise and avoid. In short, appearances of the use of the verb agapao in a negative context are blatant antitheses to what God expects and should alert the reader or listener to take notice. These negative uses are worthy of further discussion than a brief aside by scholars of their existence without additional comment.

Keywords: agape love, divine commands, focus, new testament context, sacrificial

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Authors: Dina Safrina

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This paper aims to discuss the suitability of tax administration in Indonesia based on Islamic Shari'a by looking at Abu Yusuf's idea of taxation. This research is a qualitative research and using data collection method by library research, that is by studying, deepening and citing theories or concepts from a number of literature. The purpose of this paper is to find out whether taxation in Indonesia is consistent with the thinking of Islamic economists, namely Abu Yusuf's idea which became known by economists as the canons of taxation. The ability to pay, lax time giving for taxpayers and the centralization of decision-making in the tax administration are some of the principles it emphasizes. In taxation he recommends the use of the Muqassamah (Proportional Tax) system rather than the Mixed (Fixed Tax) system. In this case, the determination of tax rates in Indonesia there are using fixed tax system, proportional tax, progressive tax and regressive tax. Abu Yusuf opposed the existence of Qabalah institution (the guarantor of tax payments to the state) at the time and suggested a tax administration centered and paid directly to the state. This is in accordance with those already applied in Indonesia where tax collection is done centrally. The tax system in Indonesia using self assessment system, which is the authority and responsibility given by the government to the taxpayer to calculate, pay and report the tax itself becomes the gap for taxpayers to commit fraud. Prerequisites that must be met for the success of this system is with the tax consciousness, tax honesty, tax mindedness, and tax discipline.

Keywords: Abu Yusuf, Indonesia, tax, tax administration

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Authors: Michael Sunday Afolayan

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This research work examined the challenges bedevilling the development of legal framework for electronic commercial transactions (e-commerce) in Nigeria. Nigeria does not have a clear-cut legislation regulating electronic commerce in its jurisdiction despite the geometrical rate of growth and adoption of this method of trade. It specifically posed a great challenge looking at taxation, evidential and jurisdictional issues in e-commerce in Nigeria. The author in a broader research work which is abridged here, traced the origin and development of e-commerce and the attendant laws applicable in Nigeria, examining their sufficiency or otherwise. In carrying out the research work, doctrinal mode of legal research was adopted, examining both primary and secondary sources of legal research materials within their contextual meanings. It was found that the failure to enact a law which has direct regulatory bearing on e-commerce in Nigeria has led to adoption and application of circumstantial laws, rules and common law principles to tackle the problems arising out of electronic commercial transactions, especially in the areas of taxation, evidential and jurisdictional challenges. It was ultimately suggested that there is urgent need to sign into law, the Electronic Transaction Bill which had already been passed by the National Assembly since 2017.

Keywords: e-commerce, legislation, taxation, evidential, jurisdiction

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Authors: Gabriele Palumbo

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This research empirically examines some of the reasons behind the fact that recently the number of people giving up their American citizenship for tax purposes has recently increased drastically. The United States Jurisdiction represents a unicum in the practice of taxing worldwide income not only to residents of the United States but also to U.S. citizens living abroad. The worldwide income taxation also affects people defined as “Accidental Americans” who are unaware that they are U.S. citizens. Those people are considered Americans even though they have not been to the United States. American residents abroad can rely on United States income tax treaties and some national law provisions, such as the exclusion of foreign income and foreign tax credits, which are designed specifically to avoid double taxation. However, this mechanism may prove unsatisfactory for people who have not been linked anymore or individuals who have never had relations with the United States. U.S. citizens who are determined to cut all of the ties between themselves and the United States, especially those that involve tax implications, can renounce their U.S. citizenship with the expatriation procedure. The expatriation process represents the extrema ratio and implicates several steps which must be followed carefully. This paper shows the complexity of the procedure that a U.S. citizen who is resident in a foreign country would have to follow to relinquish U.S. citizenship for tax purposes. The mechanism is intended to discourage people from renounce. Going beyond the question of whether U.S. tax regulation is fair or not, this principle nowadays characterizes a popular topic that many scholars and lawyers are discussing. The outcome provides interesting implications that could induce the Congress to rethink the definition of citizenship for both fiscal and nationality law purposes. Indeed, even if a sort of checks and balances has the task of mitigating the renunciation of U.S. citizenship, more and more U.S. citizens desire to get rid of their citizenship.

Keywords: double taxation, expatriation tax, international taxation, relinquishment of United States citizenship

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Authors: Axel Prettl

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This paper provides an overview of the different CFC rule settings in the OECD and 22 additional countries for the years 2004 to 2014 and compares them. In order to do so, it gives a summary of law amendments for every country, provides a comparison and afterwards all CFC rules are rated in their ”power of anti-avoidance” over time. For that rating of CFC rules, the largest common denominator of rule characteristics is used to keep it as abstract as necessary and possible. The paper points out that the CFC rules in the considered countries are very different in their specifications and they reach from very strict to very low binding. All in all these rules get more and more common and important; more countries implement a CFC legislation and the strictness of most of them rises over time.

Keywords: CFC rules, international taxation, corporate taxation, country comparison

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Authors: Khalid Javed

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This study examines a feature of the budget process called the tax expenditure budget. The tax expenditure concept relies heavily on a normative notion that shielding certain. Taxpayer income from taxation deprives government of its rightful revenues. This view is inconsistent with the proposition that income belongs to the taxpayers and that tax liability is determined through the democratic process, not through arbitrary, bureaucratic Assumptions. Furthermore, the methodology of the tax expenditure budget is problematic as its expansive tax base treats the multiple taxation of saving as the norm. By using an expansive view of income as the underlying assumption of the tax expenditure concept, this viewpoint institutionalizes a particular bias into the decision-making process.

Keywords: revenue, expenditure, tax budget, propostion

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Authors: Veronika Solilová, Danuše Nerudová

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The paper examines the interaction between the environmental taxation, size of government spending on environmental protection and greenhouse gas emissions and gross inland energy consumption. The aim is to analyze the effects of environmental taxation and government spending on environmental protection as an environmental policy instruments on greenhouse gas emissions and gross inland energy consumption in the EU15. The empirical study is performed using a VAR approach with the application of aggregated data of EU15 over the period 1995 to 2012. The results provide the evidence that the reactions of greenhouse gas emission and gross inland energy consumption to the shocks of environmental policy instruments are strong, mainly in the short term and decay to zero after about 8 years. Further, the reactions of the environmental policy instruments to the shocks of greenhouse gas emission and gross inland energy consumption are also strong in the short term, however with the deferred effects. In addition, the results show that government spending on environmental protection together with gross inland energy consumption has stronger effect on greenhouse gas emissions than environmental taxes in EU15 over the examined period.

Keywords: VAR analysis, greenhouse gas emissions, environmental taxation, government spending

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Authors: Takesure Mahohoma

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Community life is an epitome of the African axiom 'I am because we are, since we are therefore I am.' This culminates in the Ubuntu philosophy which is summarized in the Zulu words, 'umuntu ngumuntu ngabantu' (A person is a person through other people). This relationship gives honour to all people. This is the gist of the paper. This paper seeks to demonstrate the impact of community life in promoting unity from an African perspective. Using the proto-community in Acts 2:42, it is argued that community life is a solution to many social problems that divide African society today. The aim is to encourage all Africans and other people to cultivate a sense of belonging and valuing community life in the light of Acts 2:42. Hence we shall trace this theme from Old Testament, New Testament, and Christian history. The other section touches on the essence of community life and obstacles that hinder it. We shall offer spiritual suggestions and an integrative reflection. The nature of the paper is theology in general but spiritual in particular. As a spiritual paper, it is guided by the foundational approach. Thus, it employs the dialogical and integrative reflection method. The expected result is that freedom from all the miseries experienced is brought by living a community life. This is a life that gives greater assurance of enough food, education, health, peace, employment, and increased responsibility that values human dignity. Thus people are neighbours to each other. There is no stranger among them. The basic presumption is that there can be no development in any society without community life.

Keywords: community, seged, koinonia, neighbor

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Authors: Muhammad A. Ishaq, S. U. R. Aliyu

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This paper on an exposition of Islamic fiscal policy attempts to discuss the basic principles of Islamic fiscal policy in an Islamic economy. The paper presents a number of definitions of the subject matter, its nature and its tools of application. Government spending, taxation and public borrowings were identified as the tools of the policy. The paper identifies zakat both as a veritable source of revenue and a major instrument of economic stabilization. Furthermore, the paper presents an algebraic 2-sector and 3-sector models from the basic Keynesian model. The paper posits that in view of uniqueness of its instruments, absence of interest rate in the economy and the policy’s derive towards socioeconomic justice and redistribution, Islamic fiscal policy is capable of stabilizing Islamic economy and ushering it into the path of long term economic growth and prosperity.

Keywords: automatic built-in-stabilizers, government spending, Islamic fiscal policy, taxation, zakat

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Authors: Jeeban Amgain

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This paper investigates the impact of the size and composition of government expenditure and tax on GDP per capita growth in 36 Asian economies over the period of 1991-2012. The research employs the technique of panel regression; Fixed Effects and Generalized Method of Moments (GMM) as well as other statistical and descriptive approaches. The finding concludes that the size of government expenditure and tax revenue are generally low in this region. GDP per capita growth is strongly negative in response to Government expenditure, however, no significant relationship can be measured in case of size of taxation although it is positively correlated with economic growth. Panel regression of decomposed fiscal components also shows that the pattern of allocation of expenditure and taxation really matters on growth. Taxes on international trade and property have a significant positive impact on growth. In contrast, a major portion of expenditure, i.e. expenditure on general public services, health and education are found to have significant negative impact on growth, implying that government expenditures are not being productive in the Asian region for some reasons. Comparatively smaller and efficient government size would enhance the growth.

Keywords: government expenditure, tax, GDP per capita growth, composition

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Authors: Marco Sewald

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Due to the current enforcement of exterritorial U.S. legislation, up to 9 million U.S. (dual) citizens residing abroad are subject to U.S. double and surcharge taxation and at risk of losing access to otherwise basic financial services and investment opportunities abroad. The United States is the only OECD country that taxes non-resident citizens, lawful permanent residents and other non-resident aliens on their worldwide income, based on local U.S. tax laws. To enforce these policies the U.S. has implemented ‘saving clauses’ in all tax treaties and implemented several compliance provisions, including the Foreign Account Tax Compliance Act (FATCA), Qualified Intermediaries Agreements (QI) and Intergovernmental Agreements (IGA) addressing Foreign Financial Institutions (FFIs) to implement these provisions in foreign jurisdictions. This policy creates systematic cases of double and surcharge taxation. The increased enforcement of compliance rules is creating additional report burdens for U.S. persons abroad and FFIs accepting such U.S. persons as customers. FFIs in Europe react with a growing denial of specific financial services to this population. The numbers of U.S. citizens renouncing has dramatically increased in the last years. A case study is chosen as an appropriate methodology and research method, as being an empirical inquiry that investigates a contemporary phenomenon within its real-life context; when the boundaries between phenomenon and context are not clearly evident; and in which multiple sources of evidence are used. This evaluative approach is testing whether the combination of policies works in practice, or whether they are in accordance with desirable moral, political, economical aims, or may serve other causes. The research critically evaluates the financial and non-financial consequences and develops sufficient strategies. It further discusses these strategies to avoid the undesired consequences of exterritorial U.S. legislation. Three possible strategies are resulting from the use cases: (1) Duck and cover, (2) Pay U.S. double/surcharge taxes, tax preparing fees and accept imposed product limitations and (3) Renounce U.S. citizenship and pay possible exit taxes, tax preparing fees and the requested $2,350 fee to renounce. While the first strategy is unlawful and therefore unsuitable, the second strategy is only suitable if the U.S. citizen residing abroad is planning to move to the U.S. in the future. The last strategy is the only reasonable and lawful way provided by the U.S. to limit the exposure to U.S. double and surcharge taxation and the limitations on financial products. The results are believed to add a perspective to the current academic discourse regarding U.S. citizenship based taxation, currently dominated by U.S. scholars, while providing sufficient strategies for the affected population at the same time.

Keywords: citizenship based taxation, FATCA, FBAR, qualified intermediaries agreements, renounce U.S. citizenship

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Authors: Zahra Mohagheghian, Fatema Agharebparast

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The comparative study of religions is one of the ways which provides peace and makes the believers of religions closer together. Finding the common notions could be a foundation for the dialog among the monotheistic religions and a background to eliminate the misunderstandings and to reach common point of views. The cornerstone of all the common efforts of the believers of the religions is to reach an understanding for building a better world where true peace is established. So, the article seeks to verify the notion of positive thinking in the religious resources of Islam and Christianity. In order to understand the foundations of the religious teachings and to provide a better understanding among the believers, then, the article tries to discover the common fundamentals and the opposing points about the positive thinking in these two religions. We first try to explain the notion of positive thinking in Islam and Christianity and then offer recommended ways in both religions to create and to strengthen this way of thinking. As the different parts of the New Testament is not theologically homogeneous, this collection has been verified and explained in four different parts: Three Gospels (Matthew, Mark and Luke), John's thoughts, thoughts and ideas of Paul and finally the Christian sects . The findings of the survey show that the notion of positive thinking in the monotheistic religions of Islam and Christianity can be traced back by the keyword "hope". It is only the hope which could finally create the soul of positive attitude and thinking inside the humankind. This hope is accompanied by the prospect and causes the humankind to work hard to reach their goals. However, there are some opposing points in these two religions about the basic foundation of this true hope. From the Quran viewpoint, the main foundation of the hope is God and the human is obliged to follow his worldly goals in accordance with this foundation as well as faith to God and avoidance of committing sins. On the other hand, the basic foundation of hope in the Three Gospels (Matthew, Mark and Luke) and the teachings of Paul is the promise of a coming Kingdom. Although there are some opposing views about the meaning of this as well as the ways to attain this hope, this hope is generally related to the purpose of human life and afterlife. The Christ, in the John's thoughts, is the source of hope and everybody, believing in God, must also have hope for Jesus Christ. Effects and functions of such hope are strengthening the spirit of love and kindness to others. Hence, in Christianity, the hope and positive thinking about the future, along with good deeds, reflects different viewpoints. On the other hand, in Quran, this is faith to God and fulfilling the Sharia orders which ignite and strengthen this hope and way of thinking. This is the base that continues nowadays with Vilāya and the love for Ahlulbeit in the Shiite views.

Keywords: God, new testament, positive thinking, Quran

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Authors: Abdulmajeed Abdullah Alqarni

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This paper is devoted a study of the current frameworks applicable to foreign investments at the levels of domestic and international law, with a particular focus on the legitimate balance to be achieved between the rights of the host state and the legal protections owed to foreign investors. At the wider level of analysis, the paper attempts to map and critically examine the relationship between foreign investment and economic development. In doing so, the paper offers a study in how current discourses and practices on investment law can reconcile the competing interests of developing and developed countries. The study draws on the growing economic imperative for developing nations to create a favorable investment climate capable of attracting private foreign investment. It notes that that over the past decades, an abundance of legal standards that establish substantive and procedural protections for legal forms of foreign investments in the host countries have evolved and crystalized. The study then goes on to offer a substantive analysis of legal reforms at the domestic level in countries such as Saudi Arabia before going on to provide an in- depth and substantive examination of the most important instruments developed at the levels of international law: bilateral investment agreements and double taxation agreements. As to its methods, the study draws on case studies and from data assessing the link between double taxation and economic development. Drawing from the extant literature and doctrinal research, and international and comparative jurisprudence, the paper excavates and critically examines contemporary definitions and norms of international investment law, many of which have been given concrete form and specificity in an ever-expanding number of bilateral and multilateral investment treaties. By reconsidering the wider challenges of conflicts of law and jurisdiction, and the competing aims of the modern investment law regime, the study reflects on how bilateral investment treaties might succeed in achieving the dual aims of rights protection and economic sovereignty. Through its examination of the double taxation phenomena, the study goes on to identify key practical challenges raised by the implementation of bilateral treaties whilst also assessing the sufficiency of the domestic and international legal solutions that are proposed in response. In its final analysis, the study aims to contribute to existing scholarship by assessing contemporary legal and economic barriers to the free flow of investment with due regard for the legitimate concerns and diversity of developing nations. It does by situating its analysis of the domestic enforcement of international investment instrument in its wider historical and normative context. By focusing on the economic and legal dimensions of foreign investment, the paper also aims to offer an interdisciplinary and holistic perspective on contemporary issues and developments in investment law while offering practical reform proposals that can be used to be achieve a more equitable balance between the rights and interests of states and private entities in an increasingly trans nationalized sphere of investment regulation and treaty arbitration.

Keywords: foreign investment, bilateral investment treaties, international tax law, double taxation treaties

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Authors: Efrizal, Ferdiansyah, Noorlailie Soewarno, Bambang Tjahjadi

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Tax revenue plays an important role in the State Budget of the Government of Indonesia (GOI). The GOI keeps raising tax revenue portion of the Budget from year to year. The low tax ratio of 11 percent in Indonesia shows a big opportunity to collect taxes in the future. The Directorate General of Taxation (DGT) is the institution mandated by the Law to collect tax revenue. This is a case study using quantitative and qualitative approaches. This study introduces contingent factors of taxpayers’ compliance as the mediating variable and internal business process as the independent variable. This study aims to empirically test the contingency theory, especially the mediating effect of taxpayers’ compliance on internal business process-tax revenue relationship. Internal business processes of the DGT include servicing, counseling, expanding, supervising, inspecting, and enforcing. The secondary data of 31 regional offices representing 293 tax offices in Indonesia was collected and analyzed using Partial Least Square. The result showed the following: (1) internal business process affected tax revenue; (2) taxpayers’ compliance did not mediate internal business processes - tax revenue relationship, and (3) taxpayers’ compliance affected tax revenue. In-depth interviews revealed that the DGT needs to make more innovations in business processes in the future.

Keywords: innovations, internal business process, taxpayers’ compliance, tax revenue

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Authors: Lars Hornuf, Valeriia Khlopchyk

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The labor market is experiencing a significant transformation as traditional employment is being progressively supplemented or replaced by temporary, platform-mediated work. However, the full extent and impact of this shift remain not fully measured yet. In this study, we explore the size and dynamics of the crowdworking industry. Most existing studies on the number and earnings of crowdworkers are based on surveys and interviews and can be subject to reporting bias. To overcome this limitation, we adopt a hard data approach by leveraging data from multiple online platforms to provide a more comprehensive and unbiased assessment of the crowdworking industry. We estimate the number of crowdworkers, crowdworking platform revenues, and crowdworkers earnings. Additionally, we analyze the existing labor relationships and tax implications in the crowdworking industry. Our findings indicate that the number of crowdworkers shows a substantial annual growth of 11.28%. Furthermore, our study estimates the revenues of crowdworking platforms and the earnings of crowdworkers showing consistent annual growth, which demonstrates the shift in perception from crowdwork being a supplementary income to a primary source of income. We also reveal that most crowdworkers are classified as independent contractors and are solely responsible for taxation, highlighting the lack of labor protection for crowdworkers and the challenges for tax authorities in tracking taxation and recovering unpaid taxes.

Keywords: crowdsourcing, online labor, platform economy, online work, labor supply

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Authors: Ivana Prochazkova

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Cognitive linguistics offers biblical scholarship a specific methodological tool for analysis and interpretation of metaphorical expressions. Its methodology makes it possible to study processes involved in constructing the meaning of individual metaphorical expressions and whole conceptual metaphors; to analyze their function in the text; to follow the semantic development of concepts and conceptual domains, and to trace semantic changes and their motivation. The legal language in the Hebrew canon is extremely specific and formalized. Especially in the preambles to the collections of laws in the Pentateuch, more general considerations of the motif of keeping and breaking the law are encountered. This is also true in the psalms and wisdom literature. Legal theory and the philosophy of law deal with these motifs today. Metaphors play an important role in texts that reflect on more general issues. The purpose of this conference contribution is to write all over the central metaphorical concept, conceptual metaphor ךרד תורה (TORAH/LAW IS A JOURNEY), its function in the Torah and principal trends of the further development in the Prophets and the Writings. The conceptual metaphor תורה ךרד (TORAH/LAW IS A JOURNEY) constitutes a coherent system in conjunction with other metaphors that include e.g., conceptual metaphors נחה תורה (TORAH/LAW LEADS); its variant רעה תורה (TORAH IS A SHEPHERD/GUIDE); מקור תורה (TORAH/LAW IS A FOUNTAIN/A SOURCE OF LIFE). Some conceptual metaphors are well known, and their using are conventional (עשׁר תורה TORAH/LAW IS RICHES, שׂשׂון תורה TORAH/LAW IS DELIGHT, דבשׁ תורה TORAH/LAW IS HONEY, שׁמשׁ תורה TORAH/LAW IS SUN ). But some conceptual metaphors are by its occurrence innovative and unique (e.g., שׁריון תורה TORAH /LAW IS BODY ARMOR, כובע תורה TORAH /LAW IS A HELMET, בגד תורה TORAH/LAW IS A GARMENT, etc.). There will be given examples. Conceptual metaphors will be described by means of some 'metaphorical vehicles,' which are Hebrew expressions in the source domain that are repeatedly used in metaphorical conceptualizations of the target domain(s). Conceptual metaphors will be further described by means of 'generic narrative structures,' which are the particular aspects of a conceptual metaphor that emerge during the metaphorical structuring of concepts. They are the units of the metaphorical vehicles – the Hebrew expressions in the source domain – that structure concepts in much the same way that the conceptual metaphor in the target domain does. And finally, they will be described by means of the network of correspondences that exist between metaphorical vehicles – or generic metaphorical structures – and the Hebrew expressions in the target domain.

Keywords: cognitive theology, conceptual metaphor in the Old Testament, conceptual metaphors of the Torah, conceptual domain of law, righteousness, and justice

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Authors: jihen ayadi sellami

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The rapid evolution of the global financial landscape has led to increased attention to corporate tax policies and the need to understand the factors that influence their tax behavior. In order to mitigate any residual loss for shareholders resulting from tax aggressiveness and resolve the agency problem, appropriate systems that separate the function of management from that of controlling are needed. In this context of growing concerns to limit aggressive corporate taxation practices through governance, this study discusses. Its aims is to examine the influence of six key characteristics of the board of directors (board size, diligence, CEO duality, presence of audit committees, gender diversity and independence of directors), given a governance mechanism, on the tax decisions of non-financial corporations in the United State. In fact, using a sample of 90 non-financial US firms from S&P 500 over a period of 4 years going from 2014 to 2017, the results based on a multivariate linear regression highlight significant associations between these characteristics and corporate tax policy. Notably, larger board, gender diversity, diligence and increased director independence appear to play an important role in reducing aggressive taxation. While duality has a positive and significant correlation with tax aggressiveness, that can be explained by the fact that the manager did properly exploit his specific position within the company. These findings contribute to a deeper understanding of how board characteristics can influence corporate tax management, providing avenues for more effective corporate governance and more responsible tax decision-making

Keywords: tax aggressiveness, board of directors, board size, CEO duality, audit committees, gender diversity, director independence, diligence, corporate governance, united states

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Authors: Dilliram Paudyal

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The history of taxation in Nepal dates back to antiquity. However, the modern tax system gained its momentum after the establishment of democracy in 1951, which initially focused only land tax and tariff on foreign trade. In the due time, several taxes were introduced, such as direct taxes, indirect taxes, and non-taxes. However, the tax structure in Nepal is heavily dominated by indirect taxes that contribute more than 60 % of the total revenue. The government has been mobilizing revenues through a series of tax reforms during the Tenth Five-year Plan (2002 – 2007) and successive Three-year Interim Development Plans by introducing several tax measures. However, these reforms are regressive in nature, which does not lead the overall economy towards short-run stability as well as in the long run development. Based on the literature review and discussion among government officials and few taxpayers individually and groups, this paper aims to major issues and challenges that hinder the tax reform effective in Nepal. Additionally, this paper identifies potential way and process of tax reform in Nepal. The results of the study indicate that transparency in a major problem in Nepalese tax system in Nepal, where serious structural constraints with administrative and procedural complexities envisaged in the Income Tax Act and taxpayers are often unaware of the specific size of tax which is to comply them. Some other issues include high tax rate, limited tax base, leakages in tax collection, rigid and complex Income Tax Act, inefficient and corrupt tax administration, limited potentialities of direct taxes and negative responsiveness of land tax with higher administrative costs. In the context, modality of tax structure and mobilize additional resources is to be rectified on a greater quantum by establishing an effective, dynamic and highly power driven Autonomous Revenue Board.

Keywords: corrupt, development, inefficient, taxation

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Authors: Nino Pailodze, Malkhaz Sulashvili, Vladimer Kekenadze, Tea Khutsishvili, Irma Makharashvili, Aleksandre Kekenadze

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In the nearest future among the important problems which Georgia has solve the most important is economic stability, that bases on fiscal policy and the proper definition of the its directions. The main source of the Budget revenue is the national income. The State uses taxes, loans and emission in order to create national income, were the principal weapon are taxes. As well as fiscal function of the fulfillment of the budget, tax systems successfully implement economic and social development and the regulatory functions of foreign economic relations. A tax is a mandatory, unconditional monetary payment to the budget made by a taxpayer in accordance with this Code, based on the necessary, nonequivalent and gratuitous character of the payment. Taxes shall be national and local. National taxes shall be the taxes provided for under this Code, the payment of which is mandatory across the whole territory of Georgia. Local taxes shall be the taxes provided for under this Code, introduced by normative acts of local self-government representative authorities (within marginal rates), the payment of which is mandatory within the territory of the relevant self-governing unit. National taxes have the leading role in tax systems, but also the local taxes have an importance role in tax systems. Exactly in the means of local taxes, the most part of the budget is formatted. National taxes shall be: income tax, profit tax, value added tax (VAT), excise tax, import duty, property tax shall be a local tax The property tax is one of the significant taxes in Georgia. The paper deals with the taxation mechanism that has been operated in Georgia. The above mention has the great influence in financial accounting. While comparing foreign legislation towards Georgian legislation we discuss the opportunity of using their experience. Also, we suggested recommendations in order to improve the tax system in financial accounting. In addition to accounting, which is regulated according the International Accounting Standards we have tax accounting, which is regulated by the Tax Code, various legal orders / regulations of the Minister of Finance. The rules are controlled by the tax authority, Revenue Service. The tax burden from the tax values are directly related to expenditures of the state from the emergence of the first day. Fiscal policy of the state is as well as expenditure of the state and decisions of taxation. In order to get the best and the most effective mobilization of funds, Government’s primary task is to decide the kind of taxation rules. Tax function is to reveal the substance of the act. Taxes have the following functions: distribution or the fiscal function; Control and regulatory functions. Foreign tax systems evolved in the different economic, political and social conditions influence. The tax systems differ greatly from each other: taxes, their structure, typing means, rates, the different levels of fiscal authority, the tax base, the tax sphere of action, the tax breaks.

Keywords: international accounting standards, financial accounting, tax systems, financial obligations

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Authors: Simone Tedeschi, Francesco Crespi, Paolo Liberati, Massimo Paradiso, Antonio Sciala

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This paper aims at contributing to the understanding of smokers’ responses to cigarette prices increases with a focus on heterogeneity, both across individuals and price levels. To do this, a stated preference quasi-experimental design grounded in a random utility framework is proposed to evaluate the effect on smokers’ utility of the price level and variation, along with social conditioning and health impact perception. The analysis is based on individual-level data drawn from a unique survey gathering very detailed information on Italian smokers’ habits. In particular, qualitative information on the individual reactions triggered by changes in prices of different magnitude and composition are exploited. The main findings stemming from the analysis are the following; the average price elasticity of cigarette consumption is comparable with previous estimates for advanced economies (-.32). However, the decomposition of this result across five latent-classes of smokers, reveals extreme heterogeneity in terms of price responsiveness, implying a potential price elasticity that ranges between 0.05 to almost 1. Such heterogeneity is in part explained by observable characteristics such as age, income, gender, education as well as (current and lagged) smoking intensity. Moreover, price responsiveness is far from being independent from the size of the prospected price increase. Finally, by comparing even and uneven price variations, it is shown that uniform across-brand price increases are able to limit the scope of product substitutions and downgrade. Estimated price-response heterogeneity has significant implications for tax policy. Among them, first, it provides evidence and a rationale for why the aggregate price elasticity is likely to follow a strictly increasing pattern as a function of the experienced price variation. This information is crucial for forecasting the effect of a given tax-driven price change on tax revenue. Second, it provides some guidance on how to design excise tax reforms to balance public health and revenue goals.

Keywords: smoking behaviour, preference heterogeneity, price responsiveness, cigarette taxation, random utility models

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Authors: Ponghyung Lee

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This study seeks to investigate the variations occurring to Korean consonantal variations center around laryngeal features of the concerned sounds, to the exclusion of others. Our fundamental premise is that the weak contrast associated with concerned segments might be held accountable for the oscillation of the status quo of the concerned consonants. What is more, we assume that an array of notions as a measure of communicative efficiency of linguistic units would be significantly influential on triggering those variations. To this end, we have tried to compute the surprisal, entropic contribution, and relative contrastiveness associated with Korean obstruent consonants. What we found therein is that the Information-theoretic perspective is compelling enough to lend support our approach to a considerable extent. That is, the variant realizations, chronologically and stylistically, prove to be profoundly affected by a set of Information-theoretic factors enumerated above. When it comes to the biblical proper names, we use Georgetown University CQP Web-Bible corpora. From the 8 texts (4 from Old Testament and 4 from New Testament) among the total 64 texts, we extracted 199 samples. We address the issue of laryngeal feature variations associated with Korean obstruent consonants under the presumption that the variations stem from the weak contrast among the triad manifestations of laryngeal features. The variants emerge from diverse sources in chronological and stylistic senses: Christianity biblical texts, ordinary casual speech, the shift of loanword adaptation over time, and ideophones. For the purpose of discussing what they are really like from the perspective of Information Theory, it is necessary to closely look at the data. Among them, the massive changes occurring to loanword adaptation of proper nouns during the centennial history of Korean Christianity draw our special attention. We searched 199 types of initially capitalized words among 45,528-word tokens, which account for around 5% of total 901,701-word tokens (12,786-word types) from Georgetown University CQP Web-Bible corpora. We focus on the shift of the laryngeal features incorporated into word-initial consonants, which are available through the two distinct versions of Korean Bible: one came out in the 1960s for the Protestants, and the other was published in the 1990s for the Catholic Church. Of these proper names, we have closely traced the adaptation of plain obstruents, e. g. /b, d, g, s, ʤ/ in the sources. The results show that as much as 41% of the extracted proper names show variations; 37% in terms of aspiration, and 4% in terms of tensing. This study set out in an effort to shed light on the question: to what extent can we attribute the variations occurring to the laryngeal features associated with Korean obstruent consonants to the communicative aspects of linguistic activities? In this vein, the concerted effects of the triad, of surprisal, entropic contribution, and relative contrastiveness can be credited with the ups and downs in the feature specification, despite being contentiousness on the role of surprisal to some extent.

Keywords: entropic contribution, laryngeal feature variation, relative contrastiveness, surprisal

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Authors: Abraham Kuruvilla

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Since the inception of Christianity, one of the most important precepts has been that of the ‘word becoming flesh.’ Incarnation, as we understand it, is that the ‘word became flesh.’ As we know, it is a commonly held understanding that the concept of Logos was borrowed from the Greek religion. Such understanding has dominated our thought process. This is problematic as it does not draw out the deep roots of Logos. The understanding of Logos also existed in religion such as Hinduism. For the Hindu faith, the understanding of Shabd is pivotal. It could be arguably equated with the understanding of the Logos. The paper looks into the connection of the primal Christian doctrine of the Logos with that of the Hindu understanding of Shabd. The methodology of the paper would be a comparative theological analysis with the New Testament understanding of the Logos with that of the understanding of Shabd as perceived in the different Vedas of the Hindu faith. The paper would come to the conclusion that there is a conceptual connectivity between Logos and the Shabd. As such the understanding of Logos cannot just be attributed to the Greek understanding of Logos, but rather it predates the Greek understanding of Logos by being connected to the Hindu understanding of Shabd. Accordingly, such comparison brings out the implication for a constructive dialogue between Christianity and the Hindu faith.

Keywords: Christianity, Hinudism, Logos, Shabd

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Authors: Lavan Vickneson

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In today’s modern economy, the conventional banking model is the primary banking system used around the world. A significant problem faced by the conventional banking model is the recurring nature of banking crises. History’s record of the various banking crises, ranging from the Great Depression to the 2008 subprime mortgage crisis, is testament to the fact that banking crises continue to strike despite the preventive measures in place, such as bank’s minimum capital requirements and deposit guarantee schemes. If banking crises continue to occur despite these preventive measures, it necessarily follows that there are inherent flaws with the conventional banking model itself. In light of this, a possible alternative banking model to the conventional banking model is Islamic banking. To date, Islamic banking has been a niche market, predominantly serving Muslim investors. This paper seeks to explore the possibility of Islamic banking being more than just a niche market and playing a greater role in banking sectors around the world, by being a viable alternative to the conventional banking model.

Keywords: bank crises, conventional banking model, Islamic banking, niche market

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Authors: Rimma Kiseleva

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The hotel business has a long history. The basis of the service of hospitality industry enterprises is the service, attitude, and consciousness of employees as hospitable “hosts of the house”. It is generally accepted that the founder and main expert of quality service is Caesar Ritz, “the king of hoteliers and the hotelier of kings.” However when deeply immersed in the history of the universe, it turns out that the very first book about hospitality, standardization of guest reception processes and the basics of better service is nothing more than the Bible. A unique study on the topic of considering the Church as a hotel, as well as the hotel business itself as the most gracious work of Jesus Christ Himself, which is confirmed by verses from the Gospel, includes the following approaches: analytical, comparative, empirical. The study shows that it was Jesus Christ who became the founder of the rules of the most sacrificial service, real service to people, filled with brotherly love, humility, love for strangers, those qualities that are the foundation, the “three pillars” of the hospitality industry. And also that the hotel is the most charitable cause, which is still relevant today.

Keywords: Augustine Aurelius, Bible, Gospel, guest house, hospitality, hotel, humility, inn, Jesus Christ, Joseph Fletcher, New Testament, Paul Tillich, service, strangeness

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Authors: Nan Hu, Wujun Wang

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In the ever-changing digital arena, augmented reality (AR) applications have transitioned from technological enthusiasm into business endeavors, signaling a near future in which AR applications are integrated into daily life. While practitioners in the design industry continue to explore AR’s potential for innovative communication, educators have taken steps to incorporate AR into the curricula for design, explore its creative potential, and realize early initiatives for teaching AR in design-related disciplines. In alignment with recent advancements, this paper presents a pedagogical model for a hybrid studio course in which students collaborate with AR alongside 3D modeling and graphic design. The course extended students’ digital capacity, fostered their design thinking skills, and immersed them in a multidisciplinary design process. This paper outlines the course and evaluates its effectiveness by discussing challenges encountered and outcomes generated in this particular pedagogical context. By sharing insights from the teaching experience, we aim to empower the community of design educators and offer institutions a valuable reference for advancing their curricular approaches. This paper is a testament to the ever-evolving landscape of design education and its response to the digital age.

Keywords: 3D, AR, augmented reality, design thinking, graphic design

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Authors: Mh. D Tammam Ayoubi

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The Old Testament has been translated into many languages, including Arabic. There have been consecutive translations of it since Islamic antiquity. The Rabbinic translation, which rendered the Hebrew text into Arabic without a linguistic medium, appeared later. It was followed by several Orthodox and Jesuit trials, including the Protestant translation. Those two translations were chosen to study the book of Proverbs, which is classified as one of the books of Wisdom; something that distances it from being either symbolical or historical and makes the translation the subject of the translator's ideology starting from the incorporated cultural element be it Jewish, Aramaic or Islamist (Mu'tazila) of the first translation, or through the choice of the equivalent signs of origin, and the neutralization of the Rabbinic, Arabic, and Greek element of the second translation. The various Protestant translation of different authors has contributed to the multiplicity of the term of reference, mostly Christian, in contrast with the single reference of one author, which carries multiple conflicting cultural facades when it comes to the Rabbinic translation. This has led to a change in the origin through the inclusion of those various verbal or interpretative elements in the book of Proverbs, which will be examined in the verses through a comparative study with the original Hebrew text or the cultural terms or references.

Keywords: rabbinic and protestant translations, book of proverbs, hebrew, protestant translation

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Authors: Dawit Dibekulu, Tesfaye Dagnew, Tesfamaryam G. Meskel

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Echoing with memories of loss and whispers of despair, this study delves into the poignant world of melancholy in Sisay Nigusu's contemporary Amharic novel, ‘Yäqənat Zār’ (‘Zār of Jealousy’). Employing a psychoanalytic lens focused on Freud and Klein's theories of mourning and melancholia, we explore the psychological depths of characters ravaged by grief. Through an interpretive paradigm and descriptive research design, we unpack the intricate tapestry of the novel, revealing how love's ashes morph into melancholic despair. The loss of loved ones, be it sudden death or betrayal, casts long shadows on the characters' souls, distorting their behavior and twisting their narratives. Altered thoughts, self-blame, and paralyzing yearning become their companions, weaving a tragic dance of longing and despair. ‘Yäqənat Zār’ serves as a powerful testament to the transformative power of storytelling, allowing us to navigate the labyrinthine paths of melancholia and gain a glimpse into the Ethiopian soul grappling with loss. This study not only sheds light on the individual's struggle with sadness but also illuminates the cultural fabric of grief and melancholia intricately woven into Ethiopian society.

Keywords: melancholy, loss, psychoanalysis, grief, identity

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