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Source text - English (All pages)
Logical CMS for ASP.NET
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(what is Logical CMS for ASP.NET)
What is Logical CMS for ASP.NET?
Logical CMS takes in the simplest descriptions of content for a Web site and produces two things: Code to be inserted into an ASP.NET project and an interface that allows content contributors to manage the project's content. Logical CMS generates ASP.NET code which is completely customizable, and thus compatible with any ASP.NET application. Logical CMS generates code in C# and VB. The code that Logical CMS generates is compatible with both Visual Studio 2005
Translation - Chinese (所有页面)
Microfost Windows Xp, Vista, Windows Server 2003
Internet Information Server 6.0 或7.0
Microsoft SQL Server 2005 (Express 版本，或更高版本)
ASP.NET Framework 3.5
CMS 项目可以手工部署到Windows Server 2008/SQL Server 2008 平台
English to Chinese: Comparable Uncontrolled Transaction General field: Bus/Financial Detailed field: Law: Contract(s)
Source text - English Comparable Uncontrolled Transaction
The Comparable Uncontrolled Transaction Method (CUT) is used to test arm's length nature of
the intercompany transfer of intangible property, utilizing uncontrolled transaction as a
benchmarking mechanism. The controlled transaction under study involves the transfer of
tangible goods, therefore CUT is inapplicable.
Comparable Uncontrolled Price
The Comparable Uncontrolled Price Method (CUP) utilizes sales of tangible property between
unrelated parties to determine arm's length consideration for controlled transactions. More
specifically, this method "evaluates whether the amount charged in a controlled transfer is arm's
length by reference to the amount changed in a comparable uncontrolled transaction."
. It is important that prospective CUP comparables involve the same products as the controlled
transaction because "similarity of products generally will have the greatest effect on
comparability under this method....[I]f there are material product differences for which reliable
measure of an arm's length result."
In order to utilize the CUP, it would be necessary to identify transactions between AAA-Taiwan
and unrelated parties, or between one of the related parties and an unrelated party that involve the
same property under similar circumstances and collect data regarding this transaction.
AAA-Taiwan does not engage in any transaction where the related parties render/receive the
same or similar services under similar facts and circumstances to/from unrelated companies.
CUP could not be used.
The Cost Plus Method (CP) determines the arm's length consideration that the seller should earn
in an intercompany sale based on the markup or gross profit earned by sellers in comparable
uncontrolled transactions. More specifically, the CP evaluates whether the amount charged in a
controlled transaction is arm's length by reference to the gross profit markup realized in
comparable uncontrolled transactions. The CP is ordinarily used in cases involving the
manufacture, assembly, or other production of goods that are sold to related parties."
The CP focuses on the circumstances of the transaction and does not require that the property
being sold in the uncontrolled transaction be essentially identical to the property in the controlled
transaction. To clarify further, "comparability under this method is particularly dependent on
similarity of functions performed, risk borne, and contractual terms, or adjustments to account for
the effects of any such differences. If possible, the appropriate gross margin profit markup should
be derived from comparable uncontrolled transaction of the taxpayer involved in the controlled
sale, because similar characteristics are more likely to be found among sales of property by the
same producer than among sales by other producers."
Since AAA-Taiwan does not manufacture, assemble, fabricate or otherwise produce the products
that it sells, the CP is inappropriate.
Registered English-Chinese-English Translator, Interpreter of Shanghai Interpreters Association and Translators Asscociation of China since 1980s.
freelance China business consultant focusing on China Trade Compliance Service, China Business Development and China sourcing.
Contracted Translator of Shanghai Yishi Law Firm
Chief Rep and Managing Director of PMMI China Office
Senior Commercial Specialist of Commercial Servce of the U.S. Consualete Shanghai
Senior Interpreter and Tour Manager with China Int''l Travel Service
Advised foreign investors on China investment policies, corporate income tax, VAT, custom tariff, etc.
Assisted Foreign investors to set up a manufacturing plant in Shanghai including site selection, Worked with landlord regarding workshop lease, business registration application process, local managers hiring, etc.
Assisted Foreign businesse to source from China, or have parts and components made in China.
Keywords: Certified English-Chinese-English Translator, Interpreter of Shanghai Interpreters Association and Translators Asscociation of China since 1980s.
Senior Cina Business Advisor and Coordinator
10-year experience with U.S. Consualete in Shanghai as its senior commercial specialist8-year experience with PMMI China Office ras its managing director and chief rep12-year experience with China Int''l Travel Service as its Seninor Translator and Interpreter and Tour Manager
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