pred_label
stringclasses 2
values | pred_label_prob
float64 0.5
1
| wiki_prob
float64 0.25
1
| text
stringlengths 112
978k
| source
stringlengths 37
43
|
|---|---|---|---|---|
__label__wiki
| 0.710602
| 0.710602
|
Home > Middle East News > Egypt
No Hidden Rooms in King Tut's Tomb After All, Egypt Says
Experts have been divided over the existence of a concealed chamber behind the tomb, which some believe could be the final resting place of the lost Queen, Nefertiti
The golden sarcophagus of King Tutankhamun in his burial chamber is seen in the Valley of the Kings, in Luxor, Egypt, November 28, 2015\ Mohamed Abd El Ghany/ REUTERS
Scans of King Tut's tomb reveal evidence of hidden chambers
Egypt to demand Germany return bust of Queen Nefertiti
Surprise in Silk Road study: Nomads ate better than city folk
Researchers at Italy’s Turin Polytechnic University have found no evidence of the existence of any hidden chambers behind the walls in the tomb of ancient Egypt’s boy-king, Tutankhamen, the Antiquities Ministry said on Sunday.
To really understand Israel and the Middle East - subscribe to Haaretz
Experts have been divided over the existence of a concealed chamber behind the tomb, which some believe could be the final resting place of the lost Queen, Nefertiti.
International interest in Nefertiti is high. She died in the 14th century B.C. and is thought to be Tutankhamen’s stepmother, and any confirmation of her final resting place would be the most remarkable Egyptian archaeological find this century.
The 3,300-year-old bust of Queen Nefertiti is seen in Berlin, Germany, in 2011AP
Discovery of Nefertiti, whose chiseled cheekbones and regal beauty were immortalized in a 3,300-year-old bust now in a Berlin museum, would shed fresh light on what remains a mysterious period of Egyptian history.
The Egyptian Antiquities Ministry said in a statement that months of studies by Italy’s Polytechnic University in Turin has shown that no such chamber exists.
“The studies ... have shown that no chambers exist, or even an indication of any threshold or door frames, which contradicts the previous theory that had assumed the existence of passages or chambers adjacent or inside the burial chamber of King Tutankhamen,” the statement quoted Mostafa Waziri, secretary-general of the Supreme Council of Antiquities, as saying.
In 2015, the antiquities minister said that there was a “90 percent” chance that something was behind the walls of Tutankhamen’s tomb after an initial reading of radar imaging suggested such a chamber existed.
|
cc/2019-30/en_head_0021.json.gz/line27248
|
__label__wiki
| 0.878439
| 0.878439
|
David Bowie's final songs from Lazarus deserve to be cherished
By Dylan Jones 16 October 2016
Three intriguing and unreleased tracks from Lazarus, “No Plan,” “Killing A Little Time,” and “When I Met You” are finally seeing the light of day on the Lazarus Original Cast Recording album. They deserve to be cherished as much as anything on Blackstar.
Not long after David Bowie passed away, news spread that Blackstar wasn’t the sum total of his final recordings, and that there were a few songs that were finished – maybe even a whole album’s worth – that might be released in the future. Conspiracy theorists, tired of creating ever more bizarre accounts of Bowie’s own micromanagement of his own death, started suggesting that the artist had recorded not one, but maybe several album’s worth of songs, records that were scheduled to appear at regular intervals after his death - singing from beyond the grave. Well, three unreleased tracks are finally seeing the light of day on the Lazarus Cast Album, three songs written, recorded and produced by Bowie at the same time as Blackstar.
The record, which is available on 21 October, this coming Friday, contains the cast and band of the original New York production performing their versions of the 18 songs from the show (from “Life On Mars”, “All The Young Dudes” and “Heroes” through to “Valentine’s Day”, “Love Is Lost” and “Dirty Boys”), Blackstar’s “Lazarus” (which increasingly sounds like something The XX could have had a hand in) as well as the three new Bowie tracks. Co-produced by Bowie and Tony Visconti and recorded with Donny McCaslin and his quartet, the same band that played on Blackstar, these last three songs - “No Plan,” “Killing A Little Time,” “When I Met You” – are predictably intriguing.
Read more: David Bowie's new album ★ (aka Blackstar) reviewed
Musically rather more orthodox than anything on his final album, lyrically the songs - written to help join narrative threads in the play - at first appear to add an unnerving coda to the soliloquies on Blackstar. On “Killing A Little Time”, a song that sounds as though it wouldn’t be completely out of place on The Man Who Sold the World (with a thrilling Ronsonesque guitar line added to the industrial fusion and Steely Dan chord changes), he sings “I’ve got a handful of songs to sing, To sting your soul, To fuck you over”; as Bowie was never very good at being didactic (he liked to say he left that to John Lennon), you realise quite quickly that he’s singing as Thomas Jerome Newton, the man who literally fell to Earth. The second song, the boilerplate “When I Met You” is the weakest of the three, sounding a little like something he might have recorded in the mid-Nineties, if he had been trying to deconstruct a Joy Division song, that is.
The third song, “No Plan”, is the standout, a genuine Greatest Hit that sounds like it came direct from the Scott Walker songbook, with vaporous traces of Dusty Springfield. A ballad both mournful and uplifting, the version sung by Sophia Anne Caruso actually sounds like a classic show tune, while Bowie’s version is one of the most haunting things he’s ever done. Ever did. It’s a beautiful song, and sounds almost as though it’s covered in a buttery light. The words, too, while seeming to slip easily from Newton’s lips, could quite easily apply to Bowie’s present and perennial disposition: “There’s no music here, I’m lost in streams of sound, Here am I nowhere now? No plan?... All the things that are my life, My moods, My beliefs, My designs, Me Alone, Nothing to regret, This is no place, but here I am, This is not quite yet.” Ouch. It almost sounds apostolic.
Swan songs all, these songs are yet more requiems, more to add to the ones produced by David Bowie as well as all the ones produced by all of us. And they deserve to be cherished as much as anything on Blackstar.
The rest of the Lazarus cast album was produced by the show’s musical director Henry Hey, who had previously worked with Bowie on “The Next Day” and features vocals from Michael C. Hall, Caruso, Cristin Miloti, Michael Esper and other cast members backed by the seven-piece house band Hey assembled for the New York run. Extraordinarily, the album was recorded on 11 January; when the musicians turned up at the studio, they were quietly told that Bowie had died the night before.
Lazarus opens in London at the King Cross Theatre on 8 November, Lazarus (Original Cast Recording) is available 21 October
MusicMusicalsDavid Bowie
How to sauna your way to clear skin
By Adam Hurly 18 July 2019
Keith Urban: ‘In Nashville I fell in love with being a musician. Oh, and alcohol’
By Jonathan Heaf 18 July 2019
|
cc/2019-30/en_head_0021.json.gz/line27250
|
__label__wiki
| 0.507728
| 0.507728
|
© PA Photos
Zac Goldsmith on Uber, Savile Row suits and his 'heat stick'
By Conrad Quilty-Harper 3 March 2016
Zac Goldsmith, the Conservative candidate in the London mayoral election and MP for Richmond, talks to GQ about the black cabs vs Uber dispute, his father's Savile Row suits, and why he's smoking a 'heat stick'
GQ: We'll start with a question about suits. We read that you used to wear your father’s, do you still wear them?
Zac Goldsmith: This is one of my dad’s old suits.
Read more: An idiot's guide to the London mayoral candidates
What brand?
No idea. He had lots of different brands. One of the advantages is that there were two periods in his life where he was my size.
Could you check your label for the brand?
It just says Savile Row bespoke. This one’s an old one, it’s a grimy old label. I’ll probably tell you later who the guy is who did the cut, but I cant promise anything.
How do you get them tailored?
Different people. There’s a guy my sister put me in touch with who cuts on the back to shape it for me. My wife organises a couple.
Do you have a grooming routine at all?
No, I have two uniforms. Two or three suits which I wear most of the time. Or I wear a jacket and some dark corduroys, and that’s it, because I use the same routine all the time I don’t have to think about it.
Where do you get your haircut?
The last time I had my haircut was a place in Shepherd’s Market. I had never been there, and I passed by it. It had an empty seat so I had my hair cut.
Do you have a regular place?
How do you keep in shape?
These are very boring answers. I am very active – I walk a lot. I walk everywhere; I’ve got loads of kids who keep me active. Campaigning keeps you active. I don’t go to the gym. I can’t remember the last time I went to the gym, literally.
Do you worry about what you eat?
No, I don’t worry about food. With campaigns I don’t get to eat. This will be my only meal today. And I’ve been electioneering since February last year because of the general election. I’m sure there will come a moment in my life when my metabolism will go mad and I’ll start having to think about food but at the moment I’m lucky enough that I don’t have to.
You’ve stopped smoking?
I have a lot of nicotine. That’s what I was chewing just now, nicotine gum. If I can tell you something off the record [Zac later agrees for this to be on the record if I don't mention the brand]. I don’t want to look like I’m promoting a brand, but I feel like I’m on a mission. [Zac shows me a smokeless cigarette called a "heat stick"] This is not an e-cigarette. This is something a friend sent me from Italy. I don’t want to brand it, it’s such a dirty thing. But this is not an e-cigarette. You stick it in, and it heats it.
So it’s an actual cigarette?
Well more or less. It heats it rather than burns it. If you offered me a normal cigarette now, I wouldn’t want it, I’m happy with this. You get everything you need from this and none of the crap.
Do you still gamble, do you still play poker?
I would, I love it. I haven’t played for so long now as I don’t have time. If I have a spare evening now I spend it with my kids, and I don’t get any spare evenings. I would feel appalling were I to go and waste an evening playing poker.
You started a gambling company with your brother.
Well it’s a friend of ours who set it up and we backed it at the beginning. It’s not ours really.
Do you still have an interest in that at all?
I have no direct involvement.
Just a personal interest?
I suppose so, but not really. I’m not involved. He’s a great guy and it’s a good business and it does well, but I’m not involved in it. I couldn’t give you any information about the business.
We were interested that you have a shareholding in All Star Lanes, and you have an investment in something called WHEB ventures, what is that?
It’s a fund that my brother set up. It’s clean energy. I think it’s all there. If you Google it.
So you invested because you wanted to support him?
Well yes, but also clean energy is the way forward. Clean technology is clearly the future. I’m interested in it, but I haven’t had time to think about it.
On the subject of gambling, we've read in previous interviews that you’ve put a bet on David Cameron to be the leader, and Imran being PM of Pakistan. Have you made a bet on yourself winning the election?
It would be unlucky.
We thought it was honourable of you to release your tax return, transparency is very important in politics.
I wouldn’t say it was honourable. I was asked to do it, I made the commitment to do it, so I did it. I didn’t regard it as a good thing to do.
Do you think more politicians should do that?
I think it’s down to the individuals and what is expected of them. I believe in democracy. The terms and the protocols and the rules and the system, ultimately need to be set by people. And people expect certain things from their politicians and politicians should do them or they shouldn’t be involved in politics.
You were previously editor of The Ecologist and you are clearly very passionate about environmentalism...
That doesn’t change. The thing is a magazine isn’t the end, it’s the means to the end. Politics is the same thing, it’s just a different way of doing it.
How ready do you feel to take on those vested interests in London in areas of housing, on green issue and improving the environment? There are huge lobbies involved in that, how do you take them on?
You just have to do what is right. That’s the thing, you don’t allow policy to be purchased by vested interests. And that I think happens far too much in politics. It happens less here than I think in America, but it still happens. It's not a straightforward transaction, you have a disproportionate influence by certain vested interests, and that shapes policy. And I saw that in the five years that I was campaigning, and I am sure it is the same in every level of politics. As long as you set out to do what is right for the people you represent, and as Mayor of London, that is the whole of London, then you move on.
Boris set targets of having a certain number of cycle paths, and congestion zones, pedestrianised zones and he did expand the bike sharing scheme, but the reality sometimes didn't match up to the promises. How will you avoid that?
But that is the same with anything. If you want to change anything, there is always going to be resistance. In any policy, there are winners and losers, supporters and opponents, and unless you’re just doing nothing, your job is to find a way of doing something without putting people’s nose out of joint. For example, we need a least 50,000 homes a year, it’s the only way to make London affordable to Londoners. Obviously the nature of opponents, and who they are for, and all that stuff matters, but we don’t increase supply. So nothing else is relevant.
You said recently that one of the ways of doing that is improving the space in housing and demolishing old estates and rebuilding. Is that practical in the short to medium term?
It is not either/or. You need at least 50,000 homes a year, that is non-negotiable. The main things, you need the money, you need the planning, you need the land. And there is no shortage of any of this. Planning is a political issue that you can overcome, there is no shortage of capital to invest in property management. Housing associations, sitting on huge sums that they want to invest, but they don’t have the land, a lot of local authorities want to increase their supply, there is no limit to the money in pensions funds, institutional investors, some of them overseas, there is no shortage of capital.
The issue is, for now, land. And actually, there is no shortage of land either, just it is locked up. Most of it is publicly owned. So that’s one issue. But on the estates regeneration thing, it is not just about increasingly supply, we will increase supply and that is a really important thing. More than that, you have got estates which are coming to the end of life. I have just come from one now, I have been talking to figureheads about how the engagement process should look. Because I don’t think, I have made it very clear, that I do not want to regenerate an estate if the community don’t want to regenerate.
It’s not something I want to force on anyone. I have also said, that because it has been done so badly in the past, that wherever it does happen, once you get that consent, you guarantee that anyone living there today gets to stay there afterwards, gets a better home and does not get put onto a different rental scheme, so no one has to pay any more. And if you can commit to those three things, then you can have a proper discussion. Then the panic goes and people start to engage.
Why do you draw the line at developing on the green belt?
Because you don’t need to [build on it]. Theoretically, if you were to work with the communities to properly and responsibly regenerate the dilapidated Fifties and Sixties estates, according to Savills you have the potential to create 360,000 new homes. It is not really that much, but even if you cut that in half it’s a lot. If you build 50,000 homes a year, in addition to that, on brownfield land, which is publicly owned at the moment, you need to free away from government. The government will do that, in which case the government will transfer that land to the control of the mayor, you don’t need to touch the green belt.
Once you make those commitment, the reason it is a divisive issue is it is very easy to politicise the issue. I genuinely believe, and it genuinely annoys the hell out of me, I know that my opponent has ruled out the estate regenerations, not because he doesn’t think it’s a good idea, it is a good idea, it’s our obligation to do it, and whether we do it now or not, we will have to do it at some point. And the reason they have ruled it out is only one reason, and his own people in the Labour Party have had this conversation with me, it is only so he and his people can go door to door in the estates, and say “if you vote Tory, you will lose your home.” It is the only reason. It is the very seediest end of politics. It pisses me off and it is wrong, it is really wrong, and we will win that argument.
Going back to the green belt...
But on the green belt, you don’t need to [develop on it].
Surely it is one of the easier options. Who are the stakeholders against developing on it? It’s not all beautiful green space, a lot of the protected green belt land is set very arbitrarily.
One of the things that makes Greater London a great place to live and work is that we have so much green space, it is about 45, 46 per cent [green space]. And I think the moment we start compromising that, it is a very slippery slope. I do think you need to draw the line. If you have brownfield land that you can develop, it is no easier to destroy the green belt than it is to develop the brownfield. And the reason brownfield land is not being developed today, the reason not enough of it is being developed today is because it is inaccessible. So the issue then is how you make it accessible.
We need to make London accessible in any case, because the population is growing fast, people are having to move further away from the centre to find a home to live in, if they have any chance at all of finding a home to live in. We need more of a transport network to keep London moving, but we also need to be able to unlock that land. If we don’t grow that transport network, we don’t access that brownfield land, we don’t get what we need. In terms of substance, the regeneration thing, I don’t think there is a substantive difference between myself and my opponent, there is a difference in our political approach, and I am appalled by his; but on this issue, there is a real point of substance here, and that is, the pledge that [Sadiq Khan] has made in relation to fares will take 2 billion quid out of the TFL budget. If you take £2 billion out of the TFL budget it is a mathematical fact, you do not solve the housing crisis. It is just as simple as that.
The major transport changes that have happened in London in the last 15 or 20 years are the overground, Boris bikes, and Crossrail. Those are all substantial transport construction projects, and obviously you have the opposition to Heathrow. What are the positive transport changes you want to make?
I think under both mayors we have had a really good transport system. And we have grown the network. But we need to see the same again. We need to get a greenlight from the government for Crossrail 2, also some of the smaller and really important schemes. Like the Sutton tramlink, you open up the possibility of 15,000 homes which you will not get if you don’t extend the tramlink. The overground to Barking will allow us to build around 15,000 homes. If you are able to extend Crossrail from Abbeywood to Bexley, everyone says Bexley will never build, but they have said that if those links are made they will redevelop brownfield land. You would have many tens of thousands of homes if you grow the network, so the priority for me is, given there is a shortage of cash, to extend the network in a way that not only keeps London open, but also creates homes.
We are going to have to find other ways of getting that cash as well, so I took George Osborne to Sutton. This is one example, but the principle applies to the whole of London. To try and persuade them, I know that they’re not going to write a cheque for these improvements, because there are limited finances. But I also know that if you don’t extend the Sutton tram line you don’t get those 15,000 homes, and therefore it is a reasonable request that we do extend the tramline and we do get these fifteen thousand homes, that we should be able to hold the first half as a stamp duty, and that would enable us to borrow against that certainty, and enable us to do as much as we need to do.
If that applied across the board, we could be so much more ambitious in our transport. It’s a microcosm, but it is an example we can apply across the board. It is not about big ideas for transport, I am very keen to have a greater London-wide Boris bike equivalent for electric cars. I think it would be an amazing thing to do, as the technology is there, the facilities are there. It wouldn’t be very challenging. It takes a very large amount of cars off the road.
Do you have a car?
I do own a car but I never use it. It is the first Prius model, so massively outclassed by the most recent one. I had a Golf. I’ve only had two. And I think I’ve had my Prius for about ten years.
Can we talk about Uber versus the black cabs. How do you solve that problem?
I’m very committed to ensuring a future for the black cab. I think it would be a disaster for London if it didn’t. I think they're a really important part of London, and not just because of the way they look, because they’ve been round for a long time. But they offer something very special. They’re trusted – you know I would put my kids in a black cab. I couldn’t say that about all car services.
Would you say that about Uber?
I don’t use Uber. I certainly feel safer by many margins, putting my kids in a black cab rather than in an Uber.
From our perspective, a lot of our readers, that’s where a lot of the growth has come from. You find it difficult to get a black cab in places like Peckham and you still often find you can’t pay cash.
But it’s not a choice between black cabs and uber. The choice is this, you’ve got the people on the right saying let them compete, let the market sort it out. But that’s not fair, because the black cab is the most highly regulated service in the world. By a country mile. They’ve got to have a turning circle, which adds thousands of pounds, they’ve got to do The Knowledge at their own expense, they’ve got to be wheelchair accessible, and so much more besides. So to ask them then to compete with a service that regulates none of those costs, that’s not fair. That’s not a free market. You’ve got two choices: you either remove the regulations on the black cab, but that would mean losing the black cab, which is not something I would be willing to do. Or you keep a distinction between the two. There has to be a clear distinction. I’m not pretending it’s easy – it’s not easy. But you have to find a way to create real clear blue water between the two or else the black cab will go extinct.
Are you not just describing maintaining the status quo, which black cabs are not happy with?
Well it’s not, because they don’t think there’s a gap between them at the moment. They think that all the things they have which makes them unique, are going. You know the nature of the app is that you’re hailing a cab in a way that you used to only be able to do with a black cab.
Isn’t the argument that that’s why Uber exists, in this loophole, that technically you’re not hailing a cab, you’re creating a request on an app.
I’m not saying they’re breaking the law, I’m saying the law is not good. The laws regulating cabs were written up before the mobile phone existed, let alone the smart phone. They need to be upgraded, and in a way that enables competition. There’s a lot of people who use Uber who cannot use black cabs, either because of the cost or because they’re not available when they need them. Competition is good in every sector but there’s got to be a fair competition. It just isn’t fair, and I refuse to accept that it is a fair competition at the moment.
To achieve economic growth you have to create new places to grow and you’re saying with Heathrow that we shouldn’t tap into this global opportunity. Surely with Heathrow at capacity, we need to compete with Amsterdam and other airports?
No, I don’t agree with that at all. At all. There are local arguments against Heathrow expansion. It’s not just Richmond and Kingston. There’s much more than that. There would be a million homes affected by noise, way beyond the world health organisation’s experience. You’ve got air quality issues; you’ve got the cost argument. If you expand Heathrow you’ve got to accommodate twenty five million extra road passenger journeys to and from Heathrow. That’s about 20 billion quid according to TfL. Heathrow says it’s £2 billion, so it’s somewhere in between. But it’s a lot of money. You put all those to one side and you come down to the economic arguments. I still think the case for Heathrow expansion is incredibly tenuous. The Howard David review itself, if you ignore the conclusion, which I didn’t think fitted with the report – I think it was written before the report was even done and stuck on at the end – it dismantles the case for Heathrow expansion. It says you would not be creating a net additional activity.
Well that’s the argument isn’t it, that that activity would go elsewhere...
If you create an expanded Heathrow you’re taking activity from competing airports. So all you’re doing is cobbling together the old monopoly at the expense of competition, at the expense of the competing airports. And I think the arguments around competition are just as valid in relation to aviation as they are with every other sector. The model is changing – business flights are going down as people use technology more and more, and growth areas point to point – people who visit their family or go on holiday. That’s the growth in aviation at the moment. The overwhelming majority of orders for new aircraft are called Hub Busters. They’re point to point aircraft not designed for the old model.
They're much more efficient as well.
Yes. I think that our economy would be better served by a network of competing airports, not cobbling together the old monopoly. I understand why Heathrow wants a monopoly. But I have to say Gatwick put forward an incredibly powerful argument. I can be persuaded incidentally and the choice we’ve given is between Heathrow and Gatwick. That’s the choice that’s on the table. You’ve got Stansted in the equation as well.
On the topic of global competition for London as a global city, and the kind of tension with environmentalism and the fact we have to reduce these emissions, and cars. You’ve recently come out for Brexit, that you will support that vote to leave. How do you reconcile that with the case that the EU has done so much to reduce emissions?
I’m going to interpret your question in two ways. You ask at the beginning about the conflict, the contradiction. I don’t think there is a contradiction. I know that we need to find a way of growing our economy, but not at the expense of the environment. And that is the basic law of sustainability. And we all want a sustainable world. And that means, basically, creating a break between economic growth and environmental disruption. But we can do that. It’s not about saying we mustn’t have cars. I don’t think there’s a contradiction. We can have a bright and wonderful economic future, but not at the expense of the natural world.
So why reject this group?
You’re right. In the last five years there have been times where Europe has got it right and Britain has got it wrong. Things like new regulations over neonicotinoids [the European Union banned the insecticide over concerns it was affecting bees, and this ban was later overturned by the UK] an issue I had an experience in it. I’ve had more letters about these than anything else.
The bee keeping community is a passionate community…
Yes, a very passionate community, and quite right too. But for me my objection to the EU is not about the quality of decisions made, although there are plenty of decisions, its not about that. It is about democracy. I just believe that the people who make decisions on our behalf should be people who can be fired if they get it wrong. It’s not the case with the EU – it’s just not a democratic set up. I would prefer a reformed EU, I’ve always said that. But if the most we’re going to get is what’s currently on offer, and that is against the backdrop of the possibility of us going out, then it’s never going to get better than that. And that is the problem, I don’t think you have any alternative at this point than to vote for Brexit. I think the options are irreconcilable.
In terms of your specific point on the environment. I don’t think the environment is an argument for Europe. It was hopeless on cars, the reason we have the VW scandal is because of lobbying in Germany. There’s a huge campaign in Europe to try and create a more transparent testing regime, which is in their vested interests.
Surely we’re better in the European Union so we can argue that?
We can still argue that, in relation to standards and things in cars. But fundamentally, if our own politicians are setting the rules then we can hold those politicians accountable. Our job in a broader sense, as I’m a politician now, our jobs are to make sure that politicians do what is expected of them. I don’t think we need an unelected bureaucracy to tell us what to do; we ought to be able to do that ourselves. There are times when it’s wrong. I wouldn’t pretend that it’s the winner of the EU, but it’s not the clear loser either. It’s who is making the decisions.
On the subject of your personal wealth. You’ve explained that money is not a novelty to you, but I’m interested in how how you relate to people who aren’t wealthy?
If you want to be a representative, at whatever level, council, MP, Mayor, whatever, you need to be able to understand problems. You need to be able to empathise, and if you cant empathise, you shouldn’t be in politics. You should also be good at sorting problems. And I genuinely believe that I’ve been a good MP. For the last six years my record has been good and I long for my record to be completely scrutinised. Because if you’re judging a politician from his promises, that’s insane. Politicians promise the earth before an election. But you judge a politician by their record. And in the last six years I’ve delivered on everything I’ve said I would do and done. I have had more public meetings than any other MP over the last year. I’d be willing to bet that that’s true, and I’ve done a good job. That’s why I got the biggest increase majority of any incumbent MP in the country. Those are people who might not necessarily have voted Conservative in their lives, and who voted Conservative this time on the back of my record. It’s the greatest honour imaginable actually. My goal would be to get elected on May 5th, to deliver for four years, as I have for my consistency, and for people to award me in the same way in four years time. Ultimately the only way you can judge a politician is through the people he represents. I think I have represented my constituency.
It really is between you and Sadiq. There is some criticism of the way you describe Sadiq as radical and divisive in one of your leaflets? Can you say what that meant?
Yes but that criticism came from him, not from anyone else.
What did you mean by radical?
I mean that he is part of; he is an architect, of one of the most radical things that’s happened in politics, in mainstream politics, in Britain, in my lifetime. What’s happened to the Labour Party is extraordinary. He nominated Jeremy Corbyn and he said he would nominate him again. He was a chief architect in a failed Ed Miliband experiment. I can’t think of another word. It is a very, very radical offer that the Labour Party now make to this country. I think it’s a very radical offer that he makes to London. It’s a fantasy offer, it's nonsense. He is divisive; he is a very divisive figure to London. If you want to be a very good Mayor of London, you need to be able to work with the government. We depend on government for our powers. I think its real weakness of London as it happens but it’s a fact. You have got to be able to work with people outside your party.
He is the most partisan politician I have ever come across in my five or six years being directly involved in politics. Every campaign I have fought in the last five years necessarily had required me to team up with people to persuade the government, so Labour people, Lib Dems, Greens, Ukip, whoever. Where I’ve won campaigns its because I’ve been able to build bridges with other parties. Zero record, he has, ever, of working with another party. He’s very partisan; he’s a very divisive figure. And I think that alone disqualifies him from being Mayor of London. If they picked almost any other candidate in that race, I don’t know Gareth Thomas, I’ve never met him really but David Lamb, Tessa Jowell. They will always put the community and the issues first and they will always work with other people from other parties. And I will do that, clearly. I will work with anyone, from any party, to get the job done. That’s what you need to do.
We’ve interviewed Sadiq and he says he looks forward to being Mayor. Has he already won the election?
No, absolutely not. I’m spending every minute of every day, going round and round greater London. Every borough, every ward, talking to anyone who will listen to me, and I feel like I’m making a lot of progress. I’ve got 70 days left to make the case.
Now read our interview with Sadiq Khan
George Osborne to become Evening Standard editor
How to buy a men’s leather jacket
By Teo Van den Broeke 18 July 2019
The best trainers in the world this week
|
cc/2019-30/en_head_0021.json.gz/line27251
|
__label__wiki
| 0.923741
| 0.923741
|
Evidence Mounts That Coal, Nuclear Interests Influenced Perry’s Grid Resiliency Rule
The political pressures behind DOE’s request to declare coal and nuclear power plants as vital to a reliable grid.
Energy Secretary Rick Perry’s effort to change federal energy regulations to favor coal and nuclear power plants in the name of grid resilience has received a barrage of criticism for misstating the facts, ignoring the evidence, and attempting to ram through a major disruption in interstate energy markets on an emergency timeframe.
While Perry insists the initiative is necessary to "rebalance the market" and "keep our families warm," there's mounting evidence the proposal was taken from an industry playbook.
The accelerated timeline for DOE’s notice of proposed rulemaking (NOPR) is outside of the norm for such a radical market shift, but it does match up with a major political ask from one of President Donald Trump’s key supporters in the coal industry: Robert Murray, CEO of Murray Energy.
Over the past week, new details have emerged linking efforts by the outspoken private coal company owner to obtain federal financial aid for the industry, as well as the DOE’s highly unusual decision in September to directly ask the Federal Energy Regulatory Commission for an emergency intervention in the country’s interstate energy markets.
The interests of Murray Energy run through FirstEnergy, the Ohio-based utility that’s facing near-term financial challenges in managing money-losing coal plants in the region served by grid operator PJM -- the same region that would be most heavily hit by DOE’s proposal. As the Houston Chronicle noted in a Sunday article, more than 70 percent of Murray Energy’s coal delivered to U.S. power plants went to PJM.
And the timeline for FirstEnergy to seek relief is fast approaching. In its third-quarter 2017 earnings report late last month, the company noted that it has cash on hand to fund operations through March 2018. But starting in the second quarter, with $515 million of maturing debt that will “likely to be difficult to refinance” coming due, and absent any moves by Ohio state regulators to re-regulate its plants, the company’s power generation division, FirstEnergy Solutions, may be forced to “restructure debt and other financial obligations with its creditors and/or seek protection under U.S. bankruptcy laws” -- a move that could push FirstEnergy to do the same.
Time pressure from coal industry
This threat of bankruptcy without market intervention echoes similar ones made by Murray to Trump over the summer. In a letter obtained and released by the Associated Press in August, Murray wrote that his company would be forced to file for bankruptcy protection and lay off 6,500 workers -- more than the total number of employees listed on its website -- without an emergency intervention in energy markets under Section 202(c) of the Federal Power Act.
Murray, who donated to both Trump’s successful campaign and Perry’s failed 2012 presidential campaign, also wrote that he was relying on a personal assurance from Trump to get this relief, according to news reports citing the letter. “Please fight for us," the letter reads. "Even if we are wrong and this fails, at least we can tell our people you did everything possible and that you left no stone unturned. We will be forced to file for bankruptcy in October of this year if no action is taken.”
President Trump rejected this emergency request in late August, and October came and passed without a bankruptcy filing. Analysts had been skeptical about the threat, noting that it isn’t the first from Murray. FirstEnergy Solutions, by contrast, saw its bond rating downgraded yet again by Standard & Poor’s in August due to bankruptcy fears.
FirstEnergy has long sought ways out of its financial straits, including its decision late last year to exit the punishing merchant generation business, with the sale of its natural gas and hydro power assets. CEO Chuck Jones said in last month's earnings call that the company remains committed to its strategy to "become fully regulated."
As part of this plan, FirstEnergy has asked Ohio regulators for permission to raise rates on customers to help bail out its struggling power plants in the state -- one coal-fired and one nuclear. First submitted in 2014, a modified version of the proposal was approved by the Public Utilities Commission of Ohio (PUCO) in August, and is now being challenged by environmental and ratepayer groups in the state supreme court.
DOE’s move could essentially render this state-level action moot by declaring cost recovery status to power plants with 90 days of fuel supply on hand -- something that applies almost solely to nuclear and coal plants. Perry's team says this is needed to keep the grid safe from extreme weather and terrorist threats.
But this statement ignores data that shows the vast majority of outages are caused by transmission and distribution system outages, not fuel supply disruptions, and that fuel stocks don’t ensure that plants will stay running during emergencies in any case. It also ignores the conclusions of the DOE's own report on grid reliability and resilience. The report, authored by veteran energy consultant Alison Silverstein, does not explicitly support the case for subsidizing coal and nuclear, and yet Perry has cited it to justify the emergency nature of the NOPR.
In a public appearance last week, Silverstein said DOE administrators did not influence her writing, but that the NOPR, "cooked up long after," is in line with the administration's political aims.
"If you work for an administration that is making a big deal about helping coal, and you have a lot of senior staff people who don’t have a significant amount of expertise, either about the industry or about the administrative and policy issues that you are dealing with, I think what you do is say, 'Heck, we’ll send over something that’s a Hail Mary, does all the right political stuff about coal and nuclear. We’ll be the heroes, and it’s FERC’s job to do the dirty work,'" she said, according to Forbes.
"Perry and his team are doing all the right things for the cause, and if it works, great! If it doesn’t work, it’s someone else’s fault," Silverstein added. "I think that’s the raw political answer."
Appointees with long connections to Murray, FirstEnergy and coal industry
PUCO recently joined a long list of state regulators, former FERC commissioners, and other energy-sector insiders in coming out against the NOPR on the grounds that it will raise costs and prop up inefficient resources to the detriment of cheaper, less polluting alternatives. A collection of 14 different energy industry trade groups -- ranging from wind and solar, to oil and natural gas -- have argued that the NOPR's proposed payments go beyond those provided to so-called “reliability must-run” power plants, amounting to a bailout to keep certain units running.
FERC has said it will vote on the NOPR in a December 11 meeting. Most observers, including former FERC members, don’t believe that FERC will be able to turn the vague NOPR document into a final rule by next month. But with coal industry allies playing major roles in the agencies tasked with reviewing and implementing the NOPR, opponents are worried that FERC could take some action to prop up coal plants in the short term, while leaving the NOPR's larger challenges to a future date.
Longtime FirstEnergy lobbyist Sean Cunningham, now executive director of DOE’s office of energy policy and systems analysis, has been the sole DOE representative outside of Perry himself to speak publicly in support of the NOPR. In a debate last month, Cunningham repeated the assertion that coal and nuclear plants weren’t being valued properly and that failing to act on the NOPR could jeopardize grid reliability in the short term.
Meanwhile, FERC acting chairman Neil Chatterjee, a Trump appointee and former aide to Senate Majority Leader Mitch McConnell (R-Ken), said last week that he’s working on an interim plan to “rescue” FirstEnergy’s ailing coal plants, based largely on the utility’s proposals in comments before FERC.
Chatterjee said he has met with FirstEnergy Corp. CEO Chuck Jones to “really kick the tires on what they proposed and challenge them on some of what they had put forward.” Under FirstEnergy's plan, plants would receive a monthly payment from grid operators that fully offsets operation costs and includes a "fair return on equity.”
The Emergence of Utility-Branded DER Marketplaces
Next-Generation Electricity Technology is Being Held Back by Outdated Markets. Here's How to Fix It.
|
cc/2019-30/en_head_0021.json.gz/line27253
|
__label__cc
| 0.505939
| 0.494061
|
The goal of the Adopt-A-Park Program is to build a sense of community, pride and ownership around every park. Adopt-A-Park is a collaborative partnership between the Town of Harrisburg Parks and Recreation Department and groups that wish to build a sense of stewardship and advocacy within the community and parks system.
Adopt-A-Park will be eligible for a recognition/ownership plaque after completing the first 40 hours of work.
All groups will be eligible to attend the annual Volunteer Appreciation Event.
All groups will receive an official Town of Harrisburg Adopt-A-Park program t-shirt to be worn during work days.
Work days and completed projects will be advertised on the town’s website and social media outlets.
Please contact Harrisburg Parks and Recreation at 704-455-7275.
What are the Adopt-A-Park Guidelines?
Adopt-A-Park Application (PDF)
Adopt-A-Park Brochure (PDF)
Giving Assistant
|
cc/2019-30/en_head_0021.json.gz/line27254
|
__label__wiki
| 0.978035
| 0.978035
|
PATRIOTS NOTEBOOK: Pats players making history
By Mark Daniels / The Providence Journal
It's a Super Bowl of firsts for several New England players.
ATLANTA — History will be made for several Patriots players with Sunday’s Super Bowl LIII.
Joe Thuney, the Patriots' starting left guard, will become the first player in NFL history to start three straight Super Bowls in his first three NFL seasons. A third-round pick in 2018, he has started every single game in his career — 48 of 48 — at left guard.
“I’ve been fortunate to be part of this organization. It’s a great organization,” said Thuney, when asked about the record. “I just want to be out there with my teammates. I’ve had a lot of help along the way. I’m just fortunate to be here now.”
The 26-year-old led the Patriots in offensive snaps this season, playing 100 percent of the plays. Last season, he played 99.56 percent of the Patriots offensive play calls, which was second on the team. During his 2016 rookie season, Thuney led the Patriots in offensive snaps, playing 99.64 percent of the season total.
“I love being out there, playing for my teammates. I just want to help contribute to the team. I’ve been fortunate,” Thuney said. “I just want to play in the games, just want to play with the guys next to me. I just really like playing.”
Patriots offensive line coach Dante Scarnecchia described Thuney as tough and durable. He also credited the third-year player for helping left tackle Trent Brown along.
“I think in particular, he’s meant a lot to Trent Brown. Joe’s got three years of experience in our system,” Scarnecchia said. “He’s played every play for three years. Almost every play. If it’s one percent that he’s missed, I’d be shocked. He’s been a huge help to Trent and helping to integrate Trent into our system and helping him along. I can’t thank him enough for that.”
Devin and Jason McCourty are also making history as they became the first set of twins to play together in the Super Bowl. This could also be the last run for the McCourtys.
Last week, Devin McCourty said that he might retire if he wins a Super Bowl. Although the Patriots veteran safety stepped back from those comments later in the week, it does appear to be one possible outcome. According to the NFL Network, Jason McCourty is even more likely to retire following Super Bowl LIII.
If Devin McCourty doesn’t retire, according to the report, he could step away from the Patriots if the team asks him to take a pay cut. His cap hit is set to rise to $13.435 million.
Of course, the biggest name to potentially retire is Rob Gronkowski. The tight end had been noncommittal all last week about his future plans.
Fan to be penalized: The fan who attempted to distract Tom Brady with a laser in the AFC Championship game will face some stiff consequences.
Following the Patriots' win over the Kansas City Chiefs, video emerged of a green laser pointer being shined at Brady several times throughout the contest. According to ESPN, the fan responsible “has been identified, apprehended, banned from Arrowhead Stadium for life and soon will face charges from the Kansas City district attorney.”
According to the report, Chiefs officials asked that the fan face the harshest penalties possible after the Kansas City Police Department originally planned to cite the person only for disorderly conduct.
Laser pointers are prohibited at NFL games. From the Chiefs standpoint, the hope is that this incident will stop fans in the future from trying the same tactic against opposing teams. According to ESPN, members of the military have also reached out to Brady to let him know that laser pointers can cause irreversible eye damage.
Who's in, who's out: The Patriots came into Super Bowl LIII with a healthy roster. The only player to miss a practice last week in Atlanta was Dont’a Hightower and that was due to an illness. He was off the injury report by the end of the week.
The only player limited during the week was Malcom Brown (calf) and that was on Wednesday and lasted only one day. The inactive list for the game included Stephen Anderson, James Ferentz, Obi Melifonwu, Ufomba Kamalu, Keionta Davis, Derek Rivers and Duke Dawson.
On the active roster was Deatrich Wise for the first time this postseason. The second-year defensive end returned after being a healthy scratch in the team’s previous two playoff games. In the regular season, Wise finished second on the Patriots in sacks (4.5) and quarterback hits (16).
Danny Shelton also returned to the lineup. The defensive tackle was inactive in the AFC Championship game. Shelton and Wise take the game-day roster spots of Rivers and Melifonwu, who were active in Kansas City.
Assistants on the move: It won’t take the Miami Dolphins long to announce Brian Flores as their new head coach.
According to multiple reports, the Dolphins will flying Flores — the Patriots' de facto defensive coordinator — to Florida on Monday to finalize his deal to become the next Dolphins head coach.
Flores, 39, has been with the Patriots since 2004. He’s been the team’s linebackers coach since 2016 and called the defensive plays this season, replacing Matt Patricia, who left to coach the Detroit Lions. Not only will the Patriots need a new defensive coordinator and linebacker coach, but also a new receivers coach.
Chad O’Shea is expected to be named the Dolphins next offensive coordinator. He’s been the Patriots receivers coach since 2009. He was the top candidate to replace Josh McDaniels had the offensive coordinator left to become the head coach of the Green Bay Packers.
It remains to be seen who the Patriots bring in, but it has been reported that Greg Schiano will come to the Patriots as the team’s next defensive coordinator. Schiano is a former Tampa Bay Buccaneers head coach, He was also the head coach at Rutgers and a former Ohio State defensive coordinator.
|
cc/2019-30/en_head_0021.json.gz/line27256
|
__label__cc
| 0.694875
| 0.305125
|
Topics Barack Obama
Imagining the border: options for resolving the Israeli-Palestinian territorial issue
Middle East negotiators can adjust Israel’s borders to include the large majority of West Bank settlers and still meet Palestinian Authority territorial demands. This proposition may guide leaders and diplomats in the coming months as they seek to advance the peace process.
Direct talks needed for Mideast peace
The Middle East peace process has reached something of an impasse. Israel, with the US, has called for direct negotiations, without preconditions, but the Palestinians refuse to join us. Still, Israel remains committed to attaining a genuine peace grounded on the principle of two states for two peoples living side-by-side in security, prosperity and mutual acceptance.
A 63-year search for Mideast peace
Imagine a two-state solution to the Israel-Palestinian conflict: a Jewish state living alongside a Palestinian state in permanent peace, with open borders, and even economic union. Sound like fantasy? It wasn’t when the U.N. General Assembly voted in favor of Resolution 181, dividing what was then known as Palestine into independent Jewish and Arab states.
Obama’s treatment of Israel unfair, dangerous
This week, we witnessed President Obama’s shameful treatment of the leader of one of America’s closest allies. This became clear when Israeli Prime Minister Benjamin Netanyahu was hauled before a “seething” Obama and read the Riot Act behind closed doors.
Classroom battlegrounds: a new war on campus?
Before the school year started I wrote that the expectation was that this would be a good year for Israel on campus. During the summer there were no indications of any problems and, in fact, the fall had little anti-Israel activity and a good deal of positive programming from pro-Israel students.
Twitter-based news conference on Gaza conflict
Late last month the Israeli Consulate in New York held a Twitter-based news conference, inviting anyone to ask questions of the Israeli government about the conflict in Gaza. While activity around the conference blossomed, President-elect Barack Obama’s Twitter account has had little to say since Election Day last year.
No choice but self-defense for Israel in Gaza
The war in Gaza has been at the center of the world’s attention for the past two weeks. The media have discussed the end of the six-month cease-fire between Hamas and Israel, the launching of rockets and mortars into southern Israel, and the subsequent Israeli retaliation, including ground operations in Gaza.
|
cc/2019-30/en_head_0021.json.gz/line27258
|
__label__cc
| 0.623156
| 0.376844
|
19th Lusofonia Festival
Cultural Booths, gastronomy, music, dance and games
From 21 to 23 October at the Taipa Houses-Museum
繁體中文 简体中文 Versão Português
Type: ---
Organized by the Cultural Affairs Bureau (IC, from the Portuguese acronym), in co-organization with the Macao Government Tourism Office and the Civic and Municipal Affairs Bureau, the 19th Lusofonia Festival associated with the culture of the Macao Portuguese-speaking communities will be held from 21 to 23 October, at the Taipa Houses-Museum in three consecutive days. The Festival offers excellent activities including gastronomy, music, dance and games, as well as street decoration in the surrounding areas of the Taipa Houses-Museum in Portuguese style, allowing visitors to feel like travelling in a foreign country. All residents and tourists are welcome to participate in the event, and experience the Portuguese customs and feel the Festival’s cheerful atmosphere.
The 19th Lusofonia Festival Press Conference was held on 6 October at the Auditorium of the Cultural Affairs Bureau. Representatives who attended in the Press Conference included the Vice President of the Cultural Affairs Bureau, Leung Hio Ming; the Deputy Director of the Macao Government Tourism Office, Cheng Wai Tong; the Head of the Department of Cultural Events of the Cultural Affairs Bureau, Kent Ieong Chi Kin; and the Head of the Division of Recreational Activities, Cheang Kai Meng.
The first edition of the Lusofonia Festival was held in 1998, aiming to celebrate the Portuguese Expatriate Day on 10 June as to honour Portuguese-speaking individuals who resided in Macao and contributed to Macao’s development. The programme of this edition is as diversified as in previous years. Different cultural booths of Macao Portuguese-speaking communities from ten countries/regions, namely Angola, Brazil, Cape Verde, Guinea-Bissau, Goa, Daman and Diu, Mozambique, Portugal, São Tomé and Príncipe, Macao and East Timor, will be set up, introducing their countries or regions’ traditional music, photographs, arts and crafts, costume, literary books and gastronomy, thereby putting vitality in the Lusofonia Festival as well as allowing visitors to have in-depth understanding of the Portuguese-speaking countries and regions’ culture.
Three ensembles of the art groups from nine Portuguese-speaking countries or regions will perform different styles of music and dance every evening; several local Portuguese-speaking performing art groups will also offer performances in the afternoon and evening. Every night starting from 7:30pm, music performances by local groups will be held at the Carmo Square, allowing the public to enjoy music in a relaxed environment while tasting Portuguese-inspired delicacies.
In addition, activities also include Portuguese-inspired gastronomy restaurants (providing daily roasts of Portuguese flavour at lunch and typical dishes from the different Portuguese-speaking countries at dinner), a Macau Grand Prix Simulator with the Guia Circuit raceway and Portuguese traditional games such as pole climbing, bigfoot game, tug of war and sack racing, as well as activities for children (children can ride on Irish ponies in about 1-meter height and take photographs, participate in group games for children and workshops) and a table-football competition (for under 15 and over 16 years of age in two categories). A radio station will also be installed on site to broadcast Portuguese music throughout the day.
The 19th Lusofonia Festival features will be held from 7pm to 10pm on 21 October (Friday), from 12pm to 11pm on 22 October (Saturday) and from 12pm to 10pm on 23 October (Sunday) at the Taipa Houses-Museum, featuring singing, dancing, games and gastronomy in three consecutive days. In this 19th edition, the Festival further demonstrate the vibrancy of Macao as a tourism city through a diversified programme and continues to pass on rich Portuguese-inspired local culture. For more information, please access the IC’s website at www.icm.gov.mo or call IC through tel. no. 8399 6699, during office hours.
|
cc/2019-30/en_head_0021.json.gz/line27259
|
__label__cc
| 0.536279
| 0.463721
|
08-Days | Yukon Northern Lights Safari
The Yukon Territory: Whitehorse Aurora Borealis Adventure Tour
Day 1: Whitehorse
Travel with a small group and a bi-lingual tour guide (English & German) through the winter wonderland of northern Canada's Yukon Territory. You'll visit some remarkable areas, enjoy excellent sightseeing and meet locals who live here under very extreme climatically conditions. Upon arrival transfer from the airport to your hotel located within the city of Whitehorse. In the afternoon city-tour and visit of the Beringia Museum and Interpretive Center (included) - a voyage into the past gold rush days - and the SS-Klondike (Included) - a sternwheeler which represents an age when Whitehorse served as transport hub for the entire region taking miners on the Yukon River to the goldfields around Dawson City. Overnight in Whitehorse.
Day 2: Whitehorse - Watson Lake
Today we drive 420 km of the famous Alaska Highway towards Watson Lake. Photo stops along Marsh Lake, the first nation village of Teslin and the Rancheria Mountains. Since there are still a lot of trappers in the Yukon we stop at the cabin of trapper Don on the Tootsee River. In the afternoon arrival in Watson Lake and check-in the hotel. Watson Lake is well known for its "Signpost" started in 1942 by a homesick US Army Soldier. The 1996 build Northern Lights Space and Science Center boasts a State-of-the-Art panoramic video and surround-sound system. It incorporates interactive displays explaining science and folklore of the Aurora, along with the latest information about the Canadian Space Program. The nightly skies are illuminated by spectacular Northern Lights displays. Overnight in Watson Lake.
Day 3: Watson Lake – Liard Hot Springs - Watson Lake
Trip to the Liard Hot Springs. One of the best stops on the entire Alaska Highway are the fabulous Liard River Hot Springs, located in the Liard River Hotsprings Provincial Park - north of Muncho Lake. Relaxation seeps into your body as you ease into the second largest hot spring in Canada. In a natural boreal forest surrounding a soak in these Hot Springs is an exceptional experience in an incredible winter wonderland. Watch out for Moose frequently seen in the area. There are two hot springs at Liard, with water temperatures ranging from 42-52 degrees C (107-126F). The nearest is the Alpha pool, and half a mile beyond that is Beta pool, which is larger and deeper, and is likely to have few other people there. Return to Watson Lake. In the evening we will go curling in the Watson Lake Recreational Centre. Overnight in a hotel in Watson Lake.
Day 4: Watson Lake - Whitehorse
After Breakfast we leave Watson Lake and visit on snowshoes the Rancheria Falls. We plan a lunch stop in the native village of Teslin - bordered by the waters of the Nisutlin and Teslin Rivers - or in Johnsons Crossing. By 1903 the Hudson Bay Company closed the important trading post. The Teslin Lake is 125 km long with a depth of nearly 213 meters. After dinner in Whitehorse we will drive up for 25 minutes to a heated cabin - away from the disturbing city lights of Whitehorse - on Fish Lake to observe spectacular Northern Lights displays. There will be a campfire outside around and roast marsh mellows and enjoy the quiet and clear winter night. Return to the city. Overnight in a hotel in Whitehorse.
Day 5: Klondike Highway - Dawson City
We'll drive up north for 530 km along the Klondike Highway to the famous gold rush town of Dawson City. Interesting stops at Braeburn Lodge and the first nation village of Carmacks - both are serving also as checkpoints for the famous Yukon Quest Sled Race, Five Finger Rapids and the Dempster Highway Crossing. Upon arrival in Dawson we visit the famous local bar "The Pit". Dawson City is a well preserved, living and breathing cultural and historic oasis tucked away in the middle of the Yukon wilderness. Once referred to as the "Paris of the North", its name is synonymous with the 1898's Klondike Gold Rush. This "must see" northern icon should be included in any Alaska/Yukon itinerary. Overnight in a hotel in Dawson.
Day 6: Dawson City
Usually the Yukon River freezes solid around November/December and an ice bridge is built which we will cross with the Van. An excursion to the Bonanza Gold fields and to the Midnight Dome will follow. Later on we invite you to a snowshoe tour to "Cave Man Bill" who lives in a cave on the western shore of the Yukon River. Or you can discover Dawson on your own. The City of Dawson and the nearby ghost town of Forty Mile are featured prominently in the novels and short stories of famed American author Jack London, who lived in the Dawson area from October 1897 to June 1898. During these days Dawson City was a thriving city of 40.000 In 1899 the gold rush was over and the population dropped to 8.000 One of the books it's been featured in is the beloved book "The Call of the Wild". Overnight in a hotel in Dawson.
Day 7: Dawson City - Takhini Hot Springs - Whitehorse
We drive back on the Klondike Highway to Whitehorse. Short before we are arriving in Whitehorse we will visit the Yukon Wildlife Preserve, which features an array of local wildlife. During a visit of Takhini Hot Springs about 30 Km from Whitehorse - also known as the "Yukon Hotspot" you can relax and soak in the warm spring water without any sulphur smell and with a wonderful view of the snow covered mountains around you. The hot springs are offering a range of recreational activities on over 300 acres: x-country ski trails, two connected hot pools with 35-40 degree water temperature and of course - perfect Aurora viewing from October to March. Return transfer to Whitehorse and overnight at a hotel in Whitehorse.
Whitehorse is located at Historic Mile 918 of the Alaska Highway and is the former terminus of the White Pass and Yukon Route Railway from Skagway, Alaska. At the head of navigation on the Yukon River, the city was an important supply and centre during the Klondike Gold Rush. It has been the territorial capital since 1953, when the seat was moved from Dawson City after the construction of the Klondike Highway. Whitehorse is in the mountain climate region, the tundra soil region, the Arctic vegetation region, and the boreal cordillera eco zone. The city gets its name from the White Horse Rapids, which were said to look like the mane of a white horse. Alternate stories have the rapids named after a First Nations Chief who drowned while crossing the rapids. Our tour ends in the morning of day 8 with a complimentary transfer to the airport.
7 Nights Standard Hotel Accommodation including Breakfast
Transportation as Scheduled in Van Conversions
Bi-Lingual Guide Service
Sightseeing & Activities
Detailed Tour & Travel Documentation
Rates per Person in CAD $ from/to Whitehorse
Tour Number: NLT5 Single Double Triple Quad
January 01 – March 26 | Departures Saturday $ 2700.00 $ 2180.00 N/A N/A
|
cc/2019-30/en_head_0021.json.gz/line27260
|
__label__wiki
| 0.948502
| 0.948502
|
Astros Perform Well in AL's Seventh Straight All-Star Win
Soon-to-Be Tropical Storm Barry on a Path for Louisiana
Cancer Doctor Stanislaw Burzynski Sees Himself as a Crusading Researcher, Not a Quack
Craig Malisow
Craig Malisow | December 31, 2008 | 4:00am
If you were writing the story of Dr. Stanislaw Burzynski, he'd probably want you to start with him leaving Poland for America with $15 and a dream. He'd want it to end with him curing cancer.
The events in between would describe a man leaving behind an oppressive regime for what he thought was a sanctuary for medical research — only to discover that U.S. authorities were even worse than the Communists. Page after page would show authorities trying to shut him down, trying to put him in jail. But he would persevere, bolstered by the testimonies of patients who come to his Houston clinic from all around the globe. Husbands, wives, sons, daughters — condemned to death by conventional medicine, but saved by Burzynski.
The preferred ending — the one where the U.S. Food and Drug Administration approves his treatment — would be about vindication after 30 years of fighting the system. It would show how closed-minded bureaucrats with a grudge cost thousands upon thousands of lives.
Dr. Stanislaw Burzynski
He wouldn't want you to suggest there's plenty of blame to go around. He wouldn't want you to stand that scenario on its head, to where it's Burzynski, not the government, refusing to share his treatment with the world unless he was able to do it his way, and his way only. Then, all the money he's made from patients who mortgaged homes and held fund-raisers in order to see him might not seem so justified.
But what he really wouldn't want is an alternate ending. One where, when you swap testimony for science, his treatment isn't effective after all. Because then people might pin those thousands of lost lives on him.
Last December, the FDA granted orphan drug status to Burzynski for the treatment of gliomas, a group of brain tumors that are hard to treat and quick to kill.
Generally, orphan status provides extra benefits — such as extended patent protection — to drug developers targeting diseases affecting fewer than 200,000 people.
It's the latest highlight of a saga that began in 1967, when a 24-year-old Burzynski identified certain peptides — chains of amino acids — in blood and urine. He found that people suffering with cancer typically had lower levels of these peptides, and he hypothesized that these agents might be the foundation of a nontoxic cancer treatment.
He called the peptides "antineoplastons," and the more he researched, the more optimistic he became. He continually drew his own blood, and that of his extremely accommodating family members, to the point where the volume couldn't keep up with his research needs. So he collected urine samples, at one point taking them from public restrooms, until he figured out a way to synthesize the antineoplastons. (Some critics laugh at this pee-based research; one wonders if, in another age, they would have snickered at the scientist who became oddly enamored of the bacteria-fighting ability he supposedly found in some mold in a petri dish he forgot to clean).
In 1970, three years after graduating from the Medical Academy of Lublin, Burzynski emigrated to the United States and took a position as researcher and associate professor at the Baylor College of Medicine in Houston. With the help of a grant from the National Cancer Institute, Burzynski continued his antineoplaston research. But when a grant renewal was denied in 1976, Burzynski decided that if he wanted to see his theory through to the end, he would have to do it on his own.
But first he had to find out if it was even legal to manufacture, sell and administer antineoplastons in Texas. As a later court order would detail, Burzynski asked officials at the Texas Department of State Health Services if he could legally treat patients with antineoplastons.
The court order, which included a history of the steps he took in opening the clinic, states that the officials gave him a verbal green light, but never gave written consent.
Based on what the officials told him, he opened a private practice and research lab in a business park near the Westchase area. His work was not exactly inconspicuous; urine was delivered to a warehouse via tank trailer, dumped into an outdoor 3,500-gallon container, then filtered and transferred to an uncovered 450-gallon mixing tank. From there, it went through a more complex synthesization process. At another facility in Stafford, the stuff went through additional testing before it was bottled.
In 1978, two FDA officials visited Burzynski and told him he was breaking federal law: The agency believed that antineoplastons could only be administered via Phase I clinical trials, which measure a drug's safety. Neither party realized it, but that visit was the beginning of a convoluted 20-year legal battle that would be fought in state and federal courts.
After the 1978 warning, Burzynski took an unexpected course for a man under FDA scrutiny. As, for example, appearing on 20/20 with Geraldo Rivera. And then, in 1983, upgrading the Stafford facility, which was rebranded the Burzynski Research Institute, Inc.
Besides allowing the write-off of certain expenses, the Institute provided employment for his wife Barbara, a fellow Medical Academy of Lublin graduate and former research assistant in Baylor's pediatrics department. Husband and wife became co-directors.
Burzynski also recruited his brother Tadeusz, a construction supervisor with degrees from Poland's Academy of Mining and Metallurgy and Brazil's Federal University. His job title: Director and Vice President in Charge of Technical Operations. The fourth original director was then-Harris County Attorney Mike Driscoll.
By 1983, FDA officials were convinced Burzynski was engaged in nose-thumbing of the highest order. The agency sought an injunction in federal court banning the use of antineoplastons. In a motion for summary judgment that might be described as part extortion, part chutzpah, the prosecutor warned the judge, "If the court declines to grant this injunctive relief sought by the government, thus permitting continued manufacture and distribution of antineoplastons, the government would then be obliged to pursue other less efficient remedies, such as actions for seizure and condemnation of the drugs or criminal prosecution of individuals."
Hell, yeah: The FDA wasn't going to put up with anyone trying to cure cancer without its say-so.
But the FDA walked away with only a partial victory. While the judge ruled that Burzynski could not ship antineoplastons across state lines, the ruling did not prevent intrastate distribution. Later, in 1985, acting on the belief that he was still shipping antineoplastons outside Texas, FDA officials made good on their threat and raided Burzynski's office. They took whatever documents they could — including patient files — and dragged patients into grand jury hearings. Instead of securing indictments, the FDA only succeeded in making thousands of people feel their privacy had been violated.
The FDA wouldn't wrangle an indictment until 1995 — and that was a doozy: Seventy-five counts, mostly for mail fraud and shipping an unapproved drug across state lines, that would've put Burzynski behind bars for nearly 300 years.
Bizarrely enough, as a part of Burzynski's bond agreement, federal judge Sim Lake ordered Burzynski and the FDA to agree on protocols for Phase II trials of antineoplastons — trials to measure the drug's efficacy. So while the FDA, via a federal prosecutor, was trying to imprison Burzynski, it was also monitoring his clinical trials.
When the trial began in 1997, the jury deadlocked, and Lake declared a mistrial. He then tossed the 34 mail fraud counts, citing lack of evidence. For its part, the FDA dropped 40 counts, leaving — 12 years after the raid and seizure of patient records — only one count of contempt. Burzynski was promptly acquitted.
Throughout the process, Burzynski's patients picketed outside the courthouse and testified before Congress. As far as they were concerned, the FDA was persecuting a noble man who merely wanted to offer a nontoxic alternative to radiation and chemotherapy.
This network of supporters grew even more outraged when, in the years after the trial, several sets of parents were told by the FDA that they could not take their dying children to Burzynski. The rationale was this: The treatment had never been properly tested, so it might be unsafe. No, the FDA said, it's better to take that kid with the walnut-sized brain tumor to a doctor who will zap him like Hiroshima, or pump him with drugs that might turn him into a bald, anemic wraith with just enough energy to handle the incessant vomiting.
If FDA officials wanted to send a message to people about the potential dangers of antineoplastons, it would be hard to imagine how they could have done a worse job. Instead of making Burzynski a criminal, they made him a hero.
The whole saga might have been more spectacular if there were any compelling evidence that antineoplastons actually worked.
The only person who seems able to publish studies showing the treatment's positive results is Burzynski, the only person with a financial interest in the drug. The one time Burzynski agreed to an independent study under the auspices of the National Cancer Institute, it ended in acrimony. Between 1991 and 1995, the NCI spent nearly $1 million funding Phase II trials of patients treated by doctors at the Mayo Clinic and Memorial Sloan-Kettering. Because of slow patient accrual, the doctors decided to expand the agreed-upon parameters of the protocol, ultimately allowing two patients with brain tumors larger than originally called for. Then, after several of the patients experienced side effects, including seizures, edema, confusion and drowsiness, the doctors responded by lowering the patients' dosages. Convinced the doctors were deliberately sabotaging the trials, Burzynski pulled the plug.
A 1995 Phase I trial by Japanese researchers showed promise, but Phase II trials were never initiated.
None of this lack of outside support has prevented Burzynski from publishing studies (mostly in obscure journals) and presenting abstracts at medical conferences worldwide. Yet after all these presentations, and after decades of research, Burzynski seems to have amassed exactly zero outspoken allies in conventional medicine. (While outspoken critics aren't hard to find, some oncologists don't seem interested in discussing him at all. The Houston Press's request to speak with experts at M.D. Anderson fell on deaf ears.)
In 1998, Paul Goldberg, editor of The Cancer Letter, a D.C.-based newsletter covering cancer research and drug approval, investigated Burzynski's claims up to that point. He asked three renowned and independent researchers to examine Burzynski's scientific protocols — all three said they could not make sense of the data, saying it did not resemble any commonly accepted models. Ten years later, Goldberg and two of those doctors don't feel any differently.
"This is taking a long time," Goldberg told the Press in an e-mail. "Sure, drug approval is a technical, time-consuming and costly process. Nonetheless, thousands of anticancer compounds have been shown to be effective — or dismissed as ineffective — over the decades since Dr. Burzynski initiated his experiments."
Henry Friedman, a neuro-oncologist at the Duke University Medical Center, was one of the independent doctors who reviewed the data for Goldberg. He doesn't say that antineoplastons don't work — only that Burzynski has failed to prove otherwise.
"Despite thousands of patients treated with the antineoplastons, no one has yet shown in a convincing fashion, [through] the rigorous requirements for peer review, that the therapy works," he says, adding later, "You have to understand how incredible that is. Because normally, you can do a cancer study of as few as 30 [or] 40 patients...and begin to get an idea of whether there is activity or not. And then you can do larger studies, and you can really prove the merits or the lack of merit of the therapeutic strategy."
When asked why, if Burzynski's protocols were so lacking, he received orphan status from the FDA, Friedman says, "It is a Grand Canyon's distance between somebody getting orphan disease status and getting approval for the drug."
Moreover, he says, Burzynski "has been making a fortune...on patients he's treated with antineoplastons. I find that of questionable ethics."
Howard Ozer, an oncologist and hematologist at the University of Oklahoma's Health Science Center, is the other surviving doctor who reviewed Burzynski's claims for Goldberg.
"If there were something there, it would be fairly easy to prove," he says. "And you don't have to do it in any unique way other than a routine, careful Phase II trial, or, with thousands of patients, he could have done a randomized study."
Tim Gorski, an OB-GYN and president of the Dallas/Fort Worth Council Against Health Fraud, is a bit less diplomatic.
"He's selling hope at a high price," Gorski says.
But what about all those patients who credit Burzynski with saving their lives? Don't they count for anything?
"How many people are there who feel like [televangelist] Benny Hinn saved their lives?" he says, adding that "People who are dead do not get up and say, 'Burzynski did nothing for me.'"
Also, Gorski says, bold and unproven claims are "a problem for cancer in particular, because as soon as you get cancer, you've got a big target on your back [for] quacks to come and get you."
So while mainstream oncologists might believe that Burzynski orbits the quackosphere, he has achieved near-messiah status among journalists, pseudoscientists and armchair oncologists who believe in an omnipotent Cancer Industry determined to quash any treatments that threaten the standard regimens of surgery, radiation or chemo. Often, the cornerstone of their belief is that every oncologist in the country is absolutely fine with children dying gruesome deaths because they are somehow making money off standard treatments.
And while Burzynski's patients say the antineoplastons worked where other treatment failed, these patients — or their surviving family members — often operate under the belief that any success is attributable to antineoplastons alone, and any deaths are strictly the fault of previous chemo or radiation.
While speaking with these family members, or reading their testimonies, is often heartbreaking, Burzynski has not been able to translate these anecdotes into sound science.
This may be because Burzynski doesn't seem interested in persuading colleagues, only patients. And on that level, he's wildly successful.
Patient testimonies almost always contain the phrase "treated like family." His warm bedside manner, and that of his staff, is often in stark contrast to patients' experiences in mainstream hospitals. Also, his CV is long, and, depending on what you consider relevant to the practice of medicine, contains the vital information that Burzynski is a "hereditary count" and the fact that he holds hundreds of patents in dozens of countries. (According to the U.S. Patent Office, these include a patent for a cancer-fighting toothpaste, as well as antineoplaston treatments for patients with AIDS, Parkinson's disease and neurofibromatosis. The 1991 patent for AIDS treatment describes remarkable results achieved with three patients, but Burzynski doesn't appear to have continued this research.)
Burzynski can also point to the hundreds of articles he's published, which also reassures patients and makes them comfortable enough to write big checks. Some of these articles are interesting reading, such as the 2004 one titled "Antineoplastons in Dairy Products," which revealed the dramatic finding that the level of antineoplastons in whey is greater than that found in feta cheese. (Caveat, per the study: "The analysis of feta cheese was more difficult to perform due to the high content of fat.")
This feta cheese revelation unfortunately occurred after the publication of the Burzynski bible, i.e., The Burzynski Breakthrough: The Most Promising Cancer Treatment and the Government's Campaign to Squelch It, but there's no telling if it will make future editions. But the book's author, syndicated columnist Thomas Elias, remains convinced that the FDA persecuted Burzynski because he threatened the livelihood of the doctors on the agency's review boards.
"These are the very people who stand to lose the most if Burzynski's drug is proved," he says. "These are the people who radiate kids' brains at St. Jude's regularly...These are the people who are the enemies of this drug, because they have the most to lose from it...If this drug is approved, it will basically say that what they've been doing for all these decades is junk, and wasting money and lives."
Elias says that he did not set out with the intent of writing a book hailing Burzynski, but the more he researched, the more the data pointed to one conclusion. He says he randomly selected patients throughout the country to interview and follow up on. Most of those who followed the treatment plan were alive and improving, he says. "But the ones who gave up on the treatment, they were dead. Without exception."
While Elias believes Burzynski tried from the beginning to work within the system, Gorski believes otherwise: "The guy's like Leona Helmsley," he says. "Medical research and doing things by the book and having evidence and facts and so on, that's for the little people. Burzynski can do as he pleases."
And, Gorski says, claims of a drug's potential ring hollow without scientific support.
"Let's put it this way," he says. "Until it's really thoroughly tested, there's potential that when you take an antibiotic, if you jump up and down when you're taking it and say, 'ollie-ollie-oxen-free,' then it'll work better than if you don't do that, right?"
Gorski believes that, at this point, Burzynski is so convinced in his treatment's infallibility that "he is no more going to stop using his antineoplastons than the Pope is going to convert to Islam...It's an ideological commitment that has got nothing to do with facts and reason."
Generally, Burzynski's patients pay a $6,000 deposit before beginning treatment. Technically, the drug itself is free because it's only used under Phase II trials, but patients pay for incidentals, including consultations, supplies and classes on how to administer the drug. This runs about $7,500-$9,000 a month — out of pocket. Ostensibly, after paying salaries, this money goes straight into more research.
But in recent years, the Burzynski train appears to have gone off the tracks. Namely, he has taken it upon himself to rescue patients afflicted with the other Big C: Crow's-feet.
Burzynski has launched a line of creams and capsules under the brand name Aminocare, which is described as "The Genetic Solution for Anti-Aging." Aminocare Cream has allegedly been subjected to rigorous clinical trials, although the resulting publication looks a bit different from his cancer articles. For one, it contains photographs of smiling middle-aged couples, basking in the glow of their new-found freedom from wrinkles. The study indicates that Aminocare showed a reduction of "complexity," "wrinkle depth" and "wrinkle volume."
The study was commissioned by Aminocare, and Burzynski settled on an unexpected choice in the scientists he trusted: researchers at the University Victor Segalen in Bordeaux, France. It appears to have been led by the university's Alain Jacquet, whose title is listed as "toxicologist." However, according to Jacquet's CV, he is what in Europe is called a "stomatologist" and in the U.S. is called a "dentist." (Jacquet later blessed another antiaging miracle drug, manufactured by Inversion Femme, that involves using shark cartilage to "combat the excess of free radicals.")
Burzynski presents his fountain-of-youth breakthroughs at worldwide conferences held by the American Academy of Anti-Aging Medicine. The Chicago-based organization was founded by Ronald Klatz and Robert Goldman, who received their medical degrees in Belize but are not legally allowed to identify themselves as "M.D.s" in Illinois, per orders by that state's Department of Professional Regulation.
While Goldman may not be able to call himself an M.D. in Illinois, his credentials are still impressive. According to the academy Web site, he is a Chinese weapons expert with the ability to perform "13,500 consecutive sit-ups and 321 consecutive handstand pushups." For proof of the latter, Goldman has included photos of himself standing on his hands, clad in a snug stars-and-stripes-patterned swimsuit.
As for Klatz, he is the developer of the "Model of Practical Immortality," in which he predicts that by 2029, people will have lifespans of at least 150 years.
While Burzynski told the Press that Aminocare does not sponsor these conferences, the company is listed as a sponsor on the academy's Web site.
And it's best not to push the subject. In speaking with Burzynski, you need to understand some basics: If you in any way question his methods, remark on his affiliation with dubious doctors or try to understand why, after 30 years, antineoplastons are not accepted by mainstream medicine, you're in for trouble.
In his first interview, Burzynski is cordial and accommodating.
After a brief wait in his clinic lobby, lined with photographs of celebrities who were never Burzynski's patients, such as Mel Brooks and Gregory Peck, the Press follows an assistant to the doctor's well-appointed office. Burzynski may not be tall, but his white doctor's coat and impeccably managed dark brown hair and mustache lend a presence of authority. He speaks softly, in a thick accent, often punctuating sentences with a smile.
Ever an optimist, Burzynski has been excited about nearing the end of Phase II trials. Phase III should be right around the corner, a remarkable achievement for a cancer drug. Asked to explain why the FDA seems less antagonistic these days, he says, "It's like a bully on the block. You beat him, and he could become your friend."
He's used to the first round of questions — he's answered these for decades — so his answers are quick, if not altogether sensible. History is replete with renegades who were first ridiculed, then hailed. He says that respected publications were so resistant to Einstein's early groundbreaking theories that he was forced to take out ads in The New York Times, a statement unsupported by historical evidence.
"Everyone who discovers something [meets] resistance," he says. "Why should I be any different?"
Take, for example, that mid-1990s NCI study — the one in which doctors administered doses lower than Burzynski approved of — that was just another "cover-up."
"They're lucky they're not behind the bars," Burzynski says.
But a second interview does not go as smoothly.
When asked if showing three-dimensional topographies of crow's-feet in places like Dubai took time away from that whole cancer thing, Burzynski bristles at what he considers to be an irrelevant question, responding in somewhat broken English.
"I have the right to do whatever research I want, okay?" he says, followed closely by, "I spent 42 years practicing medicine, doing research, and you are little man for asking such question, okay? Maybe in three years I get Nobel Prize, and you'll look like a shit, okay, asking me such stupid questions, okay?"
The Press explains that the reasoning behind the questions is this: Is Burzynski convinced that he's done everything possible to get antineoplastons federally approved, and thus covered by insurance, thus giving a chance to those dying children whose parents can't afford the steep payments? But when pressed as to why — even after the prolonged litigation with the FDA — he still hasn't been able to prove his treatment's efficacy, he is equally offended.
"You know why?" he says. "Because I came to this country with $15 in my pocket, okay? Because I didn't speak English when I came to this country. I learned it by myself. And in order for me to do what I am doing now, I needed to establish a pharmaceutical company. I needed to establish the research institute, okay, from the scratch, okay? And I need to do all of this from my own money, which I am, okay? How many years it would take for you to do it if you come to the country [from] like, say, Afghanistan?"
The Press also asks why, if one of the biggest barriers to sharing a promising cancer treatment with the rest of the world is his language skills, he hasn't enlisted the help of English-speaking scientists.
Burzynski laughs that one off. "Listen your little brain to this thing: I came to this country with $15, okay? How can you enlist somebody, paying him $5 [out of] $15, okay?"
Which leads to one of the most troubling aspects of the Burzynski saga: Why have no credible oncologists stood up for him? Why don't oncologists regularly refer their patients to his clinic? Why aren't the greatest minds in medicine calling for the swift approval of antineoplastons?
If they are out there, the Press needs to hear from them. Burzynski obliges as best he can, throwing out the name of perhaps his biggest ally in medicine (using that term loosely). That is Julian Whitaker, an alternative medicine practitioner who claims to be "board-certified in antiaging medicine." That could be true — it's just a question of which board he's talking about. One thing is for sure: It's not the American Board of Medical Specialties, which is what most doctors are talking about when they say "board-certified." The ABMS does not recognize "anti-aging" as a medical specialty. When asked for the names of supporting doctors who don't have Web sites featuring "Rollback Savings!" on their lines of nutritional supplements, Burzynski eventually comes up with Bruce Cohen, a brain tumor specialist at the Cleveland Clinic. Cohen did not return calls.
"Certainly, some doctors don't like me, because they would like to do whatever I did, okay?" Burzynski says. "Everybody would like to establish his own pharmaceutical company...They are begging for scraps from the government. They are living on grants. I did it [by] myself."
And that appears to be the other side of the story, the one that Burzynski would probably say wouldn't belong in his biography. The story of how, as objectionable as the bureaucracy behind drug approval can be, it is the only way of getting lifesaving medicine to those in need. A doctor who plays outside the system — no matter how righteously — risks losing his right to practice medicine altogether.
So, for Burzynski, the real story does not appear to be the system, or necessarily medicine itself. It appears to be a story of independence and financial success. Of not relying on the help of other people to achieve your dream. To Burzynski, it's a powerful story.
"Why are you not enthused?" he asks. Here's the real story, he says: "'That's the poor guy who came from Poland without any money, who was able to build his own company. He was able to move all the way to the approval process, and with a little luck, he can get the approval of FDA'...It's a great American story, okay? And then you are talking to the guys who are old cronies, who hate me guts because they would dream to do whatever I do, but...they never had the guts to do it."
He's right. It's one hell of a story.
craig.malisow@houstonpress.com
Craig Malisow covers crooks, quacks, animal abusers, elected officials, and other assorted people for the Houston Press.
Still Much Uncertainty Surrounding Gulf Disturbance
Bregman Falls in Home Run Derby, Verlander to Start for AL in...
Astros Have a Chance to Break Away with Spate of AL West Games
Rockets Trade Chris Paul for Russell Westbrook in Blockbuster...
|
cc/2019-30/en_head_0021.json.gz/line27264
|
__label__wiki
| 0.670173
| 0.670173
|
Boomerang buyers: More people who lost homes during housing crisis are buying again
More people who lost homes to foreclosures or short sales in the housing crisis are buying again. Many plan to buy within 3 years
Boomerang buyers: More people who lost homes during housing crisis are buying again More people who lost homes to foreclosures or short sales in the housing crisis are buying again. Many plan to buy within 3 years Check out this story on htrnews.com: https://www.usatoday.com/story/money/2019/04/25/housing-market-2019-more-who-lost-homes-crisis-buying-again/3535675002/
Paul Davidson, USA TODAY Published 4:01 a.m. CT April 25, 2019 | Updated 7:34 a.m. CT May 21, 2019
After Teresa and Mark Taunton short sold their $535,000 four-bedroom dream home in Celebration, Florida, at the end of the real estate meltdown in 2011, buying another house was the last thing on their minds.
“It makes you feel you could somehow end up in the same position,” says Teresa, 57, describing the anxiety the couple experienced after selling their house for less than what they owed the bank. “We were just so leery of everything.”
But in late February, five years after they were officially allowed to make another home purchase, they closed on a modest ranch house for less than half the price of their former Orlando-area unit and just minutes away.
“We were really tired of renting,” Teresa says. Of their new house, she adds, “It’s comfortable. It’s home.”
With rent, “You’re looking at (shelling out) $20,000 to $30,000 a year, and you have nothing in return,” Mark adds.
Buyers that delayed purchases after the financial crisis are back in the market again. (Photo: franckreporter, Getty Images/iStockphoto)
There are signs that a growing number of Americans who lost homes to foreclosure or a short sale during the housing crisis are emerging from their post-crisis bunkers and buying again or planning to do so in the near future.
Risky backseat: Why you might be safer in the front seat than the back seat in head-on crashes
Pier 1 in trouble? Pier 1 Imports may be headed toward bankruptcy, S&P warns
The trend could allow millions of so-called boomerang buyers to build wealth again through homeownership. It also could provide support to a housing market that has sputtered lately. Existing home sales are down 6.6% so far this year compared with the year-ago period, according to the National Association of Realtors (NAR).
“I think the next phase of the housing recovery will be partly driven by people in the prime age group” of 35 to 64 that have been hesitant to buy again after losing homes in the crisis, says Kwame Donaldson, an economist with Moody’s Analytics.
Young people largely have fueled the housing recovery so far. In March, first-time home buyers made up 33% of all existing home sales, up from 30% a year earlier, according to NAR. But from the fourth quarter of 2017 to the fourth quarter of 2018, the homeownership rate jumped from 58.9% to 61.1% for 35 to 44-year-olds, the largest increase on record for any age group, and from 69.5% to 70.1% for 45 to 54-year-olds, Census Bureau figures show.
Donaldson says he believes the leap for 35- to 44-year-olds was largely spurred by boomerang buyers who were 27 to 36 during the depths of the crisis.
Housing crisis hit less qualified
The housing bust was caused by lenders who doled out subprime mortgages to Americans who couldn’t qualify for conventional loans. Many of the mortgages required low interest-only payments initially that ballooned after a few years. The model worked as long as home prices kept soaring, allowing homeowners to refinance. It unraveled when prices plunged and the Great Recession caused millions of people to lose their jobs and fall behind on their mortgage payments.
From 2006 to 2014, there were 7.3 million housing foreclosures and 1.9 million short sales, according to CoreLogic, a housing research firm. After a foreclosure, a prospective buyer must typically wait seven years to qualify for a mortgage guaranteed by Fannie Mae or Freddie Mac. The wait can be three years in certain circumstances, or for a Federal Housing Administration loan, but people who wait seven years generally benefit from higher credit scores and lower interest rates.
A short seller generally must wait three years to buy again.
Of 2.8 million former homeowners whose foreclosures, short sales or bankruptcies dropped off their credit reports from January 2016 to November 2018, 11.5% have obtained a new mortgage, according to a study by credit rating agency Experian for USA Today.
Fifty-three percent of the remaining 2.5 million had prime or super-prime credit scores in November, notes Experian Vice President Michelle Raneri. “That’s 1.3 million people who have really good credit,” she says. “Maybe they don’t realize they would qualify now.”
Some economists say many of those affected who wanted to become homeowners again already have done so. “I’m less convinced this is going to move the market,” says Ralph McLaughlin, deputy chief economist of CoreLogic.
Michael Fratantoni, chief economist of the Mortgage Bankers Association, says young people will be a far greater force in the housing market than prime-age boomerang buyers the next few years. There are about 31.7 million 24- to 38-year-old renters in the U.S., according to CoreLogic.
But Moodys' Donaldson notes that the typical pay of middle-aged Americans is 14% higher than the U.S. average, making them particularly good candidates to buy homes. Those who lost houses were financially and psychologically scarred, he says, and many could take longer than three- or seven-year waiting periods before feeling comfortable enough to make a purchase.
In the Denver area, some boomerang buyers tour homes but then get cold feet and pull back before reentering the market months later and finally buying, says Jessica Reinhardt, a broker at RE/MAX Alliance.
A NerdWallet survey, conducted for USA TODAY in January, found that 6% of Americans who lost a home due to a financial event the past decade plan to buy one this year. But a whopping 39% intend to buy over the next three years and 58% say they’ll purchase within five years. Nearly one-third said they're afraid to own a home again.
Losing the 'American dream'
The Tauntons, of Celebration, could have bought another house in 2014 when the three-year waiting period after their short sale ended. But, “the memory was still sore,” Mark says. “You’re still in the middle of what you lost.”
Teresa and Mark Taunton (Photo: Handout)
They lost the house they bought in 2005 in which they raised the five children of their blended family and that symbolized their attainment of “the American dream,” as Mark puts it. They had their own pool and the Disney-owned community sported a movie theater and spa, among other amenities.
They kept current on their mortgage even after Mark lost his job as manager of an exclusive men’s designer clothing store in the depths of the recession in 2008. But when their monthly payment jumped from $2,300 to $3,500 in 2010, they were on the verge of falling behind. Their lender advised them to stop making payments so they could get a loan modification, but it never came.
“We did everything right,” Mark says, noting they had never missed a payment. “It was traumatic.”
While they rented four apartments and homes, they squirreled money away and started thinking about buying again last November. Besides wanting to amass a retirement nest egg, they grew weary of renting because “you didn’t get to know your neighbors,” Teresa says.
This time, they resolved to spend no more than $250,000, rejecting several of the more lavish houses they visited. “You never want to go through that again,” says Mark, who is now a high school teacher.
Teresa, an accountant, asked lots of questions and took meticulous notes, and the couple provided extensive documentation. Last time, “The mortgage company made it so easy,” she says.
The couple, who used most of their savings to buy their previous house, "qualified for much more than the home" they purchased this time, says their Redfin agent, Mike Moore.
They made a down payment of 5% on the $247,000 house, giving them a monthly payment of $1,640. While they worry about getting hurt by another crash, “I feel a whole lot better about a $240,000 house than a $535,000 house,” Mark says. “I feel like I can still control it.”
Economy, wage growth aid buyers
There are concerns for boomerang buyers. Nationally, home prices have climbed 53% since their 2012 bottom and are now 11% above their 2006 peak, according to the S&P CoreLogic Case-Shiller index. That raises worries about another potential bubble and could keep already-wary former homeowners from making a purchase. But credit standards are much tighter now, “so there are fewer risky loans out there,” says Skylar Olsen, director of economic research for real estate site Zillow. “The national market is not headed towards a bubble popping,” she says.
Hiring: McDonald's commits to hiring older Americans to fill jobs
Amazon returns: Kohl's to accept Amazon returns at all stores beginning in July
In fact, home price increases have moderated since last year and mortgage rates have fallen even as wage growth has accelerated, creating a positive backdrop for boomerang and other buyers, Fratantoni says.
The economy’s steady recovery the past nine years has been a godsend for Art Fernandez, of Davie, Florida. In 2007, he and his wife Leanette leveraged an interest-only mortgage to buy a 10,000-square-foot house around the corner from their more modest home, seeking both their dream house and a sure-fire investment in the go-go years. They bought even before selling their existing house.
But the housing market seemed to crash the week they closed, Fernandez says, leaving them owing more on both homes than they were worth. Soon, Lynette had to leave her job as a mortgage broker and Art, a retail theft prevention manager, was laid off. They lost the first house through foreclosure and the second in a short sale. “It was very, very difficult,” Fernandez, 42, says.
Boeing: Global groundings of Boeing 737 Max lower company's profit, revenue in first quarter
But while they rented for three years, he got another theft-prevention job, as well as a part-time gig as a real estate broker. Leannette became a travel and lifestyle blogger.
When they decided to buy a 2,200-square-foot house in 2017 for $355,000, “It was like we had three full-time jobs,” Fernandez says. “We were confident and ready to find our 'forever home.'"
In some areas hit hardest by the housing crisis, boomerang purchases are picking up, brokers say. In Las Vegas, Thomas Blanchard, managing broker of Orange Realty Group, estimates that 15% to 20% of sales handled by his firm are to boomerang buyers, up from 1% to 2% a few years ago. In the Miami area, boomerang buyers make up four in 10 purchases, estimates Sonia “Gaby” Martinez, broker and owner of Xtreme International Realty. Sharply rising rents in Las Vegas and Miami are prodding more ex-homeowners to buy again, the brokers say.
Some want to do so before climbing prices make it impossible.
Kimberly Velasquez, 43, of Parker, Colorado, lost her four-bedroom, $320,000 house to foreclosure in 2011. After renting and going through a divorce, she decided to buy a $380,000 townhouse last August as soon as the foreclosure came off her credit report. Denver-area home prices have more than doubled since 2011.
“I decided I needed to do it now," she says, "or it would be to the point where I’d be priced out of ever being able to buy a home.”
Residential real estate has climbed back in the 10 years since the housing crash crash, but an Associated Press analysis found a financial gap has grown between renters and homeowners. (June 20) AP
Read or Share this story: https://www.usatoday.com/story/money/2019/04/25/housing-market-2019-more-who-lost-homes-crisis-buying-again/3535675002/
Manitowoc, what business do you want or miss most?
Manitowoc real estate transfers: July 14, 2019
Bank First completes merger with Partnership
Manitowoc landmark Swetlik's gas station closes
Tramontina closing Manitowoc plant, costing 145 jobs
Treehouse Theater moving to former Washington St. antiques mall
|
cc/2019-30/en_head_0021.json.gz/line27265
|
__label__wiki
| 0.69135
| 0.69135
|
Shelagh McCall QC writes on Reverse burdens and the presumption of innocence
In the recent case of Urquhart v HMA [2015] HCJAC 101, the Appeal Court held that the reverse burden placed on an accused by section 38(2) of the Criminal Justice and Licensing (Scotland) Act 2010 is an evidential, not a legal, one.
Mr Urquhart was convicted of contravening section 38(1) by shouting, swearing and brandishing a sword at police officers. Perhaps surprisingly, given the terms of the libel, he had mounted a defence based, inter alia, on section 38(2).
Section 38(2) states, “It is a defence for a person charged with an offence under subsection (1) to show that the behaviour was, in the particular, circumstances, reasonable.”
Article 6(2) enshrines the presumption of innocence as a component of the right to a fair trial. This means that the burden of proving guilt rests with the prosecution. However, presumptions of law (legal burdens) and presumptions of fact (evidential burdens) are permitted provided they are kept within reasonable limits, the rights of the defence are maintained and they take proper account of the importance of what is at stake (Salabiaku v France (1991) 13 EHRR 379).
Mr Urqhuart did not argue that section 38(2) could not be compatible with Article 6. Rather the question for the Court was whether this provision imposes a legal burden, meaning that the accused has to prove the defence on balance of probabilities; or an evidential burden, meaning that accused has to raise the issue in evidence, with the burden remaining on the prosecution to disprove it.
Previous authorities (e.g. Glancy v HMA 2012 SCCR 52) make clear that in deciding this question, the Court should examine (i) the relevant statutory provisions; (ii) the activity prohibited and the measures directed at it by the statute; and (iii) the justification for the departure from the presumption of innocence.
Applying that analysis to section 38(2), the Court first noted that the language of the section was that the person charged needed “to show” rather than “to prove” or “to establish”. This, the Court said, supported the conclusion that the burden was only an evidential one. In fact, this may be a rather weak indicator of an evidential burden, since legal burdens have been found to exist in other statutory defences where the expression “to show” is used (e.g. R v Johnstone [2003] UKHL 28 and Glancy v HMA 2012 SCCR 52).
Looking next at the activity prohibited by section 38(1), the Court’s view was that the offence created did not obviously support the imposition of a legal burden, given the spectrum of behaviour potentially criminalized by it. In other words, the mischief tackled by the provision might be minor, making a legal burden unreasonable.
Last the Court considered the justification for interpreting section 38(2) as imposing a legal burden. Legal burdens have been held to arise where the defence relates to matters closely conditioned with the accused’s own knowledge or state of mind and where the prosecution would face particular problems securing a conviction in the absence of a legal burden (Sheldrake v DPP Attorney General’s Reference (No. 4 of 2002) [2003] EWCA Crim 762). In the context of section 38(2), however, the Court observed that the assessment of reasonableness is an entirely objective test and is not, of itself, amenable to proof. In other words, in order to rely on the defence, the accused may need not adduce any additional evidence beyond that led by the Crown in proof of its case.
It is, on the facts, not surprising that the Court decided that Mr Urquhart’s behaviour could not on any view be construed as reasonable. But in future cases, it will be interesting see whether there are circumstances in which the Court will conclude that, applying an objective test, the behaviour libelled was likely to cause a reasonable person fear or alarm, and yet the behaviour was, objectively, reasonable in the circumstances.
|
cc/2019-30/en_head_0021.json.gz/line27271
|
__label__wiki
| 0.652437
| 0.652437
|
{SUPERPOSITION} was a juried show of sculptural glass and glass related sculpture held in Seattle WA in June, 2011 concurrent with the Glass Art Society Conference.
Experimentation is an exercise in the virtues of uncertainty.
{superposition} connotes a moment at which uncertainty is so great that it is impossible to differentiate on state of being from another, and we are forced to assume that both are true. This egalitarian approach to existence is a powerful metaphor for the multiplicities of identities and genres inhabited by the works and artists in the show.
ALEXANDRA BEN-ABBA
JAKE VINCENT
JAY MACDONELL
JIN WON HAN
KIRSTI TAIVIOLA
LISA KOCH
MASA BAJC
MICHELLE MECHANIC
ANNA MLASOWSKY
NETTA BACON
DANIEL PETRAITIS
BRADLEY PITTS
SEAN SALSTROM
RUI SASAKI
KEUNAE SONG
STUDIO AND (COSMAN/WOLOWIEC)
BRETT SWENSON
FOSTER TURCOTT
BRYAN WILSON
Jocelyn Prince
Jocelyne Prince exhibits her work in museums and alternative galleries and venues across North America, Asia and Europe. Recent exhibitions/events include: Emanations: Art + Process, Wheaton, NJ; Glory Studies, Urban Glass, Brooklyn; Butoh/Fiasco, Toyama, Japan; Atelier LePrince ReVisited, Illingworth Kerr Gallery, Canada; El Greco ReVisited, Tacoma Museum; andEnacting the Screen, Brick + Mortar Video Festival, Greenfield, MA. In 2014/15 she was awarded the Frazier Award for Excellence in Teaching and a George A. and Eliza Gardner Howard Foundation Fellowship. Prince is a full-time member of the faculty in RISD’s Glass department.
Jin hongo
Jin Hongo is currently th Director of Toyama City Institute of Glass Art, the first city-supported art school in Japan to specialize in glass. He has taught many workshops and lectured internationally. For 25 years Hongo has worked alongside many maestros and artists from all over the world, and his daily teaching experiences have been a strong influence on his work. Hongo's mixed media approach to sculpture is fueled by the excitement he finds in his discoveries and inventions with glass.
Michael Scheiner
Michael Scheiner is known for his provocative and enigmatic sculpture in glass. Since he completed his graduate studies in 1982 he has actively exhibited, lectured and led workshops internationally. Throughout his career he has received numerous awards and fellowships such as the Louis Comfort Tiffany foundation, Ford Foundations and the National Endowment for the Arts. Examples of his work are included in many museum collections world-wide; The Corning Museum of Glasss, Hokkaido Modern Museum of Art, the Renwick Gallery of the National Museum of American Art and New Orleans Museum of Art. Between 1983 and 2004 he served as adjunct faculty in the Rhode Island School of Design Glass Department and as professor in the Department of Formative Arts at Nagoya University of Arts from 2004 - 2012. Currently he is living and working in Central Falls, Rhode Island.
Jack Wax
Jack Wax is a two time recipient of Individual Fellowships from the National Endowment for the Arts, was nominated three times for a Tiffany Foundation Grant, was a recipient of an Illinois State Council of the Arts Grant,is a 2007-2008 recipient of both a Theresa Pollack Award and a Virginia Museum of Fine Arts Individual Professional Artists Fellowship. He received his BFA from Tyler School of Art, and his MFA from Rhode Island School of Design. Since 1983 he has taught at a number of Institutions of Higher learning including: Temple University's Tyler School of Art, The Cleveland Institute of Art, Illinois State University, Rhode Island School of Design, the Toyama Institute (Toyama Japan), and the Danmarks Designskole (Bornholm, Denmark). At present he is a full prefessor at the Virginia Commonwealth University's School of the Arts in Richmond, Virginia.At the present time he is represented by Reynolds Gallery.
|
cc/2019-30/en_head_0021.json.gz/line27274
|
__label__wiki
| 0.757848
| 0.757848
|
Telford to spend £18m on road repairs
Highways Reporters
Telford & Wrekin Council is to invest at least £18m over the next three years to improve its existing road infrastructure.
The Highways Capital Programme will see £7.5m spent in 2012/13 alone and a further £6.3m in 2013/14.
The Council is putting up £4.5m of this and the Department for Transport has already indicated it will spend a further £4m in 2014/15. The council figure for that year is still to be decided.
The council has now announced the list of projects that are planned for the first year which include resurfacing work at Purbeck Dale and Chiltern Gardens.
Councillor Shaun Davies, cabinet member for Environment, Co-operative Council and Partnerships, said: "Although the winter we've just been through has been comparatively mild, like many local authorities we are still catching up on the damage done to our roads by the previous three years.
"This planned investment over the next three years will see us take significant strides towards improving the quality of the borough's roads and our year one programme covers both residential and principle roads and was developed in consultation with Town and Parish Councils."
Additionally, the council has also been successful in securing £3.5m of direct investment from Central Government via the Department for Transport's Local Sustainable Transport programme.
highways maintenance
|
cc/2019-30/en_head_0021.json.gz/line27275
|
__label__cc
| 0.746944
| 0.253056
|
The Scientific World Journal
To receive news and publication updates for The Scientific World Journal, enter your email address in the box below.
Volume 2012, Article ID 346369, 10 pages
Secondary Data Analyses of Subjective Outcome Evaluation Data Based on Nine Databases
Daniel T. L. Shek1,2,3,4,5
1Department of Applied Social Sciences, The Hong Kong Polytechnic University, Hong Kong
2Public Policy Research Institute, The Hong Kong Polytechnic University, Hong Kong
3Department of Social Work, East China Normal University, Shanghai 200062, China
4Kiang Wu Nursing College of Macau, Macau
5Division of Adolescent Medicine, Department of Pediatrics, Kentucky Children’s Hospital, University of Kentucky College of Medicine, Lexington, KY 40536, USA
Received 30 November 2011; Accepted 25 December 2011
Academic Editor: Joav Merrick
Copyright © 2012 Daniel T. L. Shek. This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
The purpose of this study was to evaluate the effectiveness of the Tier 1 Program of the Project P.A.T.H.S. (Positive Adolescent Training through Holistic Social Programmes) in Hong Kong by analyzing 1,327 school-based program reports submitted by program implementers. In each report, program implementers were invited to write down five conclusions based on an integration of the subjective outcome evaluation data collected from the program participants and program implementers. Secondary data analyses were carried out by aggregating nine databases, with 14,390 meaningful units extracted from 6,618 conclusions. Results showed that most of the conclusions were positive in nature. The findings generally showed that the workers perceived the program and program implementers to be positive, and they also pointed out that the program could promote holistic development of the program participants in societal, familial, interpersonal, and personal aspects. However, difficulties encountered during program implementation (2.15%) and recommendations for improvement were also reported (16.26%). In conjunction with the evaluation findings based on other strategies, the present study suggests that the Tier 1 Program of the Project P.A.T.H.S. is beneficial to the holistic development of the program participants.
Although the prevention science approach that focuses on risk and protective factors of high-risk adolescent behavior has generated much research and prevention programs in the past few decades, it has been criticized as focusing too much on adolescent problems and pathology. As such, there is an alternative approach that emphasizes the importance of positive youth development. Damon [1] stated that the field of positive youth development (PYD) focuses on each child’s talents, strengths, interests, and future potential in contrast to approaches that focus on problems that some youth display when they grow up, such as delinquency and substance abuse.
There are many positive youth development programs in the field. In a review of existing programs on positive youth development, Catalano et al. [2] reviewed 77 programs and concluded that there were 25 successful programs involving 15 positive youth development constructs. These constructs include promotion of bonding, cultivation of resilience, promotion of social competence, promotion of emotional competence, promotion of cognitive competence, promotion of behavioral competence, promotion of moral competence, cultivation of self-determination, promotion of spirituality, development of self-efficacy, development of a clear and positive identity, promotion of beliefs in the future, provision of recognition for positive behavior, provision of opportunities for prosocial involvement, and fostering prosocial norms. Obviously, these positive youth development constructs can be utilized in youth development programs that aim to promote the holistic development of adolescents.
With reference to the intensification of adolescent developmental problems in Hong Kong [3, 4], there are very few systematic and multiyear positive youth development programs in Hong Kong. The existing youth enhancement programs commonly deal with isolated problems and issues in adolescent development (i.e., deficits-oriented programs), and they are relatively short term in nature. To promote holistic development among adolescents in Hong Kong, the Hong Kong Jockey Club Charities Trust initiated and launched a project entitled “P.A.T.H.S. to Adulthood: A Jockey Club Youth Enhancement Scheme” with an earmarked grant of HK$400 million for the initial phase. (P.A.T.H.S. stands for Positive Adolescent Training through Holistic Social Programmes.) Because of the overall success of the initial phase, an additional grant of HK$350 million was earmarked for the extension phase of the project.
There are two tiers of programs (Tier 1 and Tier 2 Programs) in this project. The Tier 1 Program is a universal positive youth development program in which students in Secondary 1 to 3 participate, normally with 20 h of training in the school year at each grade. Because research findings suggest that roughly one-fifth of adolescents would need help of a deeper nature, the Tier 2 Program is generally provided for at least one-fifth of the students who have greater psychosocial needs at each grade (i.e., selective program). To date, more than 244 schools (with 669 schools in the Secondary 1 level, 443 in the Secondary 2 level, and 215 in the Secondary 3 level) and 223,101 students have participated in the Tier 1 Program of the project [5, 6].
Several evaluation strategies have been utilized to evaluate the Project P.A.T.H.S. in Hong Kong. These include objective outcome evaluation, subjective outcome evaluation, qualitative evaluation, process evaluation, and evaluation based on personal construct psychology. Among these evaluation strategies, the subjective outcome evaluation method was used to assess the perceptions of the participants as well as program implementers regarding the program, instructors, and benefits of the program [7, 8]. It is noteworthy that although subjective outcome evaluation or the client satisfaction approach is commonly used in human services to collect the views of the program participants, there are comparatively fewer attempts to carry out subjective outcome evaluation among program implementers [7, 8].
There are several reasons why program implementers should be engaged in the evaluation process. First, by engaging the program implementers in the evaluation process, a more complete picture of the effectiveness of the program can be constructed. In particular, by adding the perspective of the program implementers, bias due to subjectivity of the program participants can be reduced and the related data can enrich our understanding of the program effect. Second, engagement of program implementers is commonly emphasized in different evaluation models. For example, in the utilization-focused evaluation paradigm, it is argued that as different stakeholders are involved in the evaluation process, program implementers’ views are legitimately covered [9]. Similarly, based on the standards of the Joint Committee on Standards for Educational Evaluation [10], identification of the stakeholders (Utility Standard 1) involving complete and fair assessment (Proprietary Standard 5) is important. According to these standards, program implementers’ views and assessments should be taken into account. Different researchers have also emphasized the importance of engaging different stakeholders in the evaluation process [11–13]. For example, Brandon et al. [14] pointed out that participation of program stakeholders in evaluations improves the relevance and validity of evaluation results.
In the Project P.A.T.H.S., subjective outcome evaluation is used to capture the views of the program participants and implementers. Based on these data, implementers in each school are required to submit a report documenting the effects of the program, including five conclusions that they would like to put down in the report. By utilizing and integrating the five conclusions drawn in the school-based evaluation reports prepared by the program implementers based on the views of both program participants and implementers, the present study conducted secondary data analyses to evaluate the effectiveness of the Tier 1 Program of the P.A.T.H.S. Project. According to Royse [15], secondary data analysis “involves analysis of an existing data set that results in knowledge, interpretations, and conclusions beyond those stated in the original study” (page 201), and it is a kind of unobtrusive research method, which does not need to have direct interaction with the subjects. Studies utilizing secondary data analyses are common in the social science literature [16, 17].
Several studies have been carried out to examine the five conclusions drawn in different cohorts of the Project P.A.T.H.S. [18–20]. Generally speaking, the findings showed that different stakeholders had positive perceptions of the program, instructors, and benefits of the program. There were also suggestions for improvement in the reports. As there are nine databases containing data on the five conclusions, it is exciting to look at the aggregated picture based on secondary data analysis of the available data. As such, the present study was carried out to examine the effectiveness of the Tier 1 Program of the Project P.A.T.H.S. based on the secondary data analyses of conclusions drawn by the program implementers based on the program participants and implementers.
2.1. Dataset for Secondary Data Analyses
In each year of the Experimental and Full Implementation Phases, after completion of the Tier 1 Program, students and program implementers were invited to respond to subjective outcome evaluation forms (Forms A and B, resp.). The program implementers then prepared a report based on the subjective outcome evaluation data to report the program effectiveness. Throughout the years, a total of 1,327 reports involving 244 schools, 223,101 students, and 9,915 program implementers were collected (Table 1).
Table 1: Description of data characteristics from 2005 to 2009.
There are several parts in Form A:(i)participants’ perceptions of the program, such as program objectives, design, classroom atmosphere, interaction among the students, and the respondents’ participation during class (10 items),(ii)participants’ perceptions of the instructors, such as the preparation, professional attitude, involvement, and interaction with the students (10 items),(iii)participants’ perceptions of the effectiveness of the program, such as promotion of different psychosocial competencies, resilience, and overall personal development (16 items),(iv)the extent to which the participants would recommend the program to other people with similar needs (1 item),(v)the extent to which the participants would join similar programs in the future (1 item),(vi)overall satisfaction with the program (1 item),(vii)things that the participants learned from the program (open-ended question),(viii)things that the participants appreciated most (open-ended question),(ix)opinion about the instructor(s) (open-ended question),(x)areas that require improvement (open-ended question).
Similar to Form A, Form B includes the evaluation of the following:(i)program implementers’ perceptions of the program, such as program objectives, design, classroom atmosphere, interaction among the students, and the students’ participation during class (10 items),(ii)program implementers’ perceptions of their own practice, including their understanding of the course, teaching skills, professional attitude, involvement, and interaction with the students (10 items),(iii)program implementers’ perceptions of the effectiveness of the program, such as promotion of different psychosocial competencies, resilience, and overall personal development of the students (16 items),(iv)the extent to which the workers would recommend the program to other students with similar needs (1 item),(v)the extent to which the workers would teach similar programs in the future (1 item),(vi)overall satisfaction with the program (1 item),(vii)things that the workers obtained from the program (open-ended question),(viii)things that the workers appreciated most (open-ended question),(ix)difficulties encountered (open-ended question),(x)areas that require improvement (open-ended question).
Based on the evaluation data collected in each school, program implementers in each school were required to complete a Tier 1 Program evaluation report where both quantitative and qualitative findings based on Forms A and B were summarized and described. In the last section of the report, the program implementers were requested to write down five conclusions regarding the program and its effectiveness. The involvement of the workers in writing the conclusions is consistent with the thesis that program implementers can give a more comprehensive and valid picture about the program quality and benefits to students. In addition, it is argued that they are proficient in accounting program effectiveness with reference to various aspects of the program, and providing recommendations for improving program arrangement and delivery in the real teaching context.
2.2. Data Analyses
In each cohort, the data generated from the five conclusions were analyzed using general qualitative analyses techniques [21] by two research assistants with a background in social work or psychology. The final coding and categorization were further cross-checked by another research colleague with a background in social work. All the research staff had received sufficient training on both quantitative and qualitative analyses. To guard against the subtle influence of such ideological biases and preoccupations of the coders, both intra- and interrater reliability on the coding were calculated. For intrarater reliability, each of the two research staff members who were primarily responsible for coding coded 20 randomly selected responses without looking at the original codes. For inter-rater reliability, another two research staff members who had not been involved in the data analyses coded the same 20 randomly selected responses independently without knowing the original codes given at the end of the scoring process. The data were also analyzed with reference to the principles of qualitative analyses proposed by Shek et al. [22].
In the previous analyses, the conclusions were categorized into several areas, including programs, implementers, benefits, difficulties, and recommendations. In the present secondary data analyses, the data in the existing datasets were also aggregated and analyzed with reference to these categories.
Based on the 6,618 conclusions in the 1,327 evaluation reports, 14,390 meaningful units were extracted. Utilizing the analysis framework adopted in previous studies, these raw responses were further categorized into several categories, of which 28.75% related to views on the program (Table 2), 16.87% related to views on the program implementers (Table 3), 35.97% related to perceived effectiveness of the program (Table 4), 2.15% related to difficulties encountered during program implementation (Table 5), and 16.26% were recommendations (Table 6).
Table 2: Responses on views toward the program in different cohorts.
Table 3: Responses on Views toward Program Implementers in Different Cohorts.
Table 4: Perceived effectiveness of the Tier 1 Program in different cohorts.
Table 5: Difficulties highlighted by the respondents in different cohorts.
Table 6: Recommendations suggested by the program implementers in different cohorts.
Regarding the conclusions related to the perceptions of the program, results in Table 2 showed that most of the responses were positive in nature. The percentage of positive responses in this domain was 80.22% on average. For the perceptions of the program implementers, findings in Table 3 also showed that a majority of the responses were positive in nature. Among the 2,427 responses, 97.33% were positive in nature. Findings on the perceived effectiveness of the program to the students are shown in Table 4, with a total of 5,176 meaningful units that could be categorized into several categories, including societal, familial, interpersonal, and personal enhancement. Overall, the positive effects of the program in different domains were evident, in which 95.78% were positive in nature.
To safeguard the reliability of the results, both the intra- and interreliability tests were conducted every year. The consolidated findings of the reliability analyses from 2005 to 2009 on stakeholders’ perceptions toward program, instructors and program effectiveness can be seen in Table 7. The findings generally showed that the related figures were on the high side.
Table 7: Reliability results across cohorts.
Despite the positive feedback, a small number of responses (, 2.15% of the total responses) were related to difficulties encountered. The difficulties included time constraints, difficulty in engaging the students, and inadequate school support (see Table 5). Lastly, suggestions for improvement can be seen in Table 6 (; 16.26% of the total responses). It is noteworthy that some suggestions for improvement were contradictory (e.g., “deepen program content” versus “simplify and condense the program content” under the category of program content).
Utilizing secondary data analyses, this study attempted to analyze the conclusions drawn by the program implementers of the Tier 1 Program of the Project P.A.T.H.S. in a series of studies over time. There are several unique characteristics of this study. First, a large number of reports () and schools () were involved. Second, as there are very few published evaluation studies on positive youth development programs in different Chinese contexts, this is a pioneer addition to the literature. Third, as few subjective outcome evaluation studies are based on program implementers, the present study highlights the utility of including implementers’ views in the evaluation of positive youth development programs.
In line with previous findings based on the conclusions drawn by the program implementers [18–20], results showed that the majority of the responses related to the perceptions of the Tier 1 Program, instructors, and program effectiveness were positive in nature. These findings are consistent with the previous findings based on objective outcome evaluation, process evaluation, qualitative evaluation, and personal construct evaluation showing that the different stakeholders perceived the Tier 1 Program to be beneficial to the development of the program participants. In conjunction with the evaluation findings based on other methods, the picture that can be derived from the available evaluation findings is that the Project P.A.T.H.S. can promote the holistic development of young people in Hong Kong.
Despite the positive findings observed, difficulties encountered during program implementation and recommendations for improvement were noted, although the number of comments was low as compared to other areas. There are several areas of difficulties observed. First, consistent with previous studies, classroom discipline was one of the major hindrances to the implementation of the program because the program encourages active participation of the students. As Chinese teachers traditionally expect students to sit quietly and obediently in class, engaging students, yet maintaining class discipline, is a challenge. Another major hurdle observed was time management. For those schools where the program was implemented in the class teachers’ periods, the time available for the class may not be adequate because class teachers usually have to deal with “class matters,” such as collection of class fees and discussion of class activities (e.g., classroom decoration during Christmas). Furthermore, program implementers are required to adopt a flexible and reflective approach in implementing the Tier 1 Program and they are expected to have much interaction with the students via structured activities, such as role play, group discussions, debates, and self-disclosure, which can arouse students’ interest and motivation to learn. However, as Chinese teachers typically adopt an authoritarian rather than an egalitarian role in teaching, teachers might find it hard to play and share with the students. Finally, as Hong Kong is undergoing education reform, participation in the Project P.A.T.H.S. means intensive involvement of the workers, which may pose a challenge for the teachers and social workers. On the whole, the difficulties encountered and suggestions for improvement can serve as useful pointers to fine tune the program.
Regarding the evaluation methodology, the present study utilizes evaluation reports prepared by the program implementers via secondary data analyses. The approach to analyzing the evaluation reports prepared by the program implementers is consistent with several views in the evaluation literature. According to utilization-focused evaluation, involvement of the stakeholders in evaluation is an important element of evaluation [9]. In addition, there is a movement to treat teachers as researchers/evaluators, where teachers are treated as internal evaluators who carry out authentic assessment [23–27]. In the evaluation literature, the role of “internal evaluator” has been given increasing attention. Arguments supporting the involvement of stakeholders in evaluation can be seen in Shek and Ng [20].
Although the present findings can be interpreted as evidence supporting the merits and benefits of the Project P.A.T.H.S., several alternative explanations should be noted. The first alternative explanation is that the findings are due to insufficient evaluation expertise of the program implementers. Nevertheless, this alternative explanation can be partially dismissed because professional social workers and teachers received evaluation training in this project, and evaluation is also part of the training for social workers and teachers in Hong Kong. Furthermore, there are findings showing that subjective outcome evaluation converged with objective outcome evaluation findings [28]. The second alternative explanation is that the findings are due to biases, such as drawing positive conclusions for job retention. However, since the findings are consistent across time and across methods, this possibility is not high. Based on the principle of triangulation, an integration of the existing findings indicated that there is a consistent picture derived—the Tier 1 Program is beneficial to the development of the program participants. For example, with reference to the junior school years, evaluation findings showed that relative to control group students, students in the experimental schools generally had better holistic development and less problem behavior [29–31].
There are several limitations of the present integrative study based on nine databases. First, due to the nature of the secondary data analysis, it is not possible to have interaction with the program implementers. It would be helpful if some dialogues between the program implementers and researchers could be carried out in the future. Actually, the use of focus groups as an evaluation strategy has partially solved this problem. Second, because the conclusions written by the workers were not in great detail, the relevant findings failed to give us a thorough understanding of the implementation processes involved. Third, validity of the data derived from the present study relies on the assumption that program implementers can make reasonable and fair judgments about the program based on the subjective outcome evaluation findings. While this assumption might be met because teachers and social workers are trained to conduct practice evaluation in Hong Kong, inexperienced workers may have problems in integrating the subjective outcome evaluation findings and translating them into valid conclusions. Of course, it can be counterargued that systematic training before program implementation can reduce this problem to a great extent. Despite these limitations and in conjunction with the previous research findings described above, the findings in the present study provide further support for the effectiveness of the Tier 1 Program of the Project P.A.T.H.S. in Hong Kong.
The preparation for this paper and the Project P.A.T.H.S. were financially supported by The Hong Kong Jockey Club Charities Trust.
W. Damon, “What is positive youth development?” Annals of the American Academy of Political and Social Science, vol. 591, pp. 13–24, 2004. View at Publisher · View at Google Scholar · View at Scopus
R. F. Catalano, M. L. Berglund, J. A. M. Ryan, H. S. Lonczak, and J. D. Hawkins, “Positive youth development in the United States: research findings on evaluations of positive youth development programs,” Prevention & Treatment, vol. 5, no. 1, article 15, 2002. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek, “Tackling adolescent substance abuse in Hong Kong: where we should and should not go,” TheScientificWorldJOURNAL, vol. 7, pp. 2021–2030, 2007. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek, V. M. Y. Tang, and C. Y. Lo, “Internet addiction in Chinese adolescents in Hong Kong: assessment, profiles, and psychosocial correlates,” TheScientificWorldJOURNAL, vol. 8, pp. 776–787, 2008. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek and R. C. F. Sun, “Effectiveness of the Tier 1 program of Project P.A.T.H.S.: findings based on three years of program implementation,” TheScientificWorldJOURNAL, vol. 10, pp. 1509–1519, 2010. View at Publisher · View at Google Scholar
D. T. L. Shek and R. C. F. Sun, “Development, implementation and evaluation of a holistic positive youth development program: Project P.A.T.H.S. in Hong Kong,” International Journal on Disability and Human Development, vol. 8, no. 2, pp. 107–117, 2009. View at Google Scholar · View at Scopus
D. T. L. Shek and R. C. F. Sun, “Subjective outcome evaluation of the Project P.A.T.H.S.: qualitative findings based on the experiences of program implementers,” TheScientificWorldJOURNAL, vol. 7, pp. 1024–1035, 2007. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek and R. C. F. Sun, “Subjective outcome evaluation of the Project P.A.T.H.S.: qualitative findings based on the experiences of program participants,” TheScientificWorldJOURNAL, vol. 7, pp. 686–697, 2007. View at Publisher · View at Google Scholar · View at Scopus
M. Q. Patton, Utilization-Focused Evaluation, Sage, Thousand Oaks, Calif, USA, 4th edition, 2008.
Joint Committee on Standards for Educational Evaluation , The Program Evaluation Standards, Sage, Thousand Oaks, Calif, USA, 1994.
D. Fetterman, “Steps of empowerment evaluation: from California to Cape Town,” in Evaluation Models: Viewpoints on Educational and Human Services Evaluation, D. L. Stufflebeam, G. F. Madaus, and T. Kellaghan, Eds., pp. 395–408, Kluwer Academic Publisher, Norwell, Mass, USA, 2000. View at Google Scholar
P. R. Brandon, M. A. Lindberg, and Z. Wang, “Involving program beneficiaries in the early stages of evaluation: issues of consequential validity and influence,” Educational Evaluation and Policy Analysis, vol. 15, no. 4, pp. 420–428, 1993. View at Google Scholar
P. R. Brandon, “Stakeholder participation for the purpose of helping ensure evaluation validity: bridging the gap between collaborative and non-collaborative evaluations,” American Journal of Evaluation, vol. 19, no. 3, pp. 325–337, 1998. View at Google Scholar · View at Scopus
P. R. Brandon, B. J. Newton, and J. W. Harman, “Enhancing validity through beneficiaries' equitable involvement in identifying and prioritizing homeless children's educational problems,” Evaluation and Program Planning, vol. 16, no. 4, pp. 287–293, 1993. View at Publisher · View at Google Scholar
D. Royse, Research Methods in Social Work, Nelson-Hall, Chicago, Ill, USA, 2008.
S. Boslaugh, Secondary Data Sources for Public Health: A Practical Guide, Cambridge University Press, Cambridge, UK, 2007.
K. J. Kiecolt and L. E. Nathan, Secondary Analysis of Survey Data, Sage, Beverly Hills, Calif, USA, 1985.
D. T. L. Shek, “Evaluation of the Tier 1 program of Project P.A.T.H.S.: secondary data analyses of conclusions drawn by the program implementers,” TheScientificWorldJOURNAL, vol. 8, pp. 22–34, 2008. View at Publisher · View at Google Scholar
A. M. H. Siu and D. T. L. Shek, “Secondary data analyses of conclusions drawn by the program implementers of a positive youth development in Hong Kong,” TheScientificWorldJOURNAL, vol. 10, pp. 238–249, 2010. View at Publisher · View at Google Scholar
D. T. L. Shek and C. S. M. Ng, “Evaluation of the Tier 1 program (Secondary 2 Program) of Project P.A.T.H.S.: conclusions drawn by the program implementers,” International Journal of Child and Adolescent Health, vol. 4, no. 1, pp. 41–51, 2011. View at Google Scholar
M. B. Miles and A. M. Huberman, Qualitative Data Analysis, Sage, Thousand Oaks, Calif, USA, 1994.
D. T. L. Shek, V. M. Y. Tang, and X. Y. Han, “Evaluation of evaluation studies using qualitative research methods in the social work literature (1990–2003): evidence that constitutes a wake-up call,” Research on Social Work Practice, vol. 15, no. 3, pp. 180–194, 2005. View at Publisher · View at Google Scholar · View at Scopus
S. W. Draper, M. I. Brown, F. P. Henderson, and E. McAteer, “Integrative evaluation: an emerging role for classroom studies of CAL,” Computers and Education, vol. 26, no. 1–3, pp. 17–32, 1996. View at Publisher · View at Google Scholar · View at Scopus
G. Lau and P. LeMahieu, “Changing roles: evaluator and teacher collaborating in school change,” Evaluation and Program Planning, vol. 20, no. 1, pp. 7–15, 1997. View at Google Scholar · View at Scopus
G. E. Kennedy, “An institutional approach to the evaluation of educational technology,” Education Media International, vol. 40, no. 3-4, pp. 187–199, 2003. View at Publisher · View at Google Scholar
J. B. Cousins, J. J. Donohue, and G. A. Bloom, “Collaborative evaluation in North America: evaluators’ self reported opinions, practices and consequences,” Evaluation Practice, vol. 17, no. 3, pp. 207–226, 1996. View at Publisher · View at Google Scholar
I. Shaw and A. Faulkner, “Practitioner evaluation at work,” American Journal of Evaluation, vol. 27, no. 1, pp. 44–63, 2006. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek, “Subjective outcome and objective outcome evaluation findings: insights from a Chinese context,” Research on Social Work Practice, vol. 20, no. 3, pp. 293–301, 2010. View at Publisher · View at Google Scholar · View at Scopus
D. T. L. Shek and C. M. S. Ma, “Impact of the Project P.A.T.H.S. in the junior secondary school years: individual growth curve analyses,” TheScientificWorldJOURNAL, vol. 11, pp. 253–266, 2011. View at Publisher · View at Google Scholar
D. T .L. Shek and L. Yu, “Prevention of adolescent problem behavior: longitudinal impact of the Project P.A.T.H.S. in Hong Kong,” TheScientificWorldJOURNAL, vol. 11, pp. 546–567, 2011. View at Publisher · View at Google Scholar
D. T. L. Shek and C. M. S. Ma, “Impact of the Project P.A.T.H.S. on adolescent developmental outcomes in Hong Kong: findings based on seven waves of data,” International Journal of Adolescent Medicine and Health. In press.
|
cc/2019-30/en_head_0021.json.gz/line27276
|
__label__wiki
| 0.670406
| 0.670406
|
Jul 17, 2019-Wednesday
Marking Gandhi’s 150th anniversary
There is a strong political subtext in Narendra Modi’s push to celebrate the milestone
editorials Updated: Jul 10, 2019 21:07 IST
Modi has repeatedly highlighted how the country must come together to celebrate the 150th birth anniversary of Mahatma Gandhi this year(ANI)
Prime Minister Narendra Modi takes pride in thinking big. He is also known to have a particular affinity for mega-campaigns and milestones. In his second term in office, Mr Modi has repeatedly highlighted how the country must come together to celebrate two momentous events: the 150th birth anniversary of Mahatma Gandhi this year; and the 75th year of Indian independence in 2022. From getting singers from 124 countries, to singing Gandhi’s favourite, evocative bhajan, Vaishnava Jana Tu, last year, to now urging all Bharatiya Janata Party (BJP) Members of Parliament to embark on a 150-km padyatra in their constituencies from October 2 this year, the PM has decided to invest both political and diplomatic energy in making Gandhi’s anniversary a grand occasion.
This is laudable. Gandhi’s contribution to the freedom struggle needs little elaboration. His principles — of truth, non-violence, Hindu-Muslim unity, equality by battling caste discrimination — hold resonance in contemporary India. And India’s political class would do well to go back to those values. Mr Modi, in Parliament, referred to the milestone as a national event. Parties across the spectrum, and citizens across ideological divisions, must come together to remember Gandhi.
But there is a fascinating political subtext to the BJP marking the occasion with enthusiasm. The Rashtriya Swayamsevak Sangh had an uneasy relationship with Gandhi. Both were rooted strongly within the Hindu tradition and used idioms, symbols, and messages that would resonate with Hindus. But this is where the similarities ended. The RSS had a particularly orthodox view of Hindu society, and deep antipathy for Muslims. Gandhi had a more liberal interpretation of Hindu texts, and believed tolerance, pluralism and communal harmony were essential to sustain India both as a society and a civilisation. He was finally assassinated by a man inspired by the more conservative Hindutva orientation, although it must be categorically said that Nathuram Godse was not an RSS member when he killed Gandhi. From then to now, there has been an evolution in the worldview of the RSS and its affiliates, including the BJP, and, from a critical lens, there has been a shift towards reverence. Mr Modi’s push to celebrate Gandhi is a reflection of this ideological shift. This is also in line with the BJP’s political efforts to appropriate a pantheon of national icons who represented other schools of political thought — from Sardar Vallabhbhai Patel to Babasaheb Bhimrao Ambedkar. While some critics find fault with it and focus solely on history, this evolution is actually welcome, particularly if the ruling party truly embraces the values of Gandhi in practice.
PM Modi asks BJP MPs to hold foot march to mark Mahatma’s 150th birth anniversary
Parliament Session 2019 highlights: PM Modi to constitute a committee on ‘one nation, one poll’
|
cc/2019-30/en_head_0021.json.gz/line27277
|
__label__wiki
| 0.83779
| 0.83779
|
President Eisenhower proclaims Law Day
On this day in 1958, President Eisenhower proclaims Law Day to honor the role of law in the creation of the United States of America. Three years later, Congress followed suit by passing a joint resolution establishing May 1 as Law Day.
The idea of a Law Day had first been proposed by the American Bar Association in 1957. The desire to suppress the celebration of May 1, or May Day, as International Workers’ Day aided in Law Day’s creation. May Day had communist overtones in the minds of many Americans, because of its celebration of working people as a governing class in the Soviet Union and elsewhere.
The American Bar Association defines Law Day as: “A national day set aside to celebrate the rule of law. Law Day underscores how law and the legal process have contributed to the freedoms that all Americans share.” The language of the statute ordaining May 1 calls it “a special day of celebration by the American people in appreciation of their liberties and? rededication to the ideals of equality and justice under law.”
On a day that, in many parts of the world, inspires devotion to the rights of the working classes to participate in government, Law Day asks Americans to focus upon every American’s rights as laid out in the fundamental documents of American democracy: the Declaration of Independence and the federal Constitution. The declaration insists that Americans “find these truths to be self-evident, that all men are created equal,” and guarantees the rights to “life, liberty, and the pursuit of happiness.” The Bill of Rights amended to the Constitution codifies the rights of free speech, free press and fair trial.
Law Day celebrates the legal construct for the determination of rights that the revolutionary leaders of the 1770s, hoping to prevent the sort of class warfare that went on to rack Europe from 1789 to 1917, were so eager to create.
https://www.history.com/this-day-in-history/president-eisenhower-proclaims-law-day
The U.S. destroys Spanish Pacific fleet in Battle of Manila Bay
At Manila Bay in the Philippines, the U.S. Asiatic Squadron destroys the Spanish Pacific fleet in the first battle of the Spanish-American War. Nearly 400 Spanish sailors were killed and 10 Spanish warships wrecked or captured at the cost of only six Americans wounded. The ...read more
Labour party returns to power in Britain
After 18 years of Conservative rule, British voters give the Labour Party, led by Tony Blair, a landslide victory in British parliamentary elections. In the poorest Conservative Party showing since 1832, Prime Minister John Major was rejected in favor of Scottish-born Blair, who ...read more
First-ever “Great Exhibition” opens in London
On May 1, 1851, the Great Exhibition opens to wide acclaim in the Crystal Palace in London. Inside the Crystal Palace, a giant glass-and-iron hall designed by Sir Joseph Paxton, more than 10,000 exhibitors set up eight miles of tables. Technological wonders from around the world ...read more
Empire State Building dedicated
On this day in 1931, President Herbert Hoover officially dedicates New York City’s Empire State Building, pressing a button from the White House that turns on the building’s lights. Hoover’s gesture, of course, was symbolic; while the president remained in Washington, D.C., ...read more
International Congress of Women adopts resolutions on peace, women’s suffrage
On this day in 1915 in The Hague, Netherlands, the International Congress of Women adopts its resolutions on peace and women’s suffrage. The congress, also referred to as the Women’s Peace Conference, was the result of an invitation by a Dutch women’s suffrage organization to ...read more
Adventurer and performer Calamity Jane is born
On this day, the adventurer and performer Calamity Jane is born near Princeton, Missouri. The myths and fabrications concerning the life of Calamity Jane are so numerous it is difficult to discover her true story. Legend has it that at various times Jane worked as a dishwasher ...read more
“Citizen Kane” released
Months before its release, Orson Welles’ landmark film Citizen Kane began generating such controversy that Radio City Music Hall eventually refused to show it. Instead, Citizen Kane, now revered as one of the greatest movies in history, made its debut at the smaller RKO Palace ...read more
Former NBA All-Star Jayson Williams indicted for manslaughter
On May 1, 2002, former NBA All-Star Jayson Williams was indicted on a series of charges, including aggravated manslaughter, in connection with the shooting death of limousine driver Costas Christofi at Williams’ estate on February 14. Williams enjoyed a successful NBA career with ...read more
Battle of Chancellorsville begins
On this day in 1863, the Battle of Chancellorsville begins in Virginia. Earlier in the year, General Joseph Hooker led the Army of the Potomac into Virginia to confront Robert E. Lee’s Army of Northern Virginia. Hooker had recently replaced Ambrose Burnside, who presided over the ...read more
American U-2 spy plane shot down over Soviet Union
An American U-2 spy plane is shot down while conducting espionage over the Soviet Union. The incident derailed an important summit meeting between President Dwight D. Eisenhower and Soviet leader Nikita Khrushchev that was scheduled for later that month. The U-2 spy plane was the ...read more
Ford factory workers get 40-hour week
On this day in 1926, Ford Motor Company becomes one of the first companies in America to adopt a five-day, 40-hour week for workers in its automotive factories. The policy would be extended to Ford’s office workers the following August. Henry Ford’s Detroit-based automobile ...read more
|
cc/2019-30/en_head_0021.json.gz/line27279
|
__label__wiki
| 0.78874
| 0.78874
|
Welcome to the Department of Chemical Engineering Alumni pages. Here you will find some information and resources that we hope you will find interesting. We are always keen to hear from our alumni and there a variety of methods of keeping in touch with the Department and fellow alumni. Our LinkedIn group was specifically created for alumni, students and staff of the Department, and we have also created LinkedIn groups specifically for individual year groups. You may also like to follow us on Twitter, Facebook or Instagram. You can sign up to the Departmental newsletter, contact us by email directly, or if you find yourself in London please do stop by and we'd be delighted to show you the latest developments in the Department.
Please register for a College alumni account which will allow you to access the alumni directory enabling you to contact fellow alumni, update your contact details online, set up email forwarding and access the Library.
If you require a reference from the Department please contact your former personal tutor in the first instance. If this does not evoke a response, or they are no longer available, please send an email to the address below and we will get you the support you need: chemengalumnireferences@imperial.ac.uk
Our alumni go on to do incredible things, find out what they have been up to.
Chemical Engineering Newsletter
Stay up to date with the latest developments from the Department with our Departmental e-newsletter.
Chemical Engineering Events
We host a variety of events ranging from research seminars, public talks, networking receptions, alumni events and outreach activities. We would be delighted to welcome you at any of these.
Latest alumni news
"No talking!" - memories and stories of the Class of 2016
Another year, another 120 MEng students finished ChemEng at Imperial. We interviewed six of them about their best memories and future plans. Read the interviews
Members of the Class of 1963 held a reunion in the Department on 6 October 2016. They were treated to talks from Professor Stephen Richardson (former Head of Department), Anne Barrett (College Archivist), Professor Nilay Shah (Head of Department) and had tours of the Department and Imperial West. See the photos
Judith Hackitt made a Dame
Alumna Judith Hackitt has been made a Dame in the 2016 New Year's Honours List for services to engineering and health and safety in the UK. Dame Judith currently serves as the Chair of the Health and Safety Executive which is Britain’s national regulator for workplace health and safety. She has held the Chair for the past 8 years. She also serves on the Strategic Advisory Board for the Department of Chemical Engineering at Imperial College London, where she is helping to shape the strategy of Chemical Engineering education and research through her experience and insight. Read more
Lejon Chua joins the Schwarzman Scholars
Congratulations to Lejon Chua, a recent graduate from the Department has been selected in the inaugural class of Schwarzman Scholars for a Master’s degree program at Tsinghua University in Beijing starting in August 2016. One of the most selective postgraduate programs in the world, Schwarzman Scholars is designed to prepare the next generation of global leaders. Read more
Alumni new
Hannah Moran receives Salters' Graduate Prize 2015
Hannah Moran has been awarded the 2015 Salters’ Graduate Prize in recognition of her academic achievement and her ability to make a significant contribution to the development of the UK Chemical Industry. Hannah became the fourth Imperial Chem Eng undergraduate in the last five years to receive this prestigious prize. Read more
Professor Stephen Richardson retires
We recently said farewell and congratulations to a former Head of Department (2001-08), whom many of you will have been taught by: Professor Stephen Richardson, who was also Principal of the Faculty of Engineering (2008-10) and Deputy Rector (2010-15), retired at the end 2015. He was also awarded a CBE in 2015 for Services to Chemical Engineering Education. Stephen reflected on his 40 years at the College in a nice interview on the website. You may wish to leave a message for Stephen on our Facebook page.
Marit Mohn extends PhD scholarship scheme
Alumna Mrs Marit Mohn (Chemical Engineering 1973) recently provided a generous gift to help extend our PhD scholarship scheme. A longstanding supporter of Imperial, Mrs Mohn has made a number of gifts to support education at the College, including a 2011 donation that established the Marit Mohn PhD scholarship scheme in the Department. We now award ten fully-funded Departmental PhD scholarships every year and these are open to candidates of any nationality. Find out more about our PhD scholarship scheme.
Search the full directory of staff and students
|
cc/2019-30/en_head_0021.json.gz/line27282
|
__label__wiki
| 0.937425
| 0.937425
|
Mayor Joe Hogsett's 2019 budget is an attempt to fix Indianapolis' pothole problem
The Democratic mayor derided as 'Pothole Joe' is aiming to solve the city's infrastructure problems.
Mayor Joe Hogsett's 2019 budget is an attempt to fix Indianapolis' pothole problem The Democratic mayor derided as 'Pothole Joe' is aiming to solve the city's infrastructure problems. Check out this story on IndyStar.com: https://indy.st/2MEFx0U
James Briggs, Indianapolis Star Published 1:09 p.m. ET Aug. 12, 2018 | Updated 6:00 a.m. ET Aug. 13, 2018
While potholes have been a problem across Indianapolis, the one on the Kessler Boulevard bridge that spans the White River was a particularly surprising find on search for the city's worst streets. Robert King
The city of Indianapolis has received hundreds of pothole claims this year.(Photo: Michelle Pemberton/The Star file photo)Buy Photo
Mayor Joe Hogsett will spend the weeks leading up to Indianapolis' 2019 campaign cycle trying to make progress on one of his biggest political headaches: potholes.
Hogsett on Monday is planning to introduce a budget that ratchets up investment on streets, bridges and sidewalks. The mayor wants to spend $126 million on transportation infrastructure in 2019 and more than $400 million over four years, paid for in part by bonds.
That is an increase over the $98.6 million in this year's budget, yet falls well short of $178 million, an annual spending figure that internal analysis deemed necessary to upgrade all of the city's neglected infrastructure to fair condition. The new budget would not solve Indianapolis' infrastructure problems in one year, but Hogsett administration officials view it as a step toward preventing the types of crises that arose earlier this year.
"We won't be exclusively resurfacing portions of the city that are at their worst," Thomas Cook, Hogsett's chief of staff, said. "We're going to be resurfacing portions of the city so they don't become that bad. That's, I think, a big change."
Tully: The upside of potholes
More: Mayor Joe Hogsett breaks ground on Indianapolis jail — months before council gives final OK
More: Mayor Joe Hogsett comes out in support of Rethink 65/70 coalition's vision
Hogsett's third budget advances the same priorities as his previous two: It seeks nominal spending increases for most city and county departments while pushing for major new investments in public safety and infrastructure. Like this year's budget, Hogsett is billing his 2019 spending plan as structurally balanced, though critics, including Republican Councilor Jeff Miller, took issue with that characterization last year.
Hogsett plans to emphasize his commitment to improving street repairs and maintenance in a budget address to the City-County Council on Monday. The mayor's proposed budget comes months after a winter of extreme freeze-thaw cycles that opened potholes across the city and necessitated $14.5 million in emergency funding for repairs. Republican critics, seizing on the problems, have dubbed the Democratic mayor "Pothole Joe."
Campaign season is coming
Hogsett's 2019 budget could be one of his last opportunities for a bipartisan victory before campaign season becomes all-consuming. A mix of Democrats and Republicans have signed on to be co-sponsors as the budget begins its two-month trek through the City-County Council, with final passage scheduled for Oct. 15. Both of Hogsett's previous budgets have passed by wide margins.
Hogsett has not yet said whether he will run for re-election in 2019. Michael McQuillen, the council's Republican minority leader, said he expects council and mayoral campaigns to kick off "probably right after budget season is over."
In the meantime, McQuillen said, he likes Hogsett's focus on infrastructure, including a commitment to factor in the priorities of council members across Marion County.
"I am appreciative of the fact that they're continuing to pump money into the suburbs, as well as the downtown," McQuillen said.
How to pay for it
When Hogsett took office, his administration projected the city would only have $39.6 million available for infrastructure in 2019. But Hogsett plans to use the state's 10-cent gas tax increase, which took effect last year, plus a bit of tax-increment finance maneuvering to more than triple that investment.
In addition to putting money to use from the 2017 gas tax hike, Hogsett wants to bond against the annual 1-cent increase — approved by the state legislature to occur annually through 2024 — to raise $120 million, which will be spread out over four years. That $120 million in bonding will be introduced in a separate proposal Monday.
The 20-year bonds will pay for infrastructure projects, such as concrete streets and sidewalks, which have life spans of 30 to 50 years, said Dan Parker, the city's public works director.
Indianapolis Mayor Joe Hogsett speaks during the groundbreaking ceremony for the new Community Justice Campus in the Twin Aire neighborhood of Indianapolis on Thursday, July 12, 2018. The campus will house the new jail, courthouse, Sheriff's Office, and an Assessment and Intervention Center. (Photo: Michelle Pemberton/IndyStar)
Cook said the administration settled on a modest figure that factors in unease over borrowing, as well as limitations the city would have in completing projects if it borrowed additional money.
"We could bond out $700 million worth of work next year," Cook said. "(DPW) can't do that much work. So there's also limits to the amount of roads in any given year that we're functionally able to scale up. Which is why, rather than have all of this money hit the streets in 2019, it's spread out over three or four years in order to allow that to be done in a way that's tiered and responsible from a financial and logical perspective."
Hogsett is planning to raise spending on most categories of transportation infrastructure next year. The budget includes a combined $26.8 million for bridge rehabilitation and replacement, up from $18.4 million this year; $31.4 million for streets, up from $19.3 million; and $11.5 million on curbs and sidewalks, up from $2.4 million.
The city is planning to spend $116 million on bridges over four years, a blitz that will "dig very deep into getting everything up to fair condition," Parker said.
'We can't just tax ourselves out'
To the extent that Hogsett's spending plan demonstrates progress on infrastructure, though, it also points to a dead end. Now that Indianapolis has factored the gas tax hike into long-term spending plans, there is no new revenue source on the horizon that would bring the city's infrastructure up to the standard of neighbors such as Hamilton County.
Indianapolis has more than 8,100 lane miles to maintain and receives disproportionately low returns from the state on a per-mile basis. The City-County Council is planning to address that and other issues through an infrastructure study commission, which is set to be approved Monday.
Democrat Jared Evans has pushed for the 10-person commission, which will have an even mix of Democrats and Republicans, including four council members, two state representatives, two state senators and two citizens. The members have not yet been named.
Democrat Jared Evans has pushed to create a commission to study Indianapolis' infrastructure problems. (Photo: Robert Scheer/IndyStar)
Evans proposed the commission in the midst of the city's pothole emergency earlier this year. He hopes the budget process will show state lawmakers, especially those on the commission, that Indianapolis is making good use of existing money, but needs more help.
"Indianapolis is stepping up, doing what it can do," Evans said. "We can't just tax ourselves out of this. There's no one tax that would address our infrastructure gap. So, I think there's going to be some creative discussions — I think some discussions that revolve around the (state's) infrastructure formula."
'Always a struggle at the Statehouse'
Any proposal to aid Indianapolis is going to be a tough sell. State Sen. Jim Merritt, who serves as Marion County Republican chairman and is considering a run for mayor, has said he opposes additional state money for the city. Merritt has been Hogsett's most vocal critic, releasing a torrent of statements, including a recent one that laments "our bridges are in shambles, our roads are falling apart left and right."
Merritt's position is at odds with fellow Republican McQuillen, who said "a little help from the Statehouse would certainly be appreciated."
"There's always a struggle at the Statehouse when Marion County needs something," McQuillen said. "There's always a reticence by some outside the beltway members of the Statehouse that think, 'Oh, great, Indianapolis is back for some more money.' But when you consider Indianapolis is the economic engine that drives the state, I would hope they would be a little more open to helping us with infrastructure and transportation needs."
Cook, the mayor's chief of staff, said the budget being introduced Monday should serve as "the launching point for their discussion about countywide infrastructure."
"The city of Indianapolis is serious about stretching our local dollars as far as they can go in an effort to engage in a more substantive conversation about collaboration," Cook said.
Call IndyStar reporter James Briggs at (317) 444-6307. Follow him on Twitter: @JamesEBriggs.
Read or Share this story: https://indy.st/2MEFx0U
|
cc/2019-30/en_head_0021.json.gz/line27285
|
__label__wiki
| 0.912775
| 0.912775
|
Home News Community
Church of Celebration to mark 10th year with community bash
Church of Celebration's staff has grown along wit its membership over the past 10 years. Submitted photo
It’s been a decade since Pastor Josh Barrett opened a Bible study in the young city of Maricopa.
“We just wanted to practice church,” he said. “We didn’t want to say we were a church just yet.”
A group of about 10 people, whom he calls “the launch team,” met in the Barrett home for about four months before opening the Bible study to the public. It was a gathering of about 25 in the gym of the old high school at night, the only slot they could get.
Ten years later, that little group is 1,200 strong and is called the Church of Celebration.
May 15, the church will have a 10th-anniversary celebration at Copper Sky Regional Park, and the public is invited.
“We really didn’t want to do a ton of programming on this because we just wanted to celebrate what Church of Celebration is all about, which is relationships,” Barrett said. “We are opening that celebration to the entire city.”
The church has invited city officials, former staff members and even the Maricopa Fire Department, which will be in action cooling off celebrators. There will be a water slide, inflatables, family games and food trucks, where meals are $8 for adults and $5 for kids.
At dusk, Barrett has planned a “mini-program” to talk about what Church of Celebration has done in the community for the past 10 years.
“God’s done some pretty amazing things, and he’s not done,” he said.
There will be stations where celebrators can write down what Church of Celebration has meant to them. That will be followed by a video of the church’s history.
“It’s going to be a very, very casual, relaxed atmosphere,” Barrett said. “That’s what we are – trying to be Jesus to everybody.”
Created in a partnership with Vision Arizona, Church of Celebration blossomed from relationships built from established churches in the Valley and others gained in its early existence in Maricopa.
Barrett and his wife Ginger moved to Maricopa from Springfield, Missouri, with their two sons in September 2005. He has had ministries in Colorado and Missouri. After opening the Bible Study the following January, they “practiced church” for about four months.
“Then we officially launched in May 2006, on Mother’s Day, at night,” Barrett said. “If I had to do it over again I would tell every church, ‘Don’t plan at night on Mother’s Day.’ But we just embraced what was available to us at that point in time.”
By December, the church had grown to 150 people.
“My goal from the very beginning was to come to Maricopa and make Jesus’ name more famous,” Barrett said.
By then, Maricopa Unified School District had begun building more schools. In January 2007, Church of Celebration found morning space for its services in the new Maricopa Elementary School in Alterra.
“When we went mornings, we officially started growing,” Barrett said.
What: Church of Celebration 10th Anniversary
When: May 15, 5-7:30 p.m.
Where: Copper Sky Regional Park
Info: ChurchOfCelebration.com
They started with two services and, after three months, grew to three services. In six months, the congregation was about 400 people. Less than two years later, Church of Celebration moved into more space at Maricopa Wells Middle School.
In 2011, the church moved into the Performing Arts Center at the new high school. Participation in services any given Sunday is about 1,000.
“Our partnership with the school district has been amazing,” Barrett said. “We’re extremely grateful to MUSD.”
To show that gratitude over the years, the church has offered grants for school programs and left gifts for teachers whose rooms they use. They have also hosted teacher-appreciation lunches.
Perhaps most importantly, the church started Power Pack-Copa, a nonprofit that provides weekend meals for disadvantaged elementary students by packing backpacks with food. Barrett said he heard a speaker at a conference talk about hunger in the United States.
“He said the Evangelical church of American is something like a billion-dollar industry,” Barrett recalled. “’So,’ he says, ‘somebody tell me why there are people going hungry? Why are there kids still not being fed?’ So that really moved me and bothered me.”
That led to some local research, where church leaders discovered there were more than 100 kids in Maricopa who were going home on Fridays and not eating until Monday. They worked with the county health department to determine who the kids were and began stuffing bags and taking them to the schools for distribution.
Power Pack-Copa now serves seven elementary schools every week, feeding around 250 kids.
“If you read the Bible, it’s our job,” Barrett said. “It’s our job to take care of people who may have less than us. Our church has embraced that, and it’s just been huge.”
The Barretts now have three children, all adopted. Ginger Barrett leads the Children’s Ministry, which has 250-300 kids. The youth group is comprised of about 175 teens.
Church of Celebration also has two community outreach programs. One is a summer kids camp, a modern vacation Bible school. Last year that served 500-600 kids. For the past nine years, the church has hosted Maricopa Truck or Treat, drawing 10,000-12,000 participants for a safe, fun night on Halloween.
From the beginning, leaders envisioned having a church building of their own some day.
“We know in God’s time, when he opens that door, it’ll happen,” Barrett said. “But until then it would be next to impossible to replicate what we have available to us.”
For now, Barrett and his congregation stick to the early vision of introducing more Maricopans to Jesus.
“We have the motto “Gather, grow, give and go,” he said. “There’s an importance to gather with one another, there’s an importance to grow yourself and your relationship with Jesus. Give, that’s the natural byproduct of growing. You then go and do the same.”
Church of Celebration 10th Anniversary
Church of Celebration
Josh Barrett
Church connects with community through Trunk or Treat
ACE Hardware to celebrate 10th anniversary
Pastors hope to make ‘big splash’ at youth event
|
cc/2019-30/en_head_0021.json.gz/line27289
|
__label__wiki
| 0.992666
| 0.992666
|
‘Fear The Walking Dead’: Kim Dickens Is Open To Madison’s Return
Many fans were devastated with the death of Madison Clark. So, could the character make a return?
Elizabeth Weinberg / AMC
Rachel Tsoumbakos
With the apparent demise of Madison Clark (Kim Dickens) in AMC’s Fear the Walking Dead, many fans were shocked that one of the main characters had been written out of the hit zombie apocalypse series. Even still, fans have since speculated that Madison could have actually survived this event which occurred in the Season 4 mid-season finale.
It has been previously confirmed by AMC that Madison is dead. However, her death, technically, occurred off-screen as she was shown within a stadium with a massive herd of the infected. With no dead body confirmed, many fans of Fear the Walking Dead have held on to the hope that the character could make a surprise return to the TV series.
It also appears to be something that the actress who played Madison would be open to as well. In a recent interview Kim Dickens did with MovieWeb, the star talked about the role of Madison. At first, she confirmed that Madison appeared to be dead.
“As far as I know, she’s dead,” Dickens said.
However, she then went on to explain that she would be open to the prospect of a return to Fear the Walking Dead.
“We would have to sit down and talk about it, but I love the character,” Dickens explained when asked about whether she would return to the series, even if only in a cameo or flashback role.
“I would never say no, without discussing it and seeing what they were talking about.”
Richard Foreman, Jr / AMC
Dickens also believed that there was a lot more of Madison’s story to be told, particularly with the death of her son, Nick (Frank Dillane). In Fear the Walking Dead, Madison never found out that Nick had died and Dickens feels that this could have made for wonderful character development for Madison, who had gone above and beyond in the past to help her children.
“I really feel so much of what was about that show was between mother and son and that struggle of how to really be a good parent. And there was a lot of back and forth with those characters. So, for the audience to not get to see Madison grieve that death, it hurts to not have that moment.”
While it seems unlikely that AMC will resurrect Madison’s role, as Fansided points out, if Madison were to return, not only would she find out that her son is dead, but that her daughter, Alicia (Alycia Debnam-Carey), has grown considerably as a result of the hardships she has been through. And, this would likely be a proud — and bittersweet — moment for Madison.
Season 5 of AMC’s Fear the Walking Dead will premiere on June 2 at 9 p.m.
|
cc/2019-30/en_head_0021.json.gz/line27291
|
__label__cc
| 0.53279
| 0.46721
|
Junior League of Edmonton
About the Junior League
2018 New Member of the Year Award!
By Samantha Parker
The New Member of the Year Award was established in 2015 to recognize a New Member who has a strong desire to volunteer, the willingness to devote her time to our projects as well as training and planning meetings, and is motivated to develop her own potential. In addition to showcasing creativity and enthusiasm in the planning of her new member project, this member shares our commitment to voluntarism and is eager to explore new opportunities for growth in the Junior League of Edmonton.
Congratulations to our New Member of the Year Award winner Adrianna MacPherson!
“I had the pleasure of working with Adrianna on the Social media side of the International Women’s Day new member project. She is organized, detailed, on time and well spoken. Adrianna has been and will continue to be a great new asset to the Junior League family.” -Samantha Parker, Internal Communications Chair
How long have you been a JLE member?
I’ve been a JLE member for a little under a year — I was part of the Fall 2017 class.
What does it mean to you to receive this award?
It’s a complete honour. I think it’s so easy to get wrapped up in your busy schedule, but I really try to make it a priority to give back and have a positive impact on the community, so it was touching to see that effort recognized.
What is your favorite memory in your time being with the League?
I really enjoyed the process of planning our new member project for International Women’s Day. It was a great introduction to the structure of the League and how things worked, and I really loved that Embrace was the film we ended up picking to screen. Body positivity/self-esteem are such important topics, and it was a great way to tie into our focus area of girls’ self-esteem.
What is one thing that everyone can do to improve the climate for Junior League internationally?
I think just bringing awareness to the organization and what it does. As we discussed in our latest retreat, name recognition for the League varies according to where you are in the world, and I think that just being clear on what League members do and what the organization is all about is key.
Do you have any advice for new or active JLE member?
My one piece of advice would be that you really do get what you put in. There are plenty of organizations out there that are a great fit if you’re just looking to volunteer for an afternoon or a weekend. Junior League is special because there are just so many opportunities to learn and grow, and I think that really taking advantage of all that, giving your all to your placement position, and even participating in social events and just getting to know your fellow members, is important.
What or who inspires you and why?
This may be a bit too general, but I’m truly inspired by all the amazing women out there, in the League, in the community, and around the world. I will never tire of hearing the stories, whether in articles or on podcasts or in person, of women who are just fearless and ferocious and determined to change the world.
Congratulations Adrianna on your award, you really deserve it. 🙂
10447 86 Avenue NW
Edmonton, AB T6E 2M4
© 2019 Junior League of Edmonton.
|
cc/2019-30/en_head_0021.json.gz/line27298
|
__label__wiki
| 0.889226
| 0.889226
|
Black-and-white version
Decision-making game
Films on the Topic
Glossary - C
Carinhall
Beginning in 1936, Göring began turning his hunting lodge in the Schorfheide region north of Berlin into a baronial estate, which he called "Waldhof Carinhall" (Carinhall Forest Estate). He had a 34-meter long hall created, the so-called "Great Gallery," where he displayed the most important works of art in his collection.
Central Art Collecting Point (CCP)
"Collecting Points" were what the United States Armed Forces called the places where artworks from storage facilities of looted art discovered in 1945 were registered, photographed, and restored. The most important Collecting Point was the Central Art Collecting Point in Munich.
The holdings of the "Führer Museum," Hermann Göring's collection, as well as the collections looted by the "Einsatzstab Reichsleiter Rosenberg" were stored here. Artworks from formerly occupied countries were restituted to these states with the proviso that they be returned to their original owners. Cultural assets confiscated by the National Socialists from German Jews were, in case they could be found, either returned to the former owners or their heirs.
Overall artworks from more than 600 German and Austrian storage sites were sent to the Collecting Point in Munich. The Americans handed their responsibility over to the German authorities in September 1949. Approximately 700,000 cultural assets were restituted between 1945 and 1951.
The Collecting Point began its operations on June 17, 1945. After which, truck convoys delivered crates containing paintings, sculptures, furniture and decorative arts. The building had to be closely guarded to protect the valuable artworks.
"Sonderauftrag Linz" ("Special Mission")
"Einsatzstab Reichsleiter Rosenberg"
Morris Raphael Cohen (1880-1947)
In addition to Salo W. Baron, the American philosopher and law professor Morris Raphael Cohen was also a founder of the CEJCR as well as the JCR. Their small staff drew up an overview of the Jewish cultural landscape in Europe before the war and made plans for reconstruction.
Nachfolgeorganisationen
Commission on European Jewish Cultural Reconstruction
Jewish Restitution Successor Organization
Jewish Cultural Reconstruction
Salo W. Baron
Commission de Récupération Artistique (CRA)
In September 1944, the Commission de Récupération Artistique, the French Restitution Commission, was established. During the occupation period in Germany, the French Restitution Commission published a ten-volume listing of all goods looted in France. The volumes dealing with artworks served the purpose of informing museums and galleries. They were primarily distributed in Germany, Austria and France.
Commission on European Jewish Cultural Reconstruction (CEJRC)
Salo W. Baron and Morris Cohen founded the successor organization CEJRC in 1944. Equipped with a small staff, its job was to make preparations for the possible reconstruction of Jewish cultural life in Europe after the war.
Morris Raphael Cohen
|
cc/2019-30/en_head_0021.json.gz/line27299
|
__label__cc
| 0.663059
| 0.336941
|
Swaythling Club
World champion in Beijing, Georgeta Pitica passes away
It is will great sadness that the Romanian Swaythling Club advises the death of Georgeta Pitica.
Born in 1930, she passed away quietly on Saturday 13th October, she was 88 years old.
Georgeta Pitica, sadly missed (Photo: courtesy of Beatrice Romanescu)
by Ian Marshall, Editor
The peak of her career was in the early 1960s, an era when the formula for the Women’s Team event was four singles and one doubles, two players per team but often a third being introduced for the doubles. At the 1961 World Championships in Beijing, partnering Maria Alexandru, Georgeta Pitica secured Women’s Team bronze prior clinching Women’s Doubles gold.
Notably, in the Women’s Team competition they experienced a three-two defeat at the hands of China’s Sun Meiying, Chiu Chunghei and Hu Keming; notably they won the doubles overcoming Chiu Chunghei and Hu Keming. Later, in the Women’s Doubles competition, they beat Hu Keming and Wang Chien in the semi-final prior to securing the title at the hands of Chiu Chunghei and Sun Meiying.
Success in Beijing, two years later in 1963 when the tournament was held in Prague, there was a further medal for Georgeta Pitica; lining alongside Ella Constantinescu (the former Ella Zeller) and once again Maria Alexandru, the outfit secured Women’s Doubles silver. They were beaten in the final by Japan’s Kimiyo Matsuzaki and Masako Seki.
Notably, as a result of her outstanding performances, in 1961 Georgeta Pitica was awarded the Romanian Grand Master of Sports title and the Order of Merit for Labour Class II. In 2000, she received Romania’s National Medal for Merit Grade III.
Thoughtfully on hearing the news, Beatrice Romanescu, the Director of Public Relations and Marketing for the Romanian Table Tennis Federation spoke to Madalina, Georgeta Pitica’s daughter.
“There must have been an angel up there making sure her passage would be without suffering,” Madalina.
“Few athletes have touched our hearts to the extent that Mrs Geta did. The Romanian Table Tennis Federation and the Swaythling Club Romania send their condolences to Georgeta Pitica’s family. God rest her beautiful soul!” Beatrice Romanescu
We all echo those words; our thoughts are with Romania, with the family of Georgeta Pitica.
Swaythling Club Georgeta Pitica
Almost one year to go; entries closed for Bordeaux
15 Jul 2019 Swaythling Club
Jeff Ingber, one the earliest junior internationals passes away
Bordeaux set to break all records?
The stalwart defender, Igor Solopov passes away
15 Jun 2019 Swaythling Club
|
cc/2019-30/en_head_0021.json.gz/line27301
|
__label__wiki
| 0.551557
| 0.551557
|
Handguns /
Taurus 1911PBL
The Taurus 1911PBL is, as it should be, a true 1911 in that it is a single-action, semi-automatic, short-recoil operated pistol chambered for the powerful .45 ACP cartridge. Boasting a fresh take on the iconic design introduced by John Moses Browning more than 100 years ago, the Taurus 1911PBL is just one in a new series that represents Taurus International's first take on the platform. In addition to a number of features that are both modern and practical, the Taurus 1911PBL ships with two eight-round magazines inside of a hard plastic carrying case.
SKU: 191101PBL
Taurus International Manufacturing, Inc. has quite the interesting history. It began in 1939, when a small tool and die company was founded in Porto Alegre, Brazil. The company began by producing small tools designed for use with various manufacturing processes. In the years that followed, the company branched out to include divisions focused on metals manufacturing, plastics, body armor and, most importantly, firearms. That company is Forjas Taurus, what we commonly refer to as Taurus International.
Since its inception, Taurus International has had ties to both Smith & Wesson and Beretta, which allowed the company access to information related to the design, manufacture and tooling of some of the world's most popular firearm platforms – including Beretta's 92 series. Since then the company has learned a thing or two about arms production and is now one of the largest manufacturers of small arms in the world.
Today, Taurus International offers a wide range of products, from revolvers to both steel- and polymer-framed pistols. The company now seeks to bolster their lineup with their new Taurus 1911 Series, a series of pistols with designs that are based on the crisp action provided by the legendary single-action design originally exhibited in John Browning's M1911. The Taurus 1911 Series is no run-of-the-mill 1911 platform. Each pistol, including the new Taurus 1911PBL, is jam packed with practical features that make it truly worth your consideration.
With the design of their new 1911 Series, Taurus International sought to produce a 1911 that held the potential to eventually become the standard against which all others are measured. By producing the pistol with hammer-forged frames, slides and barrels and hand-fitting and tuning each with 19 standard features, Taurus International has crafted a high-quality 1911 – what they are calling "an unbeatable gun that is also an unbeatable value".
The Taurus 1911PBL features a five-inch, hammer-forged stainless steel barrel and an overall length of 8 1/2 inches. The hammer-forged steel frame and slide both feature a blued finish to protect the components from rust and corrosion, and are joined by black polymer grips for a pistol that weighs in at a hefty yet manageable 38 ounces. Interesting is the fact that the Taurus 1911PBL also includes the Taurus Security System, an integral locking system designed to provide the pistol with enhanced security. Other features include: a ventilated trigger, the iconic beavertail grip safety, an ambidextrous manual thumb safety and a Heinie® front sight alongside Straight-8® rear sights. As noted, each pistol includes two eight-round magazines for an "8+1" capacity.
Best of all, the Taurus 1911PBL comes with the Taurus Unlimited Lifetime Repair Policy. Taurus International has pledged to repair, free of charge, any firearm manufactured or imported by the company. For details, visit the official website of Taurus International.
Taurus 709 Slim
Taurus Millennium PRO .40 S&W
Taurus 738 TCP
Taurus 1911B-1
Taurus 1911SS-1
Taurus Ultra-Lite Model 85
Taurus Ultra-Lite Model 85 (Blued)
Taurus Model 85s
|
cc/2019-30/en_head_0021.json.gz/line27304
|
__label__wiki
| 0.98388
| 0.98388
|
George glad the 'genius' that is Farrell leading England
International / 12 February 2019, 06:55am / Julian Guyer
England captain Owen Farrell celebrates after scoring a try during the match against France at Twickenham. Photo: EPA/Will Oliver
TWICKENHAM – England captain Owen Farrell is a rugby “genius” whose game is thriving with the extra responsibility of leadership, according to team-mate Jamie George.
Fly-half Farrell pulled the strings superbly as England thrashed France 44-8 at Twickenham on Sunday to make it two wins out of two this Six Nations and leave them well-placed for a potential Championship decider against a similarly unbeaten Wales in Cardiff next time out on February 23.
Jonny May ran in a hat-trick of tries inside the opening half hour, with England scoring six in total as they recorded their biggest win over France since 1911.
But while the dashing May was the headline act, the excellent tactical kicking on show from the likes of Farrell, a try-scorer himself against the French, helped create the opportunities that led to the wing's treble.
An England co-captain with Dylan Hartley during the November internationals, the hooker's injury-enforced absence has now seen Farrell take sole charge.
'Never has a bad game'
George, now England's undisputed starting hooker and a Saracens team-mate of Farrell was in no doubt of the stand-off's quality, saying: “The bloke's a genius. I never see him have a bad game and that's why he's one of the best players in the world, if not the best player in the world.
“In my eyes, it's amazing to be playing with a fly-half and captain who is as dominant as he is and who leads from the front in the way that he does.
“Owen's been a captain and leader for a long time now. It's not a new thing for us but he does it really well and it brings the best out of him in terms of his game. He's performing really well.”
Owen Farrell scores a try during the match against Australia at Twickenham in November 2018. Photo: EPA/Neil Hall
But George insisted England, set to play France again in a pool match at this year's World Cup in Japan, still had room for improvement ahead of their showdown with Wales.
“We have to be aware that we did well against France but recognise that it wasn't the perfect performance,” he said. “An exciting thing for us is there's still a lot to come. The important thing for us is to keep the ball rolling.”
England ran in four tries alone in the opening 40 minutes against France, with centre Henry Slade adding to May's treble just before the interval.
“If you're 30-8 up against France at half time you are doing something right,” said England scrum-half Ben Youngs after a win that followed a convincing 32-20 first-round victory away to Six Nations champions Ireland.
But with Wales having launched their tile challenge by defeating France and Italy, Youngs was not taking anything for granted ahead of England's visit to the Principality Stadium.
“Wales have had a good run. We are going to embrace and enjoy the big two-week build-up,” Youngs said.
“This is what the Championship is about - it always comes down to certain games.
“France was a Championship decider, the same in a fortnight's time. We will take every game as it comes but certainly, this one is hugely exciting.”
Agence France-Presse (AFP)
|
cc/2019-30/en_head_0021.json.gz/line27308
|
__label__wiki
| 0.674793
| 0.674793
|
Internal Revenue Bulletin: 2007-10
Highlights of This Issue
TAX CONVENTIONS
The IRS Mission
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
T.D. 9311
Rev. Rul. 2007-10
Part II. Treaties and Tax Legislation
Announcement 2007-23
Part III. Administrative, Procedural, and Miscellaneous
Rev. Proc. 2007-22
Part IV. Items of General Interest
REG-147144-06
Definition of Terms and Abbreviations
Numerical Finding List
Effect of Current Actions on Previously Published Items
Finding List of Current Actions on Previously Published Items
How to get the Internal Revenue Bulletin
INTERNAL REVENUE BULLETIN
CUMULATIVE BULLETINS
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
INTERNAL REVENUE BULLETINS ON CD-ROM
We Welcome Comments About the Internal Revenue Bulletin
These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
Announcement 2007-28 Announcement 2007-28
This document contains a copy of the news release issued by the Office of the Deputy Commissioner, International, on February 13, 2007, extending the deadline to March 30, 2007 for the settlement offered to certain foreign embassy staff.
Rev. Rul. 2007-10 Rev. Rul. 2007-10
Insurance companies; interest rate tables. Prevailing state assumed interest rates are provided for the determination of reserves under section 807 of the Code for contracts issued in 2006 and 2007. Rev. Rul. 92-19 supplemented in part.
T.D. 9311 T.D. 9311
Final, temporary, and proposed regulations under section 367(a) of the Code provide rules for entering into gain recognition agreements. The regulations clarify the effect that various transactions have on existing gain recognition agreements. Final regulations update certain cross-references in current regulations.
REG-147144-06 REG-147144-06
Notice 2007-22 Notice 2007-22
This notice provides guidance on rollovers from health Flexible Spending Arrangements (health FSAs) and Health Reimbursement Arrangements (HRAs) to Health Savings Accounts (HSAs) under amendments to the Code by section 302 of the Health Opportunity Patient Empowerment Act of 2006 included in the Tax Relief and Health Care Act of 2006. Notices 2002-45 and 2005-86 modified. Rev. Ruls. 69-141, 2002-41, 2003-102, 2005-24, and 2006-36 modified.
Rev. Proc. 2007-23 Rev. Proc. 2007-23
This procedure provides administrative guidance permitting the use of a “Net Consideration Method” of accounting for certain patent cross licensing arrangements. Under the method, only cash and other non-patent-right consideration are taken into account for withholding and capitalization purposes. The procedure also requests comments on the types of arrangements that should be covered by the method.
This announcement notifies Archer MSA trustees and custodians of the obligation to report the number of Archer MSAs established between (1) January 1, 2005, and June 30, 2005, and (2) January 1, 2006, and June 30, 2006.
The United States and the United Kingdom of Great Britain and Northern Ireland (on behalf of the Bailiwick of Jersey) have exchanged diplomatic notes evidencing an agreement for the reciprocal exemption of income from the international operation of ships for taxable years beginning on or after January 1, 1997.
This procedure modifies the payment procedures for user fees applicable to the processing of Form 8802, Application for United States Residency Certification, to allow for the electronic payment of such fees effective April 2, 2007. Rev. Proc. 2006-35 modified.
This document contains corrections to final and temporary regulations (T.D. 9303, 2007-5 I.R.B. 379) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) of the Code.
This document contains corrections to proposed regulations by cross-reference to temporary regulations (REG-125632-06, 2007-5 I.R.B. 415) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) of the Code.
Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).
Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.
Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations
26 CFR Parts 1 and 602
Internal Revenue Service (IRS), Treasury.
Final and temporary regulations.
This document contains final and temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. The final regulations are necessary to update cross-references in the current regulations. The temporary regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of these temporary regulations also serves as the text of the proposed regulations (REG-147144-06) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Bulletin.
Effective Date: These regulations are effective February 5, 2007.
Applicability Dates: For dates of applicability, see §§1.367(a)-3T(f) and 1.367(a)-8T(h).
Send submissions to: CC:PA:LPD:PR (REG-147144-06), room 5203, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-147144-06), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC, or sent electronically, via the IRS Internet site at www.irs.gov/regs or via the Federal eRulemaking Portal at www.regulations.gov (IRS REG-147144-06).
Daniel McCall, (202) 622-3860 (not a toll-free number).
Paperwork Reduction Act
These temporary regulations are being issued without prior notice and public procedure pursuant to the Administrative Procedure Act (5 U.S.C. 553). For this reason, the collections of information contained in these regulations have been reviewed and pending receipt and evaluation of public comments, approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)) under control number 1545-2056. Response to these collections of information is mandatory.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information, unless the collection of information displays a valid control number.
For further information concerning this collection of information, and where to submit comments on the collection of information and the accuracy of the estimated burden, and suggestions for reducing the burden, please refer to the preamble to the cross-referencing notice of proposed rulemaking (REG-147144-06) published elsewhere in this issue of the Bulletin.
Books and records relating to these collections of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.
Section 367(a)(1) provides that if, in connection with any exchange described in section 332, 351, 354, 356, or 361, a United States person (U.S. transferor) transfers property to a foreign corporation (transferee foreign corporation), such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a corporation. Section 367(a)(2), (3) and (6) provides exceptions to this general rule and grants regulatory authority to provide additional exceptions and to limit the statutory exceptions.
Exceptions to the general rule of section 367(a)(1) for certain transfers by a U.S. transferor of the stock or securities of a corporation (transferred corporation) to a transferee foreign corporation are provided in §1.367(a)-3 (initial transfer). In some cases, these exceptions require, among other things, that the U.S. transferor file a gain recognition agreement (GRA), as provided in §1.367(a)-8. Section 1.367(a)-3(b)(1)(ii) and (c)(1)(iii)(B). Pursuant to a GRA, the U.S. transferor agrees, among other things, to include in income the gain realized, but not recognized, on the initial transfer of the stock or securities, and pay any applicable interest, upon certain events (triggering events) that occur before the close of the fifth full taxable year following the year of the initial transfer. Section 1.367(a)-8(b)(1)(iii) and (3)(i).
Section 1.367(a)-8(e)(1) and (2) provides that dispositions of the stock or securities of the transferred corporation are generally triggering events. Similarly, §1.367(a)-8(e)(3) provides that dispositions of substantially all (within the meaning of section 368(a)(1)(C)) of the assets of the transferred corporation are generally treated as deemed dispositions of the stock or securities of the transferred corporation and therefore are also triggering events. Finally, dispositions of stock of the transferee foreign corporation can also be triggering events. See §1.367(a)-8(f)(2)(ii).
Notwithstanding these rules, §1.367(a)-8 provides that various nonrecognition transactions are not triggering events if certain requirements are satisfied. For example, §1.367(a)-8(g) provides exceptions for certain transactions involving the U.S. transferor, the transferee foreign corporation, and the transferred corporation. Although these exceptions clearly contemplate some nonrecognition transactions, the current regulations are unclear whether, and if so how, the exceptions apply to various asset reorganizations involving section 361 exchanges by the U.S. transferor, the transferee foreign corporation, and the transferred corporation.
Section 1.367(a)-8 also provides that certain nonrecognition transactions are not triggering events because the GRA is terminated without further effect. For example, §1.367(a)-8(h)(3) lists certain nonrecognition transactions that terminate the GRA, provided that immediately after the transaction the basis in the transferred stock is not greater than the U.S. transferor’s basis in the stock that, immediately before the initial transfer, necessitated the GRA.
On September 28, 2005, the IRS and the Treasury Department issued Notice 2005-74, 2005-2 C.B. 726, see §601.601(d)(2), which announced the intention to amend the regulations under section 367(a) to address the effect on GRAs of certain asset reorganizations involving the U.S. transferor, the transferee foreign corporation, and the transferred corporation. The notice was issued in response to comments that the current regulations do not adequately address various asset reorganizations involving the U.S. transferor, the transferee foreign corporation, and the transferred corporation. Notice 2005-74 addressed the most common of these reorganizations and requested comments on other transactions (for example, certain upstream and downstream reorganizations).
Notice 2005-74 generally provided that, if particular requirements are satisfied, certain asset reorganizations of the U.S. transferor, the transferee foreign corporation, or the transferred corporation will not constitute triggering events. A key premise of the notice was that the covered transactions involved situations where the ability to collect tax is sufficiently preserved in the event of a subsequent trigger of the GRA (that is, the obligor under the GRA remains unchanged as a result of the asset reorganization). In light of taxpayer comments and further study, however, the IRS and Treasury Department have determined that there are additional instances where the ability to collect tax after these asset reorganizations and certain other nonrecognition transactions (as defined in section 7701(a)(45)) is sufficiently preserved so that these transactions also should not constitute a triggering event if particular requirements are met. The IRS and Treasury Department also have concluded that other portions of the current section 367(a) regulations addressing GRAs should be revised.
Explanation of Provisions
A. Overview
The temporary regulations adopt the rules announced in Notice 2005-74, with a number of modifications discussed below. Notice 2005-74 only provided guidance on a particular range of transactions, namely certain asset reorganizations, that are insufficiently addressed in the current regulations. The temporary regulations respond to comments and provide guidance on the effect on GRAs of transactions that are not addressed in the current regulation or Notice 2005-74. The temporary regulations also make additional changes to the existing regulations. For example, the temporary regulations modify and clarify procedural requirements attendant to entering into GRAs. Finally, the temporary regulations reorganize the current regulation so that distinct paragraphs address triggering events, exceptions to triggering events, and events that terminate a GRA. The IRS and Treasury Department continue to consider issuing additional public guidance that further revises §1.367(a)-8.
B. Effect of Certain Asset Reorganizations and Nontaxable Liquidations on Gain Recognition Agreements
1. Transfers of transferee foreign corporation stock by U.S. transferor
a) Asset reorganizations
Notice 2005-74 provided that if, in a section 361 transaction, a U.S. transferor transfers all or a portion of the stock or securities of the transferee foreign corporation to an acquiring domestic corporation (successor U.S. transferor) pursuant to certain asset reorganizations, the exchanges made pursuant to the asset reorganization will trigger the gain recognition agreement, unless various conditions are satisfied. These conditions are: (1) the U.S. transferor must have been a member of a consolidated group (original consolidated group) at the time of the initial transfer and the common parent of such group (original common parent) entered into the original GRA; (2) immediately after the asset reorganization, the successor U.S. transferor is a member of the original consolidated group (consolidation continuity requirement); and (3) the original common parent enters into a new GRA with respect to the transfer subject to the original GRA, modified by substituting the successor U.S. transferor for the original U.S. transferor. A notice of the asset reorganization also must be provided with the successor U.S. transferor’s next annual certification.
For this purpose, an asset reorganization is defined as a reorganization described in section 368(a)(1) involving the transfer of assets by a corporation to another corporation pursuant to section 361, except that such term shall include reorganizations described in section 368(a)(1)(D) or (G) only if the requirements of section 354(b)(1)(A) and (B) are met.
The IRS and Treasury Department received several comments that the consolidation continuity requirement was unduly restrictive because it focused on maintaining the same obligor for a GRA following the asset reorganization. Commentators asserted that an equal or better ability to collect the tax due as a result of a triggering event subsequent to such a reorganization may be preserved in certain instances where the consolidation continuity requirement would not be satisfied. However, these same commentators noted that if there were no consolidation continuity requirement, such that a U.S. transferor that is a member of a consolidated group at the time of the initial transfer could be acquired in a later asset reorganization by a corporation (successor corporation) that is not a member of such group without triggering the GRA, the actions of the successor corporation could inappropriately affect the liability of the original consolidated group under the GRA. As a result, the commentators requested that the consolidation continuity requirement be curtailed or eliminated, while at the same time not inappropriately exposing the original consolidated group to the liabilities arising from the actions of the successor corporation.
The IRS and Treasury Department generally agree with these views. Therefore, the temporary regulations eliminate the consolidation continuity requirement and address concerns about the liability of a consolidated group that disposes of a U.S. transferor subject to a GRA.
Specifically, the temporary regulations provide that when a U.S. transferor transfers all or a portion of the stock of the transferee foreign corporation to an acquiring corporation in an asset reorganization, the exchanges made pursuant to the reorganization will not be triggering events and the GRA will terminate without further effect, but only if certain requirements are satisfied. These requirements ensure that the ability to collect tax is sufficiently preserved and that the terms of the GRA are administrable.
First, the acquiring corporation (successor U.S. transferor) must be a domestic corporation, and the successor U.S. transferor or the common parent of the consolidated group of which the successor U.S. transferor is a member (as applicable) must enter into a new GRA to recognize gain with respect to the initial transfer during the remaining term of the original GRA (with certain modifications).
Second, with its next certification, the successor U.S. transferor must provide to the IRS the new GRA, notice of the transaction, and Form 8838 (Consent To Extend the Time To Assess Tax Under Section 367 - Gain Recognition Agreement) to extend the period of assessment of tax on the initial transfer.
Third, unless the successor U.S. transferor is a member of the same consolidated group of which the U.S. transferor was a member immediately before the asset reorganization, the person entering into the new GRA must elect that, if the new GRA is triggered in whole or in part, the person will include the required amount in the year of the triggering event (as opposed to the year of the initial transfer). Requiring an inclusion in these circumstances only in the year of a subsequent triggering event when the U.S. transferor is no longer owned by the same consolidated group is necessary, among other reasons, because the successor U.S. transferor may not have existed in the year of the initial transfer. In such a case, the successor U.S. transferor would not be able to amend a return for the year of the initial transfer to include any tax due as a result of a subsequent triggering event. Moreover, the requirement is appropriate even if the successor U.S. transferor did exist in the year of the initial transfer because its tax year for the year of the initial transfer may be closed. In sum, this requirement assures the GRA rules are administrable and that the ability to collect tax is sufficiently preserved. If these requirements are met, the original GRA will terminate without further effect.
The IRS and Treasury Department have decided to eliminate the consolidation continuity requirement because these three requirements adequately address the government’s concern in this area by, among other things, preserving the ability to collect the tax due as a result of a triggering event subsequent to a covered asset reorganization. In many asset reorganizations, the successor U.S. transferor will have an equal or greater ability to pay the tax due in the case of a subsequent triggering event than would the original U.S. transferor. Furthermore, the current regulations generally do not impose any financial or other requirements on the ability of a U.S. transferor to enter into a GRA. But see §1.367(a)-8(d) (imposing a security requirement in certain situations). Consequently, the IRS and Treasury Department believe that even if in some circumstances an acquisition of a U.S. transferor may affect the ability to collect the tax due as a result of a subsequent triggering event (for example, the U.S. transferor is acquired from a consolidated group by another consolidated group whose value is less than that of the original consolidated group), the requirements above nonetheless sufficiently preserve the ability to collect the tax that would be due if the new GRA were triggered and ensure that the terms of the GRA are administrable.
As described in this section, the temporary regulations require that the acquirer be a domestic corporation because, among other reasons, the IRS and Treasury Department are concerned that if a foreign acquirer is allowed to enter into a new GRA, it may be difficult for the IRS to collect any tax due in the event of a subsequent trigger of the GRA. However, the IRS and Treasury Department continue to study whether it would be appropriate to allow a domestic corporate shareholder of the U.S. transferor to enter into a new GRA when a U.S. transferor is acquired by a foreign corporation in an asset reorganization under conditions similar to those provided in §1.367(a)-3T(e). The IRS and Treasury Department welcome more detailed comments on specific approaches that could extend these rules to foreign acquisitions of the U.S. transferor.
b) Nontaxable liquidations
The current regulations provide that, if a corporate U.S. transferor liquidates in a transaction that qualifies under sections 332 and 337, the GRA is triggered unless (1) the U.S. transferor filed a consolidated income tax return with a U.S. parent corporation both in the year of the initial transfer and the year of the liquidation, and (2) the common parent enters into a new GRA, with certain modifications. Section 1.367(a)-8(f)(2)(ii).
The temporary regulations provide a similar rule. However, the temporary regulations eliminate the consolidation continuity requirement, so the U.S. transferor is no longer required to be a member of the same consolidated group in the year of the initial transfer and the year of the liquidation. Consequently, the temporary regulations provide that where a U.S. transferor disposes of the stock of the foreign transferee corporation in a liquidation that qualifies under sections 332 and 337, the disposition will not constitute a triggering event provided that: (1) the distributee (successor U.S. transferor) is a domestic corporation described in section 332(b)(1); (2) the successor U.S. transferor or, if the successor U.S. transferor is a member of a consolidated group, the common parent of the successor U.S. transferor’s group, enters into a new GRA covering the remaining term of the original GRA (with certain modifications); (3) where the successor U.S. transferor is not a member of the original consolidated group immediately after the liquidation, the person entering into the GRA agrees that if there is a subsequent triggering event, the taxpayer will recognize the gain in the year of the triggering event (as opposed to the year of the initial transfer); and (4) the successor U.S. transferor provides, with its next annual certification, Form 8838 to extend the period of assessment of the tax on the initial transfer. If these conditions are satisfied, the original GRA will terminate without further effect.
For reasons similar to those discussed above in the context of asset reorganizations involving the U.S. transferor, the IRS and Treasury Department believe that the temporary regulations sufficiently address the government’s concerns in this area, including preserving the ability to collect tax due as a result of a subsequent triggering event. As a result, it is not necessary for the U.S. transferor to be a member of the same consolidated group in the year of the transfer and the year of the liquidation. In addition, the IRS and Treasury Department believe that it is appropriate to require an inclusion in the year of a subsequent triggering event if the successor U.S. transferor was not a member of a consolidated group with the U.S. transferor immediately before the liquidation for reasons similar to those discussed regarding asset reorganizations involving the U.S. transferor.
2. Transfers of transferred corporation stock or securities by transferee foreign corporation in an asset reorganization
Notice 2005-74 provided that if, in a section 361 transaction, a transferee foreign corporation transfers stock or securities of a transferred corporation to a foreign acquiring corporation in an asset reorganization, the exchanges made pursuant to the reorganization will be a triggering event, unless certain conditions are met. These conditions require that the U.S. transferor, common parent, or new common parent corporation, as applicable, enter into a new GRA, with certain modifications. In addition, the U.S. transferor also is required to provide the new GRA and a notice of the asset reorganization with its next annual certification.
For purposes of this rule, Notice 2005-74 retained the same definition of asset reorganization as used for the provision dealing with transfers of transferee corporation stock, with certain modifications. Specifically, Notice 2005-74 excludes the following asset reorganizations: (1) triangular asset reorganizations described in §1.358-6(b); and (2) asset reorganizations where, after the reorganization, the same corporation is both the transferee foreign corporation (or successor transferee foreign corporation, as applicable) and the transferred corporation (or the successor transferred corporation, as applicable).
The temporary regulations generally incorporate these rules and provide that if the above conditions are satisfied the original GRA will terminate without further effect. However, even if these conditions are satisfied, the temporary regulations provide specific gain recognition rules if the transferee foreign corporation transfers stock or securities of the transferred corporation in an asset reorganization and the U.S. transferor recognizes gain under section 356(a)(1). See section C of this preamble.
As noted in this preamble, Notice 2005-74 excluded from the definition of the term asset reorganization any triangular asset reorganizations of the transferee foreign corporation and transferred corporation and certain upstream and downstream reorganizations. In response to comments and upon further study by the IRS and Treasury Department, the temporary regulations address the treatment of triangular asset reorganizations of the transferee foreign corporation and certain upstream and downstream reorganizations. See sections G and H of this preamble.
3. Transfers of substantially all of a transferred corporation’s assets
Notice 2005-74 provides that if a transferred corporation transfers substantially all its assets in an asset reorganization, the exchanges made pursuant to the reorganization will be a triggering event, unless certain conditions are met. These conditions require that the U.S. transferor, U.S. parent corporation or new U.S. parent corporation, as applicable, enters into a new GRA, with certain modifications. The U.S. transferor also is required to provide the new GRA and the notice of the asset reorganization with its next annual certification. The definition of asset reorganization is the same as that used in asset reorganizations involving the transferee foreign corporation.
The temporary regulations generally incorporate these rules and provide that if these conditions are met, the original GRA will terminate without further effect. However, even if these conditions are satisfied, the temporary regulations provide specific gain recognition rules (described in section C of this preamble) if the transferred corporation transfers substantially all of its assets in an asset reorganization and the transferee foreign corporation recognizes gain under section 356(a)(1). In addition, although the definition of asset reorganization excludes triangular asset reorganizations and downstream mergers of the transferee foreign corporation, the temporary regulations address the tax treatment of these transactions. See sections G and H of this preamble.
C. Special Rules Regarding Nonrecognition Transactions Involving Money or Other Property
The current regulations provide that certain nonrecognition transactions are not triggering events if particular requirements are satisfied. However, commentators have stated that the current regulations provide that certain nonrecognition transactions at the transferee foreign corporation or transferred corporation level in which any money or other property (as described in sections 351(b) or 356(a)) is received in exchange are triggering events without exception. These commentators assert that it is not appropriate to trigger an entire GRA as a result of receiving a relatively minor amount of “boot” in the nonrecognition transaction. These commentators also note that the current regulations do not address clearly the treatment of transfers of transferee foreign corporation stock by a U.S. transferor in a nonrecognition transaction in which the U.S. transferor receives boot.
The IRS and Treasury Department agree that the receipt of boot under section 351(b) or 356(a)(1) in connection with the disposition of transferred corporation stock or securities, or substantially all of a transferred corporation’s assets, should not automatically trigger all the gain under a GRA. Accordingly, the temporary regulations provide that if certain conditions are met, the entire GRA will not be triggered when a transferee foreign corporation disposes of transferred corporation stock or securities in a nonrecognition transaction simply because the transferee foreign corporation receives boot.
However, the IRS and Treasury Department believe that the GRA should be triggered to the extent that gain would be recognized in such a transaction by a transferee foreign corporation or a transferred corporation, before taking into account basis increases that may apply to the stock or securities disposed of as a result of triggering the GRA. The current, as well as the temporary regulations, provide that if a U.S. transferor is required to recognize gain because of a triggering event, then certain basis increases are allowed as of the date of the initial transfer. Therefore, in determining the amount of gain that is recognized under the GRA in such a transaction, the temporary regulations provide that the U.S. transferor first must recognize that amount of gain that the transferee foreign corporation or transferred corporation would have recognized under 351(b) or 356(a)(1), before taking into account the basis increases that are allowed under the regulations as of the date of the initial transfer. Second, if the U.S. transferor has not recognized all the gain realized, but not recognized, on the initial transfer, then its new GRA will reflect any remaining unrecognized gain on the initial transfer. Third, after the consequences of the transaction are determined under the temporary regulations, then the taxpayer must determine the amount of gain, if any, that the transferee foreign corporation or transferred corporation must recognize under 351(b) or 356(a)(1). In determining the amount to be recognized, the basis of the stock disposed of shall reflect the basis increase allowed as a result of the gain recognized under the GRA by the U.S. transferor.
This special rule limiting recognition of gain in otherwise nonrecognition transactions involving boot applies only if the U.S. transferor complies with the otherwise applicable requirements of the exception to recognizing all of the gain subject to the GRA when there is a triggering event. This special rule is intended to require the U.S. transferor to recognize only an appropriate amount of income, without automatically triggering the entire GRA.
The IRS and Treasury Department also believe that additional guidance is needed on the treatment of transfers of transferee foreign corporation stock by a U.S. transferor in a nonrecognition exchange in which the U.S. transferor receives boot. Therefore, the temporary regulations treat the disposition of transferee foreign corporation stock in a nonrecognition transaction by the U.S. transferor when the U.S. transferor receives money or other property as described in section 351(b) or 356(a) as a termination of the GRA in whole or in part. Consequently, if a new GRA is filed, then the U.S. transferor will recognize gain under the new GRA in the event of a subsequent triggering event in the amount of the gain realized, but not recognized, in the initial transfer less any gain recognized by the U.S. transferor under section 351(b) and 356(a)(1) in connection with the nonrecognition transaction. If, however, a new GRA is not filed in connection with the nonrecognition transaction, then the original GRA is triggered, and the U.S. transferor must recognize the gain that was realized, but not recognized, on the initial transfer less any gain recognized by the U.S. transferor under section 351(b) or 356(a)(1) in connection with the nonrecognition transaction.
D. Effect of Consolidation and Deconsolidation on Gain Recognition Agreements
Commentators noted that the current regulation does not adequately address the effect on GRAs of certain transactions involving consolidated groups. For example, the commentators noted that it is not clear what effect a U.S. transferor becoming a member of a consolidated group has on an existing GRA. The current regulations do provide, however, that if a U.S. transferor is a member of a consolidated group at the time of the initial transfer and ceases to be a member of the group during the term of the GRA, the common parent of such group that entered into the GRA continues to be liable under the original GRA. Section 1.367(a)-8(b)(5)(ii). Several commentators have raised concerns that such a result is not appropriate because the actions of an acquirer could unilaterally affect the liability of the original consolidated group under the GRA.
The IRS and Treasury Department agree that the effect of these transactions needs to be clarified and rationalized. Accordingly, in response to these concerns, the temporary regulations provide specific rules addressing these transactions. In particular, the IRS and Treasury Department believe that the U.S. parent corporation of a consolidated group should not continue to be liable under a GRA with respect to a U.S. transferor that is no longer a member of such group.
The temporary regulations provide that when a U.S. transferor becomes a member of a consolidated group (including a transaction where it joins such a group after being a member of another consolidated group) the transaction is a triggering event unless certain conditions are met. If these conditions are satisfied, the original GRA is terminated without further effect. These conditions require the U.S. parent corporation of the consolidated group that the U.S. transferor joins (1) to enter into a new GRA for the remaining term of the original GRA and (2) to elect to recognize gain in the taxable year of any subsequent triggering event (as opposed to the year of the initial transfer). A notice of the consolidation transaction must also be filed with the next annual certification. The IRS and Treasury Department believe that these requirements ensure that a GRA remains in effect after a U.S. transferor joins a consolidated group. These requirements are also consistent with §1.1502-77(a), which provides that the common parent is the sole agent for each member of the consolidated group.
In addition, the temporary regulations also cover situations in which a U.S. transferor ceases to be a member of a consolidated group and does not become a member of a new consolidated group. In these cases, the transaction is a triggering event, unless certain conditions are met. If these conditions are satisfied, the original GRA is terminated without further effect. These conditions require the U.S. transferor (1) to enter into a new GRA for the remaining term of the original gain recognition agreement and (2) to elect that in the event of a subsequent triggering event the U.S. transferor will recognize gain in the year of the triggering event. The U.S. transferor must also provide notice of the deconsolidation with the next annual certification.
E. U.S. Transferor Goes Out of Existence in a Transaction Giving Rise to a Gain Recognition Agreement
The current regulation provides that when a U.S. transferor goes out of existence in a transaction giving rise to a GRA, gain generally qualifies for nonrecognition treatment only if the U.S. transferor is owned by a single U.S. parent corporation, the U.S. transferor and its parent corporation file a consolidated Federal income tax return for the taxable year that includes the transfer, and the parent of the consolidated group enters into a GRA. Section 1.367(a)-8(f)(2)(i). The current regulation provides that a U.S. transferor that is controlled by five or fewer domestic corporations may request a ruling that the transaction qualifies for nonrecognition treatment. Section 1.367(a)-8(f)(2)(i).
Notice 2005-74, in turn, provides a rule that treats all members of the U.S. parent’s consolidated group for the taxable year that includes the transfer as a single corporation for purposes of §1.367(a)-8(f)(2)(i). Thus, a U.S. transferor that is not directly owned by a single U.S. parent corporation may still qualify for nonrecognition, without requesting a ruling, when the U.S. transferor goes out of existence in a transaction giving rise to a GRA, if it is indirectly wholly owned by members of a consolidated group.
The IRS and Treasury Department believe it is necessary to provide additional guidance on how GRAs are entered into when a U.S. transferor is controlled by multiple corporate shareholders with which the U.S. transferor does not join in filing a consolidated return. Moreover, the IRS and Treasury Department believe that in this area a single rule should apply both in consolidated and nonconsolidated situations. As a result, the temporary regulations provide unified rules, replacing both the current regulations and Notice 2005-74, in situations in which a U.S. transferor goes out of existence in a transaction giving rise to a GRA.
The temporary regulations generally provide that when a U.S. transferor goes out of existence in a transaction giving rise to a GRA, the gain may qualify for nonrecognition treatment if (1) the requirements of section 367(a)(5) and any regulations under that paragraph are satisfied such that five or fewer domestic corporations control the U.S. transferor and appropriate basis adjustments are made, (2) the requirements of §1.367(a)-3(c)(1) are satisfied if the transferred corporation is domestic, (3) all domestic corporate shareholders of the U.S. transferor that own at least five percent of either the total voting power or the total fair market value of the stock of the transferee foreign corporation immediately after the transaction enter into GRAs with respect to their pro rata share of the gain in the transferred stock or securities that designate such domestic corporate shareholders as U.S. transferors for purposes of §§1.367(a)-3(b) and (c) and 1.367(a)-8T, and (4) all domestic corporate shareholders that enter into GRAs elect to recognize any gain upon a subsequent trigger of the GRA in the year of the triggering event.
The temporary regulations eliminate the current regulation’s option to request a private letter ruling because guidance is now provided on how GRAs are entered into by five or fewer domestic corporations that control a U.S. transferor satisfying section 367(a)(5). In addition, the temporary regulations clarify that the terms of section 367(a)(5) must be satisfied (along with other requirements) to avoid gain recognition on the U.S. transferor’s section 361 transfer of stock or securities to a foreign acquiring corporation. Therefore, the rule in Notice 2005-74 treating consolidated group members as a single corporation is incorporated by reference to section 367(a)(5), which provides that all members of the same affiliated group are treated as one corporation. Lastly, because these rules address how gain recognition may be avoided under section 367(a)(1) on the initial transfer itself, rather than the effect of subsequent transactions on existing GRAs, these rules have been removed from §1.367(a)-8 and included instead in §1.367(a)-3T(e).
F. Transfers of Transferred Corporation’s Assets
Under the current regulations, dispositions of substantially all of the assets of the transferred corporation (within the meaning of section 368(a)(1)(C)) are generally treated as deemed dispositions of the stock or securities of the transferred corporation and therefore are triggering events. Section 1.367(a)-8(e)(3). In Revenue Ruling 57-518, 1957-2 C.B. 253, see §601.601(d)(2), the IRS stated that what constitutes “substantially all of the properties” as the term is used in section 368(a)(1)(C) “will depend upon the facts and circumstances in each case rather than upon any particular percentage.” However, Revenue Procedure 77-37, 1977-2 C.B. 568, see §601.601(d)(2), provides that for ruling purposes, the transfer by a corporation of 70 percent of its gross assets or 90 percent of its assets net of liabilities will generally be deemed to be a transfer of substantially all of the assets of a corporation.
Commentators have noted that defining substantially all by reference to section 368(a)(1)(C) may not be appropriate in the context of the GRA rules. The IRS and Treasury Department, however, generally believe that defining “substantially all” for these purposes by reference to the definition of the term under section 368(a)(1)(C) is appropriate. Nonetheless, the IRS and Treasury Department believe that it is important to clarify the scope of the term “substantially all,” as used in the current regulation and the temporary regulations. One commentator suggested that if a transferred corporation disposes of less than 70 percent of its gross assets or 90 percent of its assets net of liabilities, the transfer will not be treated as a disposition of substantially all of the assets of the transferred corporation for purposes of §1.367(a)-8(e)(3), and thus, such a disposition would not trigger a GRA. This suggestion is not correct. If, upon considering the facts and circumstances, a transferred corporation has disposed of substantially all its assets, such a transaction is a triggering event, even if the transferred corporation disposes of less than 70 percent of a corporation’s gross assets or 90 percent of its assets net of liabilities. The “substantially all” safe harbor provided in Revenue Procedure 77-37 is intentionally high so that the IRS does not need to engage in a factually detailed analysis before issuing a letter ruling. As a result, in the context of GRAs, the Revenue Procedure’s threshold does not mean that a disposition of substantially all the assets does not occur upon the disposition of a lesser amount of assets. Therefore, the temporary regulations provide that whether a transferred corporation has disposed of substantially all of its assets is determined under all the facts and circumstances.
G. Transactions that Terminate the GRA
1. Taxable dispositions of transferee foreign corporation stock
Section 1.367(a)-8(h)(1) provides that a GRA will terminate, in whole or in part, as a result of certain taxable dispositions of the transferee foreign corporation stock by the U.S. transferor. A key premise for this termination rule is that the basis in the transferee foreign corporation stock received by the U.S. transferor in the initial transfer is assumed to reflect the basis in the transferred stock or securities.
The IRS and Treasury Department continue to believe this termination rule is appropriate. As a result, the temporary regulations generally retain this rule. However, the temporary regulations modify the termination rule to ensure that a GRA terminates only when the transferee foreign corporation stock disposed of in fact reflects the basis of the transferred stock or securities. This termination rule only applies to transferee foreign corporation stock that is received (or deemed received) in the initial transfer. The IRS and Treasury Department understand that in some cases, taxpayers may take the position that the basis in the transferee foreign corporation stock does not reflect the basis of the transferred stock or securities. For example, taxpayers may take the position that the basis in such transferee foreign corporation stock received also reflects the basis of other property that had a built-in loss when it was transferred to the transferee foreign corporation. Thus, the termination rule in the temporary regulations will apply only when the basis of the transferee foreign corporation stock received (or deemed received) in the initial transfer properly reflects the sum of the aggregate basis of the transferred stock or securities immediately before the initial transfer, plus any increase in the basis of such stock or securities as a result of recognizing gain on the transfer. In addition, for purposes of this basis determination, basis increases to the transferee foreign corporation stock as a result of income inclusions (for example, pursuant to section 961) shall not be taken into account.
In cases where the basis of the relevant transferee foreign corporation stock exceeds the basis of the transferred stock or securities, however, the temporary regulations allow the U.S. transferor to take advantage of this termination rule if it elects to reduce its basis in the transferee foreign corporation stock such that it does not exceed the basis it had in the transferred stock or securities. If the U.S. transferor makes this election, the basis reduction will be effective immediately before the taxable disposition that terminates the GRA. In addition, if the U.S. transferor makes this election, it may increase its basis in other stock of the transferee foreign corporation it holds, if any, by a corresponding amount but not above the fair market value of such stock.
Similar rules apply in the case of partial dispositions of transferee foreign corporation stock and dispositions of transferee foreign corporation stock in nonrecognition transactions in which a portion of the realized gain is recognized.
2. Certain inbound distributions or transfers of the transferred stock
Section 1.367(a)-8(h)(3) provides that a distribution of the transferred stock in a transaction qualifying under section 355 or sections 332 and 337 will terminate the GRA if the U.S. transferor’s basis in the transferred stock or securities that it receives in the section 355 or 332 and 337 transaction does not exceed the basis the U.S. transferor had in the transferred stock or securities immediately before the initial transfer. In response to comments, however, the temporary regulations allow the U.S. transferor to take advantage of this termination rule if it elects to reduce the basis of the transferred stock or securities if the basis exceeds the basis the U.S. transferor had in the transferred stock or securities immediately before the initial transfer. For purposes of this basis determination, basis increases to the transferred stock as a result of income inclusions (for example, pursuant to section 961) shall not be taken into account. If the U.S. transferor elects to reduce basis in the transferred stock or securities it receives, the U.S. transferor shall increase its basis in other transferee foreign corporation stock (if any) by a corresponding amount but not above the fair market value of such stock.
Although the temporary regulations generally provide that a GRA terminates in certain section 332 liquidations of the transferee foreign corporation, the IRS and Treasury Department are studying to what extent this rule should apply when the transferee foreign corporation has a minority shareholder and therefore recognizes gain under section 336 in connection with the section 332 liquidation. As noted in the request for comments, although the IRS and Treasury Department generally believe it is appropriate to terminate entirely the GRA in a section 332 liquidation, in other circumstances it may not be appropriate. For example, if after an initial transfer, a wholly-owned transferee foreign corporation issues a minority interest to a foreign shareholder, completely terminating the GRA upon a section 332 liquidation of the transferee foreign corporation does not account for the fact that the U.S. transferor has indirectly disposed of up to 20 percent of its interest in the transferred stock or securities. Therefore, when the temporary regulations are finalized, the IRS and Treasury Department may address the effect that section 336 gain has on a gain recognition agreement when a transferee foreign corporation with a minority shareholder liquidates under section 332.
The temporary regulations expand the current rule to terminate GRAs when certain U.S. persons other than the original U.S. transferor receive the stock or securities that was transferred in the initial transfer. For example, if the transferred corporation is distributed to a domestic corporation or U.S. individual other than the U.S. transferor in a section 355 “split off,” the GRA would terminate if the domestic corporation or U.S. individual receives the transferred stock or securities with a basis that is not greater than the basis the U.S. transferor had in the transferred stock or securities immediately before the initial transfer.
Finally, and in response to comments requested in Notice 2005-74, the temporary regulations also expand the current rule to provide that the GRA will terminate in additional transactions where the U.S. transferor or a domestic corporation receives the transferred stock or securities with a basis that is not greater than the basis the U.S. transferor had in the transferred stock or securities immediately before the initial transfer. These transactions are upstream asset reorganizations where the U.S. transferor acquires the assets of the transferee foreign corporation, downstream asset reorganizations where the transferred corporation acquires the assets of the transferee foreign corporation, and certain other asset reorganizations where a domestic corporation acquires the assets of the transferee foreign corporation. Consequently, the temporary regulations generally provide that the GRA terminates in particular circumstances when the transferred stock or securities are held with the correct basis by certain U.S. persons, even if the U.S. person is not the original U.S. transferor.
However, the IRS and Treasury Department believe that it is not appropriate for the GRA to terminate when the transferred stock or securities may then be disposed of, directly or indirectly, by a foreign shareholder without being subject to U.S. tax. Therefore, this termination rule is limited to section 332 liquidations, section 355 distributions, and asset reorganizations where the domestic corporation that holds the transferred stock or securities after the transaction is either the U.S. transferor or a member of the same consolidated group of which the U.S. transferor is then a member. The IRS and Treasury Department continue to study whether it would be appropriate to expand the scope of the rule to transactions where the acquirer is not a member of the same consolidated group of which the U.S. transferor is then a member and request comments regarding such a rule.
H. Triangular Reorganizations of Transferee Foreign Corporation and Transferred Corporation
Notice 2005-74 provides rules that allow a U.S. transferor to avoid gain recognition on certain asset reorganizations of the transferee foreign corporation and transferred corporation. However, Notice 2005-74 restricts the definition of “asset reorganization” to exclude triangular asset reorganizations of the transferee foreign corporation and transferred corporation.
In response to comments and after further study, the temporary regulations address the treatment of certain triangular asset reorganizations. Specifically, they provide that if the transferee foreign corporation or transferred corporation is acquired in a triangular asset reorganization, the exchanges made pursuant to the reorganization will not be triggering events if certain requirements are satisfied. For purposes of this rule, a triangular asset reorganization is limited to a transaction in which the acquiring subsidiary is foreign. The additional requirements are as follows. First, the U.S. transferor or common parent must enter into a new GRA to recognize gain with respect to the initial transfer during the remaining term of the original GRA, with certain modifications. In the case of a triangular asset reorganization of the transferee foreign corporation, the U.S. transferor also must make certain designations depending on whether the parent corporation of the foreign acquiring subsidiary is foreign or domestic and depending on the type of triangular asset reorganization. Finally, the U.S. transferor must provide notice of the transaction with its next annual certification.
I. Other Changes
The current regulations refer to “stock of the transferred corporation” in some paragraphs but refer to “stock or securities of the transferred corporation” in other paragraphs. The temporary regulations refer to “stock or securities of the transferred corporation” because either stock or securities, or both, may be subject to a GRA when transferred to a transferee foreign corporation by a U.S. person. In contrast, the temporary regulations generally refer only to stock, and not securities, of the transferee foreign corporation. The rules applying to a disposition of the transferee foreign corporation are concerned primarily with transactions in which the U.S. transferor loses or decreases its control of the transferee foreign corporation, which does not occur when a U.S. transferor disposes of securities of the transferee foreign corporation.
The current regulation provides a reasonable cause exception to triggering a GRA when the person required to file the GRA fails to comply in any material respect with the terms of a GRA, or when the person fails to meet the timeliness requirement for submitting a GRA. The temporary regulations retain this reasonable cause exception but provide additional guidance on how the person should submit a request for reasonable cause relief. The temporary regulations also provide that the Area Director or Director of Field Operations, as applicable, shall notify the person in writing within 120 days of the filing if the person will be granted reasonable cause relief or if additional time is required to make the determination. The 120-day period runs from the date that the IRS notifies the person that its request has been received. Once this period begins, the person shall be deemed to have established reasonable cause if it is not again notified within 120 days.
With the exception of the special boot rules described in section C of this preamble, these temporary regulations apply to GRAs filed with respect to transfers of stock or securities occurring on or after March 7, 2007. The boot rules described in section C of this preamble apply to GRAs filed with respect to transfers of stock or securities occurring on or after 180 days after February 5, 2007. However, GRAs that are filed after March 7, 2007 in connection with transactions entered into pursuant to a contract that was binding before February 5, 2007 are not subject to these regulations, but taxpayers may elect to apply the rules of these regulations to such a GRA. For all open years, taxpayers may apply rules of these regulations that were not already effective under §1.367(a)-8 to GRAs filed before March 7, 2007. Similar effective date rules are provided for those transfers discussed in section E of this preamble (regarding a U.S. transferor that goes out of existence in a transaction giving rise to a GRA).
Special Analyses
It has been determined that this Treasury Decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that 5 U.S.C. 553(b) and (d) do not apply to these regulations. For applicability of the Regulatory Flexibility Act, please refer to the cross-referenced notice of proposed rulemaking published elsewhere in this Bulletin. Pursuant to section 7805(f) of the Internal Revenue Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.
The IRS and Treasury Department are considering issuing subsequent public guidance to address additional issues under section 367(a). Accordingly, comments are requested regarding the application of §1.367(a)-8, including whether other transactions should be excepted from being treated as triggering events pursuant to rules similar to those contained in the temporary regulations. For example, comments are requested as to the most appropriate treatment of divisive reorganizations qualifying under section 368(a)(1)(D) or (G), involving the U.S. transferor corporation, the transferee foreign corporation, and the transferred corporation. Comments also are requested on how a GRA is affected by a subsequent transaction to which section 304 applies involving transferee foreign corporation stock or transferred corporation stock. The IRS and Treasury Department believe that the rules in the temporary regulations generally deal with many transactions to which section 304 applies but request specific comments on any issues raised.
In addition, the IRS and Treasury Department request comments on the rule in §1.367(a)-8T(b)(3)(iii), which imposes interest on the additional tax, if any, that is required to be paid as a result of a triggering event. Specifically, comments are requested on whether interest should be imposed even when no additional tax is ultimately due as a result of a triggering event because, for example, a taxpayer has sufficient net operating losses to offset the tax that would otherwise be due as a result of a triggering event. If an interest charge is not required in such a case, a taxpayer may be viewed as inappropriately benefiting from deferring the realized but unrecognized gain on the initial transfer until a later year. However, there are other instances where the current regulations clearly permit such a benefit (for example, under §1.367(a)-8(h)(1)(i) in certain taxable dispositions of the stock of the transferee foreign corporation).
As described in section B.1.a of this preamble, comments are requested on whether a GRA should not be triggered, if certain conditions similar to those provided in §1.367(a)-3T(e) are met, when a U.S. transferor is acquired by a foreign corporation in an asset reorganization. Specifically, the IRS and Treasury Department request comments on how to reconcile the terms of the GRA that would be filed pursuant to §1.367(a)-3T(e) with the terms of a new GRA that would be filed to avoid triggering the original GRA. For example, the transferee foreign corporation under the outstanding GRA (and under the new GRA filed to avoid triggering the outstanding GRA) would be the transferred corporation with respect to the GRA filed pursuant to §1.367(a)-3T(e).
Finally, and as described in section G.2 of this preamble, the IRS and Treasury Department are studying to what extent the GRA termination rule should apply when the transferee foreign corporation liquidates in a transaction described in section 332 but also recognizes gain under section 336 because of a minority shareholder. Comments are requested on how the termination rule should address such a transaction, taking into consideration potentially different results depending on whether the minority shareholder is also subject to a GRA or is, for example, instead a foreign person who was issued transferee foreign corporation stock after the initial transfer.
For information on how to submit comments or request a public hearing, see the section “Comments and Requests for a Public Hearing,” set forth in the notice of proposed rulemaking published elsewhere in this issue of the Bulletin.
Amendments to the Regulations
Accordingly, 26 CFR parts 1 and 602 are amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for part 1 is amended by adding new entries to read as follows:
Authority: 26 U.S.C. 7805* * *
Section 1.367(a)-3T(e) also issued under 367(a) and (b).* * *
Section 1.367(a)-8T also issued under 367(a) and (b).* * *
Par. 2. For each entry in the table in the “Section” column, remove the language in the “Remove” column and add the language in the “Add” column in its place.
1.367(a)-3(d)(3), Example 1(ii), fourth sentence §1.367(a)-8(e) §1.367(a)-8T(d)(1)
1.367(a)-3(d)(3), Example 1(ii), fourth sentence §1.367(a)-8(b)(1)(vii) §1.367(a)-8T(b)(1)(vii)
1.367(a)-3(d)(3), Example 1(ii), fifth sentence §1.367(a)-8(b)(1)(vii) §1.367(a)-8T(b)(1)(vii)
1.367(a)-3(d)(3), Example 1A(ii), first sentence §1.367(a)-8(a)(3) §1.367(a)-8T(a)(3)
1.367(a)-3(d)(3), Example 4(i), first sentence §1.367(a)-8(e)(3)(i) §1.367(a)-8T(d)(2)
1.367(a)-3(d)(3), Example 4(ii), first sentence §1.367(a)-8(e)(3)(i) §1.367(a)-8T(d)(2)
1.367(a)-3(d)(3), Example 4(ii), second sentence §1.367(a)-8(h)(2), because A and W filed a consolidated Federal income tax return prior to the transaction, §1.367(a)-8T(g)(2), because A owned an amount of stock in W described in section 1504(a)(2) immediately before the transaction,
1.367(a)-3(d)(3), Example 6(ii), last sentence §1.367(a)-8(e)(3)(i) §1.367(a)-8T(d)(2)
1.367(a)-3(d)(3), Example 7A(ii), last sentence §1.367(a)-8(b)(5) §1.367(a)-8T(b)(5)
paragraph (d)(3), Example 7A(ii), last sentence and (e)(3)(i). and V satisfies the requirements contained in §1.367(a)-8T(e)(1)(iii).
1.367(a)-3(d)(3), Example 8(ii), second to last sentence §1.367(a)-8(e)(3)(i) §1.367(a)-8T(d)(2)
1.367(a)-3(d)(3), Example 11(ii), sixth sentence §1.367(a)-8(e) §1.367(a)-8T(d)(1)
1.367(a)-3(d)(3), Example 11(ii), sixth sentence §1.367(a)-8(b)(1)(vii) §1.367(a)-8T(b)(1)(vii)
1.367(a)-3(e)(1)(A), first sentence (e) (g)
1.367(a)-3(e)(1)(F), third sentence (g) (j)
1.367(a)-3(e)(2), first sentence (e)(1) and (g) (g)(1) and (j)
1.367(a)-3(e)(2), second sentence (e)(2) (g)(2)
1.367(a)-3(e)(2)(G), first sentence (e)(1)(G) (g)(1)(G)
1.367(a)-3(g)(1), first sentence (g)(2) (j)(2)
1.367(a)-3(g)(2)(i), first sentence (g)(2)(iii), (g)(2)(iv) (j)(2)(iii), (j)(2)(iv)
1.367(a)-3(g)(2)(ii), first sentence (g)(2)(iii) or (iv) (j)(2)(iii) or (iv)
1.367(a)-3(g)(2)(ii), fourth sentence §1.367(a)-3(f) §1.367(a)-3(h)
1.367(a)-3(g)(2)(iii), first sentence (g)(2)(ii) (j)(2)(ii)
1.367(a)-3(g)(2)(iv), first sentence (g)(2)(i) and (ii) (j)(2)(i) and (ii)
1.367(b)-4(b)(1)(iii), Example 4(i), last sentence §1.367(a)-8(f)(2) §1.367(a)-3T(e)
Par. 3. Section 1.367(a)-3 is amended as follows:
1. The second sentence of paragraph (a) is revised.
2. The first sentence of paragraph (d)(2)(iii) is revised.
3. Paragraph (d)(2)(iv) is revised.
4. The title and introductory text of paragraph (d)(2)(v) is revised.
5. The last two sentences of paragraph (d)(3), Example 1A(ii) are revised.
7. The first and second sentences of paragraph (d)(3), Example 7(ii) are revised.
8. The third sentence of paragraph (d)(3), Example 7A(ii) is revised.
9. The last sentence of paragraph (d)(3), Example 9(ii) is revised.
10. The title of paragraph (d)(3), Example 10 is revised.
11. The third sentence of paragraph (d)(3), Example 12(ii) is revised.
12. Redesignating paragraphs (e), (f), and (g) as paragraphs (g), (h), and (j), respectively.
13. Adding new paragraphs (e) and (i).
The revisions and addition read as follows:
§1.367(a)-3 Treatment of transfers of stock or securities to foreign corporations.
(a) * * * In general, a transfer of stock or securities by a U.S. person to a foreign corporation that is described in section 351, 354 (including a reorganization described in section 368(a)(1)(B) and including an indirect stock transfer described in paragraph (d) of this section), 356 or section 361(a) or (b) is subject to section 367(a)(1) and, therefore, is treated as a taxable exchange, unless one of the exceptions set forth in paragraph (b) of this section (regarding transfers of foreign stock or securities), paragraph (c) of this section (regarding transfers of domestic stock or securities), or paragraph (e) of this section (regarding transfers of stock or securities in a section 361 exchange) applies. * * *
(d) * * *
(2)(iii) * * * For purposes of determining the amount of gain that a U.S. person is required to include in income as a result of a triggering event, see §1.367(a)-8T(b)(3)(i) and (d).
(iv) * * * The U.S. transferor’s agreement to recognize gain, as provided in §1.367(a)-8, shall include appropriate provisions consistent with the principles of §1.367(a)-3 and §1.367(a)-8, including, for example, as an additional triggering event an indirect disposition of the transferred stock or securities. For example, in the case of a triangular section 368(a)(1)(B) reorganization described in paragraph (d)(1)(iii)(A) of this section, a triggering event shall include an indirect disposition of the transferred stock or securities by the transferee foreign corporation, such as a disposition of the stock of the acquiring corporation (either foreign or domestic) by the transferee foreign corporation. In the case of a triangular section 368(a)(1)(B) reorganization described in paragraph (d)(1)(iii)(B) of this section, a disposition of the stock of the acquiring corporation by the domestic issuing corporation in a taxable transaction shall, for example, terminate the gain recognition agreement if the principles of §1.367(a)-8T(g)(1)(i)(A) and (B) are satisfied. See Examples 5 and 5A of this section.
(v) Determination of whether substantially all of the transferred corporation’s assets are disposed of. For purposes of applying §1.367(a)-8T(d)(2) to determine whether substantially all of the assets of the transferred corporation have been disposed of, the following assets shall be taken into account (but only if such assets are not fully taxable under section 367 in the taxable year that includes the indirect transfer)—
(3) * * *
Example 1A. * * *
(ii) * * * If A leaves the P group, the gain recognition agreement would be triggered pursuant to §1.367(a)-8T(d)(4), unless the exception provided under §1.367(a)-8T(e)(8) applies.
Example 5A * * *
(ii) * * * If Y sold substantially all of its assets (within the meaning of section 368(a)(1)(C)), the gain recognition agreement would be terminated because U owned an amount of stock in Y described in section 1504(a)(2) immediately before the transaction and Y is a domestic corporation. See §1.367(a)-8T(g)(2). In addition, if F disposed of the stock of S in a taxable transaction the gain recognition agreement would be terminated if the principles of §1.367(a)-8T(g)(1)(i)(A) and (B) are satisfied.
Example 7. * * *
(ii) * * * The disposition by R, the transferred corporation, of substantially all of its assets would terminate the gain recognition agreement if the assets were disposed of in a taxable transaction because V owned an amount of stock in Z described in section 1504(a)(2) immediately before the transaction, and R is a domestic corporation. See §1.367(a)-8T(g)(2). Because the assets were transferred in an exchange to which section 351 applies, such transfer does not trigger the gain recognition agreement if V complies with the requirements contained in §1.367(a)-8T(e)(1)(iii). * * *
(ii) * * * Thus, the gain recognition agreement would terminate because V owned an amount of stock in Z described in section 1504(a)(2) immediately before the transaction, and R is a domestic corporation. See §1.367(a)-8T(g)(2).* * *
(ii) * * * To determine whether there is a triggering event under §1.367(a)-8T(d)(2), both the Business A assets in M and the Business B assets in R must be considered.
Example 10. Concurrent application of asset transfer and indirect stock transfer rules in section 368(a)(1)(A)/(a)(2)(D) reorganization—(i) Facts. * * *
Example 12. * * *
(ii) * * * E’s transfer of its N stock could qualify for nonrecognition treatment if D satisfies the requirements in §1.367(a)-3T(e).* * *
(e) [Reserved]. For further guidance, see §1.367(a)-3T(e).
(f) [Reserved]. For further guidance, see §1.367(a)-3T(f).
(i) [Reserved].
Par. 4. Section 1.367(a)-3T is added to read as follows:
§1.367(a)-3T Treatment of transfers of stock or securities to foreign corporations (temporary).
(a) through (d) [Reserved]. For further guidance, see §1.367(a)-3(a) through (d).
(e) Transfers by a domestic corporation to a foreign corporation in a section 361 exchange—(1) General rule. Notwithstanding paragraphs (b) and (c) of this section, if the U.S. transferor is a domestic corporation that transfers stock or securities to a foreign corporation in a section 361 exchange that would otherwise be subject to section 367(a)(1) under paragraph (a) of this section, such transfer shall not be subject to section 367(a)(1) if—
(i) The conditions set forth in the second sentence of section 367(a)(5) and any regulations under that section have been satisfied, such that, for example, the U.S. transferor is controlled (within the meaning of section 368(c)) by 5 or fewer domestic corporations and appropriate basis adjustments are made;
(ii) In the case of transferred property that is stock or securities of a domestic corporation, the conditions set forth in paragraph (c) of this section are satisfied;
(iii) All domestic corporate shareholders of the U.S. transferor immediately before the transaction that own 5 percent or more (applying the attribution rules of section 318, as modified by section 958(b)) of the total voting power or the total fair market value of the stock of the transferee foreign corporation immediately after the transaction enter into gain recognition agreements as provided in §1.367(a)-8T with respect to their pro rata share (determined by the relative fair market value of the U.S. transferor stock or securities owned) of the gain that was realized but not recognized on the transfer of the stock or securities of the transferred corporation that, in addition to the terms of §1.367(a)-8T(b), designate such domestic corporate shareholders as U.S. transferors for purposes of paragraphs (b) and (c) of this section and §1.367(a)-8T; and
(iv) All domestic corporate shareholders that enter into gain recognition agreements pursuant to paragraph (e)(1)(iii) of this section make the election described in §1.367(a)-8T(b)(1)(vii).
(2) Certain triangular asset reorganizations. If a transaction described in paragraph (e)(1) of this section qualifies as a triangular asset reorganization described in §1.358-6(b)(2)(i) through (iii), or in sections 368(a)(1)(G) and (a)(2)(D), the principles of §1.367(a)-3(d)(2)(iv) shall apply with respect to any gain recognition agreements filed in connection with such transaction.
(3) Example. The provisions of paragraph (e)(1) of this section are illustrated in the following example:
Example. (i) Facts. US1 and US2, domestic corporations, own 60% and 40%, respectively, of the fair market value of UST, also a domestic corporation. US1 and US2 are not members of the same consolidated group and are unrelated. UST owns 100% of FC, a foreign corporation. In year 1, UST transfers 100% of the stock of FC to FA, a foreign corporation, in a reorganization described in section 368(a)(1)(A) after which US1 and US2 own 6% and 4%, respectively, of the stock of FA. At the time of the initial transfer, the section 1248 amount with respect to the FC stock is $0. The notice requirement under §1.367(b)-1(c) is satisfied. Section 7874 does not apply to FA’s acquisition of the stock of FC. US1 and US2 satisfy the conditions set forth in the second sentence of section 367(a)(5), including making appropriate basis adjustments. Pursuant to paragraph (e)(1) of this section, US1 enters into a gain recognition agreement to recognize its pro rata share of the gain realized but not recognized on UST’s transfer of the stock of FC to FA, designates itself as a U.S. transferor for purposes of paragraph (b) of this section and §1.367(a)-8T, and makes the election described in §1.367(a)-8T(b)(1)(vii). US2 does not enter into a gain recognition agreement with respect to its pro rata share of the gain realized but not recognized on UST’s transfer of the stock of FC to FA because US2 owns less than 5 percent of the stock of FA. In year 4, FA sells 30% of the FC stock for cash.
(ii) Result. Because the requirements of paragraph (e)(1)(i) through (iv) of this section are satisfied, the transfer of the FC stock by UST to FA in the year 1 reorganization is not subject to section 367(a)(1). In addition, because FA partially disposes of the stock of FC in year 4, US1 must recognize 30% of its pro rata share of the gain realized but not recognized on the initial transfer of the FC stock to FA pursuant to §1.367(a)-8T(d)(1)(iii). The proportion of gain recognized by US1 is determined by reference to the relative fair market value of the UST stock owned by US1 at the time of the initial transfer. Thus, US1 must include 18% of the gain realized, but not recognized, on the initial transfer (the 30% of the transferred property that was disposed of multiplied by the amount of gain subject to the gain recognition agreement (corresponding to the 60% of the fair market value of UST stock that US1 held immediately before the initial transfer)), and pay any applicable interest.
(iii) Alternate facts. The facts are the same as in paragraph (i) of this Example, except that US1 and US2 are members of a consolidated group in which USP is the common parent. US2 is also a 5-percent transferee shareholder as a result of applying the attribution rules of section 318, as modified by section 958(b). The result is the same as in paragraph (ii) of this Example, except that under §1.367(a)-8T(a)(3)(i)(A) USP files gain recognition agreements on behalf of both US1 and US2. Thus, US1 and US2 must include in income in year 4 18% and 12%, respectively, of the gain realized, but not recognized, on the initial transfer (the 30% of the transferred property that was disposed of multiplied by the amount of gain subject to the gain recognition agreement (corresponding to the 60% and 40% of the fair market value of UST stock that US1 and US2, respectively, held immediately before the initial transfer)), and pay any applicable interest.
(f) Effective date—(1) General rule. The rules of this §1.367(a)-3T(e) apply to transfers of stock or securities occurring on or after March 7, 2007. However, these rules do not apply to transfers of stock or securities occurring on or after March 7, 2007, if such transfer was entered into pursuant to a written agreement which was (subject to customary conditions) binding before February 5, 2007, and at all times thereafter. Solely for purposes of this paragraph (f), a transfer described in the preceding sentence shall be deemed to be a transfer occurring before March 7, 2007. For matters covered in this section for periods before March 7, 2007 but on or after July 20, 1998, the rule of §1.367(a)-8(f)(2)(i) (see 26 CFR part 1, revised April 1, 2006) applies.
(2) Transfers before effective date—(i) General rule. Taxpayers may apply the rules of §1.367(a)-3T(e) to transfers before March 7, 2007 and after July 20, 1998, for all open taxable years ending on or after July 20, 1998. This paragraph (f)(2)(i) applies only to rules in §1.367(a)-3T(e) that were not already effective under the rules of §1.367(a)-8(f)(2)(i).
(ii) Special filing rule. This paragraph (f)(2)(ii) provides the time and manner in which taxpayers may apply paragraph (f)(2)(i) of this section. Notwithstanding the rules provided in §1.367(a)-8T(a)(2), all agreements, certifications, or other information related to the gain recognition agreement that should have been filed on or before March 7, 2007 with respect to a transfer shall be treated as having been timely filed, provided they are attached to a Federal income tax return amending the taxpayer’s Federal income tax return for the taxable year in which they should have been attached. The amended return described in the preceding sentence must be filed before August 6, 2007. A taxpayer that wishes to apply paragraph (f)(2)(i) of this section but that fails to meet the filing requirement described in the preceding sentence must request reasonable cause relief as provided in §1.367(a)-8T(e)(10).
(3) Expiration. The applicability of this section expires on or before February 1, 2010.
Par. 5. Section 1.367(a)-8 is amended by revising paragraphs (a) through (i) to read as follows:
§1.367(a)-8 Gain recognition agreement requirements.
(a) through (i) [Reserved]. For further guidance, see §1.367(a)-8T(a) through (h).
§1.367(a)-8T Gain recognition agreement requirements (temporary).
(a) In general. This section specifies the terms and conditions for an agreement to recognize gain entered into pursuant to §§1.367(a)-3(b) through (d) and 1.367(a)-3T(e) to qualify for nonrecognition treatment under section 367(a).
(1) Definitions. The following definitions apply for purposes of this section:
(i) Asset reorganization. Except as otherwise provided in this paragraph (a)(1)(i), the term asset reorganization means a reorganization described in section 368(a)(1) involving the transfer of assets by a corporation to another corporation pursuant to section 361, except that such term shall include reorganizations described in section 368(a)(1)(D) or (G) only if the requirements of section 354(b)(1)(A) and (B) are met. For purposes of paragraphs (e)(3)(ii) and (e)(3)(iii) of this section, the following reorganizations are excluded from the term “asset reorganization”:
(A) Triangular asset reorganizations described in §1.358-6(b)(2)(i) through (iii) or in sections 368(a)(1)(G) and (a)(2)(D). For rules applicable to triangular asset reorganizations described in §1.358-6(b)(2)(i) through (iii) or in sections 368(a)(1)(G) and (a)(2)(D), see paragraph (e)(4) of this section.
(B) Asset reorganizations where, after the reorganization, the same corporation is both the transferee foreign corporation (or successor transferee foreign corporation, as applicable) and the transferred corporation (or the successor transferred corporation, as applicable); for example, the acquisition of the transferee foreign corporation’s assets by the transferred corporation in a reorganization described in section 368(a)(1). For rules applicable to certain upstream and downstream reorganizations involving the transferee foreign corporation and transferred corporation, see paragraphs (e)(6) and (g)(3) of this section.
(ii) The term common parent means a corporation that controls an affiliated group of corporations that files its Federal income tax returns on a consolidated basis.
(iii) The term consolidated group has the meaning set forth in §1.1502-1(h).
(iv) The term disposition means any transfer that would constitute a disposition for any purpose of the Internal Revenue Code and the regulations thereunder. It also includes an indirect disposition of the stock of the transferred corporation as described in §1.367(a)-3(d). It does not, however, include a redemption of stock under section 302(d) to the extent the redemption is treated as a distribution to which section 301(c)(1) applies.
(v) The term gain recognition agreement means an agreement described in paragraph (b) of this section.
(vi) The term initial transfer means a transfer in connection with which a gain recognition agreement is filed in connection with an exchange described in §§1.367(a)-3(b) through (d) and 1.367(a)-3T(e).
(vii) The term nonrecognition transaction means any disposition of property in a transaction in which gain or loss is not recognized in whole or in part for purposes of subtitle A.
(viii) The term transferee foreign corporation means the foreign corporation the stock of which is received in an exchange described in section 367(a) by a U.S. transferor.
(ix) Transferred corporation. Other than in the case of an indirect stock transfer, the term transferred corporation means the corporation the stock or securities of which are transferred by a U.S. transferor to a foreign corporation in an exchange described in section 367(a)(1). In the case of an indirect stock transfer, the term transferred corporation has the meaning set forth in §1.367(a)-3(d)(2)(ii).
(x) The term triggering event means an event described in paragraph (d) of this section, except as provided in paragraphs (e) (exceptions to triggering events) and (g) (terminations of gain recognition agreements) of this section.
(xi) The term U.S. transferor means a U.S. person (as defined in §1.367(a)-1T(d)(1)) that transfers stock or securities of the transferred corporation in exchange for stock or securities of the transferee foreign corporation in an exchange described in section 367(a). For the application of the rules of this section to indirect transfers involving partnerships and interests therein, see §1.367(a)-1T(c)(3).
(2) Filing requirements for gain recognition agreements. A U.S. transferor’s gain recognition agreement must be attached to, and filed by the due date (including extensions) of, the U.S. transferor’s income tax return for the taxable year that includes the date of the initial transfer, except that if the U.S. transferor is a member of a consolidated group for the taxable year in which the transfer was made, the agreement must be attached to the consolidated group’s tax return. If a new gain recognition agreement is entered into pursuant to an exception in paragraph (e) of this section, the agreement must be attached to, and filed by the due date (including extensions) of, the applicable income tax return for the taxable year that includes the date of the triggering event. If the timeliness requirement of this paragraph (a)(2) is not satisfied, see paragraph (e)(10) of this section.
(3) Who must sign—(i) General rule. The gain recognition agreement must be signed under penalties of perjury by the appropriate party corresponding to the following categories of U.S. transferor. A gain recognition agreement may also be signed by an agent authorized to do so under a general or specific power of attorney.
(A) In the case of a corporate U.S. transferor, a responsible officer, except that if the U.S. transferor (or successor U.S. transferor designated in a new gain recognition agreement entered into under paragraph (e) of this section) is a member, but not the common parent of a consolidated group for the taxable year in which the transfer was made (or for the taxable year in which a new gain recognition agreement is entered into under paragraph (e) of this section) the agreement must be entered into by the common parent and signed by a responsible officer of such common parent.
(B) In the case of an individual U.S. transferor (including a partner who is treated as a U.S. transferor by virtue of §1.367(a)-1T(c)(3)), the individual.
(C) In the case of a trust or estate, a trustee, executor, or equivalent fiduciary.
(D) In the case of a bankruptcy case under Title 11, United States Code, a debtor in possession or trustee.
(ii) Signature requirement. When a gain recognition agreement, certification, or other information is required under this section to be attached to and filed by the due date (including extensions) of a U.S. Federal income tax return and signed under penalties of perjury by the person who signs the return, the attachment and filing of an unsigned copy is considered to satisfy such requirement, provided the taxpayer retains the original in its records in the manner specified by §1.6001-1(e).
(b) Gain recognition agreement—(1) Contents. The gain recognition agreement must set forth the following information, with the heading “GAIN RECOGNITION AGREEMENT UNDER §1.367(a)-8T” and with paragraphs labeled to correspond with the numbers set forth as follows:
(i) A statement that the document submitted constitutes the U.S. transferor’s agreement to recognize gain in accordance with the requirements of this section.
(ii) A description of the property transferred as described in paragraph (b)(2) of this section.
(iii) The U.S. transferor’s agreement to recognize gain, as described in paragraph (b)(3) of this section.
(iv) A waiver of the period of limitations as described in paragraph (b)(4) of this section.
(v) An agreement to file with the U.S. transferor’s tax returns for the five full taxable years following the year of the initial transfer a certification as described in paragraph (b)(5) of this section.
(vi) A statement that arrangements have been made in connection with the transferred property to ensure that the U.S. transferor will be informed of any triggering events.
(vii) A statement as to whether, if all or a portion of the gain recognition agreement is triggered under paragraph (d) of this section, the taxpayer elects to include the required amount in the year of the triggering event rather than in the year of the initial transfer.
(2) Description of property transferred. (i) The agreement shall include a description of each property transferred by the U.S. transferor, an estimate of the fair market value of the property as of the date of the initial transfer, a statement of the cost or other basis of the property and any adjustments thereto, and the date on which the property was acquired by the U.S. transferor.
(ii) The U.S. transferor must provide the following information:
(A) The type or class, amount, and characteristics of the stock or securities transferred, as well as the name, address, and place of incorporation of the issuer of the stock or securities, and the percentage (by voting power and value) that the stock (if any) represents of the total stock outstanding of the transferred corporation.
(B) The name, address and place of incorporation of the transferee foreign corporation, and the percentage of stock (by voting power and value) that the U.S. transferor received or will receive in the transaction.
(C) If stock or securities are transferred pursuant to §1.367(a)-3T(e), a statement that the conditions set forth in the second sentence of section 367(a)(5) and any regulations under that section have been satisfied, and an explanation of any basis or other adjustments made pursuant to section 367(a)(5) and any regulations under that paragraph.
(D) If the transferred corporation is a domestic corporation, the taxpayer identification number of the transferred corporation, together with a statement describing whether, and if so, how, section 7874 applies to the transfer, and a statement that all of the requirements of §1.367(a)-3(c)(1) are satisfied.
(E) If the transferred corporation is a foreign corporation, a statement as to whether the U.S. transferor was a section 1248 shareholder, as defined in §1.367(b)-2(b), of the transferred corporation immediately before the exchange, and, if so, a statement as to whether the U.S. transferor is a section 1248 shareholder with respect to the transferee foreign corporation stock received, and whether any reporting requirements or other rules contained in regulations under section 367(b) are applicable, and, if so, whether they have been satisfied.
(F) If the transaction involved the transfer of assets other than stock or securities and the transaction was subject to the indirect stock transfer rules of §1.367(a)-3(d), a statement as to whether the reporting requirements under section 6038B have been satisfied with respect to the transfer of property other than stock or securities, and an explanation of whether gain was recognized under section 367(a)(1) and whether section 367(d) was applicable to the transfer of such assets, or whether any tangible assets qualified for nonrecognition treatment under section 367(a)(3) (as limited by section 367(a)(5) and §§1.367(a)-4T through 1.367(a)-6T).
(3) Terms of agreement—(i) General rule. If before the close of the fifth full taxable year (not less than 60 months) following the close of the taxable year of the initial transfer, there is a triggering event, then, unless an election is made under paragraph (b)(1)(vii) of this section, by the 90th day thereafter the U.S. transferor must file an amended Federal income tax return for the year of the initial transfer and recognize thereon the gain realized, but not recognized, upon the initial transfer, with interest. If an election under paragraph (b)(1)(vii) of this section was made, then, if a triggering event occurs, the U.S. transferor must include the gain realized, but not recognized, on the initial transfer in income on its Federal income tax return for the taxable year that includes the date of the triggering event. In accordance with paragraph (b)(3)(iii) of this section, interest must be paid on any additional tax due. If a taxpayer properly makes the election under paragraph (b)(1)(vii) of this section but later fails to include in income the gain realized, but not recognized, on the initial transfer, the Commissioner may, in his discretion, include the gain in the taxpayer’s income in the year of the initial transfer.
(ii) Offsets. No special limitations apply with respect to net operating losses, capital losses, credits against tax, or similar items.
(iii) Reporting of interest and gain. If additional tax is required to be paid pursuant to paragraph (b)(3)(i) of this section, then interest must be paid on that amount at the rates determined under section 6621 with respect to the period between the date that was prescribed for filing the U.S. transferor’s Federal income tax return for the year of the initial transfer and the date on which the additional tax for that year is paid. If the election in paragraph (b)(1)(vii) of this section is made, a taxpayer should include the amount of gain as taxable income on its Federal income tax return (together with other income or loss items) and include the amount of interest in its payment (or reduce the amount of any refund due by the amount of the interest). A taxpayer must also attach to its Federal income tax return a separate schedule with the heading “Calculation of Section 367 Tax and Interest,” on which the amount of tax attributable to the gain and the interest required to be paid under this section are separately identified and calculated.
(iv) Basis adjustments—(A) Transferee foreign corporation. If a U.S. transferor is required to recognize gain under this section as a result of a triggering event, then the transferee foreign corporation’s basis in the transferred stock or securities shall be increased (as of the date of the initial transfer) by the amount of gain required to be recognized (but not by any tax or interest required to be paid on such amount) by the U.S. transferor.
(B) U.S. transferor. If a U.S. transferor is required to recognize gain as a result of a triggering event, then the U.S. transferor’s basis in the stock of the transferee foreign corporation received (or deemed received) in the initial transfer shall be increased by the amount of gain required to be recognized (as of the date of the initial transfer) (but not by any tax or interest required to be paid on such amount).
(C) Other adjustments. Other appropriate adjustments to basis that are consistent with the principles of this paragraph (b)(3)(iv) may be made if the U.S. transferor is required to recognize gain under this section. In no case, however, shall the transferred corporation’s net asset basis be increased as a result of the U.S. transferor recognizing gain under this section as a result of a triggering event.
(D) Example. The principles of this paragraph (b)(3) are illustrated by the following example:
Example. (i) Facts. D, a domestic corporation owning 100 percent of the stock of S, a foreign corporation, transfers all of the S stock to F, a foreign corporation, in an exchange described in section 368(a)(1)(B). The section 1248 amount with respect to the S stock at the time of the transfer is $0. In the exchange, D receives 20 percent of the voting stock of F. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and D enters into a gain recognition agreement to qualify for nonrecognition treatment and does not make the election contained in paragraph (b)(1)(vii) of this section. Two years after the initial transfer, F transfers all of the S stock to F1, a foreign corporation, in an exchange to which section 351 applies, and D complies with the requirements of paragraph (e)(1)(ii) of this section. Four years after the initial transfer, D transfers its entire 20 percent interest in F’s voting stock to a domestic partnership in exchange for an interest in the partnership and complies with the requirements of paragraph (e)(1)(i) of this section. D complies with the notice requirement under §1.367(b)-1(c) for each transaction subject to section 367(b). Because D complies with the requirements of paragraph (e) for each transaction that would otherwise be a triggering event, D is not required to recognize the gain that was realized, but not recognized, on the initial transfer. Five years after the initial transfer, S disposes of substantially all (as described in paragraph (d)(2) of this section) of its assets, and D is required by the terms of the gain recognition agreement to recognize all the gain that it realized on the initial transfer of the stock of S.
(ii) Result. As a result of the triggering event and paragraph (b)(3)(iv) of this section, the amount of gain required to be recognized as a result of S’s disposition of substantially all its assets (but not the tax or interest required to be paid on such amount) is reflected by an increased basis (as of the date of the initial transfer) in D’s partnership interest, the partnership’s interest in the 20 percent voting stock of F, F‘s stock of F1, and F1’s stock of S. S, however, is not permitted to increase its basis in its assets for purposes of determining the direct or indirect U.S. tax results, if any, on the sale of its assets.
(4) Waiver of period of limitation. The U.S. transferor must file, with the gain recognition agreement, a waiver of the period of limitation on assessment of tax upon the gain realized on the initial transfer. The waiver shall be executed on Form 8838 “Consent To Extend the Time To Assess Tax Under Section 367—Gain Recognition Agreement” and shall extend the period for assessment of such tax to a date not earlier than the eighth full taxable year following the taxable year of the initial transfer. The waiver shall also contain such other terms with respect to assessment as may be considered necessary by the Commissioner to ensure the assessment and collection of the correct tax liability for each year for which the waiver is required. The waiver must be signed by a person who would be authorized to sign the agreement pursuant to the provisions of paragraph (a)(3) of this section.
(5) Annual certification. The U.S. transferor must file with its income tax return for each of the five full taxable years following the taxable year of the initial transfer a certification that there has not been a triggering event, and a description of any exception under paragraph (e) of this section if such an exception is relied upon for the position that there has not been a triggering event. The U.S. transferor must include with its annual certification a statement describing any dispositions of assets by the transferred corporation that are not made in the ordinary course of business. The annual certification pursuant to this paragraph (b)(5) must be signed by a person who would be authorized to sign the agreement pursuant to the provisions of paragraph (a)(3) of this section.
(c) Use of security. The U.S. transferor may be required to furnish a bond or other security that satisfies the requirements of §301.7101-1 of this chapter if the Area Director, Field Examination, Small Business/Self Employed or the Director of Field Operations, Large and Mid-Size Business (Director) determines that such security is necessary to ensure the payment of any tax on the gain realized, but not recognized, upon the initial transfer. Such bond or security generally will be required only if the stock or securities transferred are a principal asset of the U.S. transferor and the Director has reason to believe that a disposition of the stock or securities may be contemplated.
(d) Triggering events. If there is a triggering event described in this paragraph (d) during the term of the gain recognition agreement, the U.S. transferor must include in income the gain realized, but not recognized, upon the initial transfer as provided in paragraph (b)(3)(i) of this section. In addition, the U.S. transferor must pay any interest required by paragraph (b)(3)(iii) of this section. See §1.367(a)-3(d)(2)(iv) for additional triggering events when a gain recognition agreement has been filed in connection with an indirect stock transfer. Except to the extent provided in paragraphs (e) and (g) of this section, if any of the following events occur during the term of the gain recognition agreement, it shall constitute a triggering event:
(1) Disposition of stock or securities of the transferred corporation—(i) In general. A disposition, in whole or in part, by the transferee foreign corporation (or any other person) of the transferred stock or securities received by the transferee foreign corporation in the initial transfer. For purposes of this section, a reference to transferred stock or securities shall also include stock or securities of the transferred corporation the basis of which is determined (directly or indirectly) in whole or in part, by reference to the basis of the stock or securities transferred in the initial transfer. A disposition of all or a portion of the stock or securities of the transferred corporation by installment sale is treated as a disposition of the stock or securities in the year of the installment sale.
(ii) Example. The provisions of this paragraph (d)(1)(i) are illustrated by the following example:
Example. Interaction between trigger of gain recognition agreement and subpart F rules—(i) Facts. USP, a domestic corporation, owns all of the stock of two foreign corporations, CFC1 and CFC2. USP’s section 1248 amount with respect to CFC2 is $30. USP has a basis of $50 in its stock of CFC2; the stock of CFC2 has a fair market value of $100. In a transaction described in sections 351 and 368(a)(1)(B), USP transfers the stock of CFC2 to CFC1 in exchange for additional stock of CFC1 with a basis of $50. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). To qualify for nonrecognition treatment under section 367(a), USP enters into a gain recognition agreement for $50 under this section. No election under paragraph (b)(1)(vii) of this section is made. USP also complies with the notice requirement under §1.367(b)-1(c). Two years after the initial transfer, CFC1 sells the stock of CFC2 for $120. At the time of the sale, the section 1248 amount with respect to the CFC2 stock continues to be $30. The $70 of gain recognized on the sale of CFC2 stock would give rise to a $70 subpart F inclusion to USP under section 951(a)(1)(A).
(ii) Result—(A) Trigger of gain recognition agreement with no election. CFC1’s sale of CFC2 stock is a triggering event. As a result, USP must amend its return for the year of the initial transfer and include $50 in income (as well as pay any applicable interest), $30 of which will be recharacterized as a dividend pursuant to section 1248. Under paragraph (b)(3)(iv) of this section, as of the date of the initial transfer, CFC1 has a basis of $100 in its CFC2 stock, and USP has a basis in its CFC1 stock of $100. As a result of the sale of CFC2 stock by CFC1, USP will have a $20 subpart F inclusion under section 951(a)(1)(A).
(B) Trigger of gain recognition agreement with election. Assume the same facts as in paragraph (i) of this Example, except that USP elected under paragraph (b)(1)(vii) of this section to include the amount of gain realized, but not recognized, on the initial transfer, $50, in the year of the triggering event rather than in the year of the initial transfer. The result is the same as above, except that USP will include the $50 of gain on its tax return for the year of the triggering event, together with interest. For purposes of determining the amount of the $50 gain characterized as a dividend pursuant to section 1248, if any, of the $50 inclusion, USP will take into account the section 1248 amount of CFC2 at the time of the disposition in the year of the triggering event.
(iii) Partial dispositions. If the transferee foreign corporation or any other person disposes of only a portion of the stock or securities of the transferred corporation, then the U.S. transferor is required to recognize only a proportionate amount of the gain realized, but not recognized, upon the initial transfer. The proportion required to be recognized shall be determined by reference to the fair market value of the transferred stock or securities disposed of and the total fair market value of the transferred stock or securities immediately before the disposition.
(2) Disposition of substantially all of the transferred corporation’s assets. A disposition of substantially all of the transferred corporation’s assets (including stock in a subsidiary corporation or an interest in a partnership) by the transferred corporation or any other person. Solely for purposes of this section, the term substantially all has the meaning provided under section 368(a)(1)(C). Accordingly, the determination of whether substantially all of the transferred corporation’s assets have been disposed of shall be made under all the facts and circumstances. For purposes of this paragraph (d)(2), dispositions of stock in connection with an asset reorganization of a corporation all or a portion the stock of which is owned by the transferred corporation, or a liquidation of a corporation the stock of which is owned by the transferred corporation in an amount satisfying the requirements of section 1504(a)(2) and to which sections 332 and 337 apply, shall not be taken into account. If the initial transfer was an indirect stock transfer, see §1.367(a)-3(d)(2)(v). If the transferred corporation is a domestic corporation, see paragraph (g)(2) of this section. For an example of when a disposition of substantially all the transferred corporation’s assets by a person other than the transferred corporation is a triggering event under this paragraph (d)(2), see paragraph (e)(6)(ii) of this section.
(3) Disposition of the stock of the transferee foreign corporation—(i) General rule. A disposition in whole or in part, by the U.S. transferor of the stock of the transferee foreign corporation that is received (or deemed received) in the initial transfer. For purposes of this section, a reference to stock described in the preceding sentence shall also include stock of the transferee foreign corporation the basis of which is determined, directly or indirectly, in whole or in part, by reference to the basis of the stock of the transferee foreign corporation that is received (or deemed received) in the initial transfer.
(ii) Partial dispositions. If the U.S. transferor disposes of only a portion of the stock of the transferee foreign corporation that is received (or deemed received) in the initial transfer, then the U.S. transferor is required to recognize only a proportionate amount of the gain realized, but not recognized, upon the initial transfer. The proportion required to be recognized shall be determined by reference to the fair market value of the transferee foreign corporation stock disposed of and the total fair market value of the transferee foreign corporation stock immediately before the disposition.
(4) Deconsolidation. A U.S. transferor that is a member of a consolidated group ceases to be a member of the consolidated group, other than by reason of an acquisition of the assets of the U.S. transferor in a transaction to which section 381(a) applies, or by reason of joining a new consolidated group as part of the same transaction. However, in the case of a transaction to which section 381(a) applies, see paragraph (d)(3) of this section (providing that a triggering event includes a disposition of the stock of the transferee foreign corporation).
(5) Consolidation. A U.S. transferor becomes a member of a consolidated group.
(6) Individual U.S. transferor becomes a non-citizen nonresident. A U.S. transferor that is an individual loses U.S. citizenship, or a U.S. transferor that is a long-term resident ceases to be taxed as a lawful permanent resident (as defined in section 877(e)(2)). Immediately before the date that the U.S. transferor loses U.S. citizenship or ceases to be taxed as a long-term resident, the gain recognition agreement will be triggered. No additional inclusion is required under section 877 with respect to the transferred stock or securities, and a gain recognition agreement under section 877 may not be used to avoid taxation under section 367(a) resulting from the trigger of the section 367(a) gain recognition agreement.
(7) Death of an individual; trust or estate goes out of existence. An individual U.S. transferor dies, or a U.S. transferor that is a trust or estate goes out of existence.
(8) Failure to comply. The failure to comply in any material respect with the requirements of this section or with the terms of a gain recognition agreement (for example, a failure to file an annual certification or Form 8838). Such a material failure to comply shall extend the period for assessment of tax until three years after the date on which the Director of Field Operations or Area Director receives actual notice of the failure to comply.
(e) Exceptions. Notwithstanding paragraph (d) of this section, the following events shall not constitute triggering events:
(1) Certain nonrecognition transactions—(i) Dispositions of stock of the transferee foreign corporation by the U.S. transferor—(A) Transfers to a corporation or partnership. Except to the extent provided in paragraph (g)(1)(iv) of this section, a disposition of stock of the transferee foreign corporation by the U.S. transferor in an exchange to which section 351, 354 (but only in a reorganization described in section 368(a)(1)(B)), or 721 applies, will not be a triggering event under paragraph (d)(3) of this section, and the original gain recognition agreement shall terminate without further effect, if the U.S. transferor complies with requirements similar to those contained in paragraph (e)(1)(ii) of this section, providing for notice and an agreement to recognize gain in the case of a direct or indirect disposition of the stock previously held by the U.S. transferor. See paragraph (e)(3)(i) of this section for dispositions of the transferee foreign corporation stock in certain asset reorganizations.
(B) Liquidations of the U.S. transferor under sections 332 and 337. The disposition of the transferee foreign corporation stock pursuant to a liquidation of the U.S. transferor under sections 332 and 337 will not be a triggering event under paragraph (d)(3) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(1) The distributee is a domestic corporation described in section 332(b)(1).
(2) The domestic distributee corporation (successor U.S. transferor) enters into a new gain recognition agreement pursuant to which it agrees to recognize gain (during the remaining term of the original gain recognition agreement), with respect to the initial transfer, modified by substituting the successor U.S. transferor in place of the original U.S. transferor, and agreeing to treat the successor U.S. transferor as the original U.S. transferor for purposes of this section. If, however, in connection with a liquidation described in section 332, the U.S. transferor recognizes gain under section 336 with respect to a portion of the stock of the transferee foreign corporation, and the conditions described in paragraph (g)(1) of this section are satisfied, the new gain recognition agreement that the successor U.S. transferor enters into shall reflect the gain realized, but not recognized, on the initial transfer (subject to adjustment for prior partial dispositions) less that proportion corresponding to gain recognized under section 336. The proportion is determined by reference to the relative fair market values of the transferee foreign corporation stock received (or deemed received) in the initial transfer on which the U.S. transferor recognized gain under section 336 and the total fair market value of the transferee foreign corporation stock received (or deemed received) by the U.S. transferor in the initial transfer that is distributed by the U.S. transferor in the liquidation.
(3) The successor U.S. transferor makes the election described in paragraph (b)(1)(vii) of this section. However, if the U.S. transferor was a member of a consolidated group in the year of the initial transfer, and the successor U.S. transferor is also a member of the original consolidated group immediately after the liquidation, no such election must be made.
(4) The successor U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) the new gain recognition agreement, a notice of the liquidation, and Form 8838 to extend the period for assessment of the tax on the initial transfer to a date not earlier than the eighth full taxable year following the taxable year of the initial transfer.
(ii) Transfers of stock or securities of the transferred corporation by the transferee foreign corporation to a corporation or partnership. Except to the extent provided in paragraph (f)(1)(i) of this section, a disposition of stock or securities of the transferred corporation by the transferee foreign corporation in an exchange to which section 351, 354 (but only in a reorganization described in section 368(a)(1)(B)), or 721 applies, will not be a triggering event described in paragraph (d)(1) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The transferee foreign corporation receives (or is deemed to receive) in exchange for the property disposed of, stock in a corporation, or an interest in a partnership, that acquired the transferred stock or securities (or receives stock in a corporation that controls the corporation acquiring the transferred stock or securities in the case of a triangular section 368(a)(1)(B) reorganization).
(B) The U.S. transferor provides a notice of the transfer with its next annual certification under paragraph (b)(5) of this section, setting forth—
(1) A full description of the transfer;
(2) The applicable nonrecognition provision; and
(3) The name, address, and taxpayer identification number (if any) of the new transferee of the transferred stock or securities.
(C) The U.S. transferor provides with its next annual certification a new gain recognition agreement pursuant to which it agrees to recognize gain (during the remaining term of the original gain recognition agreement) with respect to the initial transfer, and in which it agrees that any of the following events also constitutes a triggering event:
(1) A disposition of the stock or securities or partnership interest that the transferee foreign corporation received in exchange for the transferred stock or securities (other than in a disposition which itself qualifies under the rules of paragraph (e) of this section).
(2) The corporation or partnership that acquired the transferred stock or securities disposes of such property (other than in a disposition which itself qualifies under the rules of paragraph (e) of this section).
(3) Any other disposition that has the effect of an indirect disposition of the transferred stock or securities.
(iii) Transfers of the transferred corporation’s assets to a corporation or partnership. Except to the extent provided in paragraph (f)(1)(ii) of this section, a disposition of substantially all of the transferred corporation’s assets by the transferred corporation in an exchange to which section 351, 354 (but only in a reorganization described in section 368(a)(1)(B)—for example, where stock in a subsidiary corporation comprises substantially all of the transferred corporation’s assets), or 721 applies, will not be a triggering event under paragraph (d)(2) of this section, and the original gain recognition agreement shall terminate without further effect, if the transferred corporation receives (or is deemed to receive) in exchange for all or a portion of its assets stock in a corporation or an interest in a partnership that acquired the assets of the transferred corporation (or receives stock in a corporation that controls the corporation acquiring the assets) and the U.S. transferor complies with requirements similar to those contained in paragraph (e)(1)(ii) of this section, (providing for notice and an agreement to recognize gain in the case of a direct or indirect disposition of the assets previously held by the transferred corporation). See paragraph (e)(3)(iii) of this section for dispositions of substantially all of the transferred corporation’s assets in certain asset reorganizations.
(2) Recapitalizations—(i) Transferred corporation. Except to the extent provided in paragraph (f)(1) of this section, a transaction described in section 368(a)(1)(E) of the transferred corporation will not be a triggering event under paragraph (d)(1) of this section. The description of this exception that is required to be filed with the annual certification under paragraph (b)(5) of this section must include a description of the type or class, amount, and characteristics of the stock or securities that the transferred corporation issued in the reorganization.
(ii) Transferee foreign corporation. A section 368(a)(1)(E) reorganization of the transferee foreign corporation will not be a triggering event under paragraph (d)(3) of this section. The description of this exception that is required to be filed with the annual certification under paragraph (b)(5) of this section must include a description of the type or class, amount, and characteristics of the stock or securities that the transferee foreign corporation issued in the reorganization. See paragraph (g)(1) of this section for rules regarding the recognition of gain by the U.S. transferor in connection with nonrecognition exchanges.
(3) Certain asset reorganizations—(i) Transfers of transferee foreign corporation’s stock by U.S. transferor. Except to the extent provided in paragraph (g)(1)(iv) of this section, if the U.S. transferor transfers all or a portion of the stock of the transferee foreign corporation to a domestic acquiring corporation (successor U.S. transferor) pursuant to an asset reorganization, the exchanges made pursuant to such asset reorganization will not be triggering events described in paragraph (d)(3) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The common parent of the original consolidated group, successor U.S. transferor, or new common parent, as applicable, enters into a new gain recognition agreement pursuant to which the successor U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement) with respect to the initial transfer, modified by substituting the successor U.S. transferor in place of the original U.S. transferor and agreeing to treat the successor U.S. transferor as the original U.S. transferor for purposes of this section.
(B) The successor U.S. transferor or new common parent, as applicable, makes the election described in paragraph (b)(1)(vii) of this section. However, if the U.S. transferor was a member of a consolidated group in the year of the initial transfer, and the successor U.S. transferor is also a member of the original consolidated group immediately after the asset reorganization, no such election must be made.
(C) The successor U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section)—
(1) The new gain recognition agreement;
(2) A notice of the transfer setting forth a full description of the transfer (including the date of such transfer), and the successor U.S. transferor’s name, address, and taxpayer identification number; and
(3) Form 8838 to extend the period for assessment of the tax on the initial transfer to a date not earlier than the eighth full taxable year following the taxable year of the initial transfer.
(ii) Transfers of transferred corporation stock or securities by transferee foreign corporation to a foreign acquiring corporation. Except to the extent provided in paragraph (f)(1) of this section, if the transferee foreign corporation transfers all or a portion of the stock or securities of the transferred corporation to a foreign acquiring corporation (successor transferee foreign corporation) in an asset reorganization, the exchanges made pursuant to such reorganization will not be triggering events described in paragraph (d)(1) or (d)(3) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The U.S. transferor or common parent, as applicable, enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement), with respect to the initial transfer, substituting the successor transferee foreign corporation in place of the original transferee foreign corporation, and agreeing to treat the successor transferee foreign corporation as the original transferee foreign corporation for purposes of this section.
(B) The U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) the new gain recognition agreement and a notice of the transfer setting forth a full description of the transfer (including the date of such transfer), and the successor transferee foreign corporation’s name, address, and taxpayer identification number (if any).
(iii) Transfers of substantially all of the transferred corporation’s assets. Except to the extent provided in paragraph (f)(2) of this section, if the transferred corporation transfers substantially all of its assets to an acquiring corporation (successor transferred corporation) pursuant to an asset reorganization, the exchanges made pursuant to such asset reorganization will not be triggering events under paragraph (d)(1) or (d)(2) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The U.S. transferor or common parent, as applicable, enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement), with respect to the initial transfer, modified by—
(1) Substituting the successor transferred corporation in place of the original transferred corporation and agreeing to treat the successor transferred corporation as the original transferred corporation for purposes of this section; and
(2) Treating only the assets acquired by the successor transferred corporation from the original transferred corporation pursuant to the asset reorganization as the assets subject to the triggering event rules under paragraph (d)(2) of this section.
(B) The U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) the new gain recognition agreement and a notice of the transfer setting forth a full description of the transfer (including the date of such transfer), and the successor transferred corporation’s name, address, and taxpayer identification number (if any).
(iv) Example. The rules of paragraph (e)(3) of this section are illustrated by the following examples:
Example 1. (i) Facts. UST, a domestic corporation incorporated under the laws of State A, owns 100% of the stock of TFD, a foreign corporation. In year 1, UST transfers all of the TFD stock to TFC, a foreign corporation, in an exchange to which section 351 applies. In the exchange, UST receives 100% of the stock of TFC. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement. UST also complies with the notice requirement under §1.367(b)-1(c). In year 3, UST transfers its assets in a section 361(a) exchange to USA, a newly formed domestic corporation incorporated under the laws of State B, in exchange for stock of USA, and UST distributes such stock to its shareholders in a transaction described in section 368(a)(1)(F).
(ii) Result. The transfer of the TFC stock by UST to USA pursuant to the section 368(a)(1)(F) reorganization is a triggering event under paragraph (d)(3) of this section. If, however, UST complies with the requirements contained in paragraph (e)(3)(i) of this section, the transfer will not be a triggering event.
(iii) Alternate facts. The facts are the same as in paragraph (i) of this Example 1, except that the acquiring corporation is foreign instead of domestic. Because paragraph (e)(3)(i) of this section provides an exception to a triggering event under paragraph (d)(3) of this section only if the acquiring corporation in the asset reorganization is a domestic corporation, the section 368(a)(1)(F) reorganization is a triggering event without exception. See also section 367(a)(5) and §§1.367(a)-1T(f) and 1.367(a)-3T(e) (providing that certain corporate shareholders of a U.S. transferor may enter into a gain recognition agreement when the U.S. transferor goes out of existence in a section 361 initial transfer).
Example 2. (i) Facts. UST, a domestic corporation, owns 100% of the stock of three foreign corporations, FC1, FC2 and FC3. In year 1, USP transfers 100% of the stock of FC1 to FC2 in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement. UST also complies with the notice requirement under §1.367(b)-1(c). In year 4, in a reorganization described in section 368(a)(1)(D), FC2 transfers all of its assets, including the stock of FC1, to FC3 in exchange for FC3 stock. FC2 transfers the FC3 stock to UST in exchange for FC2 stock held by UST, and the FC2 stock is canceled.
(ii) Analysis. The transfer of FC1 stock to FC3 and the exchange of FC2 stock for FC3 stock by UST pursuant to the reorganization described in section 368(a)(1)(D) are triggering events under paragraphs (d)(1) and (d)(3) of this section. If, however, UST complies with the requirements contained in paragraph (e)(3)(ii) of this section, the transfers will not be triggering events.
Example 3. (i) Facts. UST, a domestic corporation, owns 100% of the stock of two foreign corporations, FC1 and FC2. In year 1, UST transfers 100% of the stock of FC1 to FC2 in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement. UST also complies with the notice requirement under §1.367(b)-1(c). In year 4, in a reorganization described in section 368(a)(1)(C), FC1 transfers all of its assets to FC3, an unrelated foreign corporation, in exchange for FC3 stock. FC1 transfers the FC3 stock to FC2 in exchange for the FC1 stock held by FC2 and the FC1 stock is canceled.
(ii) Analysis. FC1’s transfer of all of its assets to FC3 and FC2’s exchange of FC1 stock for FC3 stock pursuant to the reorganization described in section 368(a)(1)(C) are triggering events under paragraphs (d)(2) and (d)(1) of this section, respectively. If, however, UST complies with the requirements contained in paragraph (e)(3)(iii) of this section, the transfers will not be triggering events.
(4) Certain triangular reorganizations—(i) Triangular asset reorganizations of the transferee foreign corporation. For purposes of this paragraph (e)(4), the term triangular asset reorganization means a triangular reorganization described in §1.358-6(b)(2)(i) through (iii) or in sections 368(a)(1)(G) and (a)(2)(D) where the acquiring subsidiary is foreign. Except to the extent provided in paragraph (f)(1) or (g)(1)(iv) of this section, the exchanges made pursuant to a triangular asset reorganization of the transferee foreign corporation will not be triggering events under paragraph (d)(1) or (d)(3) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The U.S. transferor or common parent, as applicable, enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement), with respect to the initial transfer, and in which the U.S. transferor agrees to—
(1) If the parent corporation of the foreign acquiring subsidiary is foreign, treat such foreign parent as the original transferee foreign corporation for purposes of this section and treat as a triggering event a disposition of the stock of the foreign acquiring subsidiary, or, in the case of a reorganization described in section 368(a)(2)(E), the corporation originally identified as the transferee foreign corporation; and
(2) If the parent corporation of the foreign acquiring subsidiary is domestic, treat the foreign acquiring subsidiary as the original transferee foreign corporation for purposes of this section, and apply the principles of paragraph (g) of this section to taxable dispositions by the domestic parent corporation of the foreign acquiring subsidiary or, in the case of a reorganization described in section 368(a)(2)(E), the corporation originally identified as the transferee foreign corporation. In the case of a reorganization described in section 368(a)(2)(E) where the transferee foreign corporation is the merged corporation, rather than the surviving corporation, then the surviving corporation shall be treated as the transferee foreign corporation for purposes of this section.
(B) The U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) the new gain recognition agreement and a notice of the transfer setting forth a full description of the transfer (including the date of such transfer) and the name, address, and taxpayer identification number (if any) for the parent corporation of the foreign acquiring subsidiary.
(ii) Triangular asset reorganizations of the transferred corporation. Except to the extent provided in paragraph (f)(1) or (f)(2) of this section, the exchanges made pursuant to a triangular asset reorganization of the transferred corporation will not be triggering events in paragraph (d)(1) or (d)(2) of this section, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(A) The U.S. transferor or common parent, as applicable, enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement), in accordance with the rules of paragraph (b) of this section, with respect to the initial transfer, and in which the U.S. transferor agrees to—
(1) Treat a disposition of the stock of the acquiring parent as a triggering event;
(2) If the reorganization is a triangular C reorganization or a reorganization described in section 368(a)(2)(D), treat a disposition of the stock of the foreign acquiring subsidiary as a triggering event; and
(3) If the reorganization is described in section 368(a)(2)(E) and the merged corporation is the transferred corporation, treat a disposition of the stock of the surviving corporation as a triggering event.
(5) Compulsory transfers. A compulsory transfer under §1.367(a)-4T(f)(2) that is not reasonably foreseeable by the U.S. transferor is not a triggering event under paragraphs (d)(1) through (d)(3) of this section.
(6) Certain liquidations and upstream reorganizations of the transferred corporation into the transferee foreign corporation—(i) General rule. A transfer of assets by the transferred corporation to the transferee foreign corporation pursuant to a liquidation described in section 332, where the transferee foreign corporation is described in section 332(b)(1), or pursuant to a reorganization described in section 368(a), and related exchanges of stock or securities of the transferred corporation will not be triggering events under paragraph (d)(1) or (d)(2) of this section. The description of this exception that is required to be filed with the annual certification under paragraph (b)(5) of this section must include a description of the transaction. In such a case, the original gain recognition agreement shall continue to apply during the remainder of its term. If, however, in connection with a liquidation described in section 332, the transferred corporation recognizes gain under section 336 with respect to a portion of its assets, such assets shall be treated as disposed of for purposes of paragraph (d)(2) of this section.
(ii) Example. The principles of this paragraph (e)(6) are illustrated by the following example:
Example. (i) Facts. UST, a domestic corporation, owns 100 percent of the stock of TFD, a foreign corporation. UST transfers all of the TFD stock to newly-formed TFC, a foreign corporation, in an exchange to which section 351 applies. In the exchange, UST receives 100 percent of the voting stock of TFC. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement to qualify for nonrecognition treatment and does not make the election described in paragraph (b)(1)(vii) of this section. UST also complies with the notice requirement under §1.367(b)-1(c). Two years after the initial transfer, TFD liquidates into TFC in a transaction described in sections 332 and 337, and UST complies with the requirements of this paragraph (e)(6). Four years after the initial transfer, TFC disposes of substantially all of the assets previously held by TFD.
(ii) Result. Because paragraph (d)(2) of this section provides that a disposition of substantially all of the transferred corporation’s assets by any person is a triggering event, TFC’s disposition of substantially all of the assets previously held by TFD is a triggering event. Under the terms of the gain recognition agreement, UST must amend its return for the year of the initial transfer and include in income the gain realized, but not recognized, on the initial transfer of the stock of TFD to TFC, and pay any interest charge.
(7) Death of an individual U.S. transferor. If the U.S. transferor is an individual and such individual dies, the individual’s death will not be a triggering event under paragraph (d)(7) of this section, if—
(i) The person winding up the affairs of the U.S. transferor retains, for the duration of the waiver of the statute of limitations relating to the gain recognition agreement, assets to meet any possible liability of the U.S. transferor under the duration of the gain recognition agreement;
(ii) The person winding up the affairs of the U.S. transferor provides security as provided under paragraph (c) of this section for any possible liability of the U.S. transferor under the gain recognition agreement; or
(iii) The person winding up the affairs of the U.S. transferor obtains a ruling from the Internal Revenue Service providing for successors to the U.S. transferor under the gain recognition agreement.
(8) Deconsolidation. A deconsolidation described in paragraph (d)(4) of this section will not be a triggering event, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(i) The U.S. transferor enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement) with respect to the initial transfer and makes the election described in paragraph (b)(1)(vii) of this section.
(ii) The U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) notice of the deconsolidation.
(9) Consolidation. A consolidation described in paragraph (d)(5) of this section will not be a triggering event, and the original gain recognition agreement shall terminate without further effect, if the following conditions are satisfied:
(i) The common parent of the consolidated group that includes the U.S. transferor immediately after the consolidation enters into a new gain recognition agreement pursuant to which the U.S. transferor agrees to recognize gain (during the remaining term of the original gain recognition agreement) with respect to the initial transfer and in which it makes the election described in paragraph (b)(1)(vii) of this section.
(ii) The U.S. transferor provides with its next annual certification (described in paragraph (b)(5) of this section) a notice of the consolidation.
(10) Reasonable cause exception for failure to comply—(i) Request for relief. A failure to comply described in paragraph (d)(8) of this section will not be a triggering event, and the timeliness requirement with respect to a gain recognition agreement shall be considered satisfied notwithstanding a failure to file the agreement in a timely manner, if the person required to file the gain recognition agreement, annual certification, or Form 8838 is able to demonstrate to the Area Director, Field Examination, Small Business/Self Employed or the Director of Field Operations, Large and Mid-Size Business (Director) having jurisdiction of the taxpayer’s tax return for the taxable year, that such failure was due to reasonable cause and not willful neglect. In determining whether the person has reasonable cause, the Director shall consider whether the person acted reasonably and in good faith. Whether the person acted reasonably and in good faith will be determined after considering all the facts and circumstances. The Director shall notify the person in writing within 120 days of the filing if it is determined that the failure to comply was not due to reasonable cause, or if additional time will be needed to make such determination. For this purpose, the 120-day period shall begin to run on the date the Service notifies the person in writing that the request has been received and assigned for review. Once such period commences, if the person is not again notified within 120 days, then the person shall be deemed to have established reasonable cause. The reasonable cause exception of this paragraph (e)(10) shall apply only if, once the person becomes aware of the failure to file or comply with the agreement, the person complies with the requirements of paragraph (e)(10)(ii) of this section.
(ii) Requirements for reasonable cause relief—(A) Time of submission. Requests for reasonable cause relief will only be considered if once the person becomes aware of the failure to file or comply with the agreement, the person attaches all the documents that should have been filed, as well as a complete written statement setting forth the reasons for the failure to timely comply, to an amended return that amends the return to which the documents should have been attached pursuant to the rules of section 367(a) and the regulations under that paragraph.
(B) Notice requirement. In addition to the requirement of paragraph (e)(10)(ii)(A) of this section, the person must provide a copy of the amended return and all required attachments to the Director as follows:
(1) If the taxpayer is under examination for any taxable year when the person requests relief, the taxpayer must provide a copy of the amended return and attachments to the personnel conducting the examination.
(2) If the taxpayer is not under examination for any taxable year when the person requests relief, the taxpayer must provide a copy of the amended return and attachments to the Director having jurisdiction over the taxpayer’s return.
(f) Gain recognized in connection with certain nonrecognition transactions—(1) Dispositions of transferred stock or securities—(i) General rule. If a disposition of the transferred stock or securities occurs in connection with a nonrecognition transaction described in paragraph (e)(1)(ii), (e)(2)(i), (e)(3)(ii), (e)(3)(iii), or (e)(4) of this section and gain is recognized by the transferee foreign corporation in connection with the transaction (for example, under sections 351(b) or 356(a)(1)), the U.S. transferor must recognize gain pursuant to the gain recognition agreement as determined under paragraph (f)(1)(ii) of this section. This paragraph (f)(1)(i) shall not apply to the extent that the gain recognized is treated as a dividend under section 356(a)(2).
(ii) Method for determining amount of gain to be recognized. The portion of the gain recognition agreement that must be recognized under paragraph (f)(1)(i) of this section, if any, is the gain that would be recognized by the transferee foreign corporation on such disposition (but not in excess of the amount of the gain recognition agreement). For purposes of this paragraph (f)(1)(ii), the gain that would be recognized in the nonrecognition transactions listed in paragraph (f)(1)(i) of this section by the transferee foreign corporation shall be calculated before taking into account any basis increase that may apply under paragraph (b)(3)(iv) of this section as a result of the gain that the U.S. transferor is required to recognize. If the amount of gain that the transferee foreign corporation would be required to recognize is less than the amount of the gain subject to the gain recognition agreement, then the new gain recognition agreement filed pursuant to paragraph (e)(1)(ii), (e)(2)(i), (e)(3)(ii), (e)(3)(iii), or (e)(4) of this section shall provide that the U.S. transferor shall recognize the remaining portion of the gain that was realized, but not recognized, on the initial transfer if a subsequent triggering event occurs.
(iii) Example. The rule of this paragraph (f)(1) is illustrated by the following example:
Example. (i) Facts. UST, a domestic corporation owning 100% of the stock of TFD, a foreign corporation, transfers all of the TFD stock to newly-formed TFC, a foreign corporation, in an exchange to which section 351 applies. In the exchange, UST receives 100% of the stock of TFC. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement to qualify for nonrecognition treatment and does not make the election contained in paragraph (b)(1)(vii) of this section. UST also complies with the notice requirement under §1.367(b)-1(c). At the time of the initial transfer, UST has a basis of $50 in the stock of TFD, which has a fair market value of $100. Thus, the amount of gain subject to the gain recognition agreement is $50. Two years after the initial transfer, TFC and X, an unrelated domestic corporation, form CFC, a foreign corporation. TFC transfers the stock of TFD to CFC in an exchange to which section 351 applies. UST also complies with the notice requirement under §1.367(b)-1(c). At the time of the transfer, TFC’s basis in the TFD stock equals $50 and the fair market value remains $100. In the exchange, TFC receives 25% of the stock of CFC and $35 of cash. Before taking into account adjustments made under paragraph (b)(3)(iv) of this section, TFC would recognize $35 of gain under section 351(b). X transfers property to CFC in exchange for the remaining 75% of the CFC stock. Under paragraph (d)(1) of this section, TFC’s disposition of the TFD stock is a triggering event. However, UST complies with the requirements of paragraph (e)(1)(ii) of this section providing for an exception to the triggering event.
(ii) Result. Under paragraph (f)(1)(ii) of this section, pursuant to the terms of the gain recognition agreement, UST must recognize $35 of the $50 gain realized, but not recognized, on the initial transfer. The new gain recognition agreement that UST files pursuant to paragraph (e)(1)(ii)(C) of this section will reflect the $15 that remains of the gain realized, but not recognized, on the initial transfer. Under paragraph (b)(3)(iv)(A) of this section, TFC’s basis in the TFD stock is increased (as of the date of the initial transfer) by $35 to $85. Under paragraph (b)(3)(iv)(B) of this section, UST’s basis in the TFC stock is also increased by $35. Finally, after taking account of adjustments under paragraph (b)(3)(iv) of this section, TFC must recognize $15 of gain under section 351(b).
(2) Dispositions of substantially all of the transferred corporation’s assets. If a disposition of substantially all of the assets of the transferred corporation occurs in connection with a nonrecognition transaction described in paragraph (e)(1)(iii), (e)(3)(iii), or (e)(4)(ii) of this section and gain is recognized on such disposition (for example, under section 351(b) or 356(a)(1)), the U.S. transferor must recognize gain pursuant to the gain recognition agreement to the extent of such gain recognized (but not in excess of the gain realized, but not recognized, on the initial transfer). This paragraph (f)(2) shall not apply to the extent that recognized gain is treated as a dividend under section 356(a)(2).
(g) Transactions that terminate the gain recognition agreement or reduce the amount of gain required to be recognized pursuant to a gain recognition agreement. Notwithstanding paragraph (d) of this section, the following events shall not constitute triggering events and instead shall either terminate the gain recognition agreement, or reduce the amount of gain required to be recognized pursuant to a gain recognition agreement:
(1) Taxable disposition of stock of the transferee foreign corporation by U.S. transferor—(i) General rule. If the U.S. transferor disposes of all the stock of the transferee foreign corporation that is received (or deemed received) in the initial transfer, then the gain recognition agreement shall terminate without further effect if—
(A) Immediately before the disposition, the aggregate basis of the transferee foreign corporation stock disposed of does not exceed the sum of the aggregate basis of the transferred stock or securities immediately before the initial transfer plus any increase in the basis of such stock or securities as a result of the recognition of gain on the initial transfer. For purposes of this paragraph (g)(1)(i)(A), an increase in basis of the stock disposed of as a result of an income inclusion with respect to such stock (for example, pursuant to section 961) shall not be taken into account; and
(B) All realized gain (if any) in the stock disposed of is recognized currently and included in taxable income as a result of the disposition.
(ii) Partial dispositions—(A) General rule. If the U.S. transferor disposes of a portion of the stock of the transferee foreign corporation that is received (or deemed received) in the initial transfer in a transaction that satisfies the conditions described in paragraphs (g)(1)(i)(A) and (B) of this section, such disposition will not be a triggering event and the gain recognition shall remain in effect. For purposes of determining whether the condition described in paragraph (g)(1)(i)(A) of this section is satisfied, however, the aggregate basis of the stock of the transferee foreign corporation disposed of is compared to the aggregate basis of the transferred stock or securities exchanged for such stock at the time of the initial transfer.
(B) Subsequent triggering event. If the gain recognition agreement is triggered after a disposition described in paragraph (g)(1)(ii)(A) of this section, the U.S. transferor shall be required to recognize only a proportionate amount of the gain subject to the gain recognition agreement that otherwise would be required to be recognized on a subsequent triggering event. Except as provided in paragraph (g)(1)(iv) of this section, the proportion required to be recognized shall be determined by reference to the percentage of stock (based on relative fair market value) of the transferee foreign corporation received (or deemed received) in the initial transfer that is retained by the U.S. transferor.
(iii) The rule of paragraph (g)(1)(ii) of this section is illustrated by the following example:
Example. (i) Facts. A, a United States citizen, owns 100% of the outstanding stock of foreign corporation X. In a transaction to which section 351 applies, A exchanges his stock in X (and other assets) for 100% of the outstanding stock of foreign corporation Y. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). A enters into a gain recognition agreement, makes the election contained in paragraph (b)(1)(vii) of this section, and also complies with the notice requirement under §1.367(b)-1(c). In the second year following the initial transfer, A disposes of 60% of the fair market value of the stock of Y, and the requirements of paragraphs (g)(1)(i)(A) and (B) are met with respect to such disposition. In the fourth year following the initial transfer, Y disposes of 50% of the fair market value of the stock of X.
(ii) Result. The disposition of 60% of the stock of Y is not a triggering event, and the gain recognition agreement continues in effect. The disposition of X stock, however, is a triggering event under paragraph (d)(1)(i) of this section. As a result of the subsequent disposition of 50% of the stock of X, under paragraphs (d)(1)(iii) and (g)(1)(ii)(B) of this section, A is required to include in income in the year of such disposition 20% (40% of the fair market value of Y multiplied by 50% of the fair market value of X) of the gain that A realized but did not recognize on the initial transfer of the X stock to Y, and pay any applicable interest.
(iv) Certain nonrecognition transactions. The rules described in these paragraphs (g)(1)(iv)(A) through (C) apply if the U.S. transferor disposes of all or a portion of the stock of the transferee foreign corporation received (or deemed received) in the initial transfer pursuant to a nonrecognition transaction described in paragraph (e)(1)(i), (e)(2)(ii), (e)(3)(i), or (e)(3)(ii) of this section, the condition described in paragraph (g)(1)(i)(A) of this section is satisfied with respect to such disposition, and gain is recognized in connection with the disposition (for example, under sections 351(b), 356(a)(1), or 336). If, however, only a portion of the stock of the transferee corporation stock is disposed of pursuant to this paragraph (g)(1)(iv), then for purposes of determining whether the condition described in paragraph (g)(1)(i)(A) of this section is satisfied, the aggregate basis of the stock disposed of is compared to the aggregate basis of the transferred stock or securities exchanged for such stock at the time of the initial transfer.
(A) U.S. transferor files new gain recognition agreement. This paragraph (g)(1)(iv)(A) applies if the U.S. transferor (or successor U.S. transferor, as applicable) enters into a new gain recognition agreement as provided in paragraph (e)(1)(i), (e)(3)(i), or (e)(3)(ii) of this section, as applicable. In such a case, the amount of gain subject to the new gain recognition agreement shall equal the amount of gain realized, but not recognized, on the initial transfer, less any gain recognized by the U.S. transferor in connection with the nonrecognition transaction. If the amount of gain recognized on the transfer is equal to or greater than the amount of gain realized, but not recognized, on the initial transfer, then the original gain recognition agreement shall terminate without further effect.
(B) U.S. transferor does not file a new gain recognition agreement. This paragraph (g)(1)(iv)(B) applies if the U.S. transferor (or successor U.S. transferor, as applicable) fails to enter into a new gain recognition agreement as provided in paragraph (e)(1)(i), (e)(3)(i), or (e)(3)(ii) of this section, as applicable. In such a case, the amount required to be recognized by the U.S. transferor pursuant to the gain recognition agreement shall be the amount of gain realized, but not recognized, on the initial transfer, less any gain recognized by the U.S. transferor in connection with the nonrecognition transaction.
(C) Special rule for recapitalizations. Because paragraph (e)(2)(ii) of this section does not require the U.S. transferor to enter into a new gain recognition agreement, the amount of gain subject to the gain recognition agreement shall equal the amount of gain realized, but not recognized, on the initial transfer, less any gain recognized by the U.S. transferor in connection with the nonrecognition transaction described in paragraph (e)(2)(ii) of this section.
(v) Election to reduce basis—(A) General rule. For purposes of paragraphs (g)(1)(i), (ii) and (iv) of this section, the U.S. transferor may elect to reduce its aggregate basis in the stock disposed of effective immediately before the disposition such that the condition described in paragraph (g)(1)(i)(A) is satisfied. If an election is made pursuant to this paragraph (g)(1)(v), the U.S. transferor may increase its basis in other stock of the transferee foreign corporation it holds, if any, by a corresponding amount but not above the fair market value of such stock.
(B) Election. The election pursuant to this paragraph (g)(1)(v) is made by filing with the U.S. transferor’s income tax return for the taxable year in which the disposition of the transferee foreign corporation stock occurs, a statement setting forth the following information, with the heading “Election to Reduce Stock Basis Under §1.367(a)-8T(g)(1)(v)”:
(1) A description of the transferee foreign corporation stock that the U.S. transferor has disposed of.
(2) An estimate of the fair market value of the stock as of the date of the disposition.
(3) A comparison of the basis of the transferee foreign corporation stock before and after the election that is made pursuant to this paragraph (g)(1)(v).
(4) The date on which the transferee foreign corporation stock was disposed of by the U.S. transferor.
(vi) The rules of paragraph (g)(1) of this section are illustrated by the following examples:
Example 1. (i) Facts. USP, a domestic corporation, owns 100% of the stock of two foreign corporations, FC1 and FC2. The basis and fair market value of the FC1 stock is $100 and $90, respectively. The basis and fair market value of the FC2 stock is $0 and $100, respectively. USP also owns land that has a basis and fair market value of $10. In year 1, USP transfers 100% of the stock of FC1 and FC2 and the land to FC3, a newly formed foreign corporation, in exchange for 20 shares of FC3 stock. The transfer of the stock of FC1 and FC2 qualifies under section 351 and section 368(a)(1)(B). The transfer of the land qualifies under section 351. The transfer of the FC2 stock is subject to both section 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). Pursuant to §1.367(a)-3(b)(1)(ii) and this section, USP enters into a gain recognition agreement with respect to the $100 of gain in the FC2 stock and complies with the notice requirement under §1.367(b)-1(c). USP takes the position that its basis in each of the 20 shares of FC3 stock received in the transfer equals $5.5 (($100+$0+10)/20). In year 3, USP sells 100% of its FC3 stock to an unrelated person for cash.
(ii) Result. The disposition of the FC3 stock is a triggering event described in paragraph (d)(3) of this section. The disposition does not terminate the gain recognition agreement pursuant to paragraph (g)(1)(i) of this section because USP takes the position that the basis of each of the 10 shares of FC3 stock it received in exchange for the FC2 stock in the initial transfer equals $5.5. Thus, the total basis in the 10 shares received for the FC2 stock equals $55, which exceeds the $0 basis USP had in the FC2 stock it transferred to FC3 in the initial transfer. As a result, the condition described in paragraph (g)(1)(i)(A) of this section is not satisfied. USP may, however, elect to reduce its basis in 10 of the FC3 shares it disposes of from $5.5 to $0, and increase its basis in its remaining 10 shares of FC2 stock by $5.5, pursuant to paragraph (g)(1)(v) of this section. As a result, the condition described in paragraph (g)(1)(i)(A) of this section would be satisfied, the disposition would not be a triggering event, and the gain recognition would terminate without further effect.
Example 2. (i) Facts. USP, a domestic corporation, owns 100% of the stock of FC1, a foreign corporation. The basis and fair market value of the FC1 stock is $0 and $80, respectively. In year 1, USP transfers 100% of the stock of FC1 to FC2, a newly formed foreign corporation, in exchange for 20 shares of FC2 stock. The transfer of the stock of FC1 qualifies under section 351 and section 368(a)(1)(B). The transfer of the FC1 stock is subject to both section 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). Pursuant to §1.367(a)-3(b)(1)(ii) and this section, USP enters into a gain recognition agreement with respect to the $80 of gain in the FC1 stock and complies with the notice requirement under §1.367(b)-1(c). USP’s basis and fair market value in the FC2 stock it receives at the time of the transfer is $0 and $80, respectively. In year 3, when the fair market value of the FC2 stock continues to equal $80, USP transfers land that has a basis and fair market value of $20 to FC2 in a transfer that qualifies under section 351, but does not receive additional shares of FC2 in connection with such transfer. In year 5, USP sells 100% of its FC2 stock to an unrelated person for cash.
(ii) Result. The disposition of the FC3 stock is a triggering event described in paragraph (d)(3) of this section. The disposition would not terminate the gain recognition agreement pursuant to paragraph (g)(1)(i) of this section if the basis in each of the 20 FC2 shares that USP sells equals $1 ($20/20 shares) because immediately before the disposition the basis in the FC2 shares received for the FC1 shares exceeds the basis of the FC1 shares at the time of the initial transfer. As a result, the condition described in paragraph (g)(1)(i)(A) of this section would not be satisfied. USP may, however, elect to adjust its basis in its FC2 shares such that 16 of the shares have zero basis (reflecting the basis of the FC1 stock) and 4 of the shares have $20 of basis (reflecting the basis of the land). In such a case, the condition described in paragraph (g)(1)(i)(A) of this section would be satisfied, the disposition would not be a triggering event, and the gain recognition agreement would terminate without further effect.
(2) Certain dispositions by a domestic transferred corporation of substantially all of its assets. If, immediately before the initial transfer, the U.S. transferor owned an amount of stock in the transferred corporation described in section 1504(a)(2), and the transferred corporation is domestic, then the gain recognition agreement shall terminate without further effect if the transferred corporation disposes of substantially all of its assets in a transaction in which all realized gain is recognized currently. If an indirect stock transfer necessitated the filing of the gain recognition agreement, such agreement shall terminate if, immediately before the indirect transfer, the U.S. transferor owned an amount of stock in the acquired corporation described in section 1504(a)(2) (or, in the case of a section 368(a)(1)(A) and (a)(2)(E) reorganization described in §1.367(a)-3(d)(1)(ii), the U.S. transferor owned an amount of stock in the acquiring corporation described in section 1504(a)(2)) and the transferred corporation disposes of substantially all of its assets (taking into account §1.367(a)-3(d)(2)(v)) in a transaction in which all realized gain is recognized currently.
(3) Distribution or transfer by transferee foreign corporation of stock or securities of transferred corporation under section 337, 355 or 361—(i) Scope. This paragraph (g)(3) applies if the transferee foreign corporation distributes or transfers the stock or securities that initially necessitated the filing of the gain recognition agreement (and any additional stock received after the initial transfer) pursuant to any of the following transactions:
(A) A liquidating distribution to the U.S. transferor or a domestic corporation that is a member of the same consolidated group of which the U.S. transferor is then a member and that qualifies under sections 332 and 337, if such domestic distributee corporation is described in section 332(b)(1).
(B) A distribution to the U.S. transferor, a domestic corporation that is a member of the same consolidated group of which the U.S. transferor is a member, or an individual that is a United States person, that qualifies under section 355.
(C) A transfer to the U.S. transferor or a domestic corporation that is a member of the same consolidated group of which the U.S. transferor is then a member and to which section 361 applies (but, if in connection with a reorganization described in section 368(a)(1)(D) or (G), only if the requirements of section 354(b)(1)(A) and (B) are met).
(ii) General rule. If a distribution or transfer is described in paragraph (g)(3)(i) of this section, the gain recognition agreement shall terminate without further effect, provided that immediately after such distribution or transfer the basis in the transferred stock or securities in the hands of the domestic corporation or individual, as applicable, does not exceed the basis that the U.S. transferor had in the transferred stock or securities immediately before the initial transfer. For purposes of this paragraph (g)(3)(ii), only the basis in the stock or securities transferred shall be taken into account, and increases to stock basis as a result of income inclusions with respect to stock (for example, pursuant to section 961) shall not be taken into account. In the case of a transaction described in paragraph (g)(3)(i)(B) of this section, any reductions or redistributions of stock basis under §1.367(b)-5(c)(2) or (4), respectively, shall be made before applying the rules of this paragraph (g)(3)(ii).
(iii) Election to reduce basis in stock or securities of transferred corporation. For purposes of paragraph (g)(3)(ii) of this section, the domestic corporation or individual, as applicable, may elect to reduce the basis in the stock or securities transferred to equal the basis the U.S. transferor had in the corresponding transferred stock or securities immediately before the initial transfer, such that the gain recognition agreement shall terminate without further effect. If such an election is made, the domestic corporation or individual may increase its basis in other stock of the transferred corporation it holds, if any, by a corresponding amount but not above the fair market value of such stock.
(iv) Election. The election pursuant to paragraph (g)(3)(iii) of this section is made by filing with the domestic corporation’s or individual’s income tax return for the taxable year in which the distribution or transfer occurs, a statement setting forth the following information, with the heading “Election to Reduce Stock Basis Under §1.367(a)-8T(g)(3)(iii)”:
(1) A description of the stock or securities received.
(2) An estimate of the fair market value of the stock or securities as of the date of their receipt.
(3) A statement comparing the basis of the stock or securities before and after the election.
(4) The date on which the stock or securities were received.
(v) Examples. The rules of paragraph (g)(3) of this section are illustrated by the following examples:
Example 1. (i) Facts. USP, a domestic corporation, owns 100% of the stock of two foreign corporations, FC1 and FC2. FC1 has 10 shares of stock issued and outstanding. In year 1, when the basis and fair market value of the FC1 stock is $0 and $90, respectively, USP transfers its 10 shares of FC1 stock to FC2 in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). Pursuant to §1.367(a)-3(b)(1)(ii) and this section, USP enters into a gain recognition agreement with respect to such transfer. USP also complies with the notice requirement under §1.367(b)-1(c). In year 2, FC2 transfers land with a basis and fair market value of $10 to FC1 in exchange for one newly issued share of FC1 stock. In year 4, FC2 distributes all of its FC1 stock to USP in a liquidating distribution that qualifies under sections 332 and 337.
(ii) Result. In determining whether the gain recognition agreement entered into by USP is terminated under paragraph (g)(3) of this section, or in the alternative triggered under paragraph (d)(1) of this section, only the stock of FC1 transferred by USP to FC2 in year 1 is considered. Thus, the basis in the one share of FC1 stock issued to FC2 in year 2 in exchange for land is not taken into account. If instead of FC1 actually issuing another share of stock to FC2 in exchange for the land, FC1 was deemed to issue stock to FC2 in such exchange, then the gain recognition agreement would terminate only if USP elects to adjust the basis in its FC1 shares such that nine of the shares have zero basis and one of the shares has $10 of basis.
Example 2. (i) Facts. USP, a domestic corporation, owns 100% of the stock of two foreign corporations, FC and FD. In year 1, USP transfers 100% of the stock of FC to FD in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). At the time of the initial transfer, USP has a basis of $80 in its stock of FC; the stock of FC has a fair market value of $100. USP’s basis in its stock of FD, and the fair market value of the FD stock, are both $100. Pursuant to §1.367(a)-3(b)(1)(ii) and this section, USP enters into a gain recognition agreement with respect to the initial transfer. USP also complies with the notice requirement under §1.367(b)-1(c). In year 4, FD distributes all of the stock of FC to USP in a pro rata distribution to which section 355 applies. At the time of the distribution, the fair market value of the FC stock has increased to $200, while the fair market value of the FD stock has remained $100. Under section 358, USP allocates its $180 predistribution basis in its FD stock between the FD stock and FC stock according to the stock blocks’ relative fair market values, yielding a $60 basis in the FD stock and a $120 basis in the FC stock. Immediately before the distribution, USP’s section 1248 amount with respect to FC and FD is zero.
(ii) Result. The distribution of FC stock is a triggering event under paragraph (d)(1) of this section. The distribution does not terminate the gain recognition agreement under paragraph (g)(3) of this section because after the distribution, USP’s basis of $120 in the FC stock exceeds the $80 basis that USP had in the FC stock at the time of the initial transfer. If, however, USP elects to reduce its basis in the FC stock it receives to $80, then the condition described in paragraph (g)(3) of this section will be satisfied, and the gain recognition agreement will terminate without further effect. In addition, the $40 of basis that USP elected to reduce is redistributed to the stock of FD, the result of which is that USP has a basis of $100 in its FD stock.
(h) Effective date—(1) General rule—(i) Gain recognition agreements filed for transfers on or after effective date. With the exception of paragraph (f) of this section, the rules of this section apply to gain recognition agreements filed with respect to transfers of stock or securities under Treas. Reg. §§1.367(a)-3(b) through (d) and 1.367(a)-3T(e) occurring on or after March 7, 2007. The rules of paragraph (f) of this section apply to gain recognition agreements filed with respect to transfers of stock or securities under Treas. Reg. §§1.367(a)-3(b) through (d) and 1.367(a)-3T(e) occurring on or after August 6, 2007. However, the rules of this section do not apply to gain recognition agreements filed with respect to such a transfer of stock or securities occurring on or after March 7, 2007, if such transfer was entered into pursuant to a written agreement which was (subject to customary conditions) binding before February 5, 2007, and at all times thereafter. Solely for purposes of this paragraph (h), a transfer described in the preceding sentence shall be deemed to be a transfer occurring before March 7, 2007 to which the rules of §1.367(a)-8 (see 26 CFR part 1, revised April 1, 2006) apply. See paragraph (h)(2)(iii) of this section for the ability to apply the rules of this section with respect to gain recognition agreements filed before March 7, 2007.
(ii) Gain recognition agreements filed for transfers before effective date. For matters covered in this section for periods before March 7, 2007 but on or after July 20, 1998, the corresponding rules of §1.367(a)-8 (see 26 CFR part 1, revised April 1, 2006) apply. For matters covered in this section for periods before July 20, 1998, the corresponding rules of §1.367(a)-3T(g) (see 26 CFR part 1, revised April 1, 1998) and Notice 87-85, 1987-2 C.B. 395; (see §601.601(d)(2)(ii) of this chapter) apply. In addition, if a U.S. transferor entered into a gain recognition agreement for transfers before July 20, 1998, then the rules of §1.367(a)-3T(g) (see 26 CFR part 1, revised April 1, 1998) continue to apply in lieu of this section in the event of any direct or indirect nonrecognition transfer of the same property. See also, §1.367(a)-3(h).
(2) Applicability to gain recognition agreements filed before effective date—(i) General rule. This paragraph (h)(2)(i) applies only to rules in this regulation §1.367(a)-8T that were not already effective under the rules of §1.367(a)-8 (see 26 CFR part 1, revised April 1, 2006). Taxpayers may apply all or part of these regulations to gain recognition agreements filed with respect to transfers of stock or securities, for all open years, on or after July 20, 1998. If a taxpayer failed to file a gain recognition agreement with respect to a transfer of stock or securities on or after July 20, 1998 and before March 7, 2007, the taxpayer must first obtain reasonable cause relief under §1.367(a)-8(c)(2) to file the gain recognition agreement before the taxpayer may apply this paragraph (h)(2)(i).
(ii) Special filing rule for tax year ending before effective date. This paragraph (h)(2)(ii) provides the time and manner in which taxpayers may apply paragraph (h)(2)(i) of this section. Notwithstanding the rules provided in §1.367(a)-8T(a)(2), all agreements, certifications, or other information related to such gain recognition agreement that should have been filed on or before March 7, 2007 shall be treated as having been timely filed, provided they are attached to a Federal income tax return amending the taxpayer’s Federal income tax return for the taxable year in which they should have been attached. The amended return described in the preceding sentence must be filed before August 6, 2007. A taxpayer that wishes to apply paragraph (h)(2)(i) of this section but that fails to meet the filing requirement described in the preceding sentence must request reasonable cause relief as provided in paragraph (e)(10) of this section.
(iii) Tax year ending after effective date. A taxpayer that entered into a gain recognition agreement to which §1.367(a)-8 (see 26 CFR part 1, revised April 1, 2006) applies may apply the rules of this section in a tax year ending on or after March 7, 2007 by attaching the agreement, certification, or other information related to such gain recognition agreement that the rules of this section require in accordance with the rules of this section and with the time and manner rules provided in §1.367(a)-8T(a)(2).
(iv) Examples. The rules of paragraph (h)(2) of this section are illustrated by the following examples:
Example 1. (i) Facts. USP, a domestic corporation, owns 100% of the stock of two foreign corporations, FC and FD. In 2003, USP transfers 100% of the stock of FC to FD in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). Pursuant to §1.367(a)-3(b)(1)(ii) and this section, USP enters into a gain recognition agreement with respect to the initial transfer. USP also complies with the notice requirement under §1.367(b)-1(c). In 2005, FD distributes all of the stock of FC to USP in a pro rata distribution to which section 355 applies. Under section 358, USP’s basis in its FC stock exceeds the basis that USP had in FC immediately before the initial transfer.
(ii) Result. Under paragraph (h)(1)(ii) of this section, the rules of §1.367(a)-8 apply because the gain recognition agreement was filed before March 7, 2007. As a result of the year 2005 transaction, under §1.367(a)-8(e)(1), USP is required to recognize all of the gain subject to the gain recognition agreement, and pay any applicable interest. The gain recognition agreement does not terminate under §1.367(a)-8(h)(3) because USP’s basis in its FC stock immediately after the section 355 distribution exceeds the basis USP had in the FC stock immediately before the initial transfer. However, paragraph (g)(3)(iii) of this section provides a rule that would allow USP to elect to reduce its basis in the FC stock such that the conditions in paragraph (g)(3) of this section would be satisfied and the gain recognition agreement would terminate without further effect. Under paragraph (h)(2)(i) of this section, USP may apply paragraph (g)(3)(iii) of this section to the 2005 transaction, if 2005 is an open year, because the rule provided in paragraph (g)(3)(iii) of this section was not already effective under §1.367(a)-8. Under paragraph (h)(2)(ii) of this section, USP must submit the documents required under paragraph (g)(3)(iii) of this section to a Federal income tax return amending its 2005 Federal income tax return before August 6, 2007.
Example 2. (i) Facts. UST, a domestic corporation, owns 100% of the stock of two foreign corporations, TFC and TFD. In 2003, USP transfers 100% of the stock of TFD to TFC in an exchange to which section 351 applies. The transaction is subject to both sections 367(a) and (b). See §§1.367(a)-3(b) and 1.367(b)-1(a). All of the requirements of §1.367(a)-3(b)(1) are satisfied, and UST enters into a gain recognition agreement. UST also complies with the notice requirement under §1.367(b)-1(c). In 2005, TFC transfers its TFD stock to F1, also a foreign corporation, in an exchange to which section 351 applies. UST does not file a new gain recognition agreement under §1.367(a)-8(g)(2).
(ii) Result. Under paragraph (h)(1)(ii) of this section, the rules of §1.367(a)-8 apply because the gain recognition agreement was filed before March 7, 2007. Under §1.367(a)-8(e), UST must recognize the gain realized, but not recognized, on its initial transfer of TFD stock. Paragraph (h)(2)(i) of this section does not apply because the rule in paragraph (e)(1)(ii) of this section was already effective under §1.367(a)-8(g)(2). Therefore, UST’s only recourse from recognizing the gain subject to the gain recognition agreement is the reasonable cause exception provided in §1.367(a)-8(c)(2).
PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
Par. 7. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 8. In §602.101, paragraph (b) is revised by adding an entry for §1.367(a)-8T in numerical order to the table to read as follows:
§602.101 OMB Control numbers.
CFR part or section where identified and described
Current OMB control No.
1.367(a)-8T 1545-2056
Kevin M. Brown,
Deputy Commissioner for
Services and Enforcement.
Approved January 31, 2007.
Eric Solomon,
of the Treasury (Tax Policy).
(Filed by the Office of the Federal Register on February 1, 2007, 8:52 a.m., and published in the issue of the Federal Register for February 5, 2007, 72 F.R. 5174)
Drafting Information
The principal author of these temporary regulations is Daniel McCall of the Office of Associate Chief Counsel (International). However, other personnel from the IRS and the Treasury Department participated in their development.
For purposes of § 807(d)(4) of the Internal Revenue Code, for taxable years beginning after December 31, 2005, this ruling supplements the schedules of prevailing state assumed interest rates set forth in Rev. Rul. 92-19, 1992-1 C.B. 227. This information is to be used by insurance companies in computing their reserves for (1) life insurance and supplementary total and permanent disability benefits, (2) individual annuities and pure endowments, and (3) group annuities and pure endowments. As § 807(d)(2)(B) requires that the interest rate used to compute these reserves be the greater of (1) the applicable federal interest rate, or (2) the prevailing state assumed interest rate, the table of applicable federal interest rates in Rev. Rul. 92-19 is also supplemented.
Following are supplements to schedules A, B, C, and D to Part III of Rev. Rul. 92-19, providing prevailing state assumed interest rates for insurance products with different features issued in 2006 and 2007, and a supplement to the table in Part IV of Rev. Rul. 92-19, providing the applicable federal interest rates under § 807(d) for 2006 and 2007. This ruling does not supplement Parts I and II of Rev. Rul. 92-19.
This is the fifteenth supplement to the interest rates provided in Rev. Rul. 92-19. Earlier supplements were published in Rev. Rul. 93-58, 1993-2 C.B. 241 (interest rates for insurance products issued in 1992 and 1993); Rev. Rul. 94-11, 1994-1 C.B. 196 (1993 and 1994); Rev. Rul. 95-4, 1995-1 C.B. 141 (1994 and 1995); Rev. Rul. 96-2, 1996-1 C.B. 141 (1995 and 1996); Rev. Rul. 97-2, 1997-1 C.B. 134 (1996 and 1997); Rev. Rul. 98-2, 1998-2 C.B. 259 (1997 and 1998); Rev. Rul. 99-10, 1999-1 C.B. 671 (1998 and 1999); Rev. Rul. 2000-17, 2000-1 C.B. 842 (1999 and 2000); Rev. Rul. 2001-11, 2001-1 C.B. 780 (2000 and 2001); Rev. Rul. 2002-12, 2002-1 C.B. 624 (2001 and 2002); Rev. Rul. 2003-24, 2003-1 C.B. 557 (2002 and 2003); Rev. Rul. 2004-14, 2004-1 C.B. 511 (2003 and 2004); Rev. Rul. 2005-29, 2005-1 C.B. 1080 (2004 and 2005); and Rev. Rul. 2006-25, 2006-20 I.R.B. 882 (May 15, 2006) (2005 and 2006).
Part III. Prevailing State Assumed Interest Rates — Products Issued in Years After 1982.*
STATUTORY VALUATION INTEREST RATES BASED ON THE 1980 AMENDMENTS TO THE NAIC STANDARD VALUATION LAW
A. Life insurance valuation:
Guarantee Duration (years)
Calendar Year of Issue 2007
10 or fewer 4.50**
More than 10 but not more than 20 4.25**
More than 20 4.00**
Source: Rates calculated from the monthly averages, ending June 30, 2006, of Moody’s Composite Yield on Seasoned Corporate Bonds.
* The terms used in the schedules in this ruling and in Part III of Rev. Rul. 92-19 are those used in the Standard Valuation Law; the terms are defined in Rev. Rul. 92-19.
** As these rates exceed the applicable federal interest rate for 2007 of 3.97 percent, the valuation interest rate to be used for this product under § 807 is the applicable rate specified in this table.
Part III, Schedule B
B. Single premium immediate annuities and annuity benefits involving life contingencies arising from other annuities with cash settlement options and from guaranteed interest contracts with cash settlement options:
Calendar Year of Issue
Valuation Interest Rate
Source: Rates calculated from the monthly averages, ending June 30, 2006, of Moody’s Composite Yield on Seasoned Corporate Bonds (formerly known as Moody’s Corporate Bond Yield Average — Monthly Average Corporates). The terms used in this schedule are those used in the Standard Valuation Law as defined in Rev. Rul. 92-19.
*As this prevailing state assumed interest exceeds the applicable federal interest rate for 2006 of 3.98 percent, the valuation interest rate of 5.25 percent is to be used for this product under § 807.
Part III, Schedule C24 — 2006
STATUTORY VALUATION INTEREST RATES BASED ON NAIC STANDARD VALUATION LAW FOR 2006 CALENDAR YEAR BUSINESS GOVERNED BY THE 1980 AMENDMENTS
C. Valuation interest rates for other annuities and guaranteed interest contracts that are valued on an issue year basis:
Cash Settlement Options?
Future Interest Guarantee?
Valuation Interest Rate (%) For Plan Type
Yes Yes 5 or fewer 5.25 4.75 4.50
More than 5, but not more than 10 5.25 4.75 4.50
More than 10, but not more than 20 4.75 4.50 4.25*
More than 20 4.25* 4.00* 4.00*
Yes No 5 or fewer 5.50 4.75 4.50
More than 10, but not more than 20 5.00 4.50 4.50
No Yes or No 5 or fewer 5.25
More than 5, but not more than 10 5.25 NOT APPLICABLE
More than 10, but not more than 20 4.75
More than 20 4.25*
*As these rates exceed the applicable federal interest rate for 2006 of 3.98 percent, the valuation interest rate to be used for this product under § 807 is the applicable rate specified in the above table.
Part III, Schedule D24 — 2006
D. Valuation interest rates for other annuities and guaranteed interest contracts that are contracts with cash settlement options and that are valued on a change in fund basis:
Valuation Interest Rate For Plan Type
More than 20 4.75 4.75 4.25*
*As the applicable federal interest rate for 2006 of 3.98 percent is less than the prevailing state assumed interest rate, the valuation interest rate to be used for this product under § 807 is the applicable rate specified in the above table.
Part IV. Applicable Federal Interest Rates
TABLE OF APPLICABLE FEDERAL INTEREST RATES FOR PURPOSES OF § 807
Sources: Rev. Rul. 2004-106, 2004-2 C.B. 893, for the 2005 rate; Rev. Rul. 2005-77, 2005-2 C.B. 1071, for the 2006 rate; and Rev. Rul. 2006-61, 2006-49 I.R.B. 1028 (Dec. 11, 2006) for the 2007 rate.
EFFECT ON OTHER REVENUE RULINGS
Rev. Rul. 92-19 is supplemented by the addition to Part III of that ruling of prevailing state assumed interest rates under § 807 for certain insurance products issued in 2006 and 2007 and is further supplemented by an addition to the table in Part IV of Rev. Rul. 92-19 listing applicable federal interest rates. Parts I and II of Rev. Rul. 92-19 are not affected by this ruling.
The principal author of this revenue ruling is Josephine H. Firehock of the Office of Associate Chief Counsel (Financial Institutions and Products). For further information regarding this revenue ruling, contact her at (202) 622-3970 (not a toll-free call).
Subpart A. Tax Conventions and Other Related Items
U.S.-Island of Jersey Reciprocal Exemption Agreement
The United States and the United Kingdom of Great Britain and Northern Ireland (on behalf of the Bailiwick of Jersey) have exchanged diplomatic notes evidencing a reciprocal exemption agreement for income from the international operation of ships for taxable years beginning on or after January 1, 1997. The diplomatic notes reproduced herein contain the terms of the reciprocal exemptions.
The principal author of this announcement is Patricia Bray of the Office of Associate Chief Counsel (International). For further information regarding this announcement, contact Patricia Bray at (202) 622-3880 (not a toll-free call).
The text of the agreement is as follows.
Reciprocal Exemption Agreement between the United States and Jersey
This exhibit contains an exchange of diplomatic notes between the United States and the United Kingdom of Great Britain and Northern Ireland (on behalf of the Bailiwick of Jersey) evidencing an agreement for the reciprocal exemption from taxation of income from the international operation of ships. The agreement is effective for taxable years beginning on or after January 1, 1997.
Please click here for the text description of the image.
This notice provides guidance on rollovers from health Flexible Spending Arrangements (health FSAs) and Health Reimbursement Arrangements (HRAs) to Health Savings Accounts (HSAs) under amendments to the Internal Revenue Code by section 302 of the Health Opportunity Patient Empowerment Act of 2006 (the Act) included in the Tax Relief and Health Care Act of 2006, enacted December 20, 2006, Pub. L. No. 109-432. The guidance also provides special transition relief for rollovers completed before March 15, 2007. It is anticipated that additional guidance will be published later under this provision.
As discussed in detail below, the new rules provide, in limited circumstances, for certain amounts in a health FSA or HRA to be rolled over into an HSA and for the rollover to receive favorable tax treatment. Generally, under the new rules, all of the following conditions must be satisfied in order to receive the favorable tax treatment:
By plan year end—
The plan must be amended
The employee must elect the rollover
The year-end balance must be frozen
The funds must be transferred by the employer within two and a half months after the end of the plan year and result in a zero balance in the health FSA or HRA.
Under special transition relief provided in this notice for amounts remaining at the end of 2006, however:
There is no requirement to freeze the year-end balance in the health FSA or HRA, and
The amendment, election, and transfer must be completed by March 15, 2007.
Eligible individuals, as defined in § 223(c)(1) of the Code, may contribute to HSAs. In general, these are individuals who, as of the first day of the month, are covered by a high deductible health plan (HDHP) and by no other health plan that is not an HDHP (with the exception of certain disregarded coverage, including permitted insurance). An individual covered by a general purpose health FSA or general purpose HRA is not eligible to contribute to an HSA. See Rev. Rul. 2004-45, 2004-1 C.B. 971. If a general purpose health FSA allows reimbursements for expenses incurred during a grace period following the end of the plan year, an otherwise eligible individual participating in the health FSA is generally not eligible to make contributions to an HSA until the first day of the first month following the end of the grace period. The maximum duration of a grace period is until the fifteenth day of the third month following the end of a plan year. See Notice 2005-42, 2005-1 C.B. 1204. Prior to the Act, this rule applied even if the individual’s health FSA had no unused benefits as of the end of the prior year (i.e., the balance in the health FSA was zero as of the last day of the plan year). Notice 2005-86, 2005-2 C.B. 1075. However, coverage by an HSA-compatible health FSA or HRA (limited-purpose health FSA or HRA, post-deductible health FSA or HRA, retirement HRA, or suspended HRA), does not affect an employee’s eligibility to contribute to an HSA, including coverage during a health FSA grace period. See Rev. Rul. 2004-45.
HEALTH OPPORTUNITY PATIENT EMPOWERMENT ACT OF 2006 — GENERAL RULES
Section 302(a) of the Act provides for “qualified HSA distributions” before January 1, 2012. A qualified HSA distribution is a direct distribution of an amount from a health FSA or HRA to an HSA. The distribution (rollover to an HSA) must not exceed the lesser of the balance in the health FSA or HRA (1) on September 21, 2006, or (2) as of the date of the distribution. Thus, an individual who was not covered by a health FSA or HRA on September 21, 2006 may not elect a qualified HSA distribution. Similarly, an individual who participated in a health FSA with one employer on September 21, 2006, and participates in a health FSA with a second employer after that date, may not elect a qualified HSA distribution with respect to the second employer’s health FSA.
A qualified HSA distribution must be contributed directly to the HSA trustee by the employer. Qualified HSA distributions may be made from general purpose health FSAs and HRAs, as well as from HSA-compatible health FSAs and HRAs. Only one qualified HSA distribution is allowed with respect to each health FSA or HRA of an individual. Qualified HSA distributions are not taken into account in applying the annual limit for HSA contributions. Qualified HSA distributions are treated as rollovers and thus, are not deductible.
If the individual fails to remain HSA-eligible during the testing period following the distribution, the amount of the rollover is included in gross income and is subject to an additional 10 percent tax. For this purpose, the testing period is defined as the period beginning with the month in which the qualified HSA distribution is contributed to the HSA and ending on the last day of the 12th month following that month. It is not required that an employee be an eligible individual with HDHP coverage in order to have a qualified HSA distribution made on the employee’s behalf. However, if an employee is not an eligible individual immediately following the qualified HSA distribution, the amount of the distribution is included in the employee’s income and subject to an additional 10 percent tax.
Section 302(b) of the Act provides that only certain health FSA coverage during a grace period is treated as disregarded coverage for the purpose of determining an individual’s eligibility to contribute to an HSA. Under new § 223(c)(1)(B)(iii) of the Code, coverage during a grace period by a general purpose health FSA is disregarded if (1) the balance in the health FSA at the end of the prior plan year is zero or (2) the individual makes a qualified HSA distribution of any balance remaining at the end of the plan year to an HSA.
Section 302(b) of the Act only applies to health FSA coverage during a grace period following a plan year. Thus, health FSA coverage during the plan year is not disregarded, regardless of whether the health FSA balance is reduced to zero during the plan year by a qualified HSA distribution or otherwise.
QUALIFIED HSA DISTRIBUTIONS
If an employer wants to provide qualified HSA distributions, the employer must amend the health FSA or HRA written plan. In order to comply with the comparability rules in § 4980G of the Code, the amended plan must offer qualified HSA distributions to any otherwise eligible individual covered by the employer’s HDHP. See new § 106(e)(5)(B) of the Code. However, there is no requirement that the health FSA or HRA be terminated in order to provide a qualified HSA distribution. Health FSAs and HRAs must satisfy the nondiscrimination requirements in § 105(h) of the Code.
A qualified HSA distribution may be made at any time prior to January 1, 2012. However, even if the qualified HSA distribution reduces the balance of an FSA or HRA to zero, the health FSA or HRA coverage does not end. If the FSA or HRA is not HSA-compatible, employees can become eligible individuals only after transfers at the end of the plan year of the FSA or HRA that result in either disregarded coverage under 302(b) of the Act, or the termination of the HRA coverage at the end of the plan year. Consequently, qualified HSA distributions from health FSAs or HRAs that are not HSA-compatible and that take place at any time other than the end of a plan year, generally result in the inclusion of the distribution in income and the imposition of an additional 10 percent tax.
The amendments in the Act do not change the requirement that unused amounts remaining at the end of a health FSA’s plan year must be forfeited in the absence of a grace period. Notice 2005-42. Thus, if a health FSA does not have a grace period, unused amounts remaining at the end of the plan year are forfeited and generally cannot be transferred through a qualified HSA distribution to an HSA after the end of the plan year. Although the unused amounts can be distributed to an HSA before the end of the plan year, because the health FSA coverage continues until the end of the plan year, an individual covered by the health FSA is not an eligible individual immediately after the qualified HSA distribution, and thus any such qualified HSA distribution is included in income and subject to an additional 10 percent tax. Similarly, an individual without HDHP coverage after a distribution is not an eligible individual after the distribution and thus the qualified HSA distribution is included in income and subject to an additional 10 percent tax. Unless a participant has a change in status as provided in Treas. Reg. § 1.125-4(a), health FSA elections may not be changed during a plan year. Prop. Treas. Reg. § 1.125-1, Q & A-15.
BALANCES DETERMINED ON CASH BASIS
For all purposes, balances are determined on a cash basis. Cash basis means the balance as of any date, without taking into account expenses incurred that have not been reimbursed as of that date. Thus, pending claims, claims submitted, claims received or claims under review that have not been paid as of a date are not taken into account for purposes of determining the account balance as of that date. In addition, the balance as of any date of a health FSA is determined by applying the uniform coverage rule (i.e., maximum reimbursement available for the plan year reduced for prior reimbursements paid as of the date for the same plan year). See Prop. Treas. Reg. § 1.125-2, Q&A-7(b)(2).
HDHP COVERAGE BEGINNING AFTER 1ST DAY OF THE MONTH
An employee who begins HDHP coverage after the first day of the month is not an eligible individual until the first day of the next month. If a qualified HSA distribution is made on behalf of such an employee before the first day of the next month, the employee is not an eligible individual as of the date of the qualified HSA distribution and the amount of the distribution is included in the employee’s income and subject to an additional 10 percent tax. Thus, if an employee begins HDHP coverage after the first day of the month, any qualified HSA distribution on behalf of the individual made on or after the first day of the next month avoids immediate inclusion in income.
CONSEQUENCES OF FAILING TO ROLL OVER ENTIRE BALANCE OF GENERAL PURPOSE HEALTH FSA OR GENERAL PURPOSE HRA
An employee with a balance in a health FSA with a grace period or HRA at the end of a plan year is not treated as an eligible individual for HSA purposes on the first day of the immediately following plan year if a qualified HSA distribution does not result in a zero balance in the health FSA or HRA. Because the employee is covered under a health plan that is not an HDHP during the testing period, the amount of the qualified HSA distribution is included in the employee’s gross income in the year of the distribution and is subject to a 10 percent additional tax. However, an employee with a balance in an HSA-compatible health FSA or HRA at the end of a plan year remains an eligible individual, if otherwise eligible, regardless of whether a qualified HSA distribution is made.
ADDITIONAL TAX FOR FAILURE TO REMAIN AN ELIGIBLE INDIVIDUAL
If an individual ceases to be an eligible individual during the testing period, the amount of the qualified HSA distribution is included in the gross income of the individual and subject to an additional 10 percent tax. Failing to remain an eligible individual does not require the withdrawal of the qualified HSA distribution, and the amount is not an excess contribution. However, any HSA withdrawal not used for qualified medical expenses is included in income and subject to an additional 10 percent tax (with certain exceptions), regardless of whether the HSA received a qualified HSA distribution that was previously included in the account beneficiary’s income and subject to the additional tax. See § 223(f)(4)(B).
PERMANENT RULE — INDIVIDUALS WITH A ZERO BALANCE IN GENERAL PURPOSE HEALTH FSA ON THE LAST DAY OF PLAN YEAR
Under the Act, if an individual has a zero balance in a general purpose health FSA, as determined on a cash basis, on the last day of the health FSA plan year, the individual does not fail to be an eligible individual as of the first day of the immediately following health FSA plan year because of coverage during a health FSA grace period.
PERMANENT RULE — INDIVIDUALS WITH A ZERO BALANCE IN GENERAL PURPOSE HRA ON THE LAST DAY OF PLAN YEAR
An individual with a zero balance in a general purpose HRA, determined on a cash basis, on the last day of the HRA plan year, does not fail to be an eligible individual on the first day of the immediately following HRA plan year, so long as (1) effective on the first day of the immediately following HRA plan year, the employee elects to waive participation in the HRA, or (2) effective on or before the first day of the following HRA plan year, the employer terminates the general purpose HRA with respect to all employees, or (3) effective on or before the first day of the following HRA plan year, with respect to all employees, the employer converts the general purpose HRA to an HSA-compatible HRA, as described in Rev. Rul. 2004-45.
PERMANENT RULE — PLAN-YEAR-END ROLLOVERS FROM GENERAL PURPOSE HEALTH FSA OR GENERAL PURPOSE HRA TO HSA
An employee with a balance in a general purpose health FSA with a grace period or general purpose HRA at the end of a health FSA or HRA plan year (plan year) is treated as an eligible individual for HSA purposes as of the first day of the first month in the immediately following plan year that the individual has HDHP coverage on the first day of the month if:
(1) the employer amends the health FSA or HRA written plan effective by the last day of the plan year to allow a qualified HSA distribution,
(2) a qualified HSA distribution from the health FSA or HRA has not been previously made on behalf of the employee with respect to that particular health FSA or HRA,
(3) the employee has HDHP coverage as of the first day of the month during which the qualified HSA distribution occurs, and is otherwise an eligible individual,
(4) the employee elects by the last day of the plan year to have the employer make a qualified HSA distribution from the health FSA or HRA to the HSA of the employee,
(5) the health FSA or HRA makes no reimbursements to the employee after the last day of the plan year,
(6) the employer makes the qualified HSA distribution directly to the HSA trustee by the fifteenth day of the third calendar month following the end of the immediately preceding plan year, but after the employee becomes HSA-eligible,
(7) the qualified HSA distribution from the health FSA or HRA does not exceed the lesser of the balance of the health FSA or HRA on (a) September 21, 2006, or (b) the date of the distribution, and
(8)(a) after the qualified HSA distribution there is a zero balance in the health FSA or HRA, and the employee is no longer a participant in any non-HSA compatible health plan or (b) effective on or before the date of the first qualified HSA distribution the general purpose health FSA or general purpose HRA written plan is converted to an HSA-compatible health FSA or HRA, as described in Rev. Rul. 2004-45, for all participants.
TRANSITION RULE — QUALIFIED HSA DISTRIBUTIONS FROM GENERAL PURPOSE HEALTH FSA AND GENERAL PURPOSE HRA BEFORE MARCH 15, 2007
An employee with a balance in a general purpose health FSA with a grace period or general purpose HRA after December 31, 2006 is treated as an eligible individual for HSA purposes as of the first day of the first month in 2007 that the employee has HDHP coverage on the first day of the month if:
(1) the employer amends the health FSA or HRA written plan effective on or before March 15, 2007, to allow a qualified HSA distribution,
(4) the employee elects on or before March 15, 2007, to have the employer make a qualified HSA distribution from the health FSA or HRA to the HSA of the employee,
(5) the qualified HSA distribution from the health FSA or HRA does not exceed the lesser of the balance of the respective health FSA or HRA on (a) September 21, 2006, or (b) the date of the distribution,
(6) the employer makes the qualified HSA distribution directly to the HSA trustee by March 15, 2007, but after the employee becomes HSA-eligible, and
(7)(a) after the qualified HSA distribution there is a zero balance in the health FSA or HRA, and the employee is no longer a participant in any non-HSA compatible health plan or (b) effective on or before the date of the first qualified HSA distribution, the general purpose health FSA or general purpose HRA written plan is converted to an HSA-compatible health FSA or HRA, as described in Rev. Rul. 2004-45, for all participants.
The following examples illustrate these rules. All references to balances in the following examples are determined on a cash basis. All grace periods satisfy the requirements of Notice 2005-42. It is assumed in the examples that, for purposes of § 106(e)(3)(B) and § 223(f)(4)(B), no employees are disabled.
Permanent Rule Examples
Example 1. For 2007, Employer Z has a calendar year general purpose health FSA with a grace period ending March 15, 2008. For 2007, Employee A timely elects salary reduction of $500 for the general purpose health FSA. Employer Z offers employees the option of electing HDHP coverage for the plan year beginning January 1, 2008. On or before December 31, 2007, A elects HDHP coverage beginning January 1, 2008. On December 31, 2007, A has a zero balance in the health FSA. A is otherwise an eligible individual on January 1, 2008.
A does not fail to be an eligible individual on January 1, 2008 merely because of the health FSA grace period.
Example 2. For 2007, Employer Y has a calendar year general purpose health FSA with a grace period ending on March 15, 2008. Employer Y offers employees the option of electing HDHP coverage for the plan year beginning January 1, 2008.
Before January 1, 2008, Employer Y amends the health FSA to allow for qualified HSA distributions. The amended plan allows an employee electing HDHP coverage to also elect to have any health FSA balance at year-end, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the year-end balance is the balance of the health FSA without regard to any expenses incurred but not paid. Under the amendment, if an employee elects the qualified HSA distribution, the employee cannot submit any additional claims after December 31, 2007, regardless of when the underlying expense was incurred nor are any claims paid after December 31, 2007 even if submitted prior to December 31, 2007.
Employee B has a balance of $950 in the health FSA on September 21, 2006, and a balance of $700 on December 31, 2007. On or before December 31, 2007, B elects HDHP coverage beginning January 1, 2008. B also elects to have a qualified HSA distribution of the $700 remaining in the health FSA on December 31, 2007. Employer Y contributes $700 to an HSA on behalf of B on or before March 15, 2008. B is otherwise an eligible individual as of January 1, 2008.
Employee C has a balance of $850 on December 31, 2007. On or before December 31, 2007, C elects HDHP coverage for 2008. C does not elect to have a qualified HSA distribution of the $850 remaining in the health FSA on December 31, 2007. C is otherwise an eligible individual.
B does not fail to be an eligible individual as of January 1, 2008 because after the qualified HSA distribution B has a zero balance in the health FSA. C is an eligible individual on April 1, 2008.
Example 3. For 2007, Employer W has a calendar year general purpose HRA. Employer W offers employees the option of electing HDHP coverage for the plan year beginning January 1, 2008.
Before January 1, 2008, Employer W amends the HRA to allow for qualified HSA distributions. The amended HRA allows an employee electing HDHP coverage for the plan year to also elect to have the lesser of the balance in the HRA on September 21, 2006 or the HRA balance at year-end, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the year-end balance is the balance of the HRA without regard to any expenses incurred but not paid. Under the amendment, if an employee elects the qualified HSA distribution, the employee cannot submit any additional claims after December 31, 2007, regardless of when the underlying expense was incurred, nor will the HRA reimburse any claim submitted but unpaid as of December 31, 2007. The amendment also provides that an employee who elects a qualified HSA distribution may also elect to waive participation in the HRA.
Employee D has a balance of $300 in the HRA on September 21, 2006, and a balance of $175 on December 31, 2007. On or before December 31, 2007, D elects HDHP coverage for 2008. D also elects to have a qualified HSA distribution of the $175 remaining in the HRA on December 31, 2007, and to waive participation in the HRA effective after December 31, 2007. Employer W contributes $175 to an HSA on behalf of D on or before March 15, 2008. D is otherwise an eligible individual as of January 1, 2008.
Employee E has a balance of $300 in the HRA on September 21, 2006, and a balance of $550 on December 31, 2007. On or before December 31, 2007, E elects HDHP coverage for 2008. E also elects to have a qualified HSA distribution of the $300 that was in the HRA on September 21, 2006. Employer W contributes $300 to an HSA on behalf of E on March 15, 2008. E is otherwise an eligible individual as of January 1, 2008.
Employee F has a balance of $400 in the HRA on September 21, 2006. On or before December 31, 2007, F elects HDHP coverage for 2008. On June 15, 2008, F has a balance of $275 in the HRA, and elects to have a qualified HSA distribution of the $275. Employer W contributes $275 to an HSA on behalf of F on August 20, 2008. F is otherwise an eligible individual as of January 1, 2008.
D does not fail to be an eligible individual as of January 1, 2008 because after the qualified HSA distribution D has a zero balance in the HRA and does not participate in any non-HSA compatible HRA. E fails to be an eligible individual after the qualified HSA distribution, because E has a balance exceeding zero in the HRA after the distribution. E must include $300 in gross income in 2008, as well as pay an additional 10 percent tax. F fails to be an eligible individual after the qualified HSA distribution, because F remains a participant in an HRA that is not HSA-compatible until the end of the HRA plan year. The result is the same regardless of whether F waived participation in the HRA after June 15, 2008. Thus, F must include $275 in gross income in 2008, as well as pay an additional 10 percent tax.
Example 4. The same facts as Example 3, except Employer W converted the general purpose HRA to an HSA-compatible retirement HRA for all employees effective January 1, 2008.
Employee G has a balance of $275 in the HRA on September 21, 2006, and a balance of $700 on December 31, 2007. On or before December 31, 2007, G elects HDHP coverage beginning January 1, 2008. G is otherwise an eligible individual as of January 1, 2008. G also elects to have a qualified HSA distribution of the $275 that was in the HRA on September 21, 2006. Employer W contributes $275 to an HSA on behalf of G on or before March 15, 2008. G has a balance of $425 in a retirement HRA and remains an active employee.
G is an eligible individual as of January 1, 2008, because the HRA G participates in is HSA-compatible.
Example 5. Employer V has a fiscal year general purpose health FSA with a grace period. The fiscal year of the health FSA is October 1 — September 30. The grace period ends on December 15. For the plan year beginning October 1, 2007, Employer V offers employees the option of electing HDHP coverage.
In December 2006, Employer V amends the health FSA to allow for qualified HSA distributions. The amended plan allows an employee electing HDHP coverage for the plan year to also elect to have any health FSA balance at the end of the plan year, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the plan-year-end balance is the balance of the health FSA without regard to any expenses incurred but not paid. If an employee elects the qualified HSA distribution, the employee cannot submit any additional claims after September 30, 2007, regardless of when the underlying expense was incurred. The health FSA does not reimburse claims submitted but unpaid as of September 30, 2007.
Employee H has a balance of $600 in the health FSA on September 21, 2006, and a balance of $500 on September 30, 2007. On or before September 30, 2007, H elects HDHP coverage for the plan year beginning October 1, 2007. H also elects to have a qualified HSA distribution of the $500 remaining in the health FSA on September 30, 2007. Employer V contributes $500 to an HSA on behalf of H on or before December 15, 2007. H is otherwise an eligible individual as of October 1, 2007.
H does not fail to be an eligible individual as of October 1, 2007 because after the qualified HSA distribution H has a zero balance in the health FSA.
Example 6. The same facts as Example 5, except Employer V has a limited purpose health FSA.
Employee I has a balance of $2,000 in the limited purpose health FSA on September 21, 2006, and a balance of $3,000 on September 30, 2007. On or before September 30, 2007, I elects HDHP coverage for the plan year beginning October 1, 2007. I also elects to have a qualified HSA distribution of $2,000 that was in the health FSA on September 21, 2006. Employer V contributes $2,000 to an HSA on behalf of I on or before December 15, 2007. I has a balance of $1,000 in a limited purpose health FSA. I is otherwise an eligible individual as of October 1, 2007.
I does not fail to be an eligible individual because I participates in an HSA-compatible health FSA.
Example 7. For 2007, Employer U has a calendar year general purpose health FSA with a grace period ending on March 15, 2008. Employer U has a fiscal year health plan that begins July 1, 2007. For the plan year beginning July 1, 2007, Employer U offers employees the option of electing HDHP coverage.
Before January 1, 2008, Employer U amends the health FSA to allow for qualified HSA distributions. The amended plan allows an employee electing HDHP coverage to also elect to have any health FSA balance at year-end, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the year-end balance is the balance of the health FSA without regard to any expenses incurred but not paid. Under the amendment, if an employee elects the qualified HSA distribution, the employee cannot submit any additional claims after December 31, 2007, regardless of when the underlying expense was incurred. The health FSA does not pay claims submitted but unpaid as of December 31, 2007.
Employee J has a balance of $500 in the health FSA on September 21, 2006, and a balance of $400 on June 30, 2007. On or before June 30, 2007, J elects HDHP coverage for the immediately following health plan year. J also elects to have a qualified HSA distribution of $400 that was in the health FSA on June 30, 2007. Employer U contributes $400 to an HSA on behalf of J on or before September 15, 2007. J is an otherwise eligible individual as of July 1, 2007.
J fails to be an eligible individual after the distribution because J’s participation in a health FSA is not disregarded coverage until January 1, 2008, even though the qualified HSA distribution reduces the balance of the health FSA to zero. J must include $400 in his gross income for 2007, and pay an additional 10 percent tax. J is an eligible individual on January 1, 2008.
Example 8. For 2007, Employer T has a calendar year general purpose health FSA with a grace period ending on March 15, 2008. Employer T offers employees the option of electing HDHP coverage for the plan year beginning January 15, 2008.
Before January 1, 2008, Employer T amends the health FSA to allow for qualified HSA distributions. The amended plan allows an employee electing HDHP coverage to also elect to have any health FSA balance at year-end, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the year-end balance is the balance of the health FSA without regard to any expenses incurred but not paid. Under the amendment, if an employee elects the qualified HSA distribution, the employee cannot submit any additional claims after December 31, 2007, regardless of when the underlying expense was incurred. The health FSA does not pay claims submitted but unpaid as of December 31, 2007.
Employee K has a balance of $1,000 in the health FSA on September 21, 2006, and a balance of $700 on December 31, 2007. On or before December 31, 2007, K elects HDHP coverage for the plan year beginning January 15, 2008. K also elects to have a qualified HSA distribution of the $700 remaining in the health FSA on December 31, 2007. Employer T contributes $700 to an HSA on behalf of K after February 1, 2008, but before March 15, 2008. K is otherwise an eligible individual as of January 15, 2008.
Employee L has a balance of $175 in the health FSA on September 21, 2006, and a balance of $150 on December 31, 2007. On or before December 31, 2007, L elects HDHP coverage for the plan year beginning January 15, 2008. L also elects to have a qualified HSA distribution of the $150 remaining in the health FSA on December 31, 2007. Employer T contributes $150 to an HSA on behalf of L on January 25, 2008.
K does not fail to be an eligible individual because K has a zero balance in the health FSA after the qualified HSA distribution. K is eligible to contribute to the HSA as of February 1, 2008. L is not an eligible individual at the time of the distribution because L does not have HDHP coverage on the first day of January. L must include $150 in gross income in 2008, and pay an additional 10 percent tax. As of February 1, 2008, L is an eligible individual because L has HDHP coverage and no other health plan coverage that is not an HDHP, is not enrolled in Medicare, and cannot be claimed as a dependent on another person’s tax return.
Transition Rule Examples
Example 9. For 2006, Employer S has a calendar year general purpose health FSA with a grace period ending on March 15, 2007. Employer S offers employees the option of electing HDHP coverage for the plan year beginning January 1, 2007.
Employer S amends the health FSA to allow for qualified HSA distributions. The amended plan allows an employee electing HDHP coverage to also elect to have any health FSA balance at year-end, determined on a cash basis, contributed directly to an HSA trustee for the employee. For this purpose, the year-end balance is the balance of the health FSA without regard to any expenses incurred but not paid. During the period from January 1, 2007 to March 15, 2007, an employee electing HDHP coverage for 2007 may elect a qualified HSA distribution of the health FSA balance. The amount of the qualified HSA distribution is determined on a cash basis on the date of the distribution.
Employee M has a balance of $850 on December 31, 2006. On or before December 31, 2006, M elects HDHP coverage beginning January 1, 2007. M does not elect to have a qualified HSA distribution of the $850 remaining in the health FSA on December 31, 2006. M incurred $850 of § 213(d) expenses after January 1 and the health FSA reimbursed M for that amount. M’s health FSA balance is zero on January 22, 2007. M is otherwise an eligible individual as of January 1, 2007.
Employee N has a balance of $800 in the health FSA on September 21, 2006, and a balance of $200 on December 31, 2006. On or before December 31, 2006, N elects HDHP coverage beginning January 1, 2007. During January 2007, the health FSA reimburses N for $50 in § 213(d) medical expenses. On February 12, 2007, N elects to have a qualified HSA distribution of the remaining health FSA balance of $150. Employer S contributes $150 to an HSA on behalf of N on or before March 15, 2007. N is otherwise an eligible individual as of January 1, 2007.
Employee O has a balance of $300 in the health FSA on September 21, 2006, and a balance of $175 on December 31, 2006. On or before December 31, 2006, O elects HDHP coverage for 2007. On or before March 15, 2007, O also elects to have a qualified HSA distribution of the $175 remaining in the health FSA on December 31, 2006. Employer S contributes $175 to an HSA on behalf of O on or before March 15, 2007. O is otherwise an eligible individual as of January 1, 2007.
M has disqualifying coverage by the health FSA until April 1, 2007 because M neither had a zero balance in the FSA on December 31, 2006 nor did M have a zero balance following a qualified HSA distribution on or before March 15, 2007. N is an eligible individual as of January 1, 2007 because after the qualified HSA distribution N has a zero balance in a health FSA. O is an eligible individual as of January 1, 2007, because after the qualified HSA distribution O has a zero balance in a health FSA.
Example 10. The same facts as Example 9, except M and N incurred their respective $850 and $50 in § 213(d) medical expenses in December 2006. M and N submitted the expenses and were reimbursed from the health FSA for the expenses after January 1, 2007 and before February 1, 2007. On February 12, 2007, N elects to have a qualified HSA distribution of the remaining health FSA balance of $150. Employer S contributes $150 to an HSA on behalf of N on or before March 15, 2007. N is otherwise an eligible individual as of January 1, 2007.
M has disqualifying coverage by the health FSA until April 1, 2007, because M neither has a zero balance in the FSA on December 31, 2006 nor did M have a zero balance following a qualified HSA distribution on or before March 15, 2007. N is an eligible individual as of January 1, 2007 because after the qualified HSA distribution N has a zero balance in a health FSA.
Examples of Additional 10 Percent Tax
Example 11. Employee P, who is 32 years old, has HDHP coverage as of January 1, 2008. P elects to have a qualified HSA distribution on or before December 31, 2007. On or before March 15, 2008, P’s employer contributes $250 from a general purpose health FSA to an HSA on behalf of P in a qualified HSA distribution meeting the requirements of section 302 of the Act and this notice. Following the qualified HSA distribution, P has a balance of zero in the general purpose health FSA.
In July 2008, P terminates employment with Employer R, and begins employment with Employer Q. Employer Q does not offer an HDHP. P obtains health coverage under a low deductible health plan, and ceases to be an eligible individual for HSA purposes. P must include the $250 qualified HSA distribution in his gross income for 2008, and pay an additional 10 percent tax under § 106(e)(3) of the Code. P does not have to withdraw the $250 from his HSA, and the amounts in the HSA may grow tax-free.
Example 12. The same facts as Example 11, except in February 2009, P uses $200 from his HSA for a nonqualified medical expense. The $200 is included in P’s gross income for 2009 and is subject to an additional 10 percent tax under § 223(f)(4) of the Code.
Example 13. The same facts as Example 12, except P uses $200 from his HSA for a qualified medical expense. The $200 is not included in P’s gross income, and there is no additional tax.
NO EFFECT ON HSA ESTABLISHMENT DATE
Qualified medical expenses for HSA purposes are only expenses incurred after the HSA is established. Notice 2004-2, 2004-1 C.B. 269, Q&A-26. While this notice provides that certain individuals are treated as eligible individuals as of the first day of the plan year, those rules do not treat an HSA as established before the actual establishment of the HSA.
State trust law determines when an HSA is established. Most state trust laws require that for a trust to exist, an asset must be held in trust; thus, most state trust laws require that a trust must be funded to be established.
Amounts transferred through a qualified HSA distribution are not reported in box 12 of Form W-2. Employers are not responsible for reporting whether an employee receiving a qualified HSA distribution remains an eligible individual during the testing period. However, employers must report qualified HSA distributions as rollover contributions to the HSA trustee, and the HSA trustee must report the qualified HSA distribution as a rollover contribution on Form 5498-SA.
The provision in the Act allowing qualified HSA distributions from health FSAs and HRAs is effective on or after December 20, 2006, and before January 1, 2012.
EFFECT ON OTHER DOCUMENTS
Published guidance under § 105(b) states that if any person has the right to receive cash or any other taxable or nontaxable benefit under a health FSA or HRA, other than the reimbursement of § 213(d) medical expenses of the employee, employee’s spouse or employee’s dependents, then all distributions made from the arrangement are included in the employee’s gross income, even amounts paid to reimburse medical care. See Rev. Rul. 2006-36, 2006-36 I.R.B. 353; Rev. Rul. 2005-24, 2005-1 C.B. 892; Rev. Rul. 2003-102, 2003-2 C.B. 559; Notice 2002-45, 2002-2 C.B. 93; Rev. Rul. 2002-41, 2002-2 C.B. 75; Rev. Rul. 69-141, 1969-1 C.B. 48. New § 106(e) provides that a health FSA or HRA will not fail to satisfy the requirements of §§ 105 or 106 merely because the plan provides for a qualified HSA distribution. Amounts rolled into an HSA may be used for purposes other than reimbursing the § 213(d) medical expenses of the employee, spouse or dependents. Accordingly, Rev. Rul. 2006-36, Rev. Rul. 2005-24, Rev. Rul. 2003-102, Notice 2002-45, Rev. Rul. 2002-41, and Rev. Rul. 69-141 are modified with respect to qualified HSA distributions described in § 106(e). In addition, Notice 2005-86, 2005-2 C.B. 1075, is modified effective as of December 20, 2006.
The principal author of this notice is Leslie R. Paul of the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this notice, contact Ms. Paul at (202) 622-6080 (not a toll-free call).
This revenue procedure modifies the payment procedures for user fees applicable to the processing of Form 8802, Application for United States Residency Certification, to allow for the electronic payment of such fees effective April 2, 2007.
SECTION 2. BACKGROUND
Form 8802 is used to request Form 6166, a letter that the applicant may use as proof of the applicant’s status as a resident of the United States to claim benefits under an income tax treaty or an exemption from a value added tax (VAT) imposed by a foreign country.
Rev. Proc. 2006-35, 2006-37 I.R.B. 434, announced that a new user fee charge will apply to process all requests for residency certification on Form 8802. Section 3.01 of the revenue procedure describes the fee schedule, and section 3.02 provides that the fee must be paid by check or money order to the United States Treasury in U.S. dollars.
Notice 2006-90, 2006-42 I.R.B. 688, modified Rev. Proc. 2006-35, by delaying the effective date of the user fee charge for processing Form 8802 until November 1, 2006.
Recognizing the administrative advantages to both taxpayers and the IRS of alternative payment methods, the IRS is making arrangements to allow for the electronic payment of these fees.
SECTION 3. PROCEDURES
Effective for Forms 8802 submitted on or after April 2, 2007, payment of user fees for Form 8802 may be made electronically to the IRS. The specific instructions for making payments electronically will be included in the next version of Form 8802 and its accompanying instructions, to be issued in March 2007. All further changes and modifications to these payment procedures will be reflected in Form 8802 and its accompanying instructions.
SECTION 4. INQUIRIES
For information regarding processing of Form 8802 and the user fees, contact Mr. Robert Hergenhan of Wage and Investment, Customer Account Service, Accounts Management at (215) 516-6685 (not a toll-free call).
SECTION 5. EFFECT ON OTHER DOCUMENTS
Effective February 9, 2007, Rev. Proc. 2006-35, as modified by Notice 2006-90, is further modified.
This revenue procedure is effective February 9, 2007.
SECTION 7. DRAFTING INFORMATION
The principal author of this revenue procedure is Ms. Quyen P. Huynh of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure, contact Quyen P. Huynh at (202) 622-3880 (not a toll-free call).
This revenue procedure provides administrable tax rules under domestic and international provisions of the Internal Revenue Code for certain patent cross licensing arrangements. This revenue procedure is issued in response to comments and requests for guidance in connection with Notice 2006-34, 2006-14 I.R.B. 705. In general, and as described below, this revenue procedure provides rules permitting taxpayers to change to, or continue to use, the Net Consideration Method described in section 5 of this revenue procedure for a qualified patent cross licensing arrangement (QPCLA) described in section 4 of this revenue procedure. This revenue procedure does not provide rules concerning the treatment of cross licensing arrangements that are not QPCLAs.
SECTION 2. DEFINITIONS
.01 Application. The definitions contained in this section 2 apply only for purposes of this revenue procedure.
.02 Cross Licensing Arrangement. A “cross licensing arrangement” is a contractual arrangement between two or more parties that own intellectual property under which each party grants to the other a license of specified intellectual property that is properly characterized as a license under applicable U.S. tax law principles.
.03 Consideration. The term “consideration” means, with respect to a cross licensing arrangement, any license rights, cash, or other consideration paid or received pursuant to the arrangement.
.04 Controlled. The term “controlled” has the same meaning as in § 1.482-1(i)(4) of the Income Tax Regulations.
SECTION 3 . BACKGROUND
.01 Request for Comments. Notice 2006-34 requested comments, information, and documents on cross licensing arrangements, including the: (i) business circumstances in which the arrangements arise; (ii) legal and factual means for distinguishing between different types of, or uses for, the arrangements; (iii) means for sourcing income from the arrangements; (iv) means for valuing cross-licensed rights; (v) financial accounting treatment of the arrangements; and (vi) foreign tax treatment of the arrangements.
.02 Comments. In response to the requests for information contained in Notice 2006-34, several commentators stated that many cross licensing arrangements are entered into primarily to provide each party with unfettered use of its own patents. In this way, the parties seek “freedom to operate” or the freedom to use their own intellectual property without threat of costly patent litigation from the potentially competing patent claims of the other party. These arrangements may be worded to insure “patent exhaustion” (that is, they are worded to confer rights to make, have made, import, sell, lease, use, or otherwise dispose of patented products). Commentators also stated that the use of cross licensing arrangements in this context would not typically include the transfer of other technology, such as know-how, copyright, or trademark rights. Commentators also indicated that these arrangements may or may not involve cash payments. These arrangements generally are nonexclusive.
Commentators indicated that parties to a cross licensing arrangement entered into to avoid patent litigation typically do not attempt to value the underlying patents prior to entering into the arrangement beyond a broad relative judgment that is reflected in the amount of cash payments, if any, between the parties.
Commentators pointed to the particular circumstances of patent law. Reports offered by the U.S. Patent and Trademark Office (USPTO) indicate drastic increases in the numbers of patents applied for and granted over the last 50 years. For instance, in 1950 the USPTO received 74,108 patent applications and granted 47,847 patents; by 2000, the USPTO received 315,015 patent applications and granted 175,455 patents. United States Patent and Trademark Office, Table of Annual U.S. Patent Activity Since 1790, available at http://www.uspto.gov/web/offices/ac/ido/oeip/taf/h_counts.pdf. At the same time, commentators indicated that a large number of patent infringement suits are filed each year with large associated costs. Commentators indicated that businesses, when faced with a potential “patent thicket,” often choose to negotiate and enter into cross licensing arrangements rather than face uncertain results and expenses that might accompany patent litigation.
Commentators also described other technology sharing business arrangements that may involve a shared business purpose and the sharing of intellectual property beyond patent rights. In addition to providing information regarding the different uses for cross licensing and other technology sharing arrangements, commentators stated their view that, under established tax law principles, the execution of a cross licensing arrangement without any cash payment is not an income recognition event that would trigger withholding tax.
Commentators also indicated that attempting to value any rights granted under a cross licensing arrangement, or to source any income arising therefrom, would be extremely difficult, likely incorporating all of the uncertainties of both patent law and tax law. Commentators indicated that, under U.S. generally accepted accounting principles, profit or loss is generally reported with respect to cross licenses and similar arrangements only to the extent of any cash payments. Commentators said that several policy objectives, including maintaining U.S. competitiveness in the global marketplace in light of foreign taxation rules, would be hindered if an amount in excess of any cash received under a cross licensing arrangement were subject to withholding.
For all these reasons, commentators urged that only cash received under a cross licensing arrangement should be subject to withholding.
.03 Applicable Law.
Section 61(a) of the Internal Revenue Code provides the general rule that, except as otherwise provided by law, gross income includes all income from whatever source derived.
Section 162 permits a taxpayer to deduct all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business.
Section 263(a) provides that no deduction shall be allowed for any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate.
Section 263A provides that in the case of any property to which § 263A applies, the direct costs of such property and such property’s proper share of those indirect costs (including taxes), part or all of which are allocable to such property shall, in the case of property which is inventory in the hands of the taxpayer, be included in inventory costs and, in the case of any other property, shall be capitalized. With certain exceptions, § 263A applies to real or tangible personal property produced by the taxpayer and real or personal property described in § 1221(a)(1) which is acquired by the taxpayer for resale.
In relevant part, §§ 871(a) and 881(a) impose a 30-percent tax on U.S. source fixed or determinable annual or periodical gains, profits, and income (FDAP) received by nonresident aliens and foreign corporations to the extent such FDAP is not effectively connected with the conduct of a trade or business within the United States. Royalties, whether paid in one lump sum or periodically, constitute FDAP. Commissioner v. Wodehouse, 337 U.S. 369, 392 (1949); see also §§ 1.871-7(b)(1) and 1.1441-2(b).
Section 1441(a) provides the general rule that all payors having the control, receipt, custody, disposal or payment of items described in § 1441(b) must deduct and withhold a tax equal to 30 percent on payments of certain items of income to nonresident aliens to the extent that such items constitute gross income from sources within the United States. Section 1441(b) provides that these items of income include interest, dividends, rent, salaries, wages, premiums, annuities, compensations, remunerations and emoluments or other fixed or determinable annual or periodical gains, profits, and income. Section 1442(a) provides that, in the case of foreign corporations subject to taxation under subtitle A of the Code, there shall be deducted and withheld at the source in the same manner and on the same items of income as is provided in § 1441 a tax equal to 30 percent thereof.
Section 861(a)(4) provides that rentals or royalties from property located in the United States or from any interest in such property, including rentals or royalties for the use of or for the privilege of using in the United States patents, copyrights, secret processes and formulas, good will, trade marks, trade brands, franchises, and other like property, shall be treated as income from sources within the United States.
Section 862(a)(4) provides that rentals or royalties from property located without the United States or from any interest in such property, including rentals or royalties for the use of or for the privilege of using without the United States patents, copyrights, secret processes and formulas, good will, trade marks, trade brands, franchises, and other like property, shall be treated as income from sources without the United States.
Section 863(a) provides that items of gross income, expenses, losses, and deductions, other than those specified in §§ 861(a) and 862(a), shall be allocated or apportioned to sources within or without the United States, under regulations prescribed by the Secretary.
Section 863(b) provides that, in the case of gross income derived from sources partly within and partly without the Unites States, the taxable income may first be computed by deducting the expenses, losses, or other deductions apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income. The section further provides that the portion of such taxable income attributable to sources within the United States may be determined by processes or formulas of general apportionment prescribed by the Secretary.
Sections 871(b) and 882 provide that when a nonresident alien individual or a foreign corporation is engaged in a trade or business within the United States, the individual or corporation is taxable at U.S. graduated tax rates on taxable income which is effectively connected with the conduct of a trade or business within the United States (ECI). Section 864(c) provides specific rules for determining the income, gain, or loss treated as ECI.
Section 1031(a)(1) provides generally that no gain or loss is recognized on the exchange of property held for productive use in a trade or business or for investment if such property is exchanged solely for property of like kind which is to be held either for productive use in a trade or business or for investment. For § 1031 to apply, a taxpayer must have realized gain or loss from a disposition of property, as described in § 1001. While a sale or other disposition of a patent generally gives rise to a gain or loss under § 1001, the mere grant of a patent license does not because it is not a sale or other disposition of property within the meaning of § 1001(a). Similarly, gain or loss under § 1001 does not arise in the case of mutual grants of licenses. Thus, § 1031 has no application to a QPCLA addressed in this revenue procedure.
In general, the foregoing rules regarding inclusion, deduction, sourcing, and withholding operate independently as to each item of gross income and expense.
.04 Administrability Issues. The Treasury Department (Treasury) and the Internal Revenue Service (IRS) recognize that QPCLAs entered into by uncontrolled parties to pursue their businesses free from potential patent infringement claims raise many difficult issues for both taxpayers and the IRS. In light of the large number of patent applications and grants, and the difficulty and cost of resolving patent infringement disputes, it is often very difficult to ascertain the validity and scope of patent rights without incurring significant expense, which may include the cost of litigation. Thus, this unique interaction of patent and tax law creates administrative challenges for the taxation of QPCLAs.
For instance, while valuation of intellectual property is always difficult, valuation of patent rights is exceedingly difficult where the parties enter into the cross licensing arrangement to avoid or settle patent infringement disputes. Uncertainty in the patent law increases the difficulties of reaching a valuation when the parties enter into a cross licensing arrangement to avoid the costs and risks of determining their ultimate patent rights by litigation.
Similarly, the sourcing of gross income from QPCLAs entered into to avoid or settle patent infringement disputes may present administrative problems. In those arrangements, the difficulty in tracing the location and use of intangibles to a particular jurisdiction in the absence of objective benchmarks (for example, if a QPCLA did not provide for per-unit cash royalties based on sales of products) may make it difficult to allocate income to a particular source.
For these reasons, Treasury and the IRS have determined that, in the interest of sound tax administration, taxpayers are not required to take into account amounts other than the “net consideration” as defined in section 5.02 of this revenue procedure for QPCLAs described in section 4 of this revenue procedure.
SECTION 4. QUALIFIED PATENT CROSS LICENSING ARRANGEMENT (QPCLA)
A QPCLA is a nonexclusive, nontransferable patent cross licensing arrangement among uncontrolled parties, the subject matter of which is limited to the parties’ present or future patent rights, as specified in the arrangement. If the parties to an arrangement also engage in more than de minimis licensing or other transfer of other intangible property (including copyrights, trademarks, and know how) pursuant to the arrangement, the arrangement is not a QPCLA. The determination of whether the licensing or other transfer of other intangible property is de minimis is determined under all the facts and circumstances.
SECTION 5. NET CONSIDERATION METHOD
.01 Scope. The Net Consideration Method provided in this section 5 may be used for a QPCLA by any taxpayer without regard to whether the taxpayer has made a payment of income subject to withholding with respect to the QPCLA.
.02 Net Consideration. For purposes of this section, “net consideration” is defined as the amount of consideration other than license rights and de minimis other intangible property received in the taxable year by a party pursuant to the arrangement, reduced by the amount of consideration other than license rights and de minimis other intangible property paid in the taxable year by the party pursuant to the arrangement.
.03 Financial Statement Conformity. A taxpayer may not use the Net Consideration Method discussed in this section for a QPCLA unless the taxpayer takes into account only the “net consideration”, as defined in subsection 5.02 of this revenue procedure, for such arrangement on its audited financial statements (if any), or similar statement in the case of a foreign corporation, for all years ending after February 14, 2007, that the net consideration method is used for tax purposes.
.04 Use of Net Consideration Method. A taxpayer choosing to use the Net Consideration Method must apply the Net Consideration Method as provided in sections 5.05 and 5.06 of this revenue procedure. The use of the Net Consideration Method will be presumed to clearly reflect a taxpayer’s income.
.05 Withholding. Under the Net Consideration Method, only the net consideration transferred between the parties to a QPCLA during a taxable year will be taken into account for withholding purposes. The Net Consideration Method applies whether the QPCLA is entered into in advance of, during, or after a patent dispute.
.06 Capitalization. Under the Net Consideration Method, only the net consideration transferred between the parties to a QPCLA during a taxable year will be taken into account for capitalization purposes under § 263(a) or § 263A of the Code.
.07 Example. X, a domestic corporation, and Y, a foreign corporation, each hold patents potentially implicated by the manufacture and sale of product P. In addition, each actively engages in the manufacture and sale of product P on a global basis. Y does not have income effectively connected with a U.S. trade or business. In 2007, X and Y enter into a QPCLA with respect to their respective patents. In accordance with the terms of the QPCLA, $20 million is paid by X to Y. The only consideration for the QPCLA taken into account on X’s financial statements is the $20 million payment made by X to Y. X may use the Net Consideration Method to determine its withholding obligations and the amount subject to capitalization for federal income tax purposes.
Under the Net Consideration Method, only the $20 million payment made by X under the QPCLA is treated as income to Y for withholding purposes. Therefore, withholding under § 1442 will apply only with respect to the portion of the $20 million payment by X attributable to U.S. sources under § 861(a)(4). Further, only the $20 million payment by X is subject to capitalization under § 263(a) or § 263A.
SECTION 6. CHANGE IN ACCOUNTING METHOD
A change in the reporting of a QPCLA to the Net Consideration Method described in section 5 of this revenue procedure is a change in method of accounting within the meaning of §§ 446 and 481 and the regulations issued thereunder. Accordingly, a taxpayer that wishes to change its treatment for a QPCLA to the Net Consideration Method must obtain the consent of the Commissioner under §§ 446(e) and 1.446-1(e)(3).
In general, the rules described in this revenue procedure apply to a QPCLA entered into on or after February 14, 2007.
SECTION 8. QPCLAS ENTERED INTO PRIOR TO THIS REVENUE PROCEDURE
Use of the Net Consideration Method described in section 5 of this revenue procedure for a QPCLA entered into prior to February 14, 2007 will not be raised as an issue by the IRS. If a taxpayer uses the Net Consideration Method described in section 5 of this revenue procedure for one or more QPCLAs entered into prior to February 14, 2007, and its use of that method is an issue under consideration (within the meaning of section 3.09 of Rev. Proc. 2002-9, 2002-1 C.B. 327, or its successor) in examination, in appeals, or before the U.S. Tax Court, that issue will not be further pursued by the IRS.
SECTION 9. COMMENTS
.01 Comments Requested. The Treasury and IRS request comments on the definition of a QPCLA and whether the Net Consideration Method also should extend to other types of cross licensing arrangements and, if so, under what conditions.
For example, comments are requested on the tax treatment of cross licensing arrangements for the joint development of intellectual property discussed in comments in response to Notice 2006-34. Such cross licensing arrangements are not within the definition of a QPCLA because the parties to such arrangements also engage in more than de minimis licensing or other transfer of other intangible property pursuant to the arrangements. The Treasury and IRS are considering, however, whether it may be appropriate to extend similar tax treatment to those arrangements. See § 1.482-7(g)(2) and (g)(8), Examples 4 and 5.
.02 Submission of Comments. Written comments may be submitted to the Office of Associate Chief Counsel (International), Attention: John E. Hinding (Revenue procedure 2007-23), CC:INTL:6, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC 20224. Alternatively, taxpayers may submit comments electronically to revenue procedure.comments@irscounsel.treas.gov. Please include “Revenue Procedure 2007-23” in the subject line of any electronic communications. Comments will be available for public inspection and copying.
SECTION 10. DRAFTING INFORMATION
The principal authors of this revenue procedure are John E. Hinding of the Office of Associate Chief Counsel (International) and Martin Scully, Jr. of the Office of Associate Chief Counsel (Income Tax & Accounting). However, other personnel from the IRS and Treasury participated in their development. For comments or questions regarding the international provisions applicable to cross licenses covered by this revenue procedure, contact John E. Hinding at 202-435-5265 (not a toll-free call). For comments or questions regarding the domestic provisions applicable to cross licenses covered by this revenue procedure, contact Martin Scully, Jr. at 202-622-8066 (not a toll-free call).
Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations
Notice of proposed rulemaking by cross-reference to temporary regulations.
In this issue of the Bulletin, the IRS is issuing temporary regulations (T.D. 9311) under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. These regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of those regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the temporary regulations and these proposed regulations.
Written or electronic comments and requests for a public hearing must be received by May 7, 2007.
Concerning the proposed regulations, Daniel McCall, (202) 622-3860; concerning submissions of comments, requests for a public hearing, and/or to be placed on the building access list to attend a hearing, contact Richard Hurst at (202) 622-7180 (not toll-free numbers).
The collections of information contained in this notice of proposed rulemaking have been submitted to the Office of Management and Budget for review in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)). Comments on the collection of information should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, SE:W:CAR:MP:T:T:SP, Washington, DC 20224. Comments on the collection of information should be received by May 7, 2007.
Comments are specifically requested concerning:
Whether the proposed collections of information are necessary for the proper performance of the functions of the Internal Revenue Service, including whether the information will have practical utility;
The accuracy of the estimated burden associated with the proposed collection of information;
How the quality, utility, and clarity of the information to be collected may be enhanced;
How the burden of complying with the proposed collections of information may be minimized, including through the application of automated collection techniques or other forms of information technology; and
Estimates of capital and start-up costs of operation, maintenance, and purchase of service to provide information.
The collections of information in this proposed regulation is in §1.367(a)-8(b)(3)(iii), (e)(1) through (e)(8), and (g). Responses to these collections of information are required to prevent triggering gain recognition agreements—for example, by submitting new gain recognition agreements or by submitting elections to reduce basis in certain stock. Responses are also required to facilitate electronic filing. These regulations include a rule requiring that gain or interest due under section 367(a) be included in a schedule that can be attached to a taxpayer’s electronically-filed return. Response to these collections of information is mandatory. The likely respondents are large corporations.
Estimated total annual reporting burden: 240.
Estimated average annual burden hours per respondent: from 1 hour to 2 hours, depending on individual circumstances.
Estimated number of respondents: 170.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information, unless the collection of information displays a valid control number assigned by the Office of Management and Budget.
Books or records relating to these collections of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.
Background and Explanation of Provisions
Temporary regulations in this issue of the Bulletin amend the Income Tax Regulations (26 CFR part 1) relating to section 367(a) of the Internal Revenue Code (Code) and gain recognition agreements. The text of those regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the temporary regulations and these proposed regulations.
It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required.
It is hereby certified that the collections of information contained in these regulations will not have a significant economic impact on a substantial number of small entities. Accordingly, a regulatory flexibility analysis is not required. These regulations primarily will affect United States persons that are large corporations engaged in cross-border corporate transactions. Thus, the number of affected small entities—in whichever of the three categories defined in the Regulatory Flexibility Act (small businesses, small organizations, and small governmental jurisdictions)—will not be substantial. The IRS and Treasury Department estimate that small organizations and small governmental jurisdictions are likely to be affected only insofar as they might hold a portfolio interest in stock or securities and in the unlikely event that they transfer such stock or securities to a foreign corporation. While a certain number of small entities may transfer stock or securities to a foreign corporation in connection with an acquisition or reorganization, the IRS and Treasury Department do not anticipate the number to be substantial. Furthermore, the IRS and Treasury Department estimate that those small entities that are affected by the regulations will likely face a burden of approximately two hours at an hourly rate of $200. Considering that the collections of information enable taxpayers to defer or avoid the recognition of potentially large amounts of gain that is subject to a gain recognition agreement, IRS and Treasury believe that $400 is not a significant economic impact. Comments about the accuracy of this certification may be submitted to the addresses provided in the preamble. Pursuant to section 7805(f) of the Internal Revenue Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.
Comments and Requests for a Public Hearing
Before these proposed regulations are adopted as final regulations, consideration will be given to any written comments (a signed original and eight (8) copies) or electronic comments that are submitted timely to the IRS. The IRS and Treasury Department specifically request comments on the clarity of the proposed rules and how they can be made easier to understand. For additional requests for comments, see the section “Request for Comments,” in the preamble to the cross-referenced temporary regulations of this issue of the Bulletin. All comments will be available for public inspection and copying. A public hearing will be scheduled if requested in writing by any person that timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register.
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
Par. 2. Section 1.367(a)-3 is amended by revising paragraphs (e) and (f) to read as follows:
(e) [The text of this proposed amendment is the same as the text of §1.367(a)-3T(e) published elsewhere in this issue of the Bulletin].
(f) [The text of this proposed amendment is the same as the text of §1.367(a)-3T(f) published elsewhere in this issue of the Bulletin].
Par. 3. Section 1.367(a)-8 is revised to read as follows:
[The text of proposed §1.367(a)-8 is the same as the text of §1.367(a)-8T published elsewhere in this issue of the Bulletin.]
(Filed by the Office of the Federal Register on February 1, 2007, 10:34 a.m., and published in the issue of the Federal Register for February 5, 2007, 72 F.R. 5228)
The principal author of these proposed regulations is Daniel McCall of the Office of Associate Chief Counsel (International). However, other personnel from the IRS and the Treasury Department participated in their development.
Archer Medical Savings Accounts — Trustees’ Reports on the Number of Archer MSAs Established Between January 1, 2005 and June 30, 2005 and Between January 1, 2006 and June 30, 2006
The purpose of this announcement is to notify trustees and custodians that they must report to the Internal Revenue Service (IRS) the number of Archer MSAs established (1) between January 1, 2005 and June 30, 2005 and (2) between January 1, 2006 and June 30, 2006. Trustees must report this information to IRS on separate Forms 8851 for 2005 and 2006, no later than March 20, 2007. Form 8851 (revised 2007) is currently available at www.irs.gov.
Archer Medical Savings Accounts (Archer MSAs)
Archer MSAs are authorized by section 220 of the Internal Revenue Code. The Tax Relief and Health Care Act of 2006 § 117, Pub. Law. No. 109-432, amends sections 220(j)(4), (5) of the Code to require that trustees of Archer MSAs report the number of Archer MSAs established (1) between January 1, 2005 and June 30, 2005 and (2) between January 1, 2006 and June 30, 2006. Trustees must report this information to IRS by March 20, 2007. Archer MSAs will terminate if the number of individuals establishing Archer MSAs exceeds certain numerical limits. If these limitations are exceeded in 2005 or 2006, April 19, 2007 will be a “cut-off date” after which, in general, no new Archer MSAs can be established. IRS will publish no later than April 19, 2007 the number of Archer MSAs established and whether April 19, 2007 is a “cut-off date.”
Questions regarding this announcement may be directed to Shoshanna Tanner in the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) at (202) 622-6080 (not a toll-free number).
Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)
Final and temporary regulations; correction notice.
This document contains corrections to temporary regulations (T.D. 9303, 2007-5 I.R.B. 379) that was published in the Federal Register on Tuesday, December 19, 2006 (71 FR 75879) regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D).
These corrections are effective December 19, 2006.
Bruce A. Decker at (202) 622-7550 (not a toll-free number).
The temporary regulations (T.D. 9303) that is the subject of these corrections are under sections 368 and 354 of the Internal Revenue Code.
Need for Correction
As published, the temporary regulations (T.D. 9303) contain errors that may prove to be misleading and are in need of correction.
Correction of Publication
Accordingly, the temporary regulations (T.D. 9303) that was the subject of FR Doc. E6-21565, is corrected as follows:
1. On page 75879, column 1, in the preamble, under the caption “SUMMARY:”, line 9, the language “securities of the acquiring corporation is” is corrected to read “securities of the acquiring corporation are.”
2. On page 75880, column 1, in the preamble, under the paragraph heading “Background”, first full paragraph of the column, line 5, the language “its operating assets to Y for $34x dollars,” is corrected to read “its operating assets to Y for $34x,.”
3. On page 75880, column 1, in the preamble, under the paragraph heading “Background”, second full paragraph of the column, line 7, the language “requirements of section 354 and 356, is corrected to read “requirements of sections 354 and 356,.”
4. On page 75881, column 1, in the preamble, under the paragraph heading “Special Analyses”, line 7 from the bottom of the paragraph, the language “published elsewhere in this Federal” is corrected to read “published elsewhere in this issue of the Federal.”
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§ 1.368-2T [Corrected]
Par. 2. Section 1.368-2T is amended by revising paragraph (l)(1) to read as follows:
§ 1.368-2T Definition of terms (temporary).
(l) * * *
1) General rule. In order to qualify as a reorganization under section 368(a)(1)(D), a corporation (transferor corporation) must transfer all or part of its assets to another corporation (transferee corporation) and immediately after the transfer the transferor corporation, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination thereof, must be in control of the transferee corporation; but only if, in pursuance of the plan, stock or securities of the transferee corporation are distributed in a transaction which qualifies under section 354, 355, or 356.
LaNita Van Dyke,
Chief, Publications and Regulations Branch,
Legal Processing Division,
Office of Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on January 23, 2007, 8:45 a.m., and published in the issue of the Federal Register for January 24, 2007, 72 F.R. 3057)
Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction Notice
Notice of proposed rulemaking by cross-reference to temporary regulations; Correction notice.
This document contains corrections to notice of proposed rulemaking by cross-reference to temporary regulations (REG-125632-06, 2007-5 I.R.B. 415) that was published in the Federal Register on Tuesday, December 19, 2006 (71 FR 75898) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation are issued and distributed in the transaction.
The notice of proposed rulemaking by cross-reference to temporary regulations (REG-125632-06) that is the subject of these corrections are under sections 368 and 354 of the Internal Revenue Code.
As published, notice of proposed rulemaking by cross-reference to temporary regulations (REG-125632-06) contains errors that may prove to be misleading and are in need of clarification.
Accordingly, the notice of proposed rulemaking by cross-reference to temporary regulations (REG-125632-06) that was the subject of FR Doc. E6-21572, is corrected as follows:
On page 75898, column 3, in the preamble, under the caption “SUMMARY:”, line 9, the language “acquiring corporation is issued and” is corrected to read “acquiring corporation are issued and.”
Extension of Deadline for Settlement Offered to Certain Foreign Embassy Staff
Following is a copy of the News Release issued by the Office of Deputy Commissioner, International on February 13, 2007 (IR-2007-34).
IRS Extends Deadline for Settlement Offered to Certain Foreign Embassy Staff
IR-2007-34, Feb. 13, 2007
WASHINGTON — The Internal Revenue Service will extend until March 30 the deadline for current and former U.S.-based employees of foreign embassies, consular offices and missions and international organizations to participate in a one-time settlement initiative to resolve outstanding tax matters related to their employment.
The deadline for participating in the offer, first announced November 17, had originally been February 20. Following requests from several embassies, the date is being extended to make certain those wishing to participate in the initiative have the opportunity to do so.
The offer is open to employees of those organizations who are U.S. citizens, green-card holders and foreign employees who have U.S. tax obligations. Accredited diplomatic personnel are generally exempt from income taxes on their wages under international treaties or agreements.
The IRS estimates that as many as half of these employees subject to U.S. tax either fail to report their wages, claim deductions they are not entitled to, incorrectly establish SEP/IRA retirement plans, fail to pay self-employment tax or fail to file tax returns at all.
To participate, employees must submit amended or original tax returns, which properly reflect their income and expenses, for tax years 2003, 2004 and 2005.
Failure to act now could mean facing a costly audit process in the future. Foreign embassy, consular office or international organization employees who fail to come forward may be subject to IRS audits and penalties which could cover more than just three years.
Additional guidance on the extension will be announced soon and will be posted on IRS.gov.
Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).
Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed.
Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.
Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.
Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.
Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded.
Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.
Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect:
The following abbreviations in current use and formerly used will appear in material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D. —Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2006-27 through 2006-52 is in Internal Revenue Bulletin 2006-52, dated December 26, 2006.
Bulletins 2007-1 through 2007-10
2007-1 2007-1 I.R.B. 2007-1 243
2007-10 2007-6 I.R.B. 2007-6 464
2007-23 2007-10 I.R.B. 2007-10
157711-02 2007-8 I.R.B. 2007-8 537
147144-06 2007-10 I.R.B. 2007-10
Revenue Procedures
2007-1 2007-1 I.R.B. 2007-1 1
2007-2 2007-1 I.R.B. 2007-1 88
Revenue Rulings
Treasury Decisions
9298 2007-6 I.R.B. 2007-6 434
9311 2007-10 I.R.B. 2007-10
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2006-27 through 2006-52 is in Internal Revenue Bulletin 2006-52, dated December 26, 2006.
Old Article
2002-45 Modified by Notice 2007-22 2007-10 I.R.B. 2007-10
2005-29 Modified and superseded by Notice 2007-4 2007-2 I.R.B. 2007-2 260
2006-2 Modified and superseded by Notice 2007-4 2007-2 I.R.B. 2007-2 260
2006-50 Amplified, clarified, and modified by Notice 2007-11 2007-5 I.R.B. 2007-5 405
208270-86 Corrected by Ann. 2007-4 2007-7 I.R.B. 2007-7 518
121509-00 Corrected by Ann. 2007-17 2007-8 I.R.B. 2007-8 597
125632-06 Corrected by Ann. 2007-26 2007-10 I.R.B. 2007-10
136806-06 Hearing cancelled by Ann. 2007-19 2007-7 I.R.B. 2007-7 521
98-20 Superseded by Rev. Proc. 2007-12 2007-4 I.R.B. 2007-4 354
2000-38 Modified by Rev. Proc. 2007-16 2007-4 I.R.B. 2007-4 358
2001-42 Modified and amplified by Rev. Proc. 2007-19 2007-7 I.R.B. 2007-7 515
2002-9 Modified and amplified by Rev. Proc. 2007-14 2007-4 I.R.B. 2007-4 357
2002-9 Modified by Rev. Proc. 2007-16 2007-4 I.R.B. 2007-4 358
2004-11 Superseded by Rev. Proc. 2007-16 2007-4 I.R.B. 2007-4 358
2004-65 Modified and superseded by Rev. Proc. 2007-20 2007-7 I.R.B. 2007-7 517
2006-1 Superseded by Rev. Proc. 2007-1 2007-1 I.R.B. 2007-1 1
2006-2 Superseded by Rev. Proc. 2007-2 2007-1 I.R.B. 2007-1 88
2006-3 Superseded by Rev. Proc. 2007-3 2007-1 I.R.B. 2007-1 108
2006-35 Modified by Rev. Proc. 2007-22 2007-10 I.R.B. 2007-10
69-141 Modified by Notice 2007-22 2007-10 I.R.B. 2007-10
75-161 Obsoleted by Rev. Rul. 2007-8 2007-7 I.R.B. 2007-7 469
78-330 Modified by Rev. Rul. 2007-8 2007-7 I.R.B. 2007-7 469
81-225 Clarified and amplified by Rev. Rul. 2007-7 2007-7 I.R.B. 2007-7 468
92-19 Supplemented in part by Rev. Rul. 2007-10 2007-10 I.R.B. 2007-10
2003-43 Modified by Notice 2007-2 2007-2 I.R.B. 2007-2 254
2003-92 Clarified and amplified by Rev. Rul. 2007-7 2007-7 I.R.B. 2007-7 468
2003-102 Modified by Notice 2007-22 2007-10 I.R.B. 2007-10
2005-76 Supplemented and superseded by Rev. Rul. 2007-4 2007-4 I.R.B. 2007-4 351
9263 Corrected by Ann. 2007-22 2007-9 I.R.B. 2007-9 631
9278 Corrected by Ann. 2007-9 2007-5 I.R.B. 2007-5 417
9303 Corrected by Ann. 2007-25 2007-10 I.R.B. 2007-10
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed.
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents.
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Under information for: select Businesses. Under related topics, select More Topics. Then select Internal Revenue Bulletins.
Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the
P.O. Box 371954, Pittsburgh PA, 15250-7954.
Please allow two to six weeks, plus mailing time, for delivery.
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the
IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224
Page Last Reviewed or Updated: 23-Sep-2017
|
cc/2019-30/en_head_0021.json.gz/line27310
|
__label__cc
| 0.554164
| 0.445836
|
Nepal Länderbericht
Nepal - annual report 2016
Angela Schmeink
Head of Office Berlin
Phone: +49 (0) 30 2000 900-82
Cambodia, Kyrgyzstan, Nepal, Tajikistan,
Uzbekistan, Vietnam
EU Grants
Victoria Börner | +49 (0) 30 2000 900-85
Angela Lummel | +49 (0) 30 2000 900-81
Nicole Zintel | +49 (0) 30 2000 900-83
Administration Berlin
Laura Ružman | +49 (0) 30 2000 900-80
Visit to the Ministry for Federalism and Local Development: Dr. Matthias Hartwig, Sieglinde von Wasielewski and Angela Schmeink, IRZ; Mohan Gurung, Secretary of State; Dr. Hari Paudel, Joint Secretary (from left to right)
Legal Policy Starting Point
Since the Constitution was passed in 2015, the Government of Nepal has endeavoured to implement the constitutional law stipulations into the rule of law and the judiciary. The Constitution provides for a federal state structure which constitutes a considerable challenge for Nepal as a former kingdom and creates a significant requirement for new legislation in central areas of the law.
Significant new developments relate to the newly created status as a secular state, nationality law, the judicial system and inclusion. The reform process regularly comes to a standstill due to various political conflicts, in particular because members of ethnic minorities do not consider their protection to be sufficiently safeguarded in the constitutional law provisions. At the start of 2016, the Constitution was amended by providing a certain number of parliamentary seats for representatives of the Terai and establishing consideration for ethnic groups in the configuration of electoral districts and access to the civil service. However, tensions in the country still continue. Further constitutional law modifications are in discussion.
Overall Concept
The IRZ has been advising Nepalese partners from the judicial field since 2012 and realised a consultancy project on the process of constitutional legislation in recent years with funding from the German Federal Foreign Office. A subsequent project was initiated to support the strengthening of the rule of law and democracy in the implementation of the new Constitution which is funded by the German Federal Foreign Office and started in April 2016 for a term of two years. The local project partner is the Nepal Law Society, a charitable, independent non-governmental organisation dedicated to the rule of law, an independent judiciary, human rights, the promotion of women and minorities, as well as decentralisation and the development of local self-administration. Together with this partner, the IRZ organises measures for the exchange of experts between German and Nepalese lawyers in order to discuss different legislation projects for the implementation of the constitutional law stipulations. In addition, further training measures are intended for different parties applying the law in the judiciary, the sphere of justice, the parliaments, the government structure and the ministries in Kathmandu and in various rural regions.
The project started with the constituting meeting of the “Advisory Committee” in April in Kathmandu, which views itself as the body for the conceptual and political steering of the project. This Committee comprises high-ranking representatives from different institutions which play an important role in the implementation of the constitutional law stipulations, e.g. parliamentarians of various parties or the management level of the Ministry of Justice and the Ministry of Federalism.
Once the sets of rules which came into question had been identified and conceived by the Nepalese side, initial expert consultations took place in early August 2016 in Kathmandu. In the course of this mission, two German lawyers, the IRZ and various Nepalese experts worked on specific draft legislation. This related to the establishment of a national commission for the allocation of resources and finance, as well as regulations on local self-administration. The discussions revealed the need for clarification on legal policy ideas with regard to the federal structure. In a later project phase, the exchange amongst experts was continued. In addition, legislative projects for local self-administration at the provincial and local council level were identified as potential project areas.
Strategic reform programmes have been implemented in Nepal for several years now in order to develop the judicial system into an independent, competent and efficient system that is accessible to citizens. In this context, the IRZ provided support for a study trip for an international exchange on „best practice” in the course of the bilateral cooperation, during which representatives of the Nepalese Supreme Court visited the USA, France, Great Britain and Germany. In Berlin, Nepalese judges raised current issues on the judicial and federalism reforms in discussions at the Bundesrat and the Berlin Higher Regional Court.
In 2016, the IRZ organised an internship programme in English for civil judges and commercial judges for members of its partner states for the first time. Two judges from Nepal successfully completed this programme.
Foci of Activity 2016
Civil and Commercial Law
Participation by two judges in the IRZ’s internship programme for civil judges and commercial judges in English
Constitutive meeting of the “Advisory Committee” in the project for the implementation of the Nepalese Constitution in Kathmandu
Specialist discussions in Kathmandu with key persons from Parliament, the ministries and the courts on project topics
Expert consultations in Kathmandu on the allocation of resources and finance as well as on rules for local self-administration
Study trip by a delegation from the Supreme Court to the USA, France, Great Britain and Berlin on „best practice” in the judicial systems with the support of the IRZ
The current project for the implementation of the Nepalese Constitution will be continued until 2018. This includes advice on further legislation projects and the further training of legal practitioners at central and local levels in order to deepen their knowledge of the new regulations which are relevant for their own work.
Download the entire IRZ annual report in PDF format here: annual report 2016.
|
cc/2019-30/en_head_0021.json.gz/line27311
|
__label__cc
| 0.639173
| 0.360827
|
Meet Gordy & Opal Krum. . .
Gordy & Opal Krum have lived in the village of Decatur since 1950. They built a house on Cedar St and had a cottage on Eagle Lake, where Opal and their children spent the summers. They decided to move to Lake of the Woods in 1963. A large red brick house on Meadow. . . It was perfect because they could reside on a lake and were still in the Village. Their children (Nancy lives in Decatur and Gary near PawPaw) loved to swim in the channel and they enjoyed boating around the lake.
Gordy had a Chevrolet dealership in Decatur. He also owned Airway Lanes, a bowling alley, in Kalamazoo. He eventually became the president of the First State Bank of Decatur. When they were first married Opal was a social worker. She gave that up to be a homemaker and mother. She says she also served as Gordy's "go-fer", running errands for his businesses.
Gordy belongs to the VFW, the Masons, the Lion's Club, and he is a lifetime member on the board of the Michigan Bowling Proprietors Association. He continues to work part time at the Bank, too!
Gordy & Opal love Lake of the Woods. When their children grew up and moved out of their house they decided they needed a smaller house. In 2000 they built a house right next door---still on the lake! Opal says the free swimming lessons for children and having a life guard at the public beach are wonderful perks. She remembers her daughter Nancy swimming across the lake in those swimming lessons!
They talked about how the lake has changed over the years, from small cottages to big year-round houses. Opal says that in the distant past living on the lake was undesirable. But not anymore. . .!
Their biggest concern about Lake of the Woods is the need for a sewer system around the lake. They would like all lake residents, even if they are part timers, to attend to the health of the lake for the long term.
Their favorite local restaurants are the Hard Times Cafe in Decatur, La Cantina in Paw Paw, Big Ts in Lawton, and Zeeks in Dowagiac.
Gordy & Opal appreciate the Lake Association for keeping them aware of what is going on around the lake.
|
cc/2019-30/en_head_0021.json.gz/line27314
|
__label__cc
| 0.516103
| 0.483897
|
Will Trump Back Pentagon’s Permanent War Proposals?
The two top national security officials in the Trump administration – Secretary of Defence James Mattis and national security adviser HR McMaster – are trying to secure long-term US ground and air combat roles in the three long-running wars in the greater Middle East – Afghanistan, Iraq and Syria.
Proposals for each of the three countries are still being developed, and there is no consensus, even between Mattis and McMaster, on the details of the plans. They will be submitted to Trump separately, with the plan for Afghanistan coming sometime before a NATO summit in Brussels on 25 May.
If Trump approves expected proposals for the three countries, the US ground combat role in the region will be extended for years to come
But if this power play succeeds in one or more of the three, it could guarantee the extension of permanent US ground combat in the greater Middle East for many years to come – and would represent a culmination of the “generational war” first announced by the George W Bush administration.
‘Open-ended commitment’
It remains to be seen whether President Donald Trump will approve the proposals that Mattis and McMaster have pushed in recent weeks.
Judging from his position during the campaign and his recent remarks, Trump may well baulk at the plans now being pushed by his advisers.
The plans for the three countries now being developed within the Trump administration encompass long-term stationing of troops, access to bases and the authority to wage war in these three countries.
These are the primordial interest of the Pentagon and the US military leadership, and they have pursued those interests more successfully in the Middle East than anywhere else on the globe.
US military officials aren’t talking about “permanent” stationing of troops and bases in these countries, referring instead to the “open-ended commitment” of troops. But they clearly want precisely that in all three.
Shifting timetables
The George W Bush administration and the Barack Obama administration both denied officially that they sought “permanent bases” in Iraq and Afghanistan, respectively. But the subtext in both cases told a different story.
A Defense Department official testifying before Congress at the time admitted that the termhad no real meaning, because the Pentagon had never defined it officially.
In fact, at the beginning of the negotiations with Iraq on the US military presence in 2008, the US sought access to bases in Iraq without any time limit. But the al-Maliki government rebuffed that demand and the US was forced to agree to withdraw all combat forces in a strict timetable.
In December 2011, US soldiers wave at their comrades as they cross the border between Iraq and Kuwait on the last US military convoy carrying troops from Iraq marking the end of the presence of US army in Iraq (AFP)
Despite efforts by the Pentagon and the military brass, including Gen David Petraeus, to get the Obama administration to renegotiate the deal with the Iraqi government to allow tens of thousands of combat troops to stay in the country, the Iraqis refused US demands for immunity from prosecution in Iraq, and the US had to withdraw all its troops.
Reversing withdrawals
Now the regional context has shifted dramatically in favour of the US military’s ambitions. On one hand, the war against Islamic State (IS) is coming to a climax in both Iraq and Syria, and the Iraq government recognises the need for more US troops to ensure that it can’t rise again; and in Syria, the division of the country into zones of control that depend on foreign powers is an overriding fact.
Meanwhile in Afghanistan, growing Taliban power and control across the country is being cited as the rationale for a proposal to reverse the withdrawals of US and NATO troops in recent years and to allow a limited return by US forces to combat.
Now that Islamic State forces are being pushed out of Mosul, both the Trump administration and the Iraqi government are beginning to focus on how to ensure that the terrorists do not return.
They are now negotiating on an agreement that would station US forces in Iraq indefinitely. And the troops would not be there merely to defeat IS, but to carry out what the war bureaucracies call “stabilisation operations” – getting involved in building local political and military institutions.
Plans for Syria
The question of what to do about Syria is apparently the subject of in-fighting between Mattis and the Pentagon, on one hand, and McMaster, on the other.
The initial plan for the defeat of IS in Syria, submitted to Trump in February, called for an increase in the size of US ground forces beyond the present level of 1,000.
As part of one plan, US ground troops would lead Sunni Arab troops to destroy IS in Syria rather than relying on Kurdish forces to do the job
But a group of officers who have worked closely with Gen Petraeus on Iraq and Afghanistan, which includes McMaster, has been pushing a much more ambitious plan,in which thousands – and perhaps many thousands – of US ground troops would lead a coalition of Sunni Arab troops to destroy Islamic State’s forces in Syria rather than relying on Kurdish forces to do the job.
Both the original plan and the one advanced by McMaster for Syria would also involve US troops in “stabilisation operations” for many years across a wide expanse of eastern Syria that would require large numbers of troops for many years.
Both in its reliance on Sunni Arab allies and in its envisioning a large US military zone of control in Syria, the plan bears striking resemblance to the one developed for Hillary Clintonby the Center for New American Security when she was viewed as the president-in-waiting.
Reversing Obama’s Afghanistan policy
The Pentagon proposal on Afghanistan, which had not been formally submitted by Mattis as of this week, calls for increasing the present level of 8,400 US troops in Afghanistan by 1,500 to 5,000, both to train Afghan forces and to fight the Taliban. It also calls for resuming full-scale US air strikes against the Taliban. Both policy shifts would reverse decisions made by the Obama administration.
The US and NATO were not able to pressure the Taliban to negotiate with the government even when they had more than 100,000 troops in the country
Five past US commanders in Afghanistan, including Petraeus, have publicly caIled forthe US to commit itself to an “enduring partnership” with the Afghan government. That means, according to their joint statement, ending the practice of periodic reassessments as the basis for determining whether the US should continue to be involved militarily in the war, an idea that is likely part of the package now being formulated by Mattis.
But the problem with such a plan is that the US military and its Afghan client government have now been trying to suppress the Taliban for 16 years. The longer they have tried, the stronger the Taliban have become. The US and NATO were not able to pressure the Taliban to negotiate with the government even when they had more than 100,000 troops in the country.
Committing the US to endless war in Afghanistan would only reinforce the corruption, abuses of power and culture of impunity that Gen Stanley A McChystal acknowledged in 2009 were the primary obstacles to reducing support for the Taliban. Only the knowledge that the US will let the Afghans themselves determine the country’s future could shock the political elite sufficiently to change its ways.
Most political and national security elites as well as the corporate news media support the push to formalise a permanent US presence in Afghanistan, despite the fact that national polls indicate that it is the most unpopular war in US history with 80 percent of those surveyed in a CNN poll in 2013 opposing its continuation.
Beltway brawl?
There are signs that Trump may reject at least the plans for Afghanistan and Syria. Only days after his approval of the missile strike on a Russian-Syrian airbase, Trump told Fox Business in an interview, “We’re not going into Syria.”
And White House spokesman Sean Spicer seemed to suggest this week that Trump was not enamoured with the plan to spend many more years trying to “transform” Afghanistan. “There is a difference between Afghanistan proper and our effort to defeat ISIS,” Spicer said
Despite Trump’s love for the military brass, the process of deciding on the series of new initiatives aimed at committing the US more deeply to three wars in the greater Middle East is bound to pose conflicts between the political interests of the White House and the institutional interests of the Pentagon and military leaders.
By Gareth Porter posted on May 13, 2017
About Gareth Porter
Gareth Porter is an investigative historian and journalist specialising in U.S. national security policy. The paperback edition of his latest book, "Perils of Dominance: Imbalance of Power and the Road to War in Vietnam", was published in 2006.
|
cc/2019-30/en_head_0021.json.gz/line27316
|
__label__wiki
| 0.918497
| 0.918497
|
Man in Car Is Shot; 3 Suspects Arrested
From Times Staff Reports
A 28-year-old Oxnard man was shot in the head early Saturday as he rode in a car, and three people have been arrested in connection with the shooting, authorities said.
Jose Perez was taken to St. John’s Regional Medical Center after the 12:30 a.m. shooting, said Oxnard Police Sgt. Cliff Troy. Hospital officials did not release Perez’s condition Saturday at the request of family members.
Four people were in the car in the 600 block of Colonia Road when several shots were fired, Troy said. Perez was hit once.
Raymond Coronel, 26, of Oxnard and two juveniles, both 17, were arrested within two hours of the shooting. The three were booked on suspicion of attempted murder, Troy said.
|
cc/2019-30/en_head_0021.json.gz/line27317
|
__label__wiki
| 0.731886
| 0.731886
|
Holidays may be over, but Las Vegas’ giant Chinese lantern light show continues
Motorcyclists speed through a metal sphere at Global Winter Wonderful in Las Vegas, which features illuminated replicas of world landmarks.
(Manuel Cabral)
By Jay Jones
With its own Eiffel Tower, Statue of Liberty and an Egyptian pyramid-shaped hotel, Las Vegas is no stranger to copycat landmarks. Visitors can also see imitations of Mexico’s Chichen Itza and India’s Taj Mahal during their next visit to the city at the Global Winter Wonderland.
The show is a nod to the tradition of Chinese lanterns, featuring huge light installations, some as tall as 50 feet and as long as 100 feet. It’s meant to re-create a trip around the world, with replicas of tourist attractions such as the Sydney Opera House in Australia and Italy’s leaning Tower of Pisa.
An oversized octopus illuminated with LEDs and fluorescent lights is one of the creations at the Global Winter Wonderland.
The show opened in mid-December outside the Rio All-Suite Hotel and Casino and continues through Jan. 20. It’s divided into several lands: North and South Americas as well as Africa, Australia and a winter-themed area. Larger-than-life dragons, an octopus and a penguin also are on display. The designs are illuminated by low-voltage LEDs and fluorescent lights.
In addition, visitors can sample food from various countries, shop for arts and crafts, and take carnival rides. Live entertainment includes nightly performances by kung fu masters the Shaolin Warriors at 6:30 and 8:30 p.m.
The Swan Lake exhibit at Global Winter Wonderland in Las Vegas.
Winter Wonderland is open 5-11 p.m. Tickets cost $26 for adults 18 to 60 years old, and $24 for children 6 to 17 years old and seniors.
Parking at the Rio is free.
The lantern festival is produced by the International Culture Exchange Group based in Fremont, Calif.
travel@latimes.com
@latimestravel
Jurassic World opens quietly but makes a big splash with new technology
Universal Studios Hollywood rushes to open its Jurassic World ride, which uses the latest technology.
|
cc/2019-30/en_head_0021.json.gz/line27318
|
__label__cc
| 0.724549
| 0.275451
|
Non-lawyers may be gentlemen – but they can’t be officers
Posted by Neil Rose
Texas: bonus restriction
The distance between reform in the UK and US has been shown up starkly by a Texan ethics ruling that prohibits non-lawyers working in law firms to have the word ‘officer’ in their job titles.
It has also stopped bonuses to non-lawyer employees that are contingent upon the firm achieving a specified amount of revenue or profit.
The opinion was issued after a Texas law firm proposed giving non-lawyer professionals the titles ‘chief executive officer’ and ‘chief technology officer’ and to identify them as ‘principals’ in the law firm, as well as giving them bonuses based on firm-wide targets.
Despite the growing practice of giving non-lawyers such titles in US firms, the Texas Bar’s ethics committee ruled that the term ‘officer’ in these circumstances “indicates that the person holding the title has the power to control either the entire law firm (in the case of ‘chief executive officer’) or significant areas of the firm’s operations (in the case of ‘chief technology officer’).
“Use of the term ‘principal’ for non-lawyer employees implies that the employees have an interest in the firm involving control, ownership, or both”.
This is not permitted in Texas, and so to describe them thus would be a “false or misleading communication”.
The bonus plan fell foul of a ban on lawyers sharing or promising to share legal fees with a non-lawyer, the committee said.
“Such a plan would provide an incentive for the firm’s non-lawyer employees to increase revenues, which could be accomplished through soliciting clients, or to reduce expenses, which could be accomplished by interfering with a lawyer’s independent judgment in practicing law,” it explained.
“Furthermore, tying a bonus to achieving a specified level of profit is similar to tying a bonus to achieving a specified level of revenue because profit is a function of revenue and expenses.”
The firm could, however, “consider its revenue, expenses, and profit in determining whether to pay bonuses to non-lawyer employees and the amount of such bonuses”.
|
cc/2019-30/en_head_0021.json.gz/line27334
|
__label__wiki
| 0.881357
| 0.881357
|
9th NASS: PDP reportedly picks Abaribe, Dogara as Senate, House minority leaders
2 months ago 33486 views by Wale Akinola
- PDP has reportedly foreclosed contest for Senate president and the speaker of House of Representatives
- The party has also picked Abaribe, Dogara as Senate, House minority leaders
- It was gathered that leaders of the party have resolved to tell members of the party elected into the 9th NASS not to drag the presiding officer positions with any of the APC members
There are indications that the leaders of the Peoples Democratic Party (PDP) may have foreclosed the chance of any of its members contesting for the post of Senate president or speaker of the House of Representatives in the next National Assembly.
Legit.ng reports that investigations by the Sunday Tribune confirmed that leaders of the party had been brainstorming about the role of the PDP in the incoming National Assembly due for inauguration in June.
It was confirmed that at formal and informal settings in recent weeks, the issue of how to handle the next National Assembly leadership had dominated discussions within the opposition party.
According to the newspaper, first, it was concluded that the party would not make public its choice of Senate president and speaker among the contestants on the ticket of the All Progressives Congress (APC) until very close to the inauguration of the new Assembly.
It noted that the party leaders have resolved to keep the APC guessing on this matter and that the final meeting that would arrive at the choice of the candidate for Senate president and speaker would only be known days to the elections.
A source in the know was said to have been quoted to have noted that members of the National Working Committee of the PDP and the lawmakers-elect in the Senate and the House have been talking with no final decision reached on the contestants for the nation’s number three and four positions so far.
It was gathered that leaders of the party have also resolved to tell members of the party elected into the ninth Senate and House of Representatives not to drag the presiding officer positions with any of the APC members.
A source said that the party analysed its take on the 2015 to 2019 National Assembly and then resolved to change its strategy.
“It was good enough that we foisted a sort of hybrid Senate on the National Assembly in 2015 and then we also ensured that our loyalists in the person of the speaker of the House, Honourable Yakubu Dogara got elected in 2015.
“It served as a morale booster that equally helped to galvanise our members in the two chambers. But going forward, it has been adopted that none of our members would drag the presiding officer positions with the APC in June. The idea is to make impact without necessarily dragging positions,” the source said.
Another source stated that the PDP has resolved to allow the APC run its government so that the main opposition party can face the role of opposition between 2019 and 2023.
“During the 2019 electioneering, the APC went about blaming its failure on the hostile National Assembly being led by the opposition. Right now, we are of the view that the idea has served its purpose. From now, we won’t give further room for unfounded excuses by the APC,” the source stated.
It was also gathered that the party has resolved to pick the Senator representing Abia south, Senator Enyinnaya Abaribe, who currently chairs the Senate committee on power, steel development and metallurgy as its minority leader in the ninth Senate.
It was also learnt that Dogara has been chosen as the minority leader of the 9th House of Representatives.
In picking the duo, it was gathered that the party is gunning for consistency and loyalty, while also appreciating Dogara for his firm grip on members in the House.
READ ALSO: Nobody can stop Tinubu's presidency in 2023 - Former MPPP chairman
Meanwhile, Legit.ng had previously report that the senator representing Borno south, Ali Ndume, vowed not to step down for any candidate in his quest to be the president of ninth Senate despite the earlier endorsement of Senator Ahmed Lawan by All Progressive Congress (APC).
NAIJ.com (naija.ng) -> Legit.ng We keep evolving to serve our readers better
Which of President Buhari’s ministers should he retain for 2nd term? | - on Legit TV
APC Latest NewsPDP Latest NewsNigerian Senate Latest NewsPresidential Elections 2019 in Nigeria
Checkout new stunning photos of Davido's boo Chioma
|
cc/2019-30/en_head_0021.json.gz/line27335
|
__label__cc
| 0.685787
| 0.314213
|
Trauma Services - McLaren Macomb
1000 Harrington Blvd.
Mount Clemens , MI 48043
McLaren Macomb is Macomb County's first verified trauma center. We are also the only hospital in Macomb County to have trauma surgeons at the hospital every day, all day. Because when it's someone you love, 15 minutes can be a lifetime.
Follow up care: In addition, trauma patients may be seen for follow-up care in the hospital's Trauma Clinic, located at 36500 Gratiot, Suite 102, in Clinton Township, just south of 16 Mile Road.
The trauma team at McLaren Macomb is a group of surgeons who have been specially trained in advanced trauma care. They are available 24 hours a day, seven days a week.
Our Trauma Team
Our trauma surgeons are in-house 24/7 to evaluate each trauma patient immediately upon arrival.
The team includes orthopedic surgeons, vascular and cardiothoracic surgeons, neurosurgeons, oral-maxillofacial surgeons and plastic surgeons. Also on the team are anesthesiologists, radiologists, as well as staff from physical medicine, internal medicine and rehabilitation.
Other physician specialists may be consulted when needed.
McLaren Macomb Trauma Care Physicians:
Mandip S. Atwal, D.O. - Medical Director
Douglas G. Paulk, D.O. - Medical Director
Stephen D. Cahill, D.O.
Michael J. D'Almeida, D.O.
Gregory G. Gaborek, D.O.
James J. Giliberto, Jr., D.O.
Roy E. Hanks, D.O.
James E. Johnson, D.O.
James H. McQuiston, D.O.
Carl M. Pesta, D.O.
|
cc/2019-30/en_head_0021.json.gz/line27341
|
__label__wiki
| 0.957521
| 0.957521
|
1MDB case: No plea deal seen this week for ex-Goldman banker Ng on US charges
Published 1 month ago on 23 May 2019
Ex-Goldman Sachs banker Roger Ng (left) and his lawyer Marc Agnifilo leave the federal court in New York May 6, 2019. — Reuters pic
NEW YORK, May 23 — Former Goldman Sachs Group Inc banker Roger Ng is unlikely to get a plea deal this week on criminal charges linked to a multibillion-dollar scandal at the Malaysian state investment fund 1MDB, both sides told Reuters today.
Plea negotiations are not yet on the agenda, a lawyer for Ng and a spokesman for the US Department of Justice said. Instead, they plan to only discuss scheduling for case proceedings at a Brooklyn federal court.
Prosecutors and Ng’s lawyer, in a May 6 court document related to the case, requested delaying the trial date for Ng because they believed plea negotiations “are likely to result in a disposition of this case without trial.”
The US Department of Justice accused 46-year-old Ng last year of conspiring to launder money and bribe government officials in Malaysia and Abu Dhabi through bond offerings that Goldman Sachs handled. He was extradited on May 3 to New York from Kuala Lumpur, where he had been jailed since November.
Ng pleaded not guilty to the charges on May 6 and was released in exchange for a US$20 million (RM84 million) bond.
Government lawyers have said they hope to avoid a trial by reaching a plea deal, though Ng’s attorney, Marc Agnifilo said this month it was too early to tell.
Ng, who left Goldman Sachs in 2014, faces up to 30 years in prison if convicted of the three charges based on alleged violations of the US Foreign Corrupt Practices Act.
Malaysia’s home minister wanted Ng to face criminal charges there first, but agreed to temporarily surrender him to the United States for 10 months, Malaysia’s Attorney-General Tommy Thomas, said in a statement.
The period may be extended, Thomas has said.
The 1MDB case has shaken Goldman Sachs, which is also being probed by the Justice Department for its role as underwriter and arranger for some US$6.5 billion worth of 1MDB bond offerings.
Prosecutors estimated that high-level 1MDB fund officials and their associates misappropriated US$4.5 billion between 2009 and 2014, including some of the funds that Goldman Sachs helped raise.
Goldman Sachs has consistently denied wrongdoing and said certain members of the former Malaysian government and 1MDB lied to it about how the bond proceeds would be used.
Ng was charged in Kuala Lumpur with four counts of abetting the bank to provide misleading statements in the offering prospectus for 1MDB bond sales.
Tim Leissner, another former Goldman Sachs banker, and Malaysian financier Low Taek Jho have also been charged in the United States over 1MDB. Leissner has pleaded guilty.
Low, whose whereabouts are unknown, has consistently denied wrongdoing through spokesmen.
Malaysia has said it was seeking up to US$7.5 billion in reparations from Goldman over its dealings with 1MDB, set up in 2009 by then-prime minister Datuk Seri Najib Razak.
Najib, who lost a general election last year, faces 42 criminal charges related to losses at 1MDB and other state entities. He has pleaded not guilty. — Reuters
|
cc/2019-30/en_head_0021.json.gz/line27342
|
__label__wiki
| 0.976585
| 0.976585
|
Blackhawks win razor-close Cup final
Blackhawks finish off Lightning to win one of closest Cup finals in history
Jun. 15, 2015 3:00 p.m.
Jonathan Toews raises the Stanley Cup for the third time as captain of the Chicago Blackhawks
By Stephen Whyno, The Canadian Press
CHICAGO – A puck off the edge of a stick blade, another off the cross-bar. That was the difference between winning and losing when the margin of error was almost non-existent.
After playing on a tightrope for two weeks, the dam finally broke as the Chicago Blackhawks beat the Tampa Bay Lightning 2-0 in Game 6 on Monday night to win one of the tightest Stanley Cup final series in NHL history and capture their third title in the past six years.
To star winger Patrick Kane, this was even sweeter than his first Cup in 2010 and 2013 after a lockout-shortened regular season.
“It seems like it was the hardest one,” Kane said. “We’ve been around once or twice so we know what to expect but we really enjoy these moments and these situations.
“Who knows how many of these opportunities come along? You always want to take advantage.”
The Blackhawks lifted the Cup at United Center for the first time. They had to wait, however, as the trophy was delayed by weather and needed a police escort to the arena. Chicago had not won on home ice since 1938 and hadn’t actually gotten the Cup there since 1934.
“We wanted it for each other, for the city,” captain Jonathan Toews said. “Winning a championship like this in your own city in some ways transcends the sport. Everyone wants to be a part of it.”
Fans didn’t leave for more than an hour after Toews lifted the Cup and handed it to 40-year-old Kimmo Timonen, who got to retire on top. They sang to “Sweet Caroline,” some banged on the glass and most simply didn’t want to leave.
“Full building from when we had the Cup out here,” forward Brandon Saad said. “It’s going to be a hell of a city to win it in. Looking forward to the parade.”
Conn Smythe trophy winner Duncan Keith scored the clincher on one of the best individual efforts of the playoffs, and Kane provided the exclamation point with a third-period goal. Keith was the unanimous Conn Smythe choice.
“Best D-man by far,” said Marian Hossa, who along with Keith is one of seven Blackhawks to be a part of all three championship teams. “He’s proved that over time. In this playoff he was unstoppable.”
In the final, Keith and crew got major help from goaltender Corey Crawford, who stopped 151 of the 161 shots he faced, including all 25 in Game 6. He outduelled Tampa Bay counterpart Ben Bishop, who was struggling with a groin tear suffered in Game 2.
The Lightning were banged up throughout the lineup, but that was little consolation in defeat.
“We came here to win this and we didn’t,” said captain Steven Stamkos, who did not score in the final. “Right now, it feels like we didn’t get the job done.”
Tampa Bay can feel good about not being far off. Until Kane scored with 5:14 left Monday night, the Lightning and Blackhawks were either tied or one goal apart for the entire series.
“Think it easily could have been us on the ice celebrating,” Bishop said.
A Game 7 is the only thing that could have made this series more historic. Each of the first five games was decided by one goal for the first time since 1951.
As the series turned into a battle of wills, Tampa Bay put forth its final burst of desperation facing elimination. But with several players dealing with noticeable injuries, the Lightning didn’t have enough to push back against the playoff-tested and healthier Blackhawks.
“At this point I think maybe it was just a little bit of the experience that kind of weighed over,” defenceman Johnny Oduya said. “Somehow when we play the right way, it’s tough to beat us in seven games.”
Surrounded by 22,424 fans at the building nicknamed the “Madhouse on Madison,” the Blackhawks celebrated the third Cup for Toews, Kane, Keith, Hossa, Patrick Sharp, Brent Seabrook, Niklas Hjalmarsson and Bryan Bickell.
It was the first for Timonen.
“I’m relieved, I’m happy,” the Finnish defenceman said. “I came back just to get one more chance. You can always dream about this, but you never know what can happen in hockey.”
The Blackhawks showed anything can happen, even in the salary-cap era. Fans counted down the seconds to the final buzzer, “Chelsea Dagger” again played over the loudspeakers and players and fans revelled to the sound of “Sweet Home Chicago.”
“Once you do it once, you can’t wait to do it again,” coach Joel Quenneville said. “It’s the greatest feeling in the world.”
The Cup was delayed getting to the building because of weather, but when it reached the ice commissioner Gary Bettman got to congratulate the Blackhawks on one more.
“That’s three Cups, six seasons,” Bettman said. “I’d say you have a dynasty.”
Notes — Former Blackhawks defenceman Chris Chelios, Cubs infielder Anthony Rizzo and former White Sox star Frank Thomas were among those in attendance. … The Lightning reported 16,909 fans watched on the video boards at Amalie Arena back in Tampa. … Jonathan Drouin played just his second road game of the playoffs as the Lightning dressed 12 forwards and six defencemen.
Follow @SWhyno on Twitter
Hockey Classic cause hits close to home
Maple Ridge’s elite play for charity
|
cc/2019-30/en_head_0021.json.gz/line27343
|
__label__wiki
| 0.553252
| 0.553252
|
Daily Tending
The Deep Exhale
Open to Receive
On Bravery in Creation
Over the next couple of months I will be sharing the sweet, brave stories of women that I admire who are doing beautiful work in the world. The very first of these posts is written by the powerful and delightful Esmé Weijun Wang – so I totally adore and am really pleased to welcome to my corner of the internet.
I once spent a rattling train ride in Taiwan with my mother, during which she sketched a family tree in my notebook. At the end of various branches, she drew Xs to signify those known to have some sort of mental illness.
What surprised me wasn’t the three Xs that did exist: a great-aunt who’d been institutionalized for most of her life, and lived a tragic existence as “the madwoman in the attic”; a cousin who had killed himself; and, of course, there was me, who had been living with schizoaffective disorder for years. Rather, what surprised me was how many unknown entities there were, with branches leading to blank spaces on the page.
No one talks about these things, she said, and no one wants to ask.
I chose to reveal my psychiatric diagnosis on my website years ago, before that website became the hub for a business. And even though I wasn’t ashamed, and began to give anti-stigma talks in San Francisco, I continued to think of mental health advocacy as something that rode alongside my work as an editor for visionary entrepreneurs. Being an advocate, after all, isn’t a profitable enterprise; more significantly, I worried that to speak of it too frequently might alienate potential clients. I pictured these clients as searching their Twitter feeds for productivity hacks and insights on work/life balance, and not essays about the choice of whether or not I, as a person living with what’s been called “severe mental illness,” will try to have children.
Be useful, the dominant wisdom said; I saw this again and again in books and blogs. But what “usefulness” actually looks like — lists of tips? How-to guides and templates? — remained vague.
I spent most of April living in a cottage on Whidbey Island, alone. I’d been awarded a writing residency to work on a book of essays, and was using that time to research, doodle, outline, draft, and dream. The seven cottages that belonged to the residency were deliberately not equipped with any sort of Internet connection. Without the noise of constant input, my days became quiet.
The silence, as it turns out, enabled a clown-carful of previously unattended concerns to tumble forth. I snapped awake one night to the thought that I wanted to publish a book myself, to be sold on my website. It would be a book about living well with mental illness — hopeful, but not sugarcoated; realistic, but without the gory details. This was not the book that I’d essentially been paid to work on while on Whidbey Island, but it was another kind of book, and it was a book that wanted to be birthed quickly.
I spent the next few weeks doing two things: sketching out essays for the initial project, and assembling a book — which would become Light Gets In — composed of both new writing and the best bits from three years of online writing.
And I was scared shitless.
My fears about writing Light Gets In were completely unlike my fears about the essay collection. The essay collection was something that I spoke to my literary agent about over the phone; it was something that the other writers at the residency were interested in, and understood as a Serious Project that would take years to complete. Light Gets In, on the other hand, was a book that no one had asked for. It was storytelling that revealed themes of living well with mental illness, but was still far from the sort of “useful” business move that, say, a workbook for tracking medications and symptoms might be, and this worried me.
After I returned home, and was again inundated with business advice from e-letters that I’d voluntarily signed up for, and after I finished Light Gets In, and initiated the process of hiring Allie Rice to design the 52-paged book for me, I finally understood something essential.
If I was going to push this book out into the world, I was also going to have to step into a certain kind of bravery — because I already believed that storytelling is as valuable as, and sometimes more valuable than, a 1-2-3 Guide to Infinite Happiness; but I also needed to bring that into the way I spoke about the book when it was released. I needed to have faith that its value would come through without a list of concrete deliverables.
Light Gets In came out on June 2. It isn’t a handbook, but it is a flashlight in the dark. It’s a story for everyone who is, knows, loves, might know, might love, or might interact with someone with mental illness.
My mother owns a copy of the book. She told me that she’s reading it slowly, making sure that she doesn’t miss anything. “I want to translate it into Chinese,” she says, “and have it published in Taiwan.”
About Esmé
Esmé Weijun Wang is a writer and editor-for-hire. Her site, esmewang.com, is where mental health advocacy meets meaningful work. As seen in The New York Times, Jezebel, and Clementine Daily, her site is the home of the Chronicles, a series of mini-essays that records her life with schizoaffective disorder, thoughts on compassionate business, and explorations of the writing life. Find more about her new e-book, Light Gets In, as well as a downloadable chapter, here.
Enjoy this? Please share!
Self Care that Works
Are you ready to feel less exhausted? (Like, immediately?) I’ve got your back. Sign yourself & receive my best tools for redefining your self-care so that it actually works for you.
1 thought on “On Bravery in Creation”
Pingback: Body Image Boosters From the Blogosphere 7.13.14 | Weightless
© 2019 Mara Glatzel. Privacy Policy. Terms & Conditions. Branding & Website by SixteenJuly.
Please read the privacy policy to learn how we use your information.
|
cc/2019-30/en_head_0021.json.gz/line27344
|
__label__cc
| 0.683189
| 0.316811
|
Column: Get ready to make room for baby
By Suzette Martinez Standring
The birth of a grandchild can bring about the “3 Rs” of change: renewal, reunion and sometimes, relocation. It’s what caused our daughter and son-in-law to move from California to Massachusetts three years ago when their first daughter was born.
“We want Isabella to know her grandparents,” said my daughter Star.
For years, I had campaigned for her to live closer, but to no avail. And now my dream was coming true. (You can’t underestimate the power of a free babysitter.)
Like me, my husband, David, couldn’t wait to get his “grandpaws” on the baby, and he insisted they move in with us until they found a home of their own.
Grandpa-to-be looked forward to a baby in the house, delighted at the prospect of an “instant family.” He imagined Isabella someday hopping onto his lap to watch action movies with him – no fuss, no muss and no changes to our routine.
My dear, good-hearted David — previously divorced and childless, he had no idea about the radical, all-encompassing, 20-mule team changes that a household undergoes when a wee one moves in.
But I knew that the physical lay of the land would transform a la “The Matrix.” Perhaps the subject of an extra room for the baby would be a gentle way to break him in.
Me: “Isabella will need a separate nursery.”
Him: “What? Why can’t the baby sleep in the same room as her parents?”
Me: “Their room will be too small for all of them.”
Him: “But where will our visitors sleep?”
I stopped stirring the soup to stare at him. When three people move in and one of them is in diapers, it’s goodbye to houseguests. But I simply said, “Oh, they’re going to need an extra room for all the things for the baby anyway.”
David said, “How much stuff can a little baby have?”
I imagined a playpen and a field of toys. I envisioned a high chair, the floor littered with Cheerios. Let’s see, which bathroom would sport the Diaper Genie? I could hear the washer and dryer going 24/7. The vision of a Johnny-Jump-Up hanging from the doorway to our formal dining room made me laugh out loud.
But I said nothing more than, “Well, quite a bit of stuff, actually.”
That alone unnerved him. When a man is shell-shocked, it’s best to perform triage, allow for recovery time, and above all, offer hope, so I said, “Oh, there’s plenty of time. We can work it out.”
That’s code talk for “you’ll adjust.”
That night, we talked about all the happiness ahead in the coming year. The relocation of “the kids” will coincide with a New England summer. Then we’ll revel in fall foliage and, wow, won’t it be great to have a real family Thanksgiving this year? Just imagine little Isabella’s first Christmas. Sigh.
Suddenly, David said, “The kids should feel welcome, so let them have the entire upstairs. What the heck.”
He stared off, all aglow in Norman Rockwell scenes. I surveyed the living room and mentally ticked off a to-do list: baby gates, wall socket protectors, kitchen cabinet locks and gee, I should find a way to pad these coffee table corners.
I smiled and nodded. The entire upstairs – well, that’s a good start for now.
E-mail Suzette Standring at suzmar@comcast.net. She is the author of “The Art of Column Writing: Insider Secrets from Art Buchwald, Dave Barry, Arianna Huffington, Pete Hamill and Other Great Columnists.” Visit http://www.readsuzette.com.
|
cc/2019-30/en_head_0021.json.gz/line27349
|
__label__wiki
| 0.854996
| 0.854996
|
Lenny Megliola: Big East brethren battling for spot in Detroit
Lenny Megliola
If someone says to you, “First prize is an all expenses-paid weekend in Detroit,” naturally you’re going to ask, “What’s the second prize?” Ordinarily. But for Villanova and Pittsburgh, these aren’t ordinary times, and the Motor City might as well be Club Med or the Isle of Capri. This is why tonight at the Garden the Wildcats and Panthers will be scratching and clawing to get there.
If someone says to you, “First prize is an all expenses-paid weekend in Detroit,” naturally you’re going to ask, “What’s the second prize?”
Ordinarily.
But for Villanova and Pittsburgh, these aren’t ordinary times, and the Motor City might as well be Club Med or the Isle of Capri. This is why tonight at the Garden the Wildcats and Panthers will be scratching and clawing to get there. DETROIT! That’s where the Final 4 will be played out, and if you’re into college hoops, that’s the only place to be. The NCAA could play the Final Four on the moon. Who cares?
Villanova and Pittsburgh are Big East brethren, which means they don’t much like each other. They played once this year, the Wildcats winning 67-57. Which of course means nothing tonight, except that it’s a proud moment for the conference.
“I think everybody in the Big East likes this,” said ‘Nova coach Jay Wright. “You know what, if we’re not going to win, and get to the Final 4, I’ll be glad it’s Pitt.”
But before anyone could yell “liar,” Wright smiled and said, “but I hope it’s us.”
Villanova took some of the shine off Duke, 77-54, on Thursday, while Pittsburgh took a tougher road by outlasting Xavier, 60-55.
It must have been tiring for both teams to be constantly asked about their first meeting.
“We played bad, but we were still up eight with two minutes to go,” said DeJuan Blair.
Anyway, it was a long time ago.
“A lot of changes in two months,” said starry Pitt point guard Levance Fields. “Both teams are better than they were two months ago.”
The Panthers had foul problems in that game, the 6-7 Blair most significantly. But it’s not like that game has been weighing heavily on his mind.
“I don’t know what happened a month ago,” he smiled, eliciting a round of laughter in the interview room Friday. “This (Villanova) is a bigger game, a bigger stage.”
It’s no laughing matter as to how much the Panthers desperately need Blair’s board work. He rounded up 17 rebounds (eight offensive) in the Xavier game.
Pitt’s minutes man is Sam Young, a 6-6 bruiser who doesn‘t leave the floor much, not that he’s complaining.
“To be honest, I don’t even think about it. I never want to come out of the game anyway.”
Young’s 19 points was game-high Thursday night. By the way, Young gets points for being a straight shooter, on and off the court.
Interviewer: What’s your first memory of the Big East?
Young: “To be honest, I didn’t watch college basketball until I got to college.”
Both Pitt and Villanova start three seniors. With both teams from the great state of Pennsylvania, recruiting is a cut-throat business. Dante Cunningham (14 points, 11 rebounds against Duke) is a Villanova stud.
“I remember being in Dante’s home, and I thought we were going to get him,” said Dixon. “We thought he was going to be a very good player.”
He was right, VERY good for somebody else up the road a piece.
Dixon has been coaching for 10 years in the bruising Big East, but he’s from the West Coast (born in Burbank, Calif.). His parents were from, of all places, the Bronx. Can’t get much further culturally from Burbank than the Bronx. Like Chazz Palminteri, Dixon has a Bronx Tale of his own.
“I was the only guy that summered in the Bronx. We would drive across the country and I would stay with my grandparents in the Bronx. Because of my family and my roots and New York, the Big East has even more of a special meaning than a typical kid out west. … It was a draw to me when I came to Pittsburgh 10 years ago.” He was named head coach in 2003.
Dixon played at TCU before he got into the coaching racket. He made stops at Northern Arizona, Hawaii, Cal-Santa Barbara. “Don’t forget LA Valley College,” he said. “And TeAute College in New Zealand. That was my first coaching job. I coached kids.”
He didn’t exactly have high-flung ambitions back then. “I wanted to be a California junior college coach. I thought that would be a great way to coach and be around kids. It wasn’t about the level. It was about coaching, being around the game, being around the kids and the competition.”
The competition tonight is a bit more sophisticated. The welcoming arms of Detroit are spread wide for the winner.
Lenny Megliola is a MetroWest Daily News columnist. His e-mail is lennymegs@aol.com
|
cc/2019-30/en_head_0021.json.gz/line27350
|
__label__cc
| 0.61281
| 0.38719
|
'SPECTRE' production moves to Austria next week
03-Jan-2015 • Spectre (2015)
As expected, the crew for James Bond's 24th 007 adventure, "SPECTRE", are heading to Lake Altaussee next week, with locals expecting 007 star Daniel Craig to be on location at the picturesque lake by Monday 5th. Craig will be joined by a 300-strong crew.
The Jagdhaus Seewiese, an iconic log cabin, was of particular interest to the location scouts when they first expressed an interest in the location back in October.
A flight ban has been ordered by the local authorities, in effect between the 4th and the 6th of January, with the mayor explaining this was not because of any aerial action but so that paragliders who frequent a nearby club will not spoil any of the crew's shots. Areal shots for "SPECTRE" were under way under the stewardship of second unit director Alexander Witt back in December.
The scene set at Altaussee and to feature the Jagdhaus is expected to involve 007 crossing the lake by boat. Although locals previously speculated that the scene could involve 007's latest nemesis - this time in the form of Christoph Waltz - MI6 understands Waltz will not start on 'SPECTRE' until February; he is thus unlikely to have a role in any large number of the scenes set in his native Austria.
|
cc/2019-30/en_head_0021.json.gz/line27351
|
__label__wiki
| 0.894168
| 0.894168
|
To the Beat of the World's Drum
"The rhythm is right and the music is flowing." That's how you know it's a good day in Mickey Hart's world. He and the Grateful Dead's music helped turn the world on its head in the '60s and '70s. He played stadiums in the '90s, and crossed the world studying the music of humanity. Now he's going the only place left for him to go—space. Hart sat down with the IN to talk about what the universe sounds like and how a seven-piece band could possibly recreate that on a nightly basis.
IN: You've traveled the globe studying the music of other cultures. What's the importance of doing that?
HART: I like to think of it like I'm sitting down at the dinner table. Sure, I can eat steak and potatoes every day, but there's so much more out there. I want to be nourished in every way that's humanly possible. Every culture has something to bring to the table, and if you ignore that, you're missing out on some incredible ingredients.
IN: Is there anything that all those cultures have in common?
HART: All cultures are connected to one another because they all vibrate. We have an impact on each other, no matter how distant or different we may seem.
IN: After so many years and different projects with different aims, what's your goal in making music today?
HART: It really hasn't changed after all these years. I make music for people who like music, including myself. As the years have gone by, I've gotten a lot better at my instrument, but it's still fun finding different rhythms and ways to communicate sonically. The advancement of technology has kept me on my toes, too.
IN: At what point did science become so fascinating to you?
HART: About five years ago, I began to wonder what the universe sounds like. We have all these visuals of space, but there's never an accurate depiction of what all that action sounds like. There's got to be some kind of noise going on, right? I decided to seek out some of the greatest minds in the field like Nobel Prize-winning physicist Dr. George Smoot to help me explore if it's even possible for us to hear these light waves. The finished product is this record, "Mysterium Tremendum."
IN: What's the most difficult part of transforming those light waves to sound waves?
HART: It was initially done with all sorts of computers and engineering, but the hardest part of the whole thing is recreating it live in a way that doesn't sound like a science experiment. There are very powerful memory bands at work trying to recreate part of the universe at each show we play, but in the end, people are there to groove to the music. It's music of the whole earth. It's rock and roll, but there's a universal side. A lot of the sounds are not of this world.
IN: With an uncommon project like this, was it more difficult to convey to your bandmates what exactly you were trying to accomplish?
HART: Not at all. The reason I choose these mates is because they were really interested in the project and were able to wrap their heads and instruments around the thought of dancing with infinite space. All while still playing rock and roll. It's definitely a matter of trial and error when working with these complex, sophisticated systems and making them fun, but we've done it. This band is fierce.
IN: Will you be pulling from the Grateful Dead catalog at all at the show here in Pensacola?
HART: We'll play Dead stuff, too. It's woven into the fabric of what we're doing, but it's definitely retooled for the strength of this band. It'll be familiar enough without it feeling stale.
IN: What does Dave Schools [Widespread Panic bassist] bring to the table that you might not otherwise have?
HART: Oh boy. He's one of the best bass players on the entire planet. He brings a great sensibility to the low end of this band. He's not only a great bass player, but he puts the note in the right place. It's not just about technique with him. He's got the feel that only the greats have. And he's such a likable guy, so he's a lot of fun to play with.
IN: You've talked about how music can be used as therapy in many different ways. How has it been therapeutic for you personally?
HART: Music is life-giving. Making rhythm is life. Good rhythm is good life. When I get off the stage, I feel 20 years younger and it's great exercise. It's also a spiritual encounter for me. When I play, I talk to the gods. It's a very emotional and deep bond for me.
IN: Can you talk a little bit about what it's like playing with another drummer on stage? It seems like it would have to be an intimate relationship to be able to do that well.
HART: First of all, you have to get the right drummer to play with. People I choose to play with like to have a conversation up there. A lot of times, the more people you have up there playing rhythm, the more confusion there is. With this band, there is none. Everybody is one complex grooving organism.
You can't see music. You can't touch it. You're trying to create magic up there. It's there, then it's gone, and you have to play with people who know and appreciate how precious that is. Our music is very improvisational, but it has strong structure, too. It's much like the Grateful Dead in that way.
IN: When we had originally scheduled our interview, you had to jump into the studio unexpectedly. What typically sparks an impromptu studio session like that?
HART: The muse. My guiding light. When it hits, everything else disappears. Two songs were written in that outpouring of inspiration last week. You have to get it whenever you can. These are the artist's priorities.
IN: As someone who's been a force in the activist community for years, what role do you feel music plays in progress?
HART: I hope with this particular project, people begin to appreciate the power of science in everyday life, and understand the idea of a vibratory universe. There is music everywhere. You just have to seek it out. Each star sings its own song.
By - Brett Hutchins
Independent News
|
cc/2019-30/en_head_0021.json.gz/line27353
|
__label__wiki
| 0.835685
| 0.835685
|
https://www.middletownpress.com/news/article/PD-Middletown-man-charged-with-threatening-11792160.php
PD: Middletown man charged with threatening officers’ lives
Published 12:29 pm EDT, Monday, June 15, 2015
Cassandra Day - The Middletown Press Middletown police
MIDDLETOWN >> Police arrested a city man Saturday for allegedly shouting threats at a stranger on Main Street.
Just after 1:30 p.m., a woman was eating at a table outside the Dunkin Donuts on Main Street when her daughter saw a man, later identified as Charles Stack, 23, of College Street, who appeared to be sleeping at an adjacent table, according to an arraignment.
The victim said Stack awoke and began yelling and swearing at her, warning her to leave before he “killed” her, the report says, and the woman entered the coffee shop and told an employee to call police.
When authorities arrived, Stack said he did nothing except for yell because the woman began coughing, “and he does not let anyone cough toward him,” police say.
Stack allegedly told police he doesn’t care who is coughing because he would harm them for doing so.
He was charged with breach of peace and threatening, then told officers they were lucky he allowed them to handcuff him, because otherwise he would have fought them and taken their guns away to shoot them, the arraignment says.
Stack was held in lieu of a $25,000 surety bond. He is scheduled to appear in court June 15 for his arraignment.
According to the state judicial website, Stack served 30 days in jail on a conviction for second-degree breach of peace in the Manchester district in 2011.
|
cc/2019-30/en_head_0021.json.gz/line27354
|
__label__wiki
| 0.759542
| 0.759542
|
a. M&A Transactions
Counsel to the independent power producer (“IPP”) subsidiary of an investor-owned utility in connection with its simultaneous acquisition of an in-development 150 MW solar photovoltaic electricity generating facility to be constructed in Imperial County, California, an in-development 245 MW solar photovoltaic electricity generating facility to be constructed in Imperial County, California, and an in-development 106 MW wind-powered electricity generating facility to be constructed in Stark and Morton Counties, North Dakota.
Counsel to the IPP subsidiary of an investor-owned utility in its acquisition of a proposed 100 MW solar photovoltaic electricity generating facility located in Taylor County, Georgia.
Counsel to an IPP in the sale of a portfolio of eighteen (18) distributed generation solar photovoltaic electricity generating facilities in Georgia with aggregate capacity in excess of 57 MW.
Counsel to an IPP in the sale of a portfolio of fourteen (14) distributed generation solar photovoltaic electricity generating facilities in Georgia with aggregate capacity in excess of 42 MW.
Counsel to an IPP in the acquisition of portfolio totaling 20 MW of distributed generation solar projects throughout Massachusetts. Representation included negotiation and drafting of membership interest purchase agreement and consummation of transactions.
Counsel to an IPP in the acquisition of a 7MW distributed generation solar facility in Florida. Representation included negotiation, drafting, and closing of membership interest purchase agreement and consummation of transaction.
Counsel to a major Southwestern electric utility in its requests for proposals for solar and other “renewable fuel” generating capacity.
b. EPC and Related Transactions
Counsel to a renewable energy company in connection with its development of a 280 MW concentrated-solar power facility in the Western United States. Representation included drafting the EPC Contract and related documents.
Counsel to a contractor in the negotiation and documentation of a turn-key engineering, procurement and construction agreement for the construction of two solar PV plants in California with a combined capacity of 175 MW.
Counsel to an IPP in connection with its development of a 175 MW solar photovoltaic facility in Imperial Valley, California. Representation includes drafting of EPC contract, O&M Agreement, Performance Guarantee arrangements and related documents.
Counsel to an IPP in connection with its development of a 125 MW solar photovoltaic facility in Arlington Valley, Arizona. Representation includes drafting of EPC contract, O&M Agreement, Performance Guarantee arrangements and related documents. This Project was awarded the “North American Single-Asset Power Deal of the Year” Award by Project Finance Magazine.
Counsel to an EPC contractor in the negotiation of a turn-key engineering, procurement and construction agreement for the construction of a 106 MW solar PV power plant in California.
Counsel to an EPC contractor in the negotiation of a turn-key engineering, procurement and construction agreement for the construction of a 100 MW solar PV power plant in Texas.
Counsel to an EPC contractor in connection with the development of 100 MW solar generation facility in California. Representation included negotiation of turnkey wrap EPC contract and related documents.
Counsel to an EPC Contractor in connection with the negotiation of an EPC Contract for the turnkey development of a 60 MW solar PV power project in Indiana.
Counsel to a contractor in the negotiation and documentation of a turn-key engineering, procurement and construction agreement for the construction of a 40 MW solar PV power plant in North Carolina.
Counsel to a developer/owner in connection with an EPC Agreement for a 32 MW (AC) solar PV power project in California.
Counsel to an IPP in connection with EPC work for its development of a 10 MW photovoltaic power plant in Dover, Delaware. Representation included drafting and negotiation of EPC, O&M and related agreements.
c. Equipment Procurement Transactions
Counsel to a solar PV equipment manufacturer for the negotiation of framework agreements for the supply of over 3,800 MW of thin-film solar PV panels for projects located across the United States.
Counsel to a solar PV equipment manufacturer in connection with the provision of over 400 MW of solar PV equipment for multiple PV power projects in North Carolina.
d. Real Estate Transactions
Real Estate counsel to a developer in the acquisition and due diligence review of a proposed 80 MW solar project in Idaho. Further advised on real estate project development and served as real estate counsel on the later sale of the project.
Real Estate counsel to a developer in its acquisition of early stage large scale solar projects in Texas, Nevada, Utah, Oregon, Wyoming and California. Representation included due diligence review and negotiation of ground leases and options to purchase, corrective title work, survey review and title policy issuance, federal land and mineral rights issues, transmission and other easement rights.
Real Estate counsel to a developer in the sale of several project sites in California which involved both ground mounted and roof mounted solar facilities.
Real Estate counsel to First Century Energy with regard to the preparation and negotiation of various solar ground leases in Georgia.
Real Estate outside counsel for multiple solar developers acquiring and constructing solar projects in Massachusetts.
Counsel to landowners with regard to the preparation and negotiation of ground leases for proposed wind facilities in Tennessee as well as solar facilities in Florida and New York.
Real Estate counsel to a property owner with regard to the preparation and negotiation of a Solar Ground Lease and Option with Solar Reserve.
Counsel to shopping center development company in connection with preparation of Solar Roof Lease for a shopping center in Massachusetts.
Counsel to a solar developer in Georgia in connection with the preparation of a Solar Services Agreement that involved significant rooftop property issues.
Counsel to a landowner in the preparation of a solar lease option agreement for the lease of approximately 900 acres of real property located in Dooly County, Georgia.
Counsel to a solar developer in the preparation of template solar lease option agreements and solar purchase option agreements to secure to obtain site control throughout the United States.
Counsel to a landowner in the negotiation of a solar lease option agreement for the lease of approximately 500 acres of real property located in Leon County, Florida.
Counsel to a landowner in the negotiation of a solar lease option agreement for the lease of approximately 570 acres of real property located in Laurens County, Georgia.
|
cc/2019-30/en_head_0021.json.gz/line27355
|
__label__wiki
| 0.53972
| 0.53972
|
Filtering by Tag: Man's Best Friend
Remembering Man and His Best Friend
“In Flanders fields the poppies blow
Between the crosses, row on row,
That mark our place; and in the sky
The larks, still bravely singing, fly
Scarce heard amid the guns below.”
Today we show our respect and remembrance of those who fought and lost their lives in the First World War which lasted from 28th July 1914 to 11th of November 1918.
And this day ~ November 11th 2018 ~ marks a hundred years of the end of the Great War.
Wearing your poppy is seen as a symbol of respect to remember those who have given their lives in war. Poppies were seen all over the battlefields after World War One ended and thus became the flower to represent those who fought and died on behalf of their country.
Front-line Canine
Up to 20,000 dogs were trained for front-line duties in World War One. Dogs had many roles to play from sniffing out the enemy, passing messages between the lines and carrying aid to wounded soldiers. The most common breeds used were the Border Collie, Lurchers, English Sheepdogs, Retrievers and the all - rounder mongrel. Many Dobermans were deployed as sentry dogs and trained to find injured soldiers on the battlefield. The Airedale Terrier was the most commonly used hound by the British.
A Shout Out to The Animal World
Over 16 million animals served in the First World war: Pack mules, donkeys and horses were used to carry supplies such as medical packs, food, ammunition and water. Even camels! A great film on this subject being the tear-jerking movie, ‘War Horse’, a must watch for any animal lover.
Our feathered friends also did their part such as carrier pigeons sending messages - (32 of which were awarded the Dickin Medal for their bravery) and canaries were used for detecting poisonous gasses.
Sergeant Stubby
This cute looking American Pit Bull Terrier was the only war dog to be given the title of sergeant for his efforts, loyalty and heroic acts. He was a stray dog that was found in 1917 and smuggled to France during World War 1 by Corporal. John Robert Conroy.
Stubby participated in 17 battles, four offences, warned his unit of incoming fire, gas attacks, and even located and apprehended a German spy in the trenches!
One of the most heartwarming stories heard of military K-9 heroism is that of a dog from Scotland. He travelled 12000 feet through mud, crevices and the rain filled craters of the Western front delivering a message to HQ in less than an hour. Despite being shot twice he completed the mission and died afterwards.
The skill and courage of these types of dogs is outstanding and how they served a very important purpose in conveying vital messages when all other communication had failed.
Let us all be mindful today of the acts of heroism, the call of of duty, the sacrifice and loss of lives of those who fought for us in order that we can live with the freedom that we do today.
tags The Royal British Legion, WW1, Armistice Day, Flanders Fields, WW1 Centenary, The Great War, Dogs in WW1, Seagent Stubby, The Dickin Medal, Poppy Day, Border Collie, Lurcher, Doberman, English Sheepdog, retreiver, Airedale Terrier, Amercian Pit Bull, Mongrel, War Horse, Steven Speilberg, Lest We Forget, John Mcree, John McRae, Scotland, John Robert Conroy, Man's Best Friend
|
cc/2019-30/en_head_0021.json.gz/line27357
|
__label__wiki
| 0.699347
| 0.699347
|
Wydawnictwo: Orfeo
Nr katalogowy: C 981115
Nośnik: 15 CD
Rodzaj: symfonia, koncert
Rafael Kubelik Munich Symphonic Recordings
Orfeo - C 981115
Joseph Haydn, Wolfgang Amadeus Mozart, Ludwig van Beethoven, Johannes Brahms, Antonin Dvorak, Anton Bruckner, Hector Berlioz, Bedrich Smetana, Leos Janacek, Karl Amadeus Hartmann, Bela Bartok
Symphonieorchester des Bayerischen Rundfunks / Rafael Kubelik
Joseph Haydn:
Symphony No. 99 in E fl at major, Hob. I:99
Wolfgang Amadeus Mozart:
Symphony No. 25 in G minor, K 183
Symphony No. 38 in D major K 504, “Prague”
Symphony No. 41 in C major, K 551 “Jupiter”
Ludwig van Beethoven:
Symphony No. 9 in D minor, Op. 125 with final chorus from Friedrich Schiller’s “Ode to Joy”
Johannes Brahms:
Symphony No. 2 in D major, Op. 73
Symphony No. 3 in F major, Op. 90
Symphony No. 4 in E minor, Op. 98
Antonin Dvorak:
Serenade in E major, Op. 22
Symphony No. 7 in D minor, Op. 70
Serenade in D minor, Op. 44 (version for orchestra)
Symphony No. 8 in G major, Op. 88
Symphony No. 9 in E minor, Op. 95 “From the New World”
CD 10:
Anton Bruckner:
Hector Berlioz:
Symphonie fantastique, op. 14
Ouverture “Le Corsaire”
Bedrich Smetana:
Má vlast (My Country)
Leos Janacek:
Karl Amadeus Hartmann:
Symphonic Hymns for large orchestra
Bela Bartok:
Music for strings, percussion and celesta, Sz 106
Concerto for orchestra, Sz 116
From 1961–79, Kubelík was principal conductor of the Symphony Orchestra of Bavarian Radio in Munich. He had found there his new musical home. He led the BR Symphony Orchestra to new heights, developing a unique sound and performance culture in a perfect diversity of repertoire from Baroque music up to free tonal Expressionism and to Karl Amadeus Hartmann and Benjamin Britten. As a musician, his prime directive was lyrical phrasing as well as clear and conscious articulation of the harmonic tensions and the vitality of the rhythmical and metric flow. He always had all these elements in mind, seeking to balance them. And Kubelík loved the gorgeous, lush sound, but never at the price of diaphanousness.
This CD Edition gives us a detailed overview about his legendary interpretations and is also a time document of his long time working period in the city of Munich.
Recordings: Munich, Herkulessaal, 04.05.1982, 09.05.1985 (CD 1); 10.05.1985 (CD 2); 14.05.1982 (CD 3); 26-29.04.1983, 03-06.05.1983 (CD 4-6); 16.10.1981, 25.05.1977 (CD 7); 02.04.1978, 27.05.1977 (CD 8); Würzburg, Kaisersaal, 22.06.1981 (CD 1)
|
cc/2019-30/en_head_0021.json.gz/line27359
|
__label__wiki
| 0.967904
| 0.967904
|
Home Theater & Dance What’s hot in theater and dance? Check out Vineyard Arts Project’s lineup
What’s hot in theater and dance? Check out Vineyard Arts Project’s lineup
Gwyn McAllister
Pig Pen Theatre Co., during a performance at VAP in 2012. — Photo Matthew Murphy
You might never suspect it, but at a spacious facility hidden behind a hedge row on upper Main Street, Edgartown, some of the brightest stars of the dance and theater world will create new work this summer.
Vineyard Arts Project (VAP), an organization dedicated to fostering the work of both established and up-and-coming artists, has half a dozen residencies scheduled, including a lineup of Tony award winners and a world-renowned ballet company.
Since 2008, VAP has hosted summer residencies, providing “an incubator for the creation of new work in dance and theatre,” according to their website. At the conclusion of every residency, the Vineyard community is afforded the opportunity to get a first glimpse of the fruits of the artists’ labors. The center will host five performance/discussions throughout the summer, featuring all or parts of new works.
“I think the presentations are a great way for the audience to witness the creative process rather than a fully staged, fully produced show,” says VAP founder and artistic director Ashley Melone.
Two groups who are developing new work for New York’s Public Theater have been on the Island since last weekend. The 60-year-old Public Theater, one of the nation’s preeminent cultural institutions, has been honored with 42 Tony Awards, 158 Obie Awards, 45 Drama Desk Awards, and four Pulitzer Prizes.
Ms. Melone has had a relationship with The Public Theater for the past four years. In previous summers, VAP hosted emerging writers. This year, for the first time, two works commissioned by The Public are being developed here. The Public Theater’s artistic director Oskar Eustis has accompanied the artists to the Vineyard.
Stew and Heidi Rodewald, whose Broadway rock musical “Passing Strange” won a Tony and was the subject of a Spike Lee film, are currently at VAP working on a new musical called “The Total Bent,” about a gospel singer and a legendary music producer.
Also on hand are the experimental theater group Elevator Repair Service, who last year won an OBIE Award for Sustained Excellence. Their recent show, “Gatz,” a seven-hour dramatic reading of “The Great Gatsby,” was lauded by critics. Currently the collaborative group is working on a multi-media piece called “Arguendo” about a First Amendment case brought by a group of exotic dancers in 1991.
Starting next week, VAP will host the fourth annual New Artists/New Work residents. Since the inaugural year of 2009, New Artists/New Plays alums have gone on to enjoy great success in the theater world. The musical “Witness Uganda,” whose co-writers were in residency at VAP in 2010, is scheduled for performance at the prestigious American Repertory Theater in Cambridge next year. “Disgraced,” a play also developed on the Vineyard in 2010, recently won the Pulitzer Prize for Drama.
“It’s so exiting to take a risk on these new writers when no one knows who they are and watch their success,” says Ms. Melone. “There’s nothing that makes me happier. It means we’re fulfilling our mission.”
This summer two new plays will be in development — Nastaran Ahmadi’s “The Bet,” a contemporary retelling of a Chekhov short story, and “DB,” a play about the legendary DB Cooper, created by the group Woodshed Collective, who create work collaboratively.
“The Bet” will be directed by accomplished film and television director Claudia Weill and will feature a trio of accomplished actors, including Robin Weigert who, among numerous TV and film roles, played Calamity Jane on the HBO series “Deadwood.”
In mid July, VAP hosts Ars Nova, a New York-based organization devoted to developing new talent. During the residency, a number of performing artists will work on a variety of comedy, musical, and theater projects. This is the group’s second year at VAP.
“I’m a huge fan of their work as a theater company as a whole,” says Ms. Melone. “They work in a similar way as we do, focusing on new and emerging artists in theater. I feel really aligned with them in terms of our ethos.”
The rest of the summer will be devoted to dance. In early August, VAP will host its annual Musical Theater Lab, a two-week professionally-run intensive training program for teens. During that time, Elizabeth Parkinson, co-director of the Musical Theater Lab, will give a rare performance at the annual fundraiser. Ms. Parkinson, a musical theater veteran now retired, was nominated for a Tony award for Twyla Tharp’s “Movin’ Out. “She’s one of my favorite dancers,” says Ms. Melone. “She’s really stunning. The dance world misses her. I begged and pleaded with her to perform.”
The season concludes with the acclaimed Dance Theater of Harlem in residency. Last year, the NYC-based ballet troupe attracted sellout crowds to their two residency ending performances. New dances developed during that residency were performed at Lincoln Center in April.
“It’s really exciting to see the work developed here on the Vineyard being performed in New York,” says Ms. Melone. “The Vineyard audiences gets to see it first in the studio very close to the performers. I think that’s a really important part of the Vineyard Arts Project — offering audiences a chance to see the work up close in an intimate space.”
Presentations of The Public Theater work will take place on Saturday, June 29, at 7 pm, at Vineyard Arts Project, Upper Main Street, Edgartown. All residencies include public presentations — readings, musical numbers, or selections from new work — offered on a pay-what-you-will basis. Tickets can be reserved through vineyardartsproject.org.
On Friday, July 5, VAP will host its annual Art for Art fundraiser, at VAP. The cocktail party features a silent auction and music by famed NYC deejays Andrew/ Andrew. Tickets are $35; $30 in advance. Guests will have the opportunity to meet the residents of the New Writers/New Plays series.
Previous articleDavid Wax Museum brings Americana and world sounds to Flatbread
Next articleLocal artists partner with The Trustees in “Painting the Vineyard”
Built on Stilts reschedules Sunday’s performance
Choreographer Camille Brown explores black women’s identity in two performances
The Martha’s Vineyard Playhouse gets the season started with big laughs
|
cc/2019-30/en_head_0021.json.gz/line27360
|
__label__wiki
| 0.989437
| 0.989437
|
Open skies (PDF File) - 3mb
Mr Joe Chua shared the satisfaction he derives, as well as the challenges he faces in his job as an air traffic control manager at CAAS, helping to keep Singapore’s commercial air space safe. He said that the job of an air traffic controller is critical and highly challenging, as one has to manage the numerous aircraft flying in the skies efficiently, providing air traffic control to ensure safe and expeditious flow of air traffic. It is thanks to the contributions of “unsung heroes” like Mr Chua and his team of air traffic controllers that Singapore’s busy highways in the air remain open and accessible 24 hours a day, seven days a week. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
LTA's new way to sound the ground for MRT tunnels (PDF File) - 371kb
The Land Transport Authority (LTA) is using geophysics methods - which make use of ground vibrations or electric currents - when more direct means of surveying, such as drilling boreholes cannot be done to assess soil conditions before the construction of new rail lines starts. Giving two examples, an LTA spokesman said geophysics methods were used in 2009 to survey the soil conditions at St Joseph's Institution (SJI) International and Innova Junior College. The authority said soil investigation works are conducted for between three and five years before the tender for a rail project is called. In the final phases, boreholes are drilled at intervals as close as 20m around the construction site, and rock and soil samples taken from as deep as 70m. Despite its best efforts, no assessment can provide a complete picture of the ground. For the Thomson-East Coast Line (TEL), LTA said it will closely monitor the impact of construction. Geotechnical instruments, including ground-settlement markers and water standpipes - to measure fluctuations in the ground water levels - will be used. A ground-breaking ceremony was held at Kreta Ayer Square yesterday to mark the start of construction of five TEL stations: Maxwell, Shenton Way, Marina Bay, Marina South and Gardens by the Bay. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
Expect faster rides soon on North-South Line (PDF File) - 365kb
Commuters will have faster rides on the North-South Line when rail works to replace 96,000 timber sleepers with concrete ones are completed by the end of this month. A trip between Jurong East and Marina Bay, for example, will take about 67 minutes instead of 77 minutes. Mr Chua Chong Kheng, Land Transport Authority’s (LTA) deputy chief executive for infrastructure and development, said that with the works on the line coming to an end, the speed of the trains will be returning to normal. The LTA and SMRT said on Saturday that sleeper replacement works for the East-West Line will start from the middle of next month. This will involve changing more than 92,000 sleepers between Boon Lay and Tiong Bahru stations, as well as between Lavender and Pasir Ris. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
MPA to work with AStar on maritime tech projects (PDF File) - 566kb
An agreement signed on 24 April aims to boost Singapore’s maritime technologies in areas such as communications and robots. The five-year MOU between the Maritime and Port Authority of Singapore (MPA) and A*Star will centre on collaboration in research and development. One focus will be on developing next-generation maritime communications technologies, which include satellite, terrestrial and wireless systems, particularly what is called TV White Spaces technology. This refers to a wireless spectrum with a much farther range than traditional Wi-Fi that could be crucial in improving productivity and safety. MPA chief executive Andrew Tan noted at the signing ceremony at the inaugural Singapore Maritime Technology Conference that the MOU's focus on the latest communications systems and technology will “enhance the competitive edge of our port and its operations, given the increasingly complex demands and challenges”. A*Star managing director Raj Thampuran said that the agreement will bring the partnership between both organisations to “a new level” by delivering even more ideas and innovative technologies to the maritime and offshore industry. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
The Business Times - 24 Apr 2015
MPA signs S$2.4b deal for Tuas Terminal Phase 1 works (PDF File) - 186kb
MPA has inked a S$2.42 billion deal to develop the first phase of the Tuas Terminal. The contract was awarded to a joint venture (JV) between Belgian firm Dredging International Asia Pacific and South Korea's Daelim Industrial. The JV will also tap local firms' capabilities, the authority said. Senior Minister of State for Finance and Transport Mrs Josephine Teo mentioned in her speech at the inaugural Singapore Maritime Technology Conference (SMTC) on 23 April that the project includes reclaiming 294 hectares of land, which is larger than the Brani, Keppel and Tanjong Pagar terminals combined. An MPA spokesman said the project is expected to be completed by December 2020. When the Tuas Terminal is completed, it is expected to be able to handle up to 65 million containers per year, nearly twice the Singapore port's container throughput volume in 2014. In her speech, Mrs Teo added that the MPA would pump more funds into research and green technology. MPA will also sign a MOU with the Agency for Science, Technology and Research (A*Star), which will let the authority tap the agency's expertise and its ties with research institutes and universities. SMTC was part of the 10th annual Singapore Maritime Week, which included other events such as the Sea Asia maritime convention and the Singapore Shipping Forum, which was held on 23 April by accounting firm Moore Stephens and BNP Paribas. Minister for Transport and Second Minister for Defence Mr Lui Tuck Yew had said at the opening of Sea Asia on Tuesday (21 April) that when fully operational at the end of 2017, Pasir Panjang Terminal Phases 3 and 4 will increase Singapore's port capacity by more than 40 per cent to around 50 million TEUs. Source: The Business Times © Singapore Press Holdings Limited. Permission required for reproduction.
MPA signs deal to train more global maritime leaders (PDF File) - 227kb
The Maritime and Port Authority of Singapore (MPA) is aiming to train more global maritime industry leaders even as it tries to develop the local maritime workforce further. The authority's training arm, MPA Academy, on Wednesday (22 April) inked a MOU to work on leadership development programmes with the World Maritime University, a post-graduate university set up in 1983 by the International Maritime Organization (IMO). The academy and the university may also exchange faculty members, as part of the deal. Minister also said in a speech on Tuesday that MPA will be introducing a career conversion programme for locals to switch to the maritime industry midway through their career, pointing to a "shortage of both seafaring and shore-based maritime manpower, even in nations with a rich seafaring heritage". Maritime Week events this year included a lecture by shipping industry titan CC Tung, chairman of Hong Kong-based shipping group Orient Overseas (International) Ltd. Source: The Business Times © Singapore Press Holdings Limited. Permission required for reproduction.
'No containing' Singapore's shipping capacity (PDF File) - 662kb
Singapore's plans to expand its container shipping capacity could allow it to "pull away" from its competitors, said shipping magnate Tung Chee Chen, who is chairman of Hong Kong shipping group Orient Overseas International. He was delivering the Singapore Maritime Lecture at the Fullerton Hotel yesterday. The lecture, which was organised by MPA, is a key feature of Singapore Maritime Week. About 450 maritime industry delegates attended yesterday’s lecture. Mr Tung pointed to the trend of mega-vessels and added: "If Singapore is actually looking into the future and thinking that the big ships are here to stay, then its transhipment operations could be the key to success." Meanwhile, MPA Academy inked an agreement with the World Maritime University yesterday to cooperate in the grooming of talent. The memorandum of understanding involves the two organisations collaborating on leadership development programmes and exchanging faculty members. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
New drone to give MPA better view of oil spills (PDF File) - 3mb
The Maritime and Port Authority of Singapore (MPA) is working with local engineering firm Hope Technik to develop an unmanned aerial vehicle (UAV) that is waterproof and can take off from and land on water, to assess oil spills at sea. In flight, the drone will be able to "see" for at least 150m around the vessel to which it is tethered. A prototype of the UAV was unveiled on 23 April at the International Chemical and Oil Pollution Conference and Exhibition 2015 at the Sands Expo and Convention Centre. MPA chief executive Andrew Tan said the UAV is a part of Singapore’s push to be a leader in maritime safety. MPA has also started a near-miss reporting system. “For every incident that has happened, there could be several near-misses before that point…We want to understand if it’s a risk relating to passageway or human error,” Mr Tan said. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
The Sunday Times - 22 Apr 2015
A global conversation for the maritime sector (PDF File) - 467kb
To reinforce its position as one of the region‘s leading maritime centres, it is important for Singapore to stay on top of the changes affecting the fast-evolving global industry. This is one of the aims of the annual Singapore Maritime Week (SMW), which sees delegates representing port authorities, industry leaders, as well as maritime professionals from around the world gather in Singapore to discuss key trends, opportunities and challenges facing the sector. Minister said that SMW brings together stakeholders from around the world to exchange views on key issues of the day. SMW has grown in size and significance, and is now one of the largest maritime events in the regions. The expansion of SMW reflects the growing role that Singapore plays as an international hub port and maritime centre. Themed “People, Ideas and Opportunities”, this year’s instalment features 30 events covering topics including shipping, offshore, maritime security and oil spill response. “With the evolving maritime landscape, it is critical that we keep closely with partners to remain relevant for the next 50 years,” MPA CE said. The biennial Singapore International Maritime Awards (IMA) was held at a gala dinner on Tuesday (21 Apr). This year’s IMA also recognised the immense contributions made by maritime pioneers for the first time. Source: The Business Times © Singapore Press Holdings Limited. Permission required for reproduction.
'Be ready to ride wave' of maritime growth (PDF File) - 11mb
At the opening of Sea Asia, an anchor event at Singapore Maritime Week, Minister said: “We need to ensure there is sufficient capacity to meet the growth in shipping demand, and support the proliferation of mega vessels.” He added that Singapore has already invested significantly to increase port capacity. Minister also said that the Government will ensure that the maritime industry will grow in “a sustainable and responsible way” – such as introducing LNG bunkering by 2017, in line with global efforts to use cleaner and sulphur-free fuels. It will also take steps to develop maritime talent, he said. Industry leaders at the conference also discussed the future of Asia’s shipping and offshore industry against the backdrop of falling oil prices. “It’s a question of survival over the next few years,” said Mr Khalid Hashim, managing director of Thai dry bulk shipping firm Precious Shipping. Companies need to “do some things right” in order to be successful, namely scrapping old rigs, getting rid of non-core assets, raising finances and cutting costs, he said. Pacific International Lines managing director Teo Siong Seng said ship-owners should be more “responsible” when it comes to new-builds. “There is too much new-building still.” Most of the panellists, however, remained optimistic about the medium to longer-term outlook, citing the projected growth of shipping volume, on the back of Asia’s burgeoning middle class. Source: The Straits Times © Singapore Press Holdings Limited. Permission required for reproduction.
|
cc/2019-30/en_head_0021.json.gz/line27365
|
__label__wiki
| 0.942927
| 0.942927
|
The Longest Arm of the Law
“Superjudge” Baltasar Garzón, Spain’s preeminent anti-terror prosecutor, has shown that no one is beyond the reach of the law. After the Madrid bombings, his skills are in greater demand than ever.
Tim Golden
[Update, 2/9/12: In a politically charged ruling, Spain’s Supreme Court has convicted Garzón of illegal wiretapping and ordered him suspended from the judiciary for 11 years.]
Of all the things that people say about Baltasar Garzón, what they argue over least is the belief that he must have the most dangerous enemies of any man in Spain. As an investigative judge on the nation’s high court, the Audiencia Nacional, Garzón has prosecuted drug traffickers, terrorists, rogue state-security officials, and an assortment of Latin American military figures, including the former Chilean dictator, General Augusto Pinochet. In the Spanish Basque country, threats to Garzón are splashed everywhere in the blood-red graffiti of the separatist group ETA. And last September, Garzón issued a 692-page indictment against Osama bin Laden and 34 of his reputed followers.
It can be unnerving, then, to sit in Garzón’s chambers and watch him work. The security at the Audiencia building in downtown Madrid seems inexplicably lax: Most anyone with a photo ID can step through a metal detector and enter the courthouse. There is rarely a receptionist on Garzón’s floor, so people come and go outside his office, entering with no more than a quick knock. Even the secretary works only part time, and Garzón often answers his own phone, occasionally raising his voice to be heard over the power drill that his law clerks use to punch holes in their thick case files.
Garzón’s “chambers” are really just a modest office, cluttered with law books and family pictures and the faux period furniture that is standard issue for the Spanish bureaucracy. When a tough-looking Belgian drug suspect shuffles into the office for a hearing one morning, the space seems to get even smaller. Garzón’s bodyguards are nowhere in sight. The judge himself is not an imposing presence; with his soft, handsome face and rimless glasses, he could be the well-meaning doctor on a television soap opera. The police guards who accompany the drug suspect crack off his handcuffs and wait outside the door. A prosecutor, a defense lawyer, and a stenographer pull up chairs around Garzón’s desk. The prisoner sits down directly across from him, barely three feet away.
The accused trafficker sits quietly as Garzón summarizes the Belgian government’s request for his extradition. His hard stare notwithstanding, the suspect finally agrees to return home to face the charges. Garzón then confers briefly with the lawyers before dictating his report in a husky baritone so fast and fluid that it is hard to tell where his sentences begin or end. But such hearings are not always so matter-of-fact. Last May, one of ETA’s more notorious accused killers leaped out of the same witness chair and hurled himself across Garzón’s desk, spewing threats on the judge’s life.
“If something is going to happen, it’s going to happen,” Garzón says later, shrugging a bit. “And when you take on terrorist groups, things happen.”
Garzón is not a persuasively modest man, but he tries to be discreet about the dangers of his job, having been taught not to discuss the security that surrounds him. He is less guarded about drawing lessons from the way he works. When prisoners are treated with respect, he says, they tend to be more cooperative. But even when suspected terrorists refuse to talk, a democratic state cannot afford the long-term political cost of their mistreatment, Garzón insists. He knows that some of his foreign counterparts (U.S. intelligence officials, for example) consider this view anachronistic, even naive. But he believes it is the Americans who are putting themselves at greater risk. The Spanish authorities have been fighting terrorism for a long time, he says, and they have learned some difficult lessons.
“What frightens me is when people start going beyond the limits of the law,” Garzón said. “Taking the right to a defense away from those who are detained at Guantanamo. Establishing a license to kill terrorists. In this country, we know what it means to use this heavy hand. We know that when the fight against terrorism moves outside the law, it becomes very dangerous.”
At a time when the U.S. government remains bitterly at odds with much of Europe over how to confront the dangers of an often frightening new world, the 48-year-old Garzón has emerged as one of Washington’s more resonant critics on the Continent. Almost from the moment the Bush administration declared its war on terror, Garzón has warned that curtailing civil liberties and torturing detainees would undermine public support and, eventually, the rule of law. He does not question the need for aggressive intelligence work, or even the select use of force to fight terror. But he argues for the primacy of a multinational, legal approach over what he describes as a “militaristic” strategy of intelligence gathering, extrajudicial arrests, and military detention. His sprawling indictment of bin Laden last fall—the first to charge the Al Qaeda leader in connection with the September 11 attacks—echoed his insistence that even the most terrible criminals on earth should be dealt with in courts of law. In late December, he sought the extradition of four Al Qaeda suspects from Guantanamo, arguing pointedly that the only standing charges against them were those he had filed in Spain.
Garzón has also been unflinching in his criticism of the Iraq war and the support it received from Spain’s conservative prime minister, José María Aznar. In open letters to Spanish newspapers and at a massive demonstration in downtown Madrid, Garzón decried the war as illegal, unnecessary, and almost certainly counterproductive in the pursuit of a more pro-Western Middle East. He has been especially dismissive of the American attempt to link the crimes of Saddam Hussein with those of Al Qaeda, citing several terrorism investigations that suggested otherwise. Speaking out was not without risk: Garzón was threatened with formal sanction by the judicial authorities for his remarks about Aznar.
Yet unlike most of the Europeans who now criticize American policies abroad, Garzón does so from a well-dug trench in the antiterror fight. Working closely with foreign police and intelligence agencies, including the FBI, Garzón has tracked Al Qaeda operatives for years. Since September 11, he has prosecuted a network of radical Islamists in Spain that he accuses of having assisted in the attacks. Over the last decade, he has also played a central role in Spain’s struggle against terrorism in the Basque region, leading some of the most important prosecutions of ETA, the separatist group founded in 1959 as Euskadi Ta Askatasuna, or “Basque Homeland and Freedom.” Garzón also battled his own government to expose the role of Spanish security officials behind assassination squads that hunted down Basque separatists in the mid-1980s.
Outside Spain, Garzón is best known for his attempt to extradite Pinochet while the aging general was visiting London in 1998. The prosecution took bold advantage of a 1985 Spanish law that established the courts’ jurisdiction in crimes against Spaniards even when they occur on foreign soil. But it ran into determined opposition from the Aznar administration, and it ultimately failed when Britain released the 84-year-old Pinochet for health reasons after 16 months of house arrest. Still, the case served notice to many of the world’s tyrants that their impunity had been circumscribed, and it opened the way to other prosecutions for crimes against humanity in Europe and Africa. It also made Garzón a hero to the international human-rights movement.
He has burnished that status by pressing his inquiry into Operation Condor, the plan by which South American military regimes collaborated in the 1970s and early ’80s to eliminate their suspected enemies. Last June, he won the landmark extradition from Mexico of a retired Argentine naval officer, Ricardo Miguel Cavallo, on charges that he tortured Spanish citizens, among others, during Argentina’s “Dirty War” on subversion. (It was the first time in which one country had extradited a suspect to another country to face trial for crimes committed in a third.) In July, at Garzón’s request, the Argentine government arrested 38 more former military officers. It released about half of them after the Aznar administration voided the order.
Over the last year or so, however, Garzón has begun to disappoint some of those who embraced him as a liberal champion in the war on terror. To the disquiet of civil libertarians (but now with Prime Minister Aznar very much on his side), he has steadily widened the fight against Basque separatists, targeting the teenage shock troops who intimidate moderate politicians, the relatives who raise money for ETA prisoners, and the strident Basque-language newspapers, among others. Garzón has also led a judicial effort to outlaw the radical political party Batasuna—a fixture of Basque politics that held a seat on the European Parliament—on the grounds that it serves as ETA’s political wing.
To Garzón’s mind, he is simply reaching as far as he legally can to dismantle a complex terrorist network. Should he overreach, he says, there is more than enough judicial recourse for his opponents. Already, he notes, the Batasuna ban has been the subject of appeals before the Spanish Supreme Court, the Constitutional Court, and the European Court of Human Rights. Yet even many Basque moderates are unconvinced; they count Garzón among the hardest of hardliners.
The apparent contradictions in Garzón’s approach are a favorite subject among his Spanish critics. They see a hunger for big, high-profile investigations—and the headlines they bring—as the one constant in his case file. “That desire to win spectacular cases—that is more powerful in him than any other motivation,” said Juan Alberto Belloch, a former Spanish justice minister who has battled with Garzón. “He needs attention.”
It is without question a remarkable case file. A sampling from the last couple of years includes a request to question Henry Kissinger about American support for Pinochet’s repression; a sweeping corruption investigation into Spain’s second-largest bank, BBVA; and an attempt to prosecute Italian prime minister Silvio Berlusconi for tax evasion and fraud at a Spanish television station he partly owns. Not all of these efforts have been successful: The U.S. State Department rejected Garzón’s Kissinger petition, and Spain’s Constitutional Court suspended the Berlusconi case—at least as long as he remains prime minister. A handful of executives still face charges in the BBVA case. Still, Garzón professes not to worry that his rulings are not infrequently pared back by higher courts. Under Spanish criminal law, a magistrate like himself functions like an American prosecutor and grand jury: He investigates a police accusation or citizen complaint but also weighs exculpatory evidence before bringing indictments. He then reports to more senior judges, who decide whether to bring the case to trial.
“People in Spain criticize him a lot for being vain, but so what?” said Garzón’s friend José Antonio Martínez Soler, a newspaper editor in Madrid. “He’s not vain in a petty way. He wants to make history. He is someone who takes risks. People admire that.”
Yet Garzón remains an enigmatic figure even to his compatriots. And he seems to like it that way. His investigations are often conducted in secret. He almost never discusses his cases publicly and rarely grants formal interviews. For a man who seems to enjoy his prominence, he is oddly shy. “Venga,” he says in Spanish, smiling impatiently, at the beginning of one of several long conversations for this story. “Come on. What do you need to know?”
GARZóN’S RISE is a measure of the distance that Spain has traveled since the death of the dictator Francisco Franco in 1975. Today, it passes without note that the judge investigating South America’s former tyrants once fought police riot squads as a student protester. But the old Spain weighed heavily in Torres, the small, hardscrabble town in Andalucia where Garzón grew up. Into the 1960s, it was a place almost untouched by foreign movies or television, where the authority of the Catholic Church and the Guardia Civil were absolute. Garzón attended a Catholic seminary, and he learned about politics from a favorite uncle, a well-spoken farmer who fought with the Republican Army and had been sentenced to death as the civil war ended in 1939.
“His sentence was commuted,” Garzón told me. “But from that moment on, and throughout the 40 years of Franco, he was constantly watched and persecuted—even about the most insignificant things. I saw that persecution from the time I was a child.”
By the time he entered the University of Sevilla in 1973, Garzón was already determined to become a judge. It was an unusual ambition in a country where the judiciary had often served as an arm of Franco’s repression. But if Garzón was serious, he wasn’t dull. Law-school friends remember a guy who loved flamenco and rock and roll and hated to leave a good party. He studied obsessively, often reading through the night while pulling the late shift at a gas station where his father worked. He graduated at the top of his class and married his girlfriend of eight years, Rosario Molina. He then moved his young wife to a quiet town near the Portuguese border to begin his career as a local judge.
Though Garzón rose quickly through the ranks, he showed little talent for the intricate politics of the post-Franco judiciary. Taking over at 30 as the inspector for the courts in Andalucia, he found evidence of corruption among prominent court officials in the coastal resort of Marbella and wrote a confidential report urging further inquiry. When his superiors shelved the case instead, Garzón was ready to quit. “I was just pushing paper,” he said. “I said to myself, ‘I’m not doing anything here.'”
Then, a couple of seats came open on the high court in Madrid, and at 32, Garzón qualified for one of the openings. They were not especially coveted posts; the cases that would soon fill the Audiencia’s docket—drug trafficking, financial crimes, corruption—were just starting to command public attention. And terrorism was a confounding mainstay: Despite Spain’s transition to democracy and the provision of autonomy powers to the Basque region under the 1978 constitution, ETA only escalated its attacks. Even the 1982 election of Prime Minister Felipe González, a young, charismatic Socialist, had done nothing to slow the separatists’ violent campaign.
The case that would define many of Garzón’s views about fighting terrorism was on his desk when he joined the high court in 1988. “That’s where the story began,” he told me. The investigation involved a mysterious four-year wave of bombings, shootings, and kidnappings in southern France and northern Spain in which 27 people had been killed, most of them Basque militants. The Spanish authorities had been notably slow to investigate. But the French eventually issued international warrants for the arrest of two Spanish police officials—a superintendent and his deputy.
Further evidence soon emerged tying the Spanish security forces to the rightist assassination squads that came to be known as the Grupos Anti-terroristas de Liberación, or GAL. But when Garzón sought information on secret government accounts linked to GAL, he found himself blocked. Prime Minister González maintained that the release of such information would compromise national security. Undeterred, Garzón ordered the two police officials arrested.
“Do you understand what you have set in motion here?” one of Garzón’s astonished friends, Antonio Navalón Sánchez, recalled having asked him at the time. Garzón answered directly: “It’s very simple: They either have to change the law so that they can kill people, or they have to respect it.”
Navalón, a media executive sympathetic to the González regime, didn’t know whether to be impressed by Garzón or afraid for his life. “He is kind of a Calvinist about the law,” Navalón said. “Once he comes to his conclusion, nothing stops him.”
As Garzón dug deeper, Socialist officials and even some judges began to complain that he was out of control. Belloch, the rival jurist, called him “a prosecutor in judicial robes.” But Garzón pursued ETA militants with equal passion. He pushed for information—sifting leads, suggesting theories. He built ties to key police investigators and prosecutors, and they quietly steered him cases that would otherwise have been distributed at random among the high court judges.
Garzón also began to display what was—at least by the standards of the Spanish judiciary—an unusual flair for the dramatic. He loved working with the cops and seemed always to be on the scene when they made a big drug bust or rescued a kidnapped businessman. Before important hearings, he told me, he sometimes watched a worn videotape of the 1969 film Z, Costa-Gavras’ thriller about a courageous magistrate’s inquiry into the murder of a liberal politician in Greece. (Garzón’s wife, Rosario, later told me he also saw Gladiator and The Fellowship of the Ring four or five times each.) Some compared Garzón to headline-grabbing American prosecutors like Louis Freeh and Rudolph Giuliani. But Garzón had a different model: Giovanni Falcone, the crusading Italian magistrate whose murder by the Mafia in 1992 helped to turn Italians decisively against the Cosa Nostra and its political allies.
By the early 1990s, Garzón’s high-profile investigations had made him one of the most popular public figures in Spain. At the same time, Prime Minister González and his Socialists were in a tailspin, with complaints about corruption growing louder. Promising reform, González wooed Garzón to a new, high-level post to combat drug trafficking and corruption. Many Spaniards were aghast that he would take the job, given the suggestion of government involvement in the GAL case, but he proved to be just the electoral weapon that the Socialists needed. In June 1993, González won a stunning fourth term. But the prime minister’s spell on Garzón wore off quickly. Calls to González’s office went unreturned; the anti-corruption effort went nowhere. Garzón resigned after less than a year, telling a news conference, “González used me like a puppet.”
Ten years later, Garzón is still touchy about his brief political career. “I don’t regret it—I never regret things,” he said. I pressed him a bit, asking whether he had been naive in dealing with González. “I’ve always thought that naivete is not a defect—if by naivete you mean that you think you can change things,” he said. “My sin was hubris: to think that one person could have really gotten something done there.”
Garzón returned to the high court with what one of his closest friends of that period, Ventura Pérez Mariño, remembered as “a sense of absolute failure.” Many observers felt he shouldn’t go back at all, given the prospect that he might be called upon to judge former government colleagues. Such a conflict arose almost immediately: Evidence in a new GAL case pointed to the involvement of senior government officials—perhaps even González himself—in the kidnapping of a suspected ETA militant.
Garzón’s pursuit of the matter became the stuff of Socialist nightmares. In short order, he won indictments against half a dozen current and former officials. In January 1995, González went on national television to deny any involvement in the case. But in 1996, Spanish voters delivered their own verdict, ousting the Socialists in favor of Aznar and his conservative Popular Party. (By 1998, the Supreme Court had convicted all of the major figures Garzón had indicted. It later discounted the evidence against González and reprimanded Garzón for implicating the prime minister.)
THE GREAT IRONY of the GAL cases is that by uncovering the government’s support for the death squads, the belief among many Basque separatists that they remained under siege, democracy or not, was validated. I told Garzón of meeting young Basque radicals who had talked late into the night about the “repression” they suffer at Spanish hands. Most of them had never known Franco’s rule. They had grown up in a prosperous, autonomous region with its own parliament and police force; they learned Euskera, the Basque language, in public schools. But the GAL crimes were clearly an open wound for them. They were also, Garzón admitted, just the sort of kids that ETA recruits to the underground.
The political dynamics of the global war on terrorism are not dissimilar, Garzón argued. “To fight fire with fire is always going to be catastrophic,” he said. “Very simply, that kind of action puts you on the same level as the terrorists. Although, really, you are in an even more perverse place because you are undermining the democratic system and you are getting absolutely nowhere in the process. Eventually, you will be held accountable. And that will give the terrorists a weapon they would not otherwise have.”
Garzón bristles at the notion that he might be advocating a “softer” fight against terrorism. “I am not some sort of Candide, or some kind of ultrapacifist who believes that everything can be solved without the use of force,” he went on. “It may make sense to use force—within the law of the land and according to the seriousness of the injury that you are trying to avoid or repair. But all over Europe—in England, in Germany, in Italy, in Spain—we are arresting people in terrorism cases and fighting terrorism within the law. I’m not so naive as to think we judges will do away with terrorism by ourselves. But together with good police work, with good intelligence, there is a lot that we can do.”
Garzón advocates a longer view of the struggle, one that more explicitly acknowledges the interdependence of allies. He said he understood when, in the immediate aftermath of the September 11 attacks, the United States demanded intelligence help from its allies while providing little in return. But he said that, to this day, his formal requests for information are typically met with silence from the Justice Department.
The United States’ treatment of terrorist suspects has created a problem that transcends the battle for Islamic hearts and minds, Garzón asserts. The legal assault on a global terrorist infrastructure like Al Qaeda’s is by definition an international enterprise, he says, one that may be crippled if the United States thinks only of the trials it intends to bring. “We cannot use anything that might be obtained in Guantanamo, for instance, because the prisoners there are not being given due process. So as far as any democratic state in Europe or anywhere else is concerned, that evidence is useless.”
To those who see the latest round of the U.S.-European conflict as having originated in a failure of diplomacy before the Iraq war, Garzón also offers a more pessimistic view. The dispute, he said, is in large part over two different visions of the struggle against terrorism: an American “military strategy,” in which intelligence is gathered for so-called direct action against terrorists, and a “civil approach,” in which evidence is collected with a view toward the legal prosecution of terrorist crimes. The two need not be mutually exclusive, Garzón says, but the civil approach cannot succeed, even in the long term, unless international legal standards are upheld now.
As Garzón spoke, a judge from another court knocked at the of-fice door to wish him well. The day before, the Basque provincial government had filed a motion to force Garzón off the case against the Batasuna party, arguing that he had shown bias. (The suit was quickly dismissed.) Two more colleagues stopped by in the next half-hour, wondering how he was getting on. In late 2002, Garzón suffered a facial paralysis that doctors linked to exhaustion. Even some of his friends have urged him to be more selective about the cases he chooses. But not all of them are worried.
“What makes him happiest is to be mixed up in the middle of things like this,” said Manuel Medina, who has known Garzón since his early days as a judge. “He’s like a bullfighter who thinks, ‘I am happy because I am going to die in a bullring.'”
Garzón’s wife, Rosario, said she understood her husband differently. “He might feel fear; I have felt it,” she said, alluding to the terrorists he has taken on. “I think they will come after him. If they can, they will try to eliminate Baltasar. Everyone knows that—they kill everyone they can.” Since the family moved to Madrid, Rosario said, their well-guarded home has been broken into at least twice, with warnings left behind. She revealed this almost matter-of-factly, in an interview to which she arrived alone. Then she went on: “But what sense can your life have if you spend it hiding or running away? This is history. He has to do this.”
Dispatch from Chile: On Pinochet, “He Did Nothing to Me”
Elizabeth Gettelman
Justice For Pinochet Takes the Weekend Off
Celia Perry
Policymakers on Torture Take Note – Remember Pinochet
Elizabeth Warren Has Another New Plan—And Wall Street Isn’t Going to Like It
Hannah Levintova
|
cc/2019-30/en_head_0021.json.gz/line27366
|
__label__cc
| 0.712572
| 0.287428
|
STEPHEN C. SCHOTT
Citation Homes Central
Stephen C. Schott is the Chief Executive Officer and President of Citation Homes Central and the Owner and Managing Partner of Oakland Athletic Baseball Company. Steve also leads Santa Clara Valley Housing and Award Homes, both are residential development companies. He has been personally involved in the construction of more than 30,000 homes during the past 40 years.
For Steve, building strong foundations has been his life's work, not only in construction but in his personal life. In the building industry, "If you don't have a strong foundation for a house, you'll never have a quality home to start with and you'll always have problems," he said. "Only with a strong foundation will you have success." Additionally, Steve and his wife, Pat, have been instrumental in establishing solid foundations for local education programs such as Home Run Readers and Role Model Program.
Steve received the Distinguished Alumni Award from Santa Clara Business College in 1989. In recognition of his contributions to educational advancement, he was inducted into the Horatio Alger Association of Distinguished Americans Hall of Fame in 2001 and into the Santa Clara Jr. Achievement Association Hall of Fame in 2003.
|
cc/2019-30/en_head_0021.json.gz/line27367
|
__label__cc
| 0.518844
| 0.481156
|
Behavioral Disorder News and Research
Researchers find potential link between autism and antidepressant use during pregnancy
An international team led by Duke-NUS Medical School has found a potential link between autistic-like behavior in adult mice and exposure to a common antidepressant in the womb.
Study: Child and adolescent health improved but maternal mortality worsened in the U.S.
The United States is one of only eight countries in the world where decreases in child and adolescent mortality over a 27-year period haven't also been matched by reductions in maternal mortality, according to a new scientific study.
Integrator complex proteins are crucial for healthy brain development in fruit flies, study finds
A study by Duke-NUS Medical School has found that members of the multiprotein 'Integrator complex', known for its role in gene regulation, are crucial for healthy brain development in fruit flies.
Disruptive behaviors in autistic children linked to reduced brain connectivity
More than a quarter of children with autism spectrum disorder are also diagnosed with disruptive behavior disorders.
Scientists untangle the brain's life-support network
The portion of the brain known as the hypothalamus is small but mighty -- it controls fundamental behaviors and physiology that are essential for survival.
Different sleep schedules among teens may have dissimilar effects on cognition and glucose levels
Many adolescent students sleep less than the recommended duration of 8-10 hours a night. It is unclear; however, whether short night sleep combined with an afternoon nap is as good as having the same amount of sleep continuously during the night without a nap.
Study finds motor skills problems in children exposed during pregnancy to plasticizer chemicals
Scientists with the Columbia Center for Children's Environmental Health at the Columbia University Mailman School of Public Health report motor skills problems in children exposed during pregnancy to plasticizer chemicals known as phthalates that are widely used in personal care products like moisturizers and lipstick, as well as plastic containers and children's toys.
New guidelines developed for effective management of neuropsychiatric symptoms of Huntington’s disease
Although Huntington's disease (HD) is traditionally thought of as a neurological disorder, behavioral symptoms are a common feature and frequently cause distress and difficulty to patients, family members, and other caregivers.
New research focuses on noise sensitivity and general fearfulness of canine behavior
Researchers in the Hannes Lohi research group in the University of Helsinki focused on two forms of canine fearfulness: noise sensitivity and general fearfulness.
Alcohol-linked disease overtakes hep C as top reason for liver transplant
An estimated 17,000 Americans are on the waiting list for a liver transplant, and there's a strong chance that many of them have alcohol-associated liver disease. ALD now edges out hepatitis C as the No. 1 reason for liver transplants in the United States, according to research published Tuesday in JAMA Internal Medicine.
Antiepileptic drug use by people with Alzheimer's disease linked to accumulation of hospital days
People with Alzheimer's disease who used antiepileptic drugs had a higher number of accumulated hospital days than people with Alzheimer's disease who did not use antiepileptics, according to a new study from the University of Eastern Finland.
To get mental health help for a child, desperate parents relinquish custody
When Toni and Jim Hoy adopted their son Daniel through the foster care system, he was an affectionate toddler. They did not plan to give him back to the state of Illinois, ever.
Using Assay Kits and Dyes to Advance Cell Biology Research
In this interview, Richard Delle Bovi highlights live cell ability of the CELLESTIAL® analysis kit from Enzo Life Sciences and its applications in cell biology.
From Enzo Life Sciences, Inc. 2 Jan 2019
Recent developments and challenges in hMAT inhibitors
Zhu et al. have reviewed the recent developments in the knowledge about the binding, inhibitory mechanisms and structure-activity relationships of hSERT, hNET and hDAT, which are primary human monoamine transporters hMATs.
Research: Myths about migration and health not supported by available evidence
Research published in The Lancet on 5 December revealed that harmful and unfounded myths about migration and health have become accepted and that these are used to justify policies of exclusion.
Vitamin C supplementation for pregnant smokers may reduce harm to infants’ lungs
Vitamin C may reduce the harm done to lungs in infants born to mothers who smoke during their pregnancy, according to a randomized, controlled trial published online in the American Thoracic Society’s American Journal of Respiratory and Critical Care Medicine.
Study estimates economic impact of fetal alcohol spectrum disorder
Fetal alcohol spectrum disorder is a common condition with a high economic impact in both children and adults, concludes an updated review in the Journal of Addiction Medicine, the official journal of the American Society of Addiction Medicine.
Brain plasticity associated with perceptual learning more ubiquitous than initially thought
Life-changing moments are also brain-changing moments: everything from a first kiss to a last goodbye modifies cells within the skull.
Research provides insight into neurobiology of aggression and bullying
Duke-NUS researchers have discovered that a growth factor protein, called brain-derived neurotrophic factor, and its receptor, tropomyosin receptor kinase B affects social dominance in mice. The research has implications for understanding the neurobiology of aggression and bullying.
Father’s exposure to nicotine may cause cognitive deficits in descendants
A father’s exposure to nicotine may cause cognitive deficits in his children and even grandchildren, according to a study in mice publishing on October 16 in the open-access journal PLOS Biology by Pradeep Bhide of Florida State University in Tallahassee and colleagues.
|
cc/2019-30/en_head_0021.json.gz/line27374
|
__label__wiki
| 0.977365
| 0.977365
|
Ranveer Singh on #MeToo in India: It Has Made Men Take Stock and Think
Ranveer Singh said #MeToo movement has been very impactful in India and he hopes there is a change in the patriarchal thinking of Indian men.
Updated:December 14, 2018, 8:25 AM IST
Image courtesy: Viral Bhayani
Bollywood star Ranveer Singh said the #MeToo movement has been very impactful in India and he hopes there is a change in the patriarchal thinking of Indian men.
"The #MeToo movement was historic, revolutionary. It has made guys take stock and think and, that itself, is a big thing. It has been hugely impactful and significant," Ranveer said at the Times Network India Economic Conclave 2018 on Thursday.
Ranveer said what happened in the last two months was a revolution. "It was happening all too fast, quickly. It was a revolution. You had perpetrators who aren't working anymore. It made a huge impact from where I stand. In my perception, what the movement should have done, I think it has. It has changed to a large extent the way men think.
"Every man thinks twice, they are afraid. They think if they do something wrong, it is going to be called out. It had made a huge impact at the ground level."
When asked about his idea of consent, the 'Padmavaat' actor said the thinking of men needs to change.
"We have, for the longest time, lived in a patriarchal society. Men feel very entitled in their species, in my surroundings at least. Fortunately, I have had an upbringing, my father has always been out, so I was raised by four women, mother, sister, grandmother and great grandmother, so I have a different way of looking at it.
"I also studied in America where gender dynamics are very different, the outlook and view on sex is very different. I have had that kind of exposure. I have seen guys who have a sense of entitlement that is deeply ingrained in them and they laugh at you if you tell them otherwise."
The actor said he would like to lead by example in his life. "I am hoping as a thought leader to contribute towards some positive change, by just leading in example, I am hoping I make some change. It's too slow moving," he said.
Ranveer, however, thinks India needs educational training in understanding the true meaning of consent. "These things have to start from foundational, fundamental level. Parents need to pass on to kids and schools to students. What you understand of the world and the interactions while growing up," he said.
The #MeToo movement hit India when Tanushree Dutta accused Nana Patekar of sexual misconduct while they were shooting for song for their 2008 film 'Horn Ok Pleassss'.
A number of high-profile men such as M J Akbar, Vikas Bahl, Alok Nath, Sajid Khan, Justin Das and, most recently, artist Subodh Gupta have been outed in India's #MeToo movement.
Ranveer Singh on MeToo
Times Network India Economic Conclave 2018
|
cc/2019-30/en_head_0021.json.gz/line27375
|
__label__cc
| 0.640686
| 0.359314
|
Former fugitive pleads not guilty in fiancee's stragulation
Posted Apr 15, 2019 4:12 pm ADT
NEWARK, N.J. — A man who was on the FBI’s 10 Most Wanted list when he was captured last month has pleaded not guilty to murder charges in the 2014 strangulation of his fiancee in New Jersey.
Lamont Stephenson entered his plea Monday during a brief hearing where he was represented by a public defender. He will remain jailed until his trial, which hasn’t been scheduled.
Stephenson is charged in the death of Olga DeJesus. Her body was found inside her Newark apartment. He was placed on the FBI’s Top 10 list in October 2018 and was captured in Maryland on March 7.
Stephenson was in a truck when Prince George’s County police approached him while investigating a suspicious person call. He told the officers he was homeless but later said he was a wanted man.
Sign in to comment (not connected to your Insider Club login).
You're logged in as . Edit Profile | Logout.
Unexpected error. Please try again.
Notice: Your email may not yet have been verified. Please check your email, click the link to verify your address, and then submit your comment. If you can't find this email, access your profile editor to re-send the confirmation email. You must have a verified email to submit a comment. Once you have done so, check again.
Please read our commenting policies
|
cc/2019-30/en_head_0021.json.gz/line27376
|
__label__wiki
| 0.838349
| 0.838349
|
'Chappaquiddick’ Star: ‘Everybody Gave [Ted Kennedy] a Pass’
By Christian Toto | April 7, 2018 1:30 PM EDT
Jason Clarke got quite the education after accepting the lead role in Chappaquiddick.
The movie, out April 6, follows the events surrounding the 1969 death of Mary Jo Kopechne. Sen. Ted Kennedy (Clarke) was driving Kopechne, a campaign worker for his late brother Robert F. Kennedy, home on the Massachusettes island of Chappaquiddick when he crashed his Oldsmobile through a fence, landing the car in a pond.
Kennedy escaped the submerged car but Koechne remained trapped inside. The Senator waited 10 hours to call for help.
“I was overcome, I’m frank to say, by a jumble of emotions: grief, fear, doubt, exhaustion, panic, confusion and shock,” he said at the time.
The diver who pulled Kopechne’s body from the car said she didn’t drown instantly. A trapped pocket of air temporarily kept her alive, but no autopsy was performed on the body.
Much of this proved new to Clarke, the Australian actor from Terminator: Genisys and Dawn of the Planet of the Apes.
He’s since gotten up to speed on the issue.
The film’s creative team insists Chappaquiddick is focused on the truth, not conjecture or partisan bias. Audiences can decide for themselves starting April 6. The early crush of reviews from the film’s festival circuit suggests the film succeeds on a factual level.
In short, this isn’t a smear job. That didn’t stop some “powerful people” from trying to stop the film’s production.
“We’re not making propaganda. Here is this amazing, incredible, traumatic event, which I think has had a massive impact, and still does, and effects the world we’re in now–20th century American history,” Clarke told Variety.
The role gave the actor insights into more than just the 1969 tragedy. It let him view his fellow Democrats in a new light, including those pulling the levers in the media. The film also found him re-examining those politicians who fawned over Kennedy while ignoring his darkest act.
To “become” Kennedy, the actual did his homework. He studied archival footage to nail the late Senator’s voice and mannerisms. That led him to the 2008 DNC convention where Kennedy introduced the future president, Sen. Barack Obama.
The moment chilled the actor.
“I couldn’t listen to that speech of Barack’s in the same kind of way. What have we done? … Everybody gave [Kennedy] a pass.
Other fascinating insights from Clarke based on his Deadline.com interview:
On the Chappaquiddick scandal and its legacy:
I don’t understand why it’s not taught more, why more people don’t know about it. I think the first time you watch, the facts are shocking and it’s a constricting feeling. Like, my God, this can’t be true, can it? The second time around, a lot of people have a much more emotional response, like, how can people not know about this?
On Democrats in the Age of Trump:
Remember when George W. Bush came out and said, “You’re either for us or against us”? The left has become a little like that now too. Anything that gets in the way of, [Trump] has to get out of the White House. That’s a bit scary. I guess that’s why people are afraid.
On the media’s wariness to cover Chappaquiddick:
Look, we’ve definitely gotten a lot interest from the right from Fox, but the left are not engaging. Bill Maher and Rachel Maddow passed on covering the film. I think Chris Mathews is still considering but hasn’t committed, and The New York Times isn’t really entering into a dialogue about it. [Editor’s note: The Times ran two Chappaquiddick-related stories since this interview ran]
I am finding that on the right, they’re more willing to have a look at it than the left, I don’t know if they’ll it. I don’t think they know how to fit this into their agenda….
Why won’t Rachel Maddow have us on her show to talk about how we feel about this now?
On Hillary Clinton’s handling of sensitive materials as Secretary of State:
Who does that? [Clinton] was the Secretary of State, and with everything she’d been through, how does that happen? Incompetence and hubris, across the board. Not trying to be mean, but you behaved like that in your job, you wouldn’t have a job.
[Cross-posted from Hollywood in Toto.]
Column Ted Kennedy
Christian Toto is a film critic and podcaster and runs the website HollywoodInToto.com.
|
cc/2019-30/en_head_0021.json.gz/line27377
|
__label__wiki
| 0.917972
| 0.917972
|
NYT's Halbfinger Again Skips Terror vs. Israel, Endorses Leftist 'Occupation' Propaganda
By Clay Waters | July 10, 2019 11:40 PM EDT
New York Times Jerusalem bureau chief David Halbfinger again provided a solely Palestinian view of the conflict in Israel, writing through the eyes of left-wing U.S. Jewish group J Street for Wednesday’s edition: “Absorbing a Different Slice of a Jewish Birthright – An Unflinching View Of Israeli Occupation.” Halbfinger followed a group of American college students on an “alternative” left-wing pro-Palestinian tour of the West Bank:
The fun was over before the tour bus rolled into Har Gilo.
For the past week, 28 college students from the United States had been taking part in a traveling experiment billed as an alternative to Birthright Israel, whose free trips to the country have become a rite of passage for hundreds of thousands of young American Jews.
Birthright’s avoidance of the Israeli occupation of the West Bank has made it the target of angry protests by left-leaning Jewish activists. But for sheer ambition, no critique has approached this week’s attempt by the liberal lobbying group J Street to map out an alternative route for Birthright’s tours.
The organizers said they embraced Birthright’s goal of helping young American Jews connect with Israel and with their Jewishness, but that they also needed to be exposed to the realities of the occupation.
This evasive report begs the question: Why is there an “occupation” at all? Is there any kind of threat against Israelis posed by Palestinians? They’re constantly attacking the Israel border from the unoccupied Gaza Strip (currently “governed” by the terror group Hamas). But attacks on Jews are barely mentioned in this long report:
On Sunday, after several upbeat days hiking in the Galilee, learning about the kibbutz movement and bonding over buffets and Israeli pop songs, the J Street cohort took a sharp left turn into territory where Birthright does not go.
In the West Bank settlement of Har Gilo, they received a harsh history lesson from a veteran opponent of the occupation. Then they toured an impoverished, water-starved Palestinian village that Israeli settlers want to demolish, and visited the city of Hebron, where repeated outbreaks of violence have turned an entire Palestinian business district into a ghost town.
Left-wing terminology was consistently applied (click “expand”):
The organizers of the J Street trip, called “Let Our People Know,” said newcomers to Israel also needed to understand the experiences of Palestinians living under Israeli occupation.
(....)
The ride to Har Gilo, just south of Jerusalem, took the bus through an Israeli checkpoint. Hagit Ofran, a leader of Peace Now, addressed the group over a microphone and described how soldiers decided which motorists to stop: “To look suspicious,” she said, “you need to look Arab.”
It was a bracing how-do-you-do for liberals unaccustomed to blunt racial profiling.
But it was atop Har Gilo, peering out over the southern West Bank, that the travelers began to see troubling aspects of a country they had mainly loved from far away.
He played the race card, cynically using the history of Jewish oppression against the state of Israel (click “expand”):
Ms. Foye, who as a black Jew said she had experienced more than her share of bigotry, said she was hit hard by the idea that a “state founded to protect one marginalized group” was oppressing another.
She said she had always loved Israel and seen it as a “beacon of light.” But what she saw on Sunday overwhelmed her: “My joy and my light shouldn’t be coming from someone else’s darkness,” she said.
As the day grew long, the facial expressions more pained and the questions more anguished, the J Street tour seemed increasingly incompatible with Birthright’s goal of hooking young American Jews on Israel.
By dinnertime, two participants said they were reconsidering their belief in a Jewish state. Jesse Steshenko, 19, of Santa Cruz, Calif., who has a Star of David tattooed on his right wrist, said he was “disgusted” with Israel’s government.
Mission accomplished.
Halbfinger has a history of minimizing the existential threat Israel faces in the region, while repeating Hamas talking points as fact. He has infantilized Palestinians and downgraded Israeli lives by accepting the excuse of “impatience” for death-dealing, like this amazing euphemism for violence by Hamas in its attack on Israel's border: “But at other times, it can express its impatience with weapons.”
And this, from a related story:
....The outbreak of violence appears to have begun on Friday, when a sniper wounded two Israeli soldiers, a violent but localized expression of Palestinian impatience with Israel’s failure to alleviate dire humanitarian conditions in Gaza.
Israel/Palestine Bias by Omission New York Times David Halbfinger
Clay Waters
Clay Waters was director of Times Watch, a former project of the Media Research Center.
|
cc/2019-30/en_head_0021.json.gz/line27378
|
__label__cc
| 0.6351
| 0.3649
|
G C College
Everything you need to know about G C College: news, reviews, in-depth analysis, opinion and more
Couples vying on whose office day was worse 'may end up in divorce'
London, Feb 19 (ANI): Couples who compete with each other over who has had the worse day or bombard the family with their workplace problems may be on the road to divorce, experts have warned.
How supportive spouses help cope with work-related stress
Washington, Feb 17 (ANI): Researchers have shed light on the role of support in households where daily stress is common to both spouses.
Why love is actually a 'drug'
London, Feb 14 (ANI): It is often believed that 'love is a drug'' and now a new research has confirmed that romance really does work in a similar manner as addiction to illegal substances and activates a reaction in the same part of the brain.
Assad's UK-born wife, children 'stopped by rebel forces from trying to flee Syria'
Damascus, Jan 31 (ANI): Syrian President Bashar Assad's British-born wife Asma, and children have reportedly been stopped by rebel forces trying to flee the country with the help of the nation's security forces.
|
cc/2019-30/en_head_0021.json.gz/line27379
|
__label__wiki
| 0.91323
| 0.91323
|
Full Coverage of the 2019 FIFA Women's World Cup in France
Trump Tells US Soccer Star Megan Rapinoe to 'Never Disrespect' White House
"I am a big fan of the American Team, and Women's Soccer, but Megan should WIN first before she TALKS! Finish the job!" the president tweeted.
Published Jun 26, 2019 at 8:49 AM
President Trump (L) and Megan Rapinoe (R)
President Donald Trump tweeted Wednesday that he will invite the U.S. women's national soccer team to the White House following this year's Women's World Cup — whether or not they win the mega sporting event.
But his attempt at extending a level of courtesy toward the women's team came with a dig at co-captain Megan Rapinoe, who said in a video clip shared on social media this month that "I'm not going to the f------- White House."
"I am a big fan of the American Team, and Women's Soccer, but Megan should WIN first before she TALKS! Finish the job!" Trump wrote in a series of tweets, at first tagging the wrong Twitter account for Rapinoe.
"We haven't yet invited Megan or the team, but I am now inviting the TEAM, win or lose," Trump added. "Megan should never disrespect our Country, the White House, or our Flag, especially since so much has been done for her & the team. Be proud of the Flag that you wear. The USA is doing GREAT!"
Golf Ball Kills 6-Year-Old
Community members in Orem, Utah are in shock after a freak golfing accident killed a little girl. Investigators say 6-year-old Aria Hill was sitting in a golf cart next to a tee box when her father hit a ball that struck her in the back of the head.
(Published Wednesday, July 17, 2019)
The president also said that sports teams "love" coming to the White House.
Rapinoe said in an interview this month in Eight by Eight magazine that "no f---in' way will we be invited to the White House." She surmised that Trump doesn't invite teams that he knows will decline or "like he did when the Warriors turned him down, he'll claim they hadn't been invited in the first place."
|
cc/2019-30/en_head_0021.json.gz/line27380
|
__label__wiki
| 0.977837
| 0.977837
|
Army's Public Website Hacked by Unknown Intruders
The PentagonAFP - Getty Images file
June 8, 2015, 7:34 PM UTC / Updated June 8, 2015, 8:10 PM UTC
Defense officials confirm the official public Army website has been hacked by unknown intruders demanding the U.S. stop training rebel fighters inside Syria.
Unlike the massive hack into Office of Personnel Management records, the officials stress the website contains no official classified information or private personal data of any Amy personnel, military or civilian.
The messages reportedly proclaimed “YOU’VE BEEN HACKED” and added “YOUR COMMANDERS ADMIT THEY ARE TRAINING THE PEOPLE THEY HAVE SENT YOU TO DIE FIGHTING.”
Defense officials confirm the official public Army website has been hacked by unknown intruders demanding the US stop training rebel fighters inside Syria. The officials stress the website contains no official classified information or private personal data of any Amy personnel, military or civilian.
It’s not clear yet whether the Army or the hackers shut down the website.
"Today an element of the Army.mil service provider's content was compromised," Army Brig. Gen. Malcolm Frost, chief of public affairs, said on the website hacking. "After this came to our attention, the Army took appropriate preventive measures to ensure there was no breach of Army data by taking down the website temporarily."
Related: White House to Congress: Get Out of Cyber 'Dark Ages'
The officials say the website is for general public access with general information about the Army, press releases and Army generated news stories.
The news comes less than a week after Obama administration officials announced that four million federal workers may have had their personal information compromised in a cyber attack, which officials said could affect every agency of the U.S. government.
Related: Federal Data Breach: Can the Government Protect Itself From Hackers?
Starting today, approximately four million current and former government employees will be notified that their personal information — including names, Social Security numbers and birth dates — might have been hacked.
The compromised data was stored in a system shared by the Interior Department and the Office of Personnel Management, which screens and hires federal workers and approves security clearances for 90 percent of the federal government.
The FBI is leading the investigation into the breach, which happened in December and was discovered in April using new tools.
On Friday, the White House said the threat of cyber attacks is persistent and while the federal government has raced to outpace would-be hackers, legislation aimed at shoring up cybersecurity is desperately needed to do more. Those proposals included measures that would improve information sharing between the private sector and federal investigators, require companies to give 30 day notice of a security breach, increase punishments for cyber crimes and create uniform standards of data breach notification laws.
"Since the president submitted those pieces of legislation in January we've seen very little action," White House press secretary Josh Earnest told reporters on Friday. "We need the United States Congress to come out of the Dark Ages and join us in the 21st century."
The House passed a measure earlier this year, which the White House supports, pushing companies to share data records with federal investigators. The Senate Intelligence Committee had previously approved a similar measure, but the full Senate has not yet voted on the legislation.
Opponents to the measure cite privacy concerns and worries about government overreach.
Jim Miklaszewski and Halimah Abdullah contributed.
|
cc/2019-30/en_head_0021.json.gz/line27381
|
__label__cc
| 0.648991
| 0.351009
|
Elementary Teacher Preparation: Idaho
The state should ensure that its teacher preparation programs provide elementary teachers with a broad liberal arts education, the necessary foundation for teaching to the Common Core Standards.
Does not meet
National Council on Teacher Quality. (2011). Elementary Teacher Preparation: Idaho results. State Teacher Policy Database. [Data set].
Retrieved from: https://www.nctq.org/yearbook/state/ID-Elementary-Teacher-Preparation-6
Analysis of Idaho's policies
Although Idaho has adopted the Common Core Standards, the state does not ensure that its elementary teacher candidates are adequately prepared to teach the rigorous content associated with these standards.
Idaho requires candidates to pass the Praxis II general elementary content test, which does not report teacher performance in each subject area, meaning that it is possible to pass the test and still fail some subject areas, especially given the state's low passing score. Further, based on available information on the Praxis II, there is no reason to expect that the current version would be well aligned with the Common Core Standards.
The state now requires that all candidates seeking an elementary education endorsement earn a subject-area endorsement (allowing the teaching of that subject through grade 9) or a K-12 endorsement as outlined in the requirements for a secondary certificate.
Although the state does not specify any coursework requirements for general education or elementary teacher candidates, Idaho's standards for elementary education teachers articulate that candidates must "understand the concepts" of subjects such as language arts, science, social studies and the arts. These are important curricular areas, but this statement is far too ambiguous to set a meaningful standard for holding either programs or teachers accountable.
Finally, there is no assurance that arts and sciences faculty will teach liberal arts classes to elementary teacher candidates.
Idaho Administrative Code 08.02.02.018 Idaho Standards for Initial Certification http://www.sde.idaho.gov/site/teacher_certification/accredited.htm Praxis II www.ets.org
Recommendations for Idaho
Require a content test that ensures sufficient knowledge in all subjects.
Idaho should ensure that its subject-matter test for elementary teacher candidates is well aligned with the Common Core Standards, which represent an effort to significantly raise the standards for the knowledge and skills American students will need for college readiness and global competitiveness.
The state should also require separate passing scores for each content area on the test because without them it is impossible to measure knowledge of individual subjects. Further, to be meaningful, Idaho should ensure that these passing scores reflect high levels of performance.
Provide broad liberal arts coursework relevant to the elementary classroom.
Idaho should either articulate a more specific set of standards or establish comprehensive coursework requirements that are specifically geared to the areas of knowledge needed by PK-6 teachers. Further, the state should align its requirements for elementary teacher candidates with the Common Core Standards to ensure that candidates will complete coursework relevant to the common topics in elementary grades. An adequate curriculum is likely to require approximately 36 credit hours in the core subject areas of English, science, social studies and fine arts.
Require at least an academic concentration.
An academic concentration, if not a full academic major, would not only enhance Idaho teachers' content knowledge, but it would also ensure that prospective teachers have taken higher-level academic coursework. Further, it would provide an option for teacher candidates unable to fulfill student teaching or other professional requirements to still earn a degree. Idaho's requirement of a subject-area endorsement is a step in the right direction; however, there is no limitation to academic subject areas relevant to the elementary classrooms.
Ensure that arts and sciences faculty teach liberal arts coursework.
Although an education professor is best suited to teach effective methodologies in subject instruction, faculty from the university's college of arts and sciences should provide subject-matter foundation.
Idaho was helpful in providing NCTQ with facts that enhanced this analysis. The state added that it is currently considering a Praxis II test for elementary teachers that would report subscores in all areas.
NCTQ commends the efforts of states, like Idaho, that have advocated for a new elementary education test from ETS. Requiring subscores for each of the content areas is a significant step toward ensuring that all elementary teachers possess the requisite knowledge for the classroom. NCTQ looks forward to reviewing Idaho's progress in future editions of the Yearbook.
Elementary teachers need liberal arts coursework that is relevant to the PK through 6 classroom.
The Common Core Standards, adopted by nearly all states, represent an effort to significantly raise expectations for the knowledge and skills American students will need for college readiness and global competitiveness. However, many states' policies fail to ensure that elementary teacher candidates will have the subject-area knowledge to teach to the Common Core Standards. Even when states specify liberal arts requirements for teacher candidates, the regulatory language can be quite broad, alluding only minimally to conceptual approaches such as "quantitative reasoning" or "historical understanding." Another common but inadequate approach that states take is to specify broad curricular areas like "humanities" or "physical sciences." A humanities course could be a general overview of world literature—an excellent course for a prospective elementary teacher—but it could also be "Introduction to Film Theory." Likewise, a physical science course could be an overview of relevant topics in physics, chemistry and astronomy, or it could focus exclusively on astronomy and fail to give a teacher candidate an understanding of the basic concepts of physics. Too few states' requirements distinguish between the value gained from a survey course in American history, such as "From Colonial Times to the Civil War," and an American history course such as "Woody Guthrie and Folk Narrative in the Great Depression."
In addition to the common-sense notion that teachers ought to know the subjects they teach, research supports the benefits to be gained by teachers being broadly educated. Teachers who are more literate—who possess richer vocabularies—are more likely to be effective. In fact, of all the measurable attributes of a teacher, teacher literacy correlates most consistently with student achievement gains. Some states still require that elementary teacher candidates major in elementary education, with no expectation that they be broadly educated. Others have regulatory language that effectively requires the completion of education coursework instead of liberal arts coursework by mandating only teaching methods courses in subject areas without also requiring content-based coursework in the areas themselves.
Standards-based programs can work when verified by testing.
Many states no longer prescribe specific courses or credit hours as a condition for teacher candidates to qualify for a license. Instead, they require teacher candidates to complete an approved program that meets state-specific standards or standards set forth by accrediting bodies—the National Council for Accreditation of Teacher Education (NCATE) and the Association for Childhood Education International (ACEI)—and leave it at that. The advantage of this "standards-based" approach is that it grants greater flexibility to teacher preparation programs regarding program design.
However, a significant disadvantage is that the standards-based approach is far more difficult to monitor or enforce. While some programs respond well to the flexibility, others do not. Though the ACEI/NCATE standards may be beneficial, they are too general for states to rely on in their efforts to ensure adequate subject-matter training. For example, ACEI's standard for social studies requires that elementary teacher candidates be "able to use knowledge, skills and dispositions from social studies to organize and provide integrated instruction in grades K-6 for the study of major themes, concepts, and modes of inquiry drawn from academic fields that address: (1) culture; (2) time, continuity, and change; (3) people, places, and environment; (4) individual development and identity; (5) individuals, groups, and institutions; (6) power, governance, and authority; (7) production, distribution, and consumption; (8) science, technology, and society; (9) global connections; and (10) civic ideals and practices." These broad concepts do very little to articulate the actual knowledge that elementary teacher candidates should possess.
Standards are important but essentially meaningless absent rigorous tests to ensure that teacher candidates have met them. Most states that have chosen the standards-based approach have not implemented such tests. In their absence, verifying that teacher preparation programs are teaching to the standards requires an exhaustive review process of matching every standard with something taught in a course. This approach is neither practical nor efficient. Tests of broad subject matter are also not the solution, given that it is possible to pass without necessarily demonstrating knowledge in each subject area. For instance, on many tests of teacher content knowledge, a passing score is possible while answering every mathematics question incorrectly.
Mere alignment with student learning standards is not sufficient.
Another growing trend in state policy is to require teacher preparation programs to align their instruction with the state's student learning standards, and this is likely to increase with the introduction of the Common Core Standards. In many states, this alignment exercise is the only factor considered in deciding the content to be delivered to elementary teacher candidates. Alignment of teacher preparation with student learning standards is an important step but by no means the only one. For example, a program should prepare teachers in more than just the content that the state expects of its fourth graders. Also critical is moving past alignment and deciding the broader set of knowledge a teacher needs to be able to effectively teach fourth grade. The teacher's perspective must be both broader and deeper than what he or she will actually teach.
An academic concentration enhances content knowledge and ensures that prospective elementary teachers take higher-level academic coursework.
Few states require prospective elementary teachers to major or minor in an academic subject area. Consequently, in most states these teachers can meet subject-matter requirements without taking any advanced-level coursework. At minimum, states should require a concentration in an academic area. In addition to deepening subject-matter knowledge in a particular area, building this concentration into elementary education programs ensures that prospective teachers complete academic coursework on a par with peers earning bachelor's degrees in other areas.
A concentration also provides a fallback for education majors whose programs deem them unready for the classroom. In most education programs, virtually all coursework is completed before candidates begin student teaching. The stakes are high once student teaching begins: if a candidate cannot pass, he or she cannot meet requirements for a major or graduate. This may create a perverse incentive for programs to set low standards for student teaching and/or pass candidates whose clinical experience is unsatisfactory. If they were required to have at least an academic concentration, candidates who failed student teaching could still complete a degree with minimal additional coursework.
Subject-area coursework should be taught by arts and sciences faculty.
Most states do not explicitly require that subject-matter coursework be taught by academics in the field, that is, faculty from a university's college of arts and sciences. While an education professor who specializes in science education, for instance, is well suited to teach effective methodologies in science instruction, a scholar in science should provide the foundation work in the subject itself.
States cannot leave these decisions entirely to teacher preparation programs because sending teacher candidates to the college of arts and sciences to complete coursework can run counter to programs' financial interests.
Numerous research studies have established the strong relationship between teachers' vocabulary (a proxy for being broadly educated) and student achievement. For example: A.J. Wayne and P. Youngs, "Teacher characteristics and student achievement gains: A review," Review of Educational Research 3, No. 1 (2003): 89-122. See also G.J. Whitehurst, "Scientifically based research on teacher quality: Research on teacher preparation and professional development," presented at the 2002 White House Conference on Preparing Teachers; R. Ehrenberg and D. Brewer, "Did Teachers' Verbal Ability and Race Matter in the 1950s? Coleman Revisited," Economics of Education Review 14 (1995), 1-21.
Research also connects individual content knowledge with increased reading comprehension, making the capacity of the teacher to infuse all instruction with content of particular importance for student achievement. See Willingham, D. T., "How knowledge helps: It speeds and strengthens comprehension, learning—and thinking," American Educator 30(1), (2006).
For the importance of teachers' general academic ability, see R. Ferguson, "Paying for Public Education: New Evidence on How and Why Money Matters," Harvard Journal on Legislation 28 (1991), 465-498; R. Greenwald, L. Hedges, and R. Laine, "Does Money Matter? A Meta-Analysis of Studies of the Effects of Differential School Inputs on Students' Outcomes," Educational Researcher 23, no. 3 (1994), 5-14; E. Hanushek, "Teacher Characteristics and Gains in Student Achievement: Estimation Using Micro-Data," American Economic Review 61, no. 2 (1971), 280-288; E. Hanushek, "A More Complete Picture of School Resource Policies," Review of Educational Research 66 (1996), 397-409; H. Levin, Concepts of Economic Efficiency and Educational Production," in Education as an Industry, ed. J. Froomkin, D. Jamison, and R. Radner (Cambridge, MA: Ballinger, 1976); D. Monk and J.R. King, "Subject Area Preparation of Secondary Mathematics and Science Teachers and Student Achievement," Economics of Education Review 12, no. 2 (1994), 125-145; R. Murnane, "Understanding the Sources of Teaching Competence: Choices, Skills, and the Limits of Training," Teachers College Record 84, no. 3 (1983) R. Murnane and B. Phillips, Effective Teachers of Inner City Children: Who They Are and What Are They? (Princeton, NJ: Mathematica Policy Research, 1978); R. Murnane and B. Phillips, "What Do Effective Teachers of Inner City Children Have in Common?" Social Science Research 10 (1981), 83-100; M. McLaughlin and D. Marsh, "Staff Development and School Change," Teachers College Record 80, no. 1 (1978), 69-94; R. Strauss and E. Sawyer, "Some New Evidence on Teacher and Student Competencies," Economics of Education Review 5 (1986), 41; A. A. Summers and B.L. Wolfe, "Which School Resources Help Learning? Efficiency and Equity in Philadelphia Public Schools," Business Review (Federal Reserve Bank of Philadelphia, February 1975).
Sandra Stotsky has documented the fact that teacher candidates often make inappropriate or irrelevant coursework choices that nonetheless satisfy state requirements. See S. Stotsky, "Can a State Department of Education Increase Teacher Quality? Lessons Learned in Massachusetts," in Brookings Papers on Education Policy, ed. Diane Ravitch (Washington, D.C.: Brookings Institution Press, 2004).
On the need for colleges and universities to improve their general education coursework requirements, see The Hollow Core: Failure of the General Education Curriculum (Washington, D.C.: American Council of Trustees and Alumni, 2004). For a subject-specific example of institutions' failure to deliver solid liberal arts preparation see, The Coming Crisis in Citizenship: Higher Education's Failure to Teach America's History and Institutions (Wilmington, DE: Intercollegiate Studies Institute, 2006).
For information on teacher licensing tests, see The Academic Quality of Prospective Teachers: The Impact of Admissions and Licensure Testing (Princeton, NJ: Educational Testing Service, 1999). A study by C. Clotfelter, H. Ladd, and J.Vigdor of elementary teachers in North Carolina also found that teachers with test scores one standard deviation above the mean on the Elementary Education Test as well as a test of content was associated with increased student achievement of 0.011 to 0.015 standard deviations. "How and Why Do Teacher Credentials Matter for Student Achievement?" The Calder Institute (2007).
For information on where states set passing scores on teacher licensing tests across the U.S., see chart on p. 13 of NCTQ "Recommendations for the Reauthorization of the Elementary and Secondary Education Act, Removing the Roadblocks: How Federal Policy Can Cultivate Effective Teachers," (2011).
|
cc/2019-30/en_head_0021.json.gz/line27382
|
__label__wiki
| 0.901042
| 0.901042
|
Tax/
‘Jewel’ of Australia’s tax-system destroyed in budget
Tax 1 minute read
Tax | 14 May 2018 | Lucy Dean
Lucy Dean
14 May 2018 — 7:53 am
By cutting out the 37 per cent tax bracket, the latest budget also removes the “jewel” that is Australia’s progressive tax system, The Australia Institute has argued.
The 2018-19 budget, announced by Treasurer Scott Morrison last Tuesday, includes the removal of the 37 per cent tax bracket.
The removal of this bracket, which applied to those earning between $120,000 and $200,000, means those earning between $41,000 and $200,000 now effectively pay the same 32.5 per cent tax rate.
That’s factoring in the higher threshold for the 32.5 per cent tax bracket, increasing from $37,000 to $41,000.
Mr Morrison argued this would simplify the tax system.
However, to The Australia Institute’s (TAI) senior economist Matt Grudnoff, the removal of the bracket is an example of how “inequitable this tax plan is”.
According to TAI modelling, 62 per cent of the benefits of the tax cuts flow through to those in the highest income brackets.
At the same time, just 7 per cent are received by the 30 per cent of Australians in the lowest-earning bracket.
In a briefing note, Mr Grudnoff said removing the 37 per cent bracket, while bumping up the 32.5 per cent threshold, will see someone earning $40,000 accrue a tax cut of $455. Someone earning $200,000 would receive a tax cut of $7,225 a year.
“The jewel in the tax system is the progressive nature of our income tax,” the economist said.
“It means those who can afford to pay more do so. Moving from a progressive system to a flat tax system means a big tax cut for those at the top and very little for those at the bottom.”
Arguing that inequality is the most significant economic issue of the time, Mr Grudnoff characterised the budget as a “radical plan to increase inequality”.
‘The best way to deliver fairness is through a stronger economy’: Scott Morrison
Mr Morrison disagrees with Mr Grudnoff’s interpretation.
Speaking to the ABC, the Treasurer defended the changes, arguing the best way to “deliver fairness” was through a stronger economy.
Questioning whether someone earning $200,000 a year was rich, he said it’s “great” that those on lower incomes will likely never face a higher tax rate, thanks to the removal of the 37 per cent bracket.
“Our tax plan is a plan. It goes over seven years. It addresses the situation for all Australians, and it provides more incentive and more reward. It’s not based on envy and bitterness,” he claimed.
According to an ongoing Nest Egg poll, 53.9 per cent of readers believe an Australian is wealthy if they have an annual taxable income of at least $200,000.
That’s followed by the 22.7 per cent who think you can be wealthy with an income of between $150,000 and $200,000.
Just over 14 per cent consider a wealthy Australian to be one with an annual taxable income of between $80,000 and $150,000, while 9.3 per cent believe a wealthy Australian can earn between $60,000 and $80,000.
Last Updated: 15 May 2018 Published: 14 May 2018
‘Lead me to what I need to investigate’: tax inspector
What can we expect from this ‘Baby Boomer budget’?
The tax cuts and cash boosters in the works for Australians
The hurdles facing your promised tax cuts
Sweeping changes to income tax cop more backlash
|
cc/2019-30/en_head_0021.json.gz/line27385
|
__label__wiki
| 0.890037
| 0.890037
|
Net Worth is $87.74 Billion
11 January 2018 | Investments
Warren Buffett was bornon 30 August 1930 in Omaha, Nebraska, United States, is CEO, Berkshire Hathaway. Warren Buffett is #3 in List Billionaires People In The World. Known as the "Oracle of Omaha," B...
Net worth statistics
Thomas Peterffy
Thomas Peterffy was bornon 1944 in Palm Beach, Florida, United States. Thomas Peterffy is #48 in List Billionaires People In The World. A pioneer of digital trading, Peterffy is CEO of Interactive Bro...
James Simons
James Simons was bornon 1938 in East Setauket, New York, United States, is Founder, Renaissance Technologies Corp.. James Simons is #46 in List Billionaires People In The World. James Simons is the fo...
Ray Dalio was bornon 1 August 1949 in Greenwich, Connecticut, United States, is Founder & Co-Chief Investment Officer, Bridgewater Associates. Ray Dalio is #69 in List Billionaires People In The World...
Prince Alwaleed Bin Talal Alsaud
Prince Alwaleed Bin Talal Alsaud was bornon 7 March 1955 in Riyadh, Saudi Arabia, Saudi Arabia. Prince Alwaleed Bin Talal Alsaud is #71 in List Billionaires People In The World. High-profile Saudi Ara...
Carl Icahn was bornon 16 February 1936 in New York, New York, United States, is Founder, Icahn Capital Management. Carl Icahn is #78 in List Billionaires People In The World. Carl Icahn is one of Wall...
Steve Cohen
Net Worth is $14 Billion
Steve Cohen was bornon 24 May 1949 in Greenwich, Connecticut, United States, is Founder, Point72 Asset Management. Steve Cohen is #113 in List Billionaires People In The World. Steve Cohen oversees Po...
Philip Anschutz
Philip Anschutz was bornon 28 December 1939 in Denver, Colorado, United States. Philip Anschutz is #111 in List Billionaires People In The World. Over five decades Philip Anschutz has built fortunes i...
Stephen Schwarzman
Stephen Schwarzman was bornon 14 February 1947 in New York, New York, United States, is Chairman and CEO, Blackstone Group. Stephen Schwarzman is #119 in List Billionaires People In The World. The son...
Andrew Beal
Andrew Beal was bornon 29 November 1952 in Dallas, Texas, United States. Andrew Beal is #138 in List Billionaires People In The World. Andrew Beal is the founder and chairman of Beal Bank and Beal Ban...
David Tepper
David Tepper was bornon 11 September 1957 in Miami Beach, Florida, United States, is President and Founder, Appaloosa Management. David Tepper is #142 in List Billionaires People In The World. David T...
Graeme Hart
Graeme Hart was bornon 1955 in Auckland, New Zealand, New Zealand. Graeme Hart is #156 in List Billionaires People In The World. New Zealand's perennial richest person, Graeme Hart accumulated a packa...
|
cc/2019-30/en_head_0021.json.gz/line27386
|
__label__wiki
| 0.629541
| 0.629541
|
Noel Gallagher’s daughter asks owners of Oasis-inspired dog kennel to stop breeding pedigrees
Dan Stubbs Jul 31, 2014 4:06 pm BST
Anaïs Gallagher sent letter in collaboration with PETA
Anaïs Gallagher, daughter of Noel Gallagher, has appealed to the Finnish dog breeders who have named their kennel and puppies after Oasis songs to stop breeding dogs.
The 14-year-old, who was recently hired to co-host Friday Download on children’s channel CBBC, sent a letter to the breeders in collaboration with People for the Ethical Treatment of Animals (PETA).
In it, she writes about her concerns over the health of selectively bred dogs, citing her own Boston Terrier’s health problems. She also expresses concern over the number of unwanted dogs that cannot be homed.
She asks the breeders to cease their activities. “You can be a rock’n’roll star for dogs by spaying and neutering your Labrador retrievers and promoting adoption instead,” she writes.
She also tells the kennel’s owner, Ville Kormilainen, that her favourite Oasis album is ‘Definitely Maybe’.
The owners of the Glory Morning kennels have been contacted for a response.
“Dear Mr Kormilainen,
I was happy to read in NME that you’re a big Oasis fan – so am I! Obviously. What’s your favourite album? Mine is ‘Definitely Maybe’. I also read that you breed dogs and want to name your next litter of Labrador retrievers after your fave Oasis songs. I wish you wouldn’t do that.
I love dogs and would do anything for my Boston terrier, Oscar. But after seeing the health problems that Oscar has grown up with ever since he was a puppy, just because he came from a breeder, I am now completely against dog breeding.
Oscar had a cleft palate and was constantly sick. For the first few weeks after we bought him, we had to take him to the vet almost every day for one problem or another. He got sicker and sicker and lost lots of weight until he was so skinny you could see his bones. Mum and I were terrified that he wouldn’t make it. When we took Oscar to see experts at the Royal Veterinary College, they told us his stomach wasn’t connected to his organs properly and he had had this problem since birth because of breeding! Poor Oscar had to have lots of operations just to be able to eat normally.
Since then I’ve learned from my friends at PETA, who are trying to educate people about the problems with pedigrees, that many dog breeds have health issues like Oscar’s. Labrador retrievers are at risk for something called progressive retinal atrophy, which can make them go blind, bulldogs suffer from breathing problems which can become an emergency if they get overheated, and German shepherds are prone to hip dysplasia, which can cripple them. It’s horrible to think about – don’t you agree?
But that’s not the only problem with breeding dogs. In my country, we have a big problem with homeless dogs, and I imagine you do in your country, too. There are millions of sweet, fun-loving dogs all around the world who are living in animal shelters and just waiting for someone to take them home. Whenever people buy a dog from a breeder or a pet shop or even accidentally allow their own dog to have a litter of puppies, they are practically signing a death sentence for a dog in an animal shelter, who will never get to have a home and a family. It breaks my heart to think that dogs are being euthanised just because there aren’t enough good homes for them, while breeders produce more litters. Breeding dogs is wrong as long as we’re still killing animals who don’t have homes.
On behalf of Oscar and all the other wonderful dogs who don’t have anyone to speak up for them, please don’t produce any more litters. You can be a rock’n’roll star for dogs by spaying and neutering your Labrador retrievers and promoting adoption instead.
Anaïs Gallagher (Noel’s daughter)”
Florence + The Machine at BST Hyde Park 2019 Credit: Ben Bentley / NME
“Welcome to the matriarchy, it’s fun!” Florence + The Machine hails female line-up as she headlines BST Hyde Park
Prophets of Rage Credit: Getty Images
Watch Prophets of Rage perform ‘Made With Hate’ for the first time live at Mad Cool festival
Brandon Urie and Billie Joe Armstrong Credit: Getty Images
Panic! At The Disco frontman Brendon Urie has revealed he would “love” to collaborate with Green Day
|
cc/2019-30/en_head_0021.json.gz/line27387
|
__label__cc
| 0.619563
| 0.380437
|
Some sun in the morning with increasing clouds during the afternoon. A stray shower or thunderstorm is possible. High around 90F. Winds WNW at 5 to 10 mph..
Mainly cloudy. A stray shower or thunderstorm is possible. Low 73F. Winds W at 5 to 10 mph.
The Oostanaula River begins where the Conasauga and Coosawattee Rivers merge near Calhoun.
New places on life’s journey
STEVE HUDSON Get Outside Georgia, aa4bw@comcast.net
I like rivers — especially new-to-me rivers I’ve never floated or fished before. Such rivers get harder to find, but one that’s still on the list is the Oostanaula.
The Oostanaula River begins where the Conasauga and Coosawattee rivers merge near Calhoun. It flows south and west for about 50 miles, eventually merging with the Etowah in downtown Rome to form the Coosa River.
There are tales to be told about the Coosa, and one day I’ll tell some of them here. But right now let’s talk about the Oostanaula.
I’d crossed the Oostanaula many times while traversing the far reaches of Highway 140 (yes, the same 140 that’s a rush-hour nightmare in Roswell). The highway crosses the river just east of the community of Armuchee, and a great public boat ramp near the bridge makes river access there easy.
Armuchee, by the way, is pronounced as if it has two R’s — that is, “ar-MUR-chee.” Pronounce it “ar-MUCH-chee” or even “ar-MOO-chee” and you’ll mark yourself an outsider unworthy of knowing the secret handshake. What secret handshake? Wait — forget I said that.
Anyway, every time I drove over that bridge, I’d always think to myself, “One day I’m going to stop and take a look.” But I’d never stopped until a week or so ago.
Here’s how it happened. I’d driven my son the clarinet player to Huntsville, where he would spend the week as part of the faculty at the Tennessee Valley Music Festival. He’s done that for several years now, and driving him over there has become something of a tradition. We have good conversation on the way, and we’ve found a couple of barbecue joints (plus one stellar catfish place) where we like to stop for lunch. I’ll tell you about ’em sometime.
So I dropped Andy off in Huntsville and then turned the car once more toward Alpharetta. It was a quiet drive going back. Huntsville to Scottsboro…Scottsboro to Summerville…then U.S. 27 to Armuchee, where I picked up Highway 140 for the last leg of the trip…driving…driving…and then all of a sudden there it was – the bridge over the Oostanaula.
Should I stop? Sure. Looking at rivers is always good for you. Besides, I had the spinning rod in the car. “Who knows?” I said to myself. “I might even catch a fish.”
Yeah, I know. I really shouldn’t have taken the time. We were in the midst of moving, you see — “downsizing,” some have optimistically called it, but it just made me a little wistful. Moving does that to you.
“Maybe a quick stop would be good for the soul,” said the voice in my head, “for there is therapeutic value in stopping to look at rivers.”
But another voice chimed in right away. “What about,” it said, “those nine million empty moving boxes waiting for you at home?”
I considered the options and decided I liked the first voice better. Then the river called again, and that was that.
I pulled into the boat ramp parking area. It was almost empty. I picked a spot near the ramp and then walked down to the water. The river was beautiful. How had I missed it all these years?
I recalled reading that one popular float on the Oostanaula starts at that very spot and ends at Ridge Ferry Park in Rome, about 13 river miles (roughly 6 hours) downriver. I’d heard that the fishing could be pretty good, too. There was even a chance of encountering a lake sturgeon, a prehistoric-looking monster of a fish that’s making a comeback thanks to Georgia’s Department of Natural Resources. If you should catch one, return it to the water right away. Let DNR know about it, too; they’ll use your report to help fine-tune the sturgeon reintroduction program.
All that thought of fish got me thinking about fishing again, so I hiked back up the ramp to the van to retrieve my spinning rod. I’d have time for a cast or two, wouldn’t I? Sure. But then I realized I’d left all my spinning lures at home.
No worries. I’ll just walk back down the ramp and spend a few more minutes looking at the river.
So down the ramp I went — and then what should I see lying in the mud at the end of the concrete but a four-inch-long crankbait.
“Aha!” I said. “Fate has spoken!”
I picked up the little lure, rinsed it off, and deemed it fully functional. Then I hiked back up the ramp again to retrieve the spinning rod. I tied that crankbait to the line, checked my knot, and then made my way (for the third time) back down the ramp to the river, where I made a cast. The lure sailed smoothly through the air and plopped onto the water. I began the retrieve.
I’d like to tell you that it was immediately hammered by a huge ol’ bass. But it wasn’t — not then, or on the next cast, or on any of the other dozen or so casts I made. No fish at all, in fact. But it still felt good to cast. It always does.
Pretty soon, reinvigorated, I knew it was time to go. Boxes really were calling. So I hiked up the ramp again, tucked the rod back into the van, and headed east toward the trusty old house that was home, but only for another couple of days.
A new house awaited.
New houses, like new rivers, are adventures waiting to unfold. The “house” adventure was about to hit full-force — closings, lawyers, movers, boxes and all the rest.
But since we’re in the new house as I write this, I guess that means we survived.
Sure, I’m surrounded by cardboard and chaos. There’s a ton of unpacking to do.
But the kayak is tucked safely away in the new garage, ready to go — and pretty soon, even I (the most intrepid of unpackers) will need to take a break.
Yeah. And when I do, the Oostanaula will still be calling my name.
Oostanaula River
Spinning Rod
Follow Steve Hudson
|
cc/2019-30/en_head_0021.json.gz/line27388
|
__label__wiki
| 0.550513
| 0.550513
|
Legal scholarship
Norton Rose Fulbright launches technology consulting practice
Press release - Transform | March 2019
Global law firm Norton Rose Fulbright has broadened its offering to clients with the launch of a technology consulting practice.
Computer scientist and professor Peter McBurney has been appointed to lead the new practice, which will provide technical expertise to help clients take full advantage of new and emerging disruptive technologies, such as Artificial Intelligence (AI), Distributed Ledger Technologies (DLT) including blockchain, and cryptocurrencies. The new practice will work with clients across all sectors globally on projects such as the redesign of business processes to adopt new technologies; the evaluation and design of proposed technologies for new business ventures such as new DLT platforms; and the development of AI, DLT and cryptocurrency strategies.
Sean Murphy, Norton Rose Fulbright global head of FinTech, commented:
“We are delighted to work with Peter McBurney who has exceptional technical knowledge that corresponds with our clients’ current and future priorities. By combining deep technological expertise with our extensive, multidisciplinary legal and regulatory experience, we can advise on all aspects of technology adoption across all sectors around the world.”
Peter McBurney commented:
“Disruptive technologies have an unprecedented impact on information-intensive industries, particularly those subject to heavy regulation such as financial services. The adoption of these technologies is expected to lead to major redesigns of business processes, particularly in sectors relying on inter-company collaboration across a value chain. The firm’s new technology consulting practice is dedicated to helping financial institutions, corporations and start-ups develop and implement these new businesses processes.”
Peter is a Professor of Computer Science and former head of department in the Department of Information at King’s College London. He is a member of the Academic Advisory Council of the FCA, advising on the use of AI and DLT in financial regulation.
Norton Rose Fulbright’s Technology Consulting Practice is one of a number of new initiatives created as the firm continues its focus on client value, technology and innovation. These include NRF Transform, the firm’s global change and innovation program; The Institute, an exclusive client knowledge site; Regulatory Compliance Consulting, providing risk and compliance advisory services to clients; Risk Advisory, leveraging industry expertise to provide legal and regulatory guidance; NRF Parker, a chatbot powered by artificial intelligence designed and built by Norton Rose Fulbright in-house technology experts.
Heledd Phelps Brown, Head of PR, EMEA
Tel +44 20 7444 2890; Mob: +44 77 0297 1352
heledd.phelps-brown@nortonrosefulbright.com
Notes for editors:
Norton Rose Fulbright is a global law firm providing the world’s preeminent corporations and financial institutions with a full business law service. The firm has more than 4,000 lawyers and other legal staff based in Europe, the United States, Canada, Latin America, Asia, Australia, Africa and the Middle East.
Recognized for its industry focus, Norton Rose Fulbright is strong across all the key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare. Through its global risk advisory group, the firm leverages its industry experience with its knowledge of legal, regulatory, compliance and governance issues to provide clients with practical solutions to the legal and regulatory risks facing their businesses.
Norton Rose Fulbright operates in accordance with its global business principles of quality, unity and integrity, aiming to provide the highest possible standard of legal service in each of its offices and to maintain that level of quality at every point of contact.
Norton Rose Fulbright Verein, a Swiss verein, helps coordinate the activities of Norton Rose Fulbright members but does not itself provide legal services to clients. Norton Rose Fulbright has offices in more than 50 cities worldwide, including London, Houston, New York, Toronto, Mexico City, Hong Kong, Sydney and Johannesburg. For more information, see nortonrosefulbright.com/legal-notices.
Peter McBurney
|
cc/2019-30/en_head_0021.json.gz/line27389
|
__label__wiki
| 0.927845
| 0.927845
|
Carnival Corp. Agrees To $20 Million Fine For Pollution Violations Executives with Carnival Corporation, the world's largest cruise line, were in court explaining why its ships continue to dump plastics and other pollutants into waters in the Caribbean and Alaska.
Carnival Corp. Agrees To $20 Million Fine For Pollution Violations
Carnival Corp. Agrees To $20 Million Fine For Pollution Violations 3:43
Executives with Carnival Corporation, the world's largest cruise line, were in court explaining why its ships continue to dump plastics and other pollutants into waters in the Caribbean and Alaska.
RACHEL MARTIN, HOST:
A remarkable scene unfolded in a Miami courtroom - the head of the world's largest cruise line company, Carnival, stood before a federal judge and pleaded guilty to six counts of violating probation. Carnival has been on probation for more than two years for environmental violations, including dumping plastics and oily water off Alaska and in the Caribbean. NPR's Greg Allen was in the courtroom yesterday and joins us now. Tell me more, Greg, about what Carnival is accused of.
GREG ALLEN, BYLINE: Hi, Rachel. Yeah. Well, Carnival's had a long history of violations of dumping plastic trash and oily discharge from its ships. Violations go back to 1993, and they've continued in recent years. Two years ago, Carnival agreed to pay a $40-million fine after one of its ships on the Princess line was caught dumping oily water, and also, they were caught falsifying their books. Judge Seitz placed the company on probation - this is Judge Patricia Seitz in Miami. She told them to clean up its act, and she ordered ongoing audits, inspections to make sure the company's ships comply with environmental laws.
But a court-appointed monitor who's conducting these inspections found that Carnival had actually created a special team that would go to ships beforehand that were due to be inspected and correct things before inspectors arrived. The court also found other instances that they - the company was falsifying records and dumping plastics in the ocean. So all of which convinced the judge yesterday that the company was more interested in protecting its bottom line than the environment, and she said so in court.
MARTIN: What was it like in the courtroom?
ALLEN: Well, the judge is very frustrated with the company - had, you know, brought all the company officials there. We had more than a dozen company officials, including the CEO Arnold Donald, the chairman Micky Arison. Ultimately, the judge approved an agreement by which Carnival pleads guilty to violating probation and pays a $20-million fine. The company will also change its corporate structure to make compliance with environmental regulations a priority, perhaps for the first time. And it says it's going to change how it deals with plastics and food waste, by kind of creating these teams that will go and kind of create whole new systems on the ships. They're going to move to reduce single-use plastics on its ships, they say.
And all this is going to be subject to court supervision. And to convince the judge it's serious this time, Carnival says it's going to have a compliance plan in place by mid-August. And they're going to pay a fine - they've agreed to pay a fine of more than $1 million a day if the plan is not ready by then.
MARTIN: I mean, does that mean they have to pull all their cruise-liners to make those changes?
ALLEN: Well, it's interesting because at at one point, the judge - at an earlier hearing, the judge was so frustrated with Carnival and the fact that they'd continued to violate these - this probation order that she threatened to block Carnival from docking at U.S. ports. She said she was hearing from passengers who are worried about their - their cruises would be canceled.
I think it was all really a sign of the frustration of Judge Patricia Seitz, who's been hearing this case for two years. In court, she says she became convinced that the employees of Carnival wanted to do the right thing on the environment, but it was the company itself, the top executives - including its CEO and the chairman of the board - that she became convinced weren't serious about complying with environmental laws. So that's why she wanted them all there yesterday, and they were.
MARTIN: So what's the next step here?
ALLEN: Well, now they've got this agreement in place. They're going to come up with this plan. I think the judge really wanted to talk to the company's CEO, Arnold Donald, and she lectured him on the need, as she said, to be a steward of the environment. But there are skeptics, like Kendra Ulrich. She's an environmentalist with a group called Stand.earth. Here's what she had to say about it.
KENDRA ULRICH: It is in no way acceptable for a corporate actor to continually get a slap on the wrist and let off the hook. Clearly, these environmental compliance programs are not working.
ALLEN: And Judge Seitz, still skeptical herself, but she says there will be continued court supervision.
MARTIN: All right. NPR's Greg Allen, reporting from Miami. Greg, thanks. We appreciate it.
ALLEN: You're welcome.
(SOUNDBITE OF SIGNAL HILL'S "LLANGOLLEN")
|
cc/2019-30/en_head_0021.json.gz/line27390
|
__label__cc
| 0.548738
| 0.451262
|
CONTEXT New York
Date(s): Mar 3, 2016 – Mar 6, 2016
Location: 299 South Street, New York, NY, United States
CONTEXT New York will take place March 3-6, 2016, at the fair’s Presenting Sponsor and venue Pier 36, located on the East River at 299 South Street.
Like its hugely successful sister fair CONTEXT Art Miami, which launched during Miami Art Week in 2012, CONTEXT New York’s open atmosphere will create meaningful dialogue between artists, galleries and collectors while providing the ultimate platform for the presentation of mid-career, emergent and cutting-edge talent by emerging and established galleries. The fair will feature eighty international galleries, vetted by the CONTEXT Selection Committee. CONTEXT New York will provide a unique and alternative opportunity for leading primary dealers and their artists to be marketed and promoted internationally during one of the most important weeks for contemporary art in New York City.
Further details.
|
cc/2019-30/en_head_0021.json.gz/line27394
|
__label__cc
| 0.550352
| 0.449648
|
Research Bulletin: The Popularity of Older Male and Female Actors
There exists a lay belief that aging is particularly hard on female film actors in comparison to their male counterparts. Male actors, it seems, continue to have successful careers as they get older whereas female actors struggle to find work once they reach a certain age. But is there empirical evidence to support this belief? Christa Taylor, James Kaufman, and Matt Riggs from California State University San Bernadino examined this question by looking at data from the popular website IMDb (i.e., the Internet Movie Database). In order to gauge an actor’s popularity, they recorded IMDb’s “Starmeter” rankings (based on page views by the public) for 347 different actors (153 males, 194 females), along with that actor’s age and numerous other aspects of the person’s career (e.g., roles, awards). What they found was that age predicted a lower ranking of popularity even after controlling for various other factors. The same was true of gender, with female actors being less popular than male ones, even after controlling for the influence of age. Lastly, controlling for both age and gender, critical acclaim predicted greater popularity. In a subsequent analysis, they found that the popularity of both male and female actors declined with age, but that the popularity of female actors did not decline more rapidly than male actors. In other words, it did not appear to be the case that aging did not detrimentally affect the popularity female actors more than male actors. This is a fascinating result and a good demonstration of how interesting data need not be collected in a laboratory, but can often be found from readily available public resources. A slightly separate and equally interesting question might be whether the number and profile of film roles decreases more rapidly for female actors relative to males, even though public popularity does not appear to be differentially affected by aging.
Taylor, C. L., Kaufman, J. C., & Riggs, M. (2012). Equally discarded?: The influence of age and gender on the popularity of screen actors. Empirical Studies of the Arts, 30, 215-231.
Labels: Research Bulletins
|
cc/2019-30/en_head_0021.json.gz/line27396
|
__label__cc
| 0.528888
| 0.471112
|
Although TG Sheppard is the bonafide country music legend of this dynamic duo, the first time I heard Kelly Lang sing, I wrote that she displayed “a depth of passion that is most often associated with only legendary singers.” There is no doubt in my mind that if the beautiful, brilliant, Lang hadn't put her career on hold for a decade or so, to devote full time to being a mother to her two daughters, she too would have already earned the title of legend.
When you put two legends on the same album, you set the bar high, very high. Luckily for music lovers, TG and his incredibly gifted wife don't disappoint. Further proof of their legend status is how effortlessly they are able to take some of the most iconic songs of all time, recorded by some of the most recognizable artists in music history, and make them sound like you are hearing them for the first time.
The entire album is enjoyable from start to finish and because all of the songs are sung so well, choosing a favorite wasn't possible. However, I will confess to hitting the replay button several times on “Every Time Two Fools Collide”, “After The Fire Is Gone”, and “Just You And I”.
This album was made at the urging of the fans, ultimately for the fans. On the liner notes they say, “Hope you enjoy the songs herein as much a we've enjoyed recording them.” Well now, I'd say that's a given, so let's start urging for an encore. Since they are both prolific songwriters perhaps the next album should be of songs only they've written. And if they ever decide to do a boxed set they could include all twenty-one of the number one hits Sheppard has had during the course of his career, to date. Yep, that ol' bar was high, but it turns out that Sheppard and Lang, together, eased on over it with plenty of room to spare. That kind of talent is a step beyond legend, it falls under the title of genius.
www.kellylang.com
www.TGSheppard.com
|
cc/2019-30/en_head_0021.json.gz/line27399
|
__label__wiki
| 0.991183
| 0.991183
|
Archives|The Memo That Rehnquist Wrote and Had to Disown
The Memo That Rehnquist Wrote and Had to Disown
By ADAM LIPTAK SEPT. 11, 2005
AT his confirmation hearings this week, Judge John G. Roberts Jr. will be asked to respond to questions about documents he wrote as a young government lawyer.
The questions are sure to be sharp, but at least he can take solace in the fact that his mentor, and the man whom he seeks to replace, the late Chief Justice William H. Rehnquist, endured two rocky confirmation hearings, for associate justice in 1971 and for chief justice in 1986. They were marked by accusations of racial insensitivity and ethical impropriety, based in part on Mr. Rehnquist's writings as a young lawyer.
Indeed, if anything, his confirmation hearings provide lessons in how to respond to accusations far more charged than anything Judge Roberts is likely to face. And Mr. Rehnquist's hearings also show how much the coaching and prepping of nominees have changed.
In 1971, Newsweek magazine revealed that in 1952, Mr. Rehnquist, then a law clerk to Justice Robert H. Jackson, prepared a memorandum called "A Random Thought on the Segregation Cases." It was written in the first person and bore Mr. Rehnquist's initials. It urged Justice Jackson to reject arguments made by lawyers in Brown v. Board of Education, the landmark school desegregation case, and to uphold Plessy v. Ferguson, the 1896 Supreme Court decision holding that "separate but equal" facilities were constitutional.
Mr. Rehnquist wrote, "I realize that this is an unpopular and unhumanitarian position for which I have been excoriated by 'liberal' colleagues, but I think Plessy v. Ferguson was right and should be re-affirmed."
Justice Jackson ultimately joined the unanimous Brown decision, handed down in 1954, but 17 years later Mr. Rehnquist's memo created a storm. As opposition to Mr. Rehnquist mounted during the Senate debates, he submitted a letter to the chairman of the judiciary committee. "I believe that the memorandum was prepared by me as a statement of Justice Jackson's tentative views for his own use," Mr. Rehnquist wrote.
Richard Kluger, in his history of the Brown case, "Simple Justice," wrote that substantial internal and external evidence cast doubt on Mr. Rehnquist's account. For instance, Justice Jackson's secretary, Elsie Douglas, told Newsweek that Mr. Rehnquist's account was "incredible on its face."
Justice Rehnquist repeated his statements at his 1986 hearings. "The bald statement that Plessy was right and should be reaffirmed," he said, "was not an accurate reflection of my own views at the time."
The Brown decision also figured in Justice Rehnquist's discussion of the power of judicial precedent. At the 1971 hearing, Mr. Rehnquist said that the Brown decision deserved special respect, in part because it "has been repeatedly reaffirmed by a changing group of justices."
Today, Arlen Specter, the Republican chairman of the Senate Judiciary Committee, has suggested that Roe v. Wade also deserves special respect. Like Brown, it has been reaffirmed by other justices, notably in a 1992 decision known as Casey. Senator Specter said Roe has become a "superprecedent," that is, a decision reaffirmed by the court with new members.
Many legal scholars find that concept novel and puzzling, and Judge Roberts will surely be asked for his views.
Judge Roberts benefits from having been closely vetted and rigorously prepared. John W. Dean, who was White House counsel during the first Rehnquist nomination, said Mr. Rehnquist had neither of those advantages, leaving him open to surprises.
"What really caught Rehnquist cold," Mr. Dean continued, "was when they found out about his activities in confronting black and Hispanic voters in Phoenix" in the 1960's.
Mr. Rehnquist denied that he had worked as a poll watcher or harassed voters, but said he had led a Republican lawyers' committee that advised challengers of their rights.
In the end, it could be asked, what was gained by this examination of Mr. Rehnquist's past? Were the Rehnquist confirmation hearings indicative of anything?
Mark Tushnet, a law professor at Georgetown and the author of a book on the Rehnquist court, said that small pieces of evidence can collectively help bring a nominee into focus.
"When you put the memo together with his voting registration challenges and with his opposition to a local antidiscrimination ordinance in Phoenix," Professor Tushnet said, "you get a picture of somebody for whom issues of racial justice and nondiscrimination were not a high priority."
Cass Sunstein, a law professor at the University of Chicago, said that it would be a mistake to overemphasize the controversies that emerged at the Rehnquist hearings.
"Rehnquist really was treated unfairly," Professor Sunstein said. "A person is a career, not a moment."
Judge Roberts, in any event, has stayed away from retail politics. His life has been almost solely in the law, and his task at his own hearings will be to find the sweet spot of saying just enough to show his temperament, competence and fidelity to fundamental constitutional principles but not so much that he seems to prejudge particular cases or invites political controversy.
And in the end, Judge Roberts can take solace from the past. Although Democrats like Senator Birch Bayh of Indiana said the Rehnquist letter raised "most serious questions as to Mr. Rehnquist's candor," Mr. Rehnquist was, after all, twice confirmed.
A version of this article appears in print on September 11, 2005, on Page 4004005 of the National edition with the headline: THE NATION; The Memo That Rehnquist Wrote and Had to Disown. Order Reprints| Today's Paper|Subscribe
|
cc/2019-30/en_head_0021.json.gz/line27401
|
__label__wiki
| 0.616596
| 0.616596
|
David directs the Frontier Centre’s Saskatchewan office. He holds degrees in Electrical Engineering and Philosophy from the University of Auckland. In his first two years working for the Frontier Centre, David has carried out extensive media work, presenting policy analysis through local and national television, newspapers, and radio. His policy columns have been published in newspapers in every province as well as the Globe and Mail and the National Post. David has produced policy research papers on telecommunications privatization, education, environmental policy, fiscal policy, poverty, and taxi deregulation. However his major project with the Frontier Centre is the annual Local Government Performance Index (LGPI). The inaugural LGPI was released in November 2007 and comes at a time when municipal accounting standards in Canada must improve if the municipal government sector is to reach its potential as an economic growth engine for Canada.
Canada – putting the economy first
By David Seymour
Of all the arguments for adopting a nationwide carbon emission reduction policy such as the Emissions Trading Scheme, one of the most peculiar runs something like this: New Zealand should adopt emission reduction legislation even if it wouldn’t make the slightest difference to the climate because other countries will punish us with trade barriers if we don’t.
Helen Clark made this argument in a leadership debate last election. Colin James recently opined similarly (NZ Herald) as did Rod Oram (see >>). On and on they all go.
The first thing to do when faced with a threat is to ask how real it is. More specifically, would other countries really have blocked New Zealand exports or stop patronising our tourism industry if we hadn’t adopted an Emissions Trading Scheme or similar? Or could it be that those who present the threat within New Zealand are bluffing, exaggerating the threat in order to advance an agenda that has nothing to do with New Zealand’s trade relationships with other countries?
As I’m currently exiled in Canada, I’d like to share a few observations of how the Great White North has dealt with the international politics of climate change. Perhaps the quickest way is to describe a cartoon circulating in Canadian papers this week of the Prime Minister bending over to give a gesture Tame Iti would be proud of.
Symbols aside, it is worth looking at the path Canada has taken over the past few years with respect to carbon emissions policy.
Canada is approximately fifty per cent wealthier than New Zealand on a GDP per capita basis, and on some days temperatures in some cities are colder than those at the North Pole. Unsurprisingly, Canadians burn a lot of fossil fuels. Putting aside a few small oil-rich nations, only the United States and Australia emitted more greenhouse gases per capita than Canada did in 2005. Canada’s 22.6 tonnes per capita was twenty per cent higher than New Zealand’s 18.8, and by 2007 they were thirty-four per cent above their Kyoto target.
Anybody who supposes they might be sorry for it is in for a rude shock. Only last week did Prime Minister Stephen Harper agree to go to Copenhagen next month, and in case anybody was to take this as an act of contrition, his Minister for the Environment had this to say: “One thing the Conservative government will never do is fly over to Copenhagen, pull a target out of the air that is ill-suited to our industrial base, to our geography and agree to damaging the Canadian economy.”
Tough talk from the unfailingly polite Canadians. Unfortunately it’s the kind that we in God’s own country, the country which led the world with votes for women, a principled stand on nuclear weapons, and unilateral free trade can only hear wistfully today as or own environment minister panders along with waffle like “[Adopting the Emissions Trading Scheme] is a balanced and responsible approach to a very difficult and complex issue.”
Of course you might expect that such intransigence would be punished somehow? Surely Canada is now facing the wrath of a disappointed international community? To be fair a “coalition of scientists” did ask for Canada to be suspended from the Commonwealth, but nobody is taking them seriously, and we all know what a bombshell that sanction was for Robert Mugabe.
In reality, Canada has not suffered trade problems due to its position on climate change policy. President Obama has mused about Canada’s “dirty oil” extracted from oil sands on the Canadian prairies, but as energy security becomes a critical issue in the United States, its peaceful neighbour can probably afford to remain calm as one of the few reliable and stable energy suppliers Americans have.
Meanwhile, Canada has shown that a commitment to free trade is the most important factor in getting trade deals done. With a trained economist as a Prime Minster, Canada has brought agreements with four new countries into effect over the past two years, and has a further eleven currently pending. Since 2003, Canadian exports have risen twenty per cent, hardly the sign of a country that is becoming an economic leper in the international community.
Perhaps the true difference in the rhetoric and behaviour of Canadian and New Zealand politicians is the political will of the two countries’ voters. In Canada’s latest election, the Liberal party practically signed its own death warrant by promoting as its main platform “green shift” policy that would shift a large part of the Federal Governments’ tax burden onto carbon emission behaviour.
Although it was once the natural party of government in Canada,
the complexity of its scheme, its hapless leader, an economic decline and widespread suspicion of any carbon reducing policy meant that Canadians sent the Liberals to a record low in the polls. As one Western Canadian commentator wrote “green shift (Ed. note: Please stop leaving the “f” out of that term.)”
In New Zealand, the level of opposition to such policies has been too low, perhaps muffled by the national narrative that our “greenness” is one of our distinguishing characteristics. By comparison, our “conservative” government has spent most of its time trying to ignore the demands of the ACT party, whose position is similar to that of the Canadian Conservatives. Whether you believe that politicians are inevitably followers of public opinion (e.g. Helen Clark) or should be leaders who do what they think is right and take the consequences at election time (e.g. Ruth Richardson), there is clearly much that the New Zealand body politic can learn from Canada.
Being a world leader is one thing, but being the only “conservative” leader “pushing centrally-planned economies in the name of saving the earth,” as the Wall Street Journal recently pointed out, is not helpful, Mr. Key. New Zealanders would be better served by leadership that politely puts New Zealand first. Perhaps more of us need to politely ask for it.
Colin James: http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1objectid=10544814pnum=2
Nick Smith: http://www.national.org.nz/Article.aspx?articleId=31461
Countries by Emissions: http://en.wikipedia.org/wiki/List_of_countries_by_carbon_dioxide_emissions
Countries by per capita Emissions: http://en.wikipedia.org/wiki/List_of_countries_by_greenhouse_gas_emissions_per_capita
Guardian Article on Kyoto target and commonwealth suspension: http://en.wikipedia.org/wiki/List_of_countries_by_greenhouse_gas_emissions_per_capita
Canadian FTAs: http://www.international.gc.ca rade-agreements-accords-commerciaux/agr-acc/index.aspx
Canadian Trade Stats: http://www.statcan.gc.ca/tables-tableaux/sum-som/l01/cst01/gblec02a-eng.htm
|
cc/2019-30/en_head_0021.json.gz/line27402
|
__label__wiki
| 0.539538
| 0.539538
|
Rt Hon. David Cameron MP Prime Minister
David Cameron is the Member of Parliament for Witney and Prime Minister and Leader of the Conservative Party. About David Cameron
By Rt Hon. David Cameron MP Prime Minister
It’s great to be here at this outstanding school, Ninestiles School. Your inspiring teachers and your commitment to British values means you are not just achieving outstanding academic success, but you are building a shared community where children of many faiths and backgrounds learn not just with each other, but from each other too.
And that goes right to the heart of what I want to talk about today.
I said on the steps of Downing Street that this would be a ‘one nation’ government, bringing our country together.
Today, I want to talk about a vital element of that. How together we defeat extremism and at the same time build a stronger, more cohesive society.
My starting point is this.
Over generations, we have built something extraordinary in Britain – a successful multi-racial, multi-faith democracy. It’s open, diverse, welcoming – these characteristics are as British as queuing and talking about the weather.
It is here in Britain where different people, from different backgrounds, who follow different religions and different customs don’t just rub alongside each other but are relatives and friends; husbands, wives, cousins, neighbours and colleagues.
It is here in Britain where in one or two generations people can come with nothing and rise as high as their talent allows.
It is here in Britain where success is achieved not in spite of our diversity, but because of our diversity.
So as we talk about the threat of extremism and the challenge of integration, we should not do our country down – we are, without a shadow of doubt, a beacon to the world.
And as we debate these issues, neither should we demonise people of particular backgrounds. Every one of the communities that has come to call our country home has made Britain a better place. And because the focus of my remarks today is on tackling Islamist extremism – not Islam the religion – let me say this.
I know what a profound contribution Muslims from all backgrounds and denominations are making in every sphere of our society, proud to be both British and Muslim, without conflict or contradiction.
And I know something else: I know too how much you hate the extremists who are seeking to divide our communities and how you loathe that damage they do.
As Prime Minister, I want to work with you to confront and defeat this poison. Today, I want to set out how. I want to explain what I believe we need to do as a country to defeat this extremism, and help to strengthen our multi-racial, multi-faith democracy. Jihadi John, or Mohammed Emwazi, is one of the ‘Five Brits a week’ who travel to fight for Isis Jihadi John, or Mohammed Emwazi, is one of the ‘Five Brits a week’ who travel to fight for Isis
Roots of the problem
It begins – it must begin – by understanding the threat we face and why we face it. What we are fighting, in Islamist extremism, is an ideology. It is an extreme doctrine.
And like any extreme doctrine, it is subversive. At its furthest end it seeks to destroy nation-states to invent its own barbaric realm. And it often backs violence to achieve this aim – mostly violence against fellow Muslims – who don’t subscribe to its sick worldview.
But you don’t have to support violence to subscribe to certain intolerant ideas which create a climate in which extremists can flourish.
Ideas which are hostile to basic liberal values such as democracy, freedom and sexual equality.
Ideas which actively promote discrimination, sectarianism and segregation.
Ideas – like those of the despicable far right – which privilege one identity to the detriment of the rights and freedoms of others.
And ideas also based on conspiracy: that Jews exercise malevolent power; or that Western powers, in concert with Israel, are deliberately humiliating Muslims, because they aim to destroy Islam. In this warped worldview, such conclusions are reached – that 9/11 was actually inspired by Mossad to provoke the invasion of Afghanistan; that British security services knew about 7/7, but didn’t do anything about it because they wanted to provoke an anti-Muslim backlash.
And like so many ideologies that have existed before – whether fascist or communist – many people, especially young people, are being drawn to it. We need to understand why it is proving so attractive. CCTV still of 15-year-old Amira Abase, left, Kadiza Sultana,16, center, and Shamima Begum, 15, walk through Gatwick airport, south of London, before catching their flight to Turkey. The three teenage girls left the country in a suspected bid to travel to Syria to join the Islamic State extremist group CCTV still of 15-year-old Amira Abase, left, Kadiza Sultana,16, center, and Shamima Begum, 15, on their way to join Isis in Syria
Some argue it’s because of historic injustices and recent wars, or because of poverty and hardship. This argument, what I call the grievance justification, must be challenged.
So when people say “it’s because of the involvement in the Iraq War that people are attacking the West”, we should remind them: 9/11 – the biggest loss of life of British citizens in a terrorist attack – happened before the Iraq War.
When they say that these are wronged Muslims getting revenge on their Western wrongdoers, let’s remind them: from Kosovo to Somalia, countries like Britain have stepped in to save Muslim people from massacres – it’s groups like ISIL, Al Qaeda and Boko Haram that are the ones murdering Muslims.
Now others might say: it’s because terrorists are driven to their actions by poverty. But that ignores the fact that many of these terrorists have had the full advantages of prosperous families or a Western university education.
Now let me be clear, I am not saying these issues aren’t important. But let’s not delude ourselves. We could deal with all these issues – and some people in our country and elsewhere would still be drawn to Islamist extremism.
No – we must be clear. The root cause of the threat we face is the extremist ideology itself.
And I would argue that young people are drawn to it for 4 main reasons.
One – like any extreme doctrine, it can seem energising, especially to young people. They are watching videos that eulogise ISIL as a pioneering state taking on the world, that makes celebrities of violent murderers. So people today don’t just have a cause in Islamist extremism; iin ISIL, they now have its living and breathing expression. Isis fighters celebrating in Fallujah, which the militants took in 2014 Isis fighters celebrating in Fallujah, which the militants took in 2014
Two – you don’t have to believe in barbaric violence to be drawn to the ideology. No-one becomes a terrorist from a standing start. It starts with a process of radicalisation. When you look in detail at the backgrounds of those convicted of terrorist offences, it is clear that many of them were first influenced by what some would call non-violent extremists.
It may begin with hearing about the so-called Jewish conspiracy and then develop into hostility to the West and fundamental liberal values, before finally becoming a cultish attachment to death. Put another way, the extremist world view is the gateway, and violence is the ultimate destination.
Three: the adherents of this ideology are overpowering other voices within Muslim debate, especially those trying to challenge it. There are so many strong, positive Muslim voices that are being drowned out.
Ask yourself, how is it possible that when young teenagers leave their London homes to fight for ISIL, the debate all too often focuses on whether the security services are to blame? And how can it be that after the tragic events at Charlie Hebdo in Paris, weeks were spent discussing the limits of free speech and satire, rather than whether terrorists should be executing people full stop?
When we allow the extremists to set the terms of the debate in this way, is it any wonder that people are attracted to this ideology?
Four: there is also the question of identity.
For all our successes as multi-racial, multi-faith democracy, we have to confront a tragic truth that there are people born and raised in this country who don’t really identify with Britain – and who feel little or no attachment to other people here. Indeed, there is a danger in some of our communities that you can go your whole life and have little to do with people from other faiths and backgrounds. The town of Dewsbury in West Yorkshire, the home of Mohammad Sidique Khan, the ringleader of the four suicide bombers that attacked London on July 7, 2005 The town of Dewsbury in West Yorkshire, the home of Mohammad Sidique Khan, the ringleader of the four suicide bombers that attacked London on July 7, 2005
So when groups like ISIL seek to rally our young people to their poisonous cause, it can offer them a sense of belonging that they can lack here at home, leaving them more susceptible to radicalisation and even violence against other British people to whom they feel no real allegiance.
So this is what we face – a radical ideology – that is not just subversive, but can seem exciting; one that has often sucked people in from non-violence to violence; one that is overpowering moderate voices within the debate and one which can gain traction because of issues of identity and failures of integration.
So we have to answer each 1 of these 4 points. If we do that, the right approach for defeating this extremism will follow.
In the autumn, we will publish our Counter-Extremism Strategy, setting out in detail what we will do to counter this threat. But today I want to set out the principles that we will adopt.
Counter-ideology
First, any strategy to defeat extremism must confront, head on, the extreme ideology that underpins it. We must take its component parts to pieces – the cultish worldview, the conspiracy theories, and yes, the so-called glamorous parts of it as well.
In doing so, let’s not forget our strongest weapon: our own liberal values. We should expose their extremism for what it is – a belief system that glorifies violence and subjugates its people – not least Muslim people.
We should contrast their bigotry, aggression and theocracy with our values. We have, in our country, a very clear creed and we need to promote it much more confidently. Wherever we are from, whatever our background, whatever our religion, there are things we share together.
We are all British. We respect democracy and the rule of law. We believe in freedom of speech, freedom of the press, freedom of worship, equal rights regardless of race, sex, sexuality or faith.
We believe in respecting different faiths but also expecting those faiths to support the British way of life. These are British values. And are underpinned by distinct British institutions. Our freedom comes from our Parliamentary democracy. The rule of law exists because of our independent judiciary. This is the home that we are building together.
Whether you are Muslim, Hindu, Jewish, Christian or Sikh, whether you were born here or born abroad, we can all feel part of this country – and we must now all come together and stand up for our values with confidence and pride.
And as we do so, we should together challenge the ludicrous conspiracy theories of the extremists. The world is not conspiring against Islam; the security services aren’t behind terrorist attacks; our new Prevent duty for schools is not about criminalising or spying on Muslim children. This is paranoia in the extreme.
In fact that duty will empower parents and teachers to protect children from all forms of extremism – whether Islamist or neo-Nazi. A supporter of the far-right English Defence League (EDL) speaks with police during a march in London, 2014 Mr Cameron also took aim at the far-right
We should challenge together the conspiracy theories about our Muslim communities too and I know how much pain these can cause.
We must stand up to those who try to suggest that there is some kind of secret Muslim conspiracy to take over our government, or that Islam and Britain are somehow incompatible.
People who say these things are trying to undermine our shared values and make Muslims feel like they don’t belong here, and we will not let these conspiracy theorists win.
We must also de-glamourise the extremist cause, especially ISIL. This is a group that throws people off buildings, that burns them alive, and as Channel 4’s documentary last week showed, its men rape underage girls, and stone innocent women to death. This isn’t a pioneering movement – it is vicious, brutal, and a fundamentally abhorrent existence.
And here’s my message to any young person here in Britain thinking of going out there:
You won’t be some valued member of a movement. You are cannon fodder for them. They will use you.
If you are a boy, they will brainwash you, strap bombs to your body and blow you up. A British man who called himself Abu Musa al-Britani reportedly blew himself up in a suicide bombing operation for Isis A British man who called himself Abu Musa al-Britani reportedly blew himself up in a suicide bombing operation for Isis
If you are a girl, they will enslave and abuse you.
That is the sick and brutal reality of ISIL.
So when we bring forward our Counter- Extremism Strategy in the autumn, here are the things we will be looking at:
using people who really understand the true nature of what life is like under ISIL to communicate to young and vulnerable people the brutal reality of this ideology
empowering the UK’s Syrian, Iraqi and Kurdish communities, so they can have platforms from which to speak out against the carnage ISIL is conducting in their countries
countering this ideology better on the ground through specific de-radicalisation programmes
I also want to go much further in dealing with this ideology in prison and online. We need to have a total rethink of what we do in our prisons to tackle extremism. And we need our internet companies to go further in helping us identify potential terrorists online.
Many of their commercial models are built around monitoring platforms for personal data, packaging it up and selling it on to third parties. And when it comes to doing what’s right for their business, they are happy to engineer technologies to track our likes and dislikes. But when it comes to doing what’s right in the fight against terrorism, we too often hear that it’s all too difficult.
Well I’m sorry – I just don’t buy that.
They – the internet companies – have shown with the vital work they are doing in clamping down on child abuse images that they can step up when there is a moral imperative to act. And it’s now time for them to do the same to protect their users from the scourge of radicalisation.
And as we do all of this work to counter the Islamist extremist ideology, let’s also recognise that we will have to enter some pretty uncomfortable debates – especially cultural ones. Too often we have lacked the confidence to enforce our values, for fear of causing offence. The failure in the past to confront the horrors of forced marriage I view as a case in point. So is the utter brutality of Female Genital Mutilation (FGM).
It sickens me to think that there were nearly 4,000 cases of FGM reported in our country last year alone. Four thousand cases; think about that. And 11,000 cases of so called honour-based violence over the last 5 years – and that’s just the reported cases.
We need more co-ordinated efforts to drive this out of our society. More prosecutions. No more turning a blind eye on the false basis of cultural sensitivities. Why does this matter so much?
Well, think what passive tolerance says to young British Muslim girls.
We can’t expect them to see the power and liberating force of our values if we don’t stand up for them when they come under attack. So I am glad we have gone further than any government in tackling these appalling crimes. And we are keeping up the pressure on cultural practices that can run directly counter to these vital values.
That’s why the Home Secretary has already announced a review of sharia courts.
It’s why we have said we will toughen the regulations. so schools have to report children who go missing from school rolls mid-year – some of whom, we fear, may be being forced into marriage.
It’s why we legislated for authorities to seize the passports of people they suspect are planning on taking girls abroad for FGM – new protection orders which came into force last Friday and were used immediately by Bedfordshire police to prevent two girls being taken to Africa
And it’s why today I can also announce we will consult on legislating for lifetime anonymity for victims of forced marriage, so that no-one should ever again feel afraid to come forward and report these horrific crimes.
There are other examples of this passive tolerance of practices running totally contrary to our values. The failure of social services, the police and local authorities, to deal with child sex abuse in places like Rotherham was frankly unforgiveable.
And look what happened in Tower Hamlets, in the heart of our capital city. We had political corruption on an epic scale: with voters intimidated and a court adjudicating on accusations of ‘undue spiritual influence’ for the first time since the 19th century. As the judge said: those in authority were too afraid to ‘confront wrongdoing for fear of allegations of racism’.
Well this has got to stop.
We need everyone – government, local authorities, police, schools, all of us – to enforce our values right across the spectrum.
Non-violent and violent
Second, as we counter this ideology, a key part of our strategy must be to tackle both parts of the creed – the non-violent and violent.
This means confronting groups and organisations that may not advocate violence – but which do promote other parts of the extremist narrative.
We’ve got to show that if you say “yes I condemn terror – but the Kuffar are inferior”, or “violence in London isn’t justified, but suicide bombs in Israel are a different matter” – then you too are part of the problem. Unwittingly or not, and in a lot of cases it’s not unwittingly, you are providing succour to those who want to commit, or get others to commit to, violence.
For example, I find it remarkable that some groups say “We don’t support ISIL” as if that alone proves their anti-extremist credentials. And let’s be clear Al-Qaeda don’t support ISIL. So we can’t let the bar sink to that level. Condemning a mass-murdering, child-raping organisation cannot be enough to prove you’re challenging the extremists.
We must demand that people also condemn the wild conspiracy theories, the anti-Semitism, and the sectarianism too. Being tough on this is entirely keeping with our values. We should challenge every part of the hateful ideology spread by neo-Nazis – so why shouldn’t we here?
Government has a key role to play in this. It’s why we ban hate preachers from our country. It’s why we threw out Abu Hamza and Abu Qatada. And it’s why, since my Munich speech in 2011, we have redirected public funds from bodies that promote non-violent extremism to those that don’t. We also need to do more in education.
We undertook an immediate review when it became apparent that extremists had taken over some of our schools in the so-called Trojan Horse scandal here in Birmingham. But I have to be honest here – one year on, although we are making progress, it is not quick enough. It has taken too long to take action against the governors and teachers involved in the scandal and to support the schools affected to turn themselves around.
So as we develop our Counter-Extremism Strategy, I want us to deal with these issues properly, and we will also bring forward further measures to guard against the radicalisation of children in some so-called supplementary schools or tuition centres.
And there’s something else we will do.
We need to put out of action the key extremist influencers who are careful to operate just inside the law, but who clearly detest British society and everything we stand for. These people aren’t just extremists. There are despicable far right groups too. And what links them all is their aim to groom young people and brainwash their minds.
And again let’s be clear who benefits most from us being tough on these non-violent extremists – it’s Muslim families living in fear that their children could be radicalised and run off to Syria, and communities worried about some poisonous far right extremists who are planning to attack your mosque.
So as part of our Extremism Bill, we are going to introduce new narrowly targeted powers to enable us to deal with these facilitators and cult leaders, and stop them peddling their hatred. And we will also work to strengthen Ofcom’s role to enable us to take action against foreign channels that broadcast hate preachers and extremist content.
But confronting non-violent extremism isn’t just about changing laws, it’s about all of us, changing our approach. Take, for example, some of our universities. Now, of course universities are bastions of free speech and incubators of new and challenging ideas. But sometimes they fail to see the creeping extremism on their campuses.
When David Irving goes to a university to deny the Holocaust – university leaders rightly come out and condemn him. They don’t deny his right to speak but they do challenge what he says. But when an Islamist extremist goes there to promote their poisonous ideology, too often university leaders look the other way through a mixture of misguided liberalism and cultural sensitivity.
As I said, this is not about clamping down on free speech. It’s just about applying our shared values uniformly.
And while I am it, I want to say something to the National Union of Students. When you choose to ally yourselves with an organisation like CAGE, which called Jihadi John a “beautiful young man” and told people to “support the jihad” in Iraq and Afghanistan, it really does, in my opinion, shame your organisation and your noble history of campaigning for justice.
We also need the support of families and communities too. The local environment, their families, their peers, their communities, are among the key influencers in any young person’s life. So if they hear parts of the extremist worldview in their home, or their wider community, it will help legitimise it in their minds.
And government will help where it can. I know how worried some people are that their children might turn to this ideology – and even seek to travel to Syria or Iraq.
So I can announce today we are going to introduce a new scheme to enable parents to apply directly to get their child’s passport cancelled to prevent travel.
Together, in partnership, let us protect our young people.
Now the third plank of our strategy is to embolden different voices within the Muslim community. Just as we do not engage with extremist groups and individuals, we’re now going to actively encourage the reforming and moderate Muslim voices. This is a significant shift in government approach – and an important one.
In the past, governments have been too quick to dismiss the religious aspect of Islamist extremism. That is totally understandable. It cannot be said clearly enough: this extremist ideology is not true Islam. I have said it myself many, many times, and it’s absolutely right to do so. And I’ll say it again today.
But simply denying any connection between the religion of Islam and the extremists doesn’t work, because these extremists are self-identifying as Muslims. The fact is from Woolwich to Tunisia, from Ottawa to Bali, these murderers all spout the same twisted narrative, one that claims to be based on a particular faith.
Now it is an exercise in futility to deny that. And more than that, it can be dangerous. To deny it has anything to do with Islam means you disempower the critical reforming voices; the voices that are challenging the fusing of religion and politics; the voices that want to challenge the scriptural basis which extremists claim to be acting on; the voices that are crucial in providing an alternative worldview that could stop a teenager’s slide along the spectrum of extremism.
These reforming voices, they have a tough enough time as it is: the extremists are the ones who have the money, the leaders, the iconography and the propaganda machines. We need to turn the tables.
We can’t stand neutral in this battle of ideas. We have to back those who share our values. So here’s my offer.
If you’re interested in reform; if you want to challenge the extremists in our midst; if you want to build an alternative narrative or if you just want to help protect your kids – we are with you and we will back you – with practical help, with funding, with campaigns, with protection and with political representation.
This should form a key part of our Counter-Extremism Strategy.
And let’s remember that it’s only the extremists who divide people into good Muslims and bad Muslims, by forcing their warped doctrine onto fellow Muslims and telling them that it is the only way to believe. Our new approach is about isolating the extremists from everyone else, so that all our Muslim communities can be free from the poison of Islamist extremism.
Now for my part, I am going to set up a new community engagement forum so I can hear directly from those out there who are challenging extremism. And I also want to issue a challenge to the broadcasters in our country. You are, of course, free to put whoever you want on the airwaves.
But there are a huge number of Muslims in our country who have a proper claim to represent liberal values in local communities – people who run credible charities, community organisations, councillors and MPs – including Labour MPs here in Birmingham – so do consider giving them the platform they deserve.
I know other voices may make for more explosive television – but please exercise your judgement, and do recognise the huge power you have in shaping these debates in a positive way.
Isolation and identity
The fourth and final part of our strategy must be to build a more cohesive society, so more people feel a part of it and are therefore less vulnerable to extremism.
And I want to say this directly to all young people growing up in our country.
I understand that it can be hard being young, and that it can be even harder being young and Muslim, or young and Sikh, or young and black in our country. I know that at times you are grappling with huge issues over your identity, neither feeling a part of the British mainstream nor a part of the culture from your parents’ background.
And I know that for as long as injustice remains – be it with racism, discrimination or sickening Islamophobia – you may feel there is no place for you in Britain. But I want you to know: there is a place for you and I will do everything I can to support you.
The speech I was proudest to give in the election campaign was where I outlined my 2020 vision for our black and minority ethnic communities.
20% more jobs; 20% more university places; a 20% increase in apprenticeship take-up and police and armed forces that are much more representative of the people they serve.
And it’s not just about representation – it’s about being in positions of influence, leadership and political power. That also means more magistrates, more school governors, more Members of Parliament, more councillors, and yes, Cabinet Ministers too.
When we discussed childcare at Cabinet last week (political content), the item was introduced by a Black British son of a single parent – Sam Gyimah, who was backed up by the daughter of Gujarati immigrants from East Africa – Priti Patel – and the first speaker was the son of Pakistani immigrants – Sajid Javid – whose father came to Britain to drive the buses.
So we’ve made good progress in recent years, including I am pleased to say – in my own political party. But we need to go further. Because it comes down to this.
We need young people to understand that here in the UK they can shape the future by being an active part of our great democracy.
Achieve this and more people from ethnic minority backgrounds will feel they have a real stake in our society. And at the same time we need to lift the horizons of some of our most isolated and deprived communities. At the moment we have parts of our country where opportunities remain limited; where language remains a real barrier; where too many women from minority communities remain trapped outside the workforce and where educational attainment is low.
So we need specific action here. So I can announce today I have charged Louise Casey to carry out a review of how to boost opportunity and integration in these communities and bring Britain together as one nation. She will look at issues like how we can ensure people learn English; how we boost employment outcomes, especially for women; how state agencies can work with these communities to properly promote integration and opportunity but also learning lessons from past mistakes – when funding was simply handed over to self-appointed ‘community leaders’ who sometimes used the money in a divisive way.
Louise will provide an interim report early next year. And we will use this report to inform our plans for funding a new wider Cohesive Communities Programme next year, focusing resources on improving integration and extending opportunity in those communities that most need it.
But as well as tackling isolation, there is one other area we must look at if we are to build a truly cohesive society – and that is segregation.
It cannot be right, for example, that people can grow up and go to school and hardly ever come into meaningful contact with people from other backgrounds and faiths. That doesn’t foster a sense of shared belonging and understanding – it can drive people apart. Now let’s be clear that these patterns of segregation in schools or housing are not the fault or responsibility of any particular community. This is a complex problem that dates back decades.
But we do need to recognise the scale of the challenge in some communities. Areas of cities and towns like Bradford or Oldham continue to be some of the most segregated parts of our country. And it’s no coincidence that these can be some of the places where community relations have historically been most tense, where poisonous far right and Islamist extremists desperately try to stoke tension and foster division.
Now let me be clear. I’m not talking about uprooting people from their homes or schools and forcing integration. But I am talking about taking a fresh look at the sort of shared future we want for our young people. In terms of housing, for example, there are parts of our country where segregation has actually increased or stayed deeply entrenched for decades.
So the government needs to start asking searching questions about social housing, to promote integration, to avoid segregated social housing estates where people living there are from the same single minority ethnic background.
Similarly in education, while overall segregation in schooling is declining, in our most divided communities, the education that our young people receive is actually even more segregated than the neighbourhoods they live in.
Now, bussing children to different areas is not the right approach for this country. Nor should we try to dismantle faith schools.
Many faith schools achieve excellent results and I’m the first to support the great education they provide. I chose one for my own children. Today I visited King David’s school, a Jewish school here in Birmingham where the majority of children are from faith backgrounds.
But it is right to look again more broadly at how we can move away from segregated schooling in our most divided communities. We have already said that all new faith academies and free schools must allocate half their places without reference to faith.
But now we’ll go further to incentivise schools in our most divided areas to provide a shared future for our children, whether by sharing the same site and facilities; by more integrated teaching across sites; or by supporting the creation of new integrated free schools in the most segregated areas.
At the same time, we will continue to back National Citizen Service, which is bringing together 16 and 17 year olds from every background and every part of our country.
Because when you see how NCS changes the perceptions that young people have of other communities – I’ve seen it myself many, many times – it should give us all the hope and the confidence that our young people can be the key to bringing our country together.
So this is how I believe we can win the struggle of our generation. Countering the extremist ideology by standing up and promoting our shared British values. Taking on extremism in all its forms – both violent and non-violent.
Empowering those moderate and reforming voices who speak for the vast majority of Muslims that want to reclaim their religion. And addressing the identity crisis that some young people feel by bringing our communities together and extending opportunity to all.
And I hope I have given a sense of how we have all got to contribute to this process. This isn’t an issue for just any one community or any one part of our society – it’s for all of us. Of course, Muslim communities have crucial parts to play. You are part of the solution. But we in government have got to deal with failure, like dealing with extremism in schools.
We need the police to step up and not stand by as crimes take place. We need universities to stand up against extremism; broadcasters to give platforms to different voices; and internet service providers to do their bit too. Together, we can do this.
Britain has never been cowed by fear or hatred or terror.
Our Great British resolve faced down Hitler; it defeated Communism; it saw off the IRA’s assaults on our way of life. Time and again we have stood up to aggression and tyranny.
We have refused to compromise on our values or to give up our way of life. And we shall do so again.
Together we will defeat the extremists and build a stronger and more cohesive country, for our children, our grandchildren and for every generation to come.
Audio: listen to David Cameron’s speech on extremism. This speech was delivered on July 20 2015 and can be read on the Prime Minister’s website HERE.
|
cc/2019-30/en_head_0021.json.gz/line27403
|
__label__wiki
| 0.697369
| 0.697369
|
Home > World
Trump closing Palestinian mission in pro-Israel move
The Washington office of the Palestine Liberation Organization. The US has notified the Palestinians it's closing their mission in Washington. Photo / AP
US President Donald Trump is closing the Palestine Liberation Organisation's mission in Washington, the latest US blow against the Palestinians and an international court during the stalled Mideast peace process.
Some things to know:
The administration's move to close the PLO office in Washington is not directly connected to the Trump White House's opposition to the International Criminal Court, although the administration is trying to link them.
But the Trump administration is trotting out discussions about the two on the same day — Rosh Hashana, the Jewish New Year — in a move certain to inflame the White House's already bitter relations with Palestinians.
On the one hand, the State Department announced Monday that the administration is closing the PLO office in Washington because the Palestinians aren't directly negotiating any peace agreement with Israel. A provision in a US law says the PLO mission must close if the peace process does not go forward.
US President Donald Trump is openly pro-Israel. Photo / AP
Meanwhile, National Security Adviser John Bolton was expected to discuss the US's refusal to recognise the ICC, which the Palestinians are trying to get to prosecute Israel for war crimes.
The administration is trying to draw a connection between the two and pressure Palestinians to talk directly with Israel. State Department spokeswoman Heather Nauert called the two developments "consistent".
"This is yet another affirmation of the Trump administration's policy to collectively punish the Palestinian people," Palestinian official Saeb Erekat said.
It's another strike at a half-century of US policy toward the region. For decades, even amid close US-Israeli ties, Washington had tried to position itself as a neutral party in the vexing Mideast conflict, willing to call out both sides when they take steps seen as contrary to the pursuit of peace.
Several US presidents in both parties have tried to broker a peace accord without success. The two-state solution envisions an independent Palestinian state alongside Israel, with the boundaries negotiated in talks between the parties.
The US does not currently recognise the Palestinian territories as an independent state, though the UN General Assembly overwhelmingly voted in 2012 to recognise Palestine as a "non-member observer state".
Closing the PLO mission in Washington almost certainly will stiffen the Palestinians' opposition to any Trump peace plan now being worked on by Trump's Middle East point men, son-in-law Jared Kushner and Jason Greenblatt.
The Palestinian leadership has been openly hostile to any proposal from the administration, citing what it says is a pro-Israel bias.
YANKING AID
The State Department announced this month that the United States is ending its decades of funding for the UN agency that helps Palestinian refugees. A week earlier, the administration slashed bilateral U.S. aid for projects in the West Bank and Gaza.
The US supplies nearly 30 per cent of the total budget of the UN Relief and Works Agency, or UNRWA, and had been demanding reforms in the way it is run. The department said in a written statement the US "will no longer commit further funding to this irredeemably flawed operation." The decision cuts nearly $300 million of planned support.
Those cuts came after the Trump administration announced it was cutting more than $200 million in bilateral aid to the Palestinians and spend the money for "high priority projects elsewhere."
UNRWA was founded after the 1948 war surrounding Israel's creation to serve some 700,000 Palestinians who fled or were uprooted from their homes. Today, it provides education and social services to over 5 million people across the region.
Hamas militants control Gaza, and the US said the militants were endangering "lives of Gaza's citizens and degrades an already dire humanitarian and economic situation."
One issue the US has had with support for the Palestinian Authority had been its stipends paid to the families of Palestinians killed, injured or jailed for attacks on Israel. Israel and the Trump administration, have repeatedly demanded that those payments from a so-called "martyrs' fund" be halted because they encourage terrorism. PLO President Mahmoud Abbas has refused to do so.
The Palestine Liberation Organization quickly denounced the decision, calling it "the use of cheap blackmail as a political tool."
Trump during the 2016 presidential campaign promised to move the US Embassy from Tel Aviv to contested Jerusalem. The consulate opened in May with a star-studded reception that included the president's daughter, Ivanka and Kushner, as well as Israel's top leaders.
Israel killed more than 60 Palestinians, including a 14-year-old girl, during protests that followed. It was the bloodiest day since a war between Hamas and Israel ended in 2014.
Israel said it is defending its border and accuses Hamas, the Islamic militant group that rules Gaza, of trying to carry out attacks under the cover of the protests.
WHAT THE PLO HAS SAID
PLO Executive Committee Member Dr. Hanan Ashrawi called the US policy "blackmail" that "once again seeks to punish the Palestinian people as a whole who are already victims of the ruthless Israeli military occupation."
- AP
Tinder rapist's sick web of lies exposed
Who owns the moon? And why it matters
Frank Greenall: One Cook, too many critics
Moon TV Episode 15: Relax and reflect with sultry smooth crooner Mike the Mongolian
Sit back, relax and reflect with this sweet tune.
|
cc/2019-30/en_head_0021.json.gz/line27404
|
__label__wiki
| 0.517838
| 0.517838
|
Other networks & communities
The ‘Thinking Allowed’ lecture series, exploring questioning, experiencing non-literal faith, is available on-line and flows from the partnership between Cairns Church in Milngavie and Orchardhill Parish Church in Giffnock, Glasgow region.
http://www.cairnschurch.org.uk/ThinkingAllowedOnline.htm
Our mission is to help people like you find, and walk, a spiritual path that will bring comfort, hope, clarity, strength, and happiness. Whether you’re exploring your own faith or other spiritual traditions, we provide you inspiring devotional tools, access to the best spiritual teachers and clergy in the world, thought-provoking commentary, and a supportive community.
http://www.beliefnet.com/
The Center for Action and Contemplation, located in Albuquerque, New Mexico, was founded in 1987 by Franciscan Father Richard Rohr, who saw the need for a training/formation center. It would serve as a place of discernment and growth for activists and those interested in social service ministries—a place to be still, and learn how to integrate a contemplative lifestyle with compassionate service. The Center’s purpose would be to serve not only as a forum for peaceful, non-violent social change but also as a radical voice for renewal and encouragement.
http://www.cacradicalgrace.org
Changing Attitude Scotland
Changing Attitude Scotland is a network of members of the Scottish Episcopal Church and ecumenical friends. Some of us are lesbian, some gay, some straight, some bisexual. We welcome everyone, lay and ordained, whose concern is to work for change in the church’s understanding of human sexuality.
http://www.changingattitudescotland.org.uk/
Changing Attitude Trawsnewid Agwedd Cymru
This is an organisation which is working towards the full inclusion of gay, lesbian, bisexual and transgender people in the life of the Anglican Communion in Wales. (NB Changing Attitude England has now merged with LGCM to form OneBodyOneFaith)
https://www.facebook.com/ChangingAttitudeCymru/
EvolutionaryChristianity.com
Free e-seminar series: The Advent of Evolutionary Christianity. This is a Michael Dowd initiative, Christianity from a perspective which sees no difficulty with evolution. Michael will be ‘working’ as the host and sounding board for the next two months, beginning 4th December 2010. The series will interview 30 leading speakers [many well known to PCN Britain members] considered to be at the leading edge of a new spirituality. Broadcasts can either be heard ‘live’ and on audio links after the event.
http://evolutionarychristianity.com/
Explore Faith
We are a community of faith dedicated to sharing our beliefs and experiences with anyone seeking answers to spiritual questions. Launched in 1999, explorefaith.org is a non-profit organization with a growing list of Partner Churches that support its mission and development. Explorefaith.org and its associates are deeply committed to ongoing spiritual formation for people of all ages and all backgrounds, living in countries around the world.
http://www.explorefaith.org
Holy City
HOLY CITY is the a monthly, Glasgow city-centre workshop & worship event for curious folk and faithful doubters concerned with the contemporary challenges for progressive Christianity. It is organised by the Wild Goose Resource Group and a motley crew of Glaswegian citizens. This is in effect WGRG’s laboratory where they experiment and develop their uniqie participative approach through workshops & worship. It runs from October to May and takes place in Renfield St Stephen’s Centre, Bath Street, Glasgow.
http://www.holycity-glasgow.co.uk
Norwich Christian Meditation Centre
The Norwich Christian Meditation Centre is an expression of St Augustine’s Church, Norwich. It is centred on the church hall, which also houses the Sunday morning Anglican congregation.
There is a speaker programme which brings world class teachers in the area of meditation and contemplative Christianity to Norwich. These are usually held in St Luke’s Church Centre.
This started in January 2008 with Richard Rohr.
http://www.norwichmeditation.co.uk/
OneBodyOneFaith
This organisation was formed in 2017 from the amalgamation of two organisations that have campaigned for LGBTI+ liberation and integration in churches in England for over forty years - LGCM (formerly the Lesbian and Gay Christian Movement) and Changing Attitude England. As they themselves put it: “United to campaign together for the changes that we need to see for LGBTI+ people to fully embraced and for their gifts and contributions to the life and mission of the church in England to be fully realised.
http://www.onebodyonefaith.org.uk/
12 ›
Organisations we work with
Resource-based links
Discussion sites
Browse all links
PCN Britain cannot be held responsible for the content of external websites.
|
cc/2019-30/en_head_0021.json.gz/line27408
|
__label__cc
| 0.594083
| 0.405917
|
Preventing a crisis in Somalia becoming a catastrophe
Emergency Response, Hunger
by Oxfam | May 7, 2014
by Ed Pomfret
New emergencies seem to hit the world on a monthly basis. Right now we are grappling with situations in the DRC, South Sudan, Sudan, Central African Republic and Syria to name just a few. Having worked on many disasters for Oxfam from the Haiti earthquake to floods in Pakistan, and the food crisis in the Sahel to conflict in Congo,
I am all too aware that faced with such a barrage of suffering, it is extremely difficult for people to know how to react. This includes countries that regularly provide humanitarian funding for countries in crisis. There is only so much money to go around, and if you give funds to one country at the expense of another, it isn’t long before you have organisations (like Oxfam) knocking on the door reminding you of people facing desperate circumstances elsewhere.
You may not have seen much information about Somalia recently. Other emergencies command more media attention, and too often Somalia – following twenty years of civil war and recurrent drought – is written off as a problem that just rumbles on in the background. But it’s worth revisiting what is going on.
We must not turn away from the fact that Somalia is in crisis. Just this month we have seen the latest of several warnings that underperforming rains, displacement and ongoing conflict will result in food shortages and increased suffering. Despite this, the country remains on the backburner, with few donors putting it at the top of their list. The humanitarian fund for Somalia is only 12 percent funded so far this year.
22 organisations working in Somalia, have gathered new information highlighting what people really face. The bare statistics are extreme:
2.9 million Somalis are in humanitarian crisis.
50,000 children are severely malnourished and at death’s door.
Women in Somalia face the second highest risk of maternal death in the world, and babies are at the highest risk of dying on the day of their birth.
1.1 million people are displaced within the country and a further one million are refugees in neighbouring countries.
Polio has returned, with 193 cases recorded in the last year.
Just 30 percent of the population has access to clean drinking water and fewer than one in four people have access to adequate sanitation facilities.
The sad thing is that these figures are better than in previous years. But “better” is not the same as “success”. These figures and the others you can find in “Risk of Relapse: Somalia Crisis Alert” are as bad as you will find in many crises across the world.
Following the food crisis that happened in Somalia in 2011, Oxfam and Save the Children reviewed what had gone wrong in “Dangerous Delay: The cost of late response to early warnings in the 2011 drought in the Horn of Africa”. One of the most telling findings was that the international community as a whole (including the NGOs we work for) had responded far too late to early warnings of a looming calamity.
We need donors to find the money to deal with the situation in Somalia right away, including for example the lack of clean water and sanitation. The funding also needs to be flexible enough to respond to changing circumstances, and build the ability of people to deal with bad harvests. If we don’t act now, we risk the current crisis becoming a catastrophe.
Ed Pomfret is Oxfam International Somalia Campaign Manager
This blog originally appeared at blogs.oxfam.org
Backgrounder:
Risk of Relapse: Somalia Crisis Alert
|
cc/2019-30/en_head_0021.json.gz/line27409
|
__label__wiki
| 0.926991
| 0.926991
|
Serena Williams’ former training partner faces charges in hit and run crash in Palm Beach
By Wendy RhodesDaily News Staff Writer
May 15, 2019 at 6:30 AM May 20, 2019 at 4:38 PM
A 34-year-old West Palm Beach man and former hitting partner for tennis star Serena Williams has been arrested after Palm Beach police say he took off after injuring another driver in a crash last month in front of The Breakers.
Police say Sylvester Robert Poole, who is also known as "Robbeye" and "Robbye" Poole, crashed his white Range Rover into another car at Breakers Row and South County Road on April 26, sending a 53-year-old man to Good Samaritan Medical Center. Few other details about the late-evening crash were released.
Poole, a tennis coach and former All-American player, faces one felony count of leaving the scene of a traffic crash with injury, one misdemeanor count of failure to render aid or give information of a traffic crash and one misdemeanor count of resisting arrest without violence/obstruction in violation.
Poole also has an active restraining order against him that was filed by a West Palm Beach woman who cites years of physical abuse and stalking, according to a separate report.
For three years, Poole was a hitting partner to Williams, a former top-ranked WTA player who lives in Palm Beach Gardens, according to multiple sources. He is also a former assistant tennis coach at the University of Mississippi, from which he graduated in 2008, according to the school's website.
Both the WTA and the United States Tennis Association declined to verbally verify whether Poole is a professionally certified tennis coach or if he worked with Williams.
Minutes after the crash, Palm Beach officers caught up with Poole in the lobby of his West Palm Beach apartment building, where they found him with a fresh cut on top of his head, a police report shows. When questioned about the injury, Poole told police he cut himself shaving.
Poole told officers a “very convoluted story” and appeared to be “attempting to deceive officers and obstruct their investigation,” according to the report.
His car had a broken front windshield and police collected skin evidence from a SunPass transponder in the vehicle, records show.
The driver of the other vehicle, who could not be reached, was treated at the scene for neck and back injuries before he was taken the hospital by Palm Beach Fire-Rescue, the report says.
According to an investigation, Poole was driving his Range Rover when it was involved in the crash at 11:09 p.m. on April 26. The Range Rover then crossed over the middle bridge heading out of town at 11:11 p.m., as seen on town video surveillance, and was next seen on video at 11:16 p.m. entering the parking garage where Poole lives.
Police made contact with Poole in the lobby of the building where they noted an “obvious wound to the top of his head that is consistent with the skin found on the SunPass transmitter from the windshield of the Range Rover," the report states.
Poole denied any involvement in the crash and was not initially arrested, the report shows. But shortly thereafter, police records show that Poole’s attorney, Anthony Barbuto, arrived at the police station asking police not to file charges against his client. Barbuto also “wanted to negotiate the best possible deal for his client with little to no notoriety," the report says.
Police encouraged Barbuto to have his client turn himself into the police department, the report shows.
Nine days later, on May 5, Poole was arrested and taken to the Palm Beach County Jail. He was released hours later on a $3,000 bond. A hearing on the charges is scheduled for 8:30 a.m. June 6.
This is not Poole’s first brush with the law. On April 11, a married West Palm Beach woman who says she is a former tennis student and former lover of Poole’s, was granted a restraining order against him, court records show.
In her petition for the restraining order, the woman cites examples dating to December 2017, when she says Poole “beat me so badly that I needed 10 stitches to close the wound and plastic surgery to later address the scarring.”
Since the woman attempted to break off the affair, Poole has repeatedly stalked her (including when she is with her children), threatened to “expose her and ruin her,” and threatened to send compromising pictures of her to her husband, the petition states.
The woman, whom the Daily News is not naming, also cited incidents in which Poole “screamed at her as he choked her” and forced her to stop on the interstate with his aggressive driving when she tried to get away from him.
Poole also stole all of the woman’s tennis racquets, smashed three of her cellphones, and took a video of himself in her backyard with a knife to his throat threatening to kill himself, according to the petition, in which the woman states that she is “in real fear of imminent violence.”
The injunction requires Poole to turn over any firearms in his possession and provide proof that he has done so.
The restraining order was extended April 24, and a hearing is scheduled for 1:30 p.m. June 25.
Poole's attorney, Barbuto, did not return a call for comment.
This story has been updated to remove a reference to a player who, according to her agent, was only temporarily coached by Poole.
@WendyRhodesFL
|
cc/2019-30/en_head_0021.json.gz/line27412
|
__label__cc
| 0.705201
| 0.294799
|
Andrei Soldatov
Andrei Soldatov and Irina Borogan are cofounders of Agentura.Ru and authors of The Red Web and The New Nobility. Their work has been featured in the New York Times, Moscow Times, Washington Post, Online Journalism Review, Le Monde, Christian Science Monitor, CNN, and BBC. The New York Times has called Agentura.ru “a web site that came in from the cold to unveil Russian secrets.” Soldatov and Borogan live in Moscow, Russia.
The Compatriots
The authors of The Red Web examine the shifting role of Russian expatriates throughout history, and their complicated, unbreakable relationship with the mother country--be it…
The Red Web
With important new revelations into the Russian hacking of the 2016 Presidential campaigns"[Andrei Soldatov is] the single most prominent critic of Russia's surveillance apparatus." -Edward…
The New Nobility
In The New Nobility, two courageous Russian investigative journalists open up the closed and murky world of the Russian Federal Security Service. While Vladimir Putin…
|
cc/2019-30/en_head_0021.json.gz/line27415
|
__label__wiki
| 0.502953
| 0.502953
|
Chris Bradfield, Ph.D.
Overview Directory of Scholars Chris Bradfield, Ph.D. Program Details To Apply
bradfield@oncology.wisc.edu
http://mcardle.oncology.wisc.edu/bradfield
Our laboratory is interested in a family of transcriptional regulators known as PAS proteins. Members of this emerging family of proteins control a number of processes, including xenobiotic metabolism (Ah-receptor and Arnt), circadian rhythms (Per), angiogenesis (HIF1a and Arnt), and neurogenesis (Sim). To understand these proteins and their signal transduction pathways, we are focusing on the characterization of the Ah-receptor/Arnt pathway in genetically manipulable organisms such as mice and yeast. We use yeast genetics as a method to identify genes that are required for signaling. In addition, the yeast system is proving valuable in modifier screens to identify novel components of the dioxin signaling pathway. Experiments in the murine system help us to understand the physiological function of these proteins, as well as to identify new members of the PAS family. Current areas of interest include the use of gene-targeting to generate informative bHLH-PAS loci and the use of more classical transgenic approaches to construct murine models that will help us characterize the mechanisms that underlie the toxicological and developmental effects of halogenated aromatics like dioxin.
Scholar Keywords
PAS proteins
1992 Search Pew Scholars
Jerry R. Faust, Ph.D.
Jonathan M. Horowitz, Ph.D.
Maria Jasin, Ph.D.
Mark P. Kamps, Ph.D.
Adrian R. Krainer, Ph.D.
John M. Leong, M.D., Ph.D.
Roderick MacKinnon, M.D.
Timothy J. McDonnell, M.D., Ph.D.
Jeff F. Miller, Ph.D.
Marjorie A. Oettinger, Ph.D.
Susan M. Parkhurst, Ph.D.
Lorraine Pillus, Ph.D.
Ann M. Pullen, Ph.D.
Pradip Raychaudhuri, Ph.D.
Lee W. Riley, M.D.
Paul B. Rothman, M.D.
Didier Trono, M.D.
John H. Weiss, M.D., Ph.D.
Jeffrey Wilusz, Ph.D.
Submit an update to this directory entry for Chris Bradfield, Ph.D.
|
cc/2019-30/en_head_0021.json.gz/line27416
|
__label__wiki
| 0.872134
| 0.872134
|
FDA Warns of Infections From Fecal Transplants After One Death
Fecal microbiota transplantation is a still-experimental procedure, as yet unapproved by the FDA
FRIDAY, June 14, 2019 (HealthDay News) -- On Thursday, federal health officials announced that a patient has died after fecal microbiota transplantation, highlighting the potential for severe infections linked to the procedure.
"While we support this area of scientific discovery, it's important to note that fecal microbiota for transplantation does not come without risk," Peter Marks, M.D., Ph.D., director the Center for Biologics Evaluation and Research at the U.S. Food and Drug Administration, said in a statement. After reports of serious, antibiotic-resistant infections linked to the procedures, the FDA wants "to alert all health care professionals who administer fecal microbiota transplant about this potential serious risk so they can inform their patients," Marks added.
Fecal microbiota transplant is a still-experimental procedure, as yet unapproved by the FDA. It has been primarily used to treat serious infections of antibiotic-resistant forms of the Clostridium difficile bacterium. But every therapy comes with risks, and the FDA said that two patients who received fecal microbiota transplants as part of a clinical trial developed life-threatening infections from multidrug-resistant bacteria delivered in the transplants. One of the patients has died. Both patients had weakened immune systems. So, the FDA is now mandating that special screening and testing of the stool used in these procedures be done to ensure that no drug-resistant bacteria are in the donated material. Also, when fecal microbiota transplants are used, doctors need to have adequate informed consent from the patient, the FDA said. Patients need to be warned of any potential risks associated with the treatment and should be told that the treatment is still considered experimental.
Marks stressed that the FDA still supports research into fecal transplant therapy. "The medical community is actively engaged in exploring the potential uses of fecal microbiota for transplantation," he said. To that end, "we will continue to aggressively monitor clinical trials to ensure patients are protected when safety concerns arise."
Continuous Anticoagulants + Cold Snare Polypectomy Noninferior
Colonoscopy Rates Increased in Those Aged 45 to 54 Years
Man's Award in Roundup Cancer Case Slashed by Judge
Physical Activity Linked to Slower Aβ-Related Cognitive Decline
|
cc/2019-30/en_head_0021.json.gz/line27418
|
__label__cc
| 0.707489
| 0.292511
|
Happy Birthday JSB! - The Greatness of Johann Sebastian Bach
Since it's Bach's 327th birthday today, I thought it is appropriate to commemorate his genius by outlining some of his greatest achievements.
At the end of this article, I hope will enjoy the video of one of my favorites Bach organ compositions - Ton Koopman's performance of chorale prelude "Schmucke dich, o liebe Seele" from the Great 18 organ chorales.
Johann Sebastian Bach (1685-1750) was arguably one of the most influential composers, organists, and pedagogues of all time. He surely can
be considered as one of the greatest composers in the history of music. The
features of D major Prelude and Fugue from the Well-Tempered Clavier II, B flat major Prelude and Fugue from the Well-Tempered Clavier I, the cantata “Ein feste Burge ist unser Gott”, St. Matthew Passion, Clavierübung III, and ”Musical Offering” will demonstrate his genius.
The first sign of his greatness is Bach’s productivity. Although part of his
compositions is lost, what has survived shows that his compositional output was far greater than any other composer who lived before or after him. In addition, Bach created music in almost all known genres of the time, except opera and ballet. However, his vocal works, such as St. Matthew Passion have elements of baroque opera (da capo arias). Furthermore, he composed instrumental and vocal, sacred and secular music.
Bach tends to exhaust all available possibilities within the piece. For example, D major Fugue from WTC II and Kyrie, Gott Vater in Ewigkeit Clavierübung III show that he used all available pitches of the scale for the beginning of the subject, time and pitch intervals, and form of the subject. If one particular possibility was unavailable, he would modify the subject in order to imply that one entrance of the subject. In addition, as is evident from the Fugue in D major and Kyrie, Gott Vater, he draws a piece from a short idea from which everything is constructed. Bach used his musical ideas so economically, that it seems at times there is hardly any other motive besides the theme and countersubject.
In case of D major and B flat major preludes and fugues from WTC, Bach seems to be very much concerned with the relationship between the pieces. Very often prelude foreshadows the fugue by having initial notes of the fugue subject. In addition, Bach’s interest in polyphonic devices (double invertible counterpoint) can be seen in the Fugue in B flat major from WTC I.
The crucial element in Bach’s music is symmetry. All pieces mentioned above
include various forms of architectural thinking. Proportionally, often his pieces can be divided in two (1/2), three (1/3 and 2/3), and four parts (¼ and ¾). Yet symmetry for Bach sometimes means even further (Clavierübung III, St. Matthew Passion or Cantata 80). Here the cycle is symmetrical in terms
of general structure.
Another feature which makes Bach so great is number symbolism. Perhaps the most evident example of this is Clavierübung III where Trinitarian
symbolism is all pervasive. This is not only apparent in chorale-based works,
but also in the Fugue in E flat where number of subject entrances reflect on
number Mass, catechism, and non-chorale based pieces. In addition, Bach often included his signature in numbers.
Bach’s all vocal works, such as Cantata 80 and St. Matthew Passion deal with
text painting. In Cantata 80, especially noticeable place is opening Chorus where cantus firmus is in canon in outer voices and symbolizes God the fortress which surrounds us. In the St. Matthew Passion, all of the recitatives are full of instances of text painting where dramatic leaps, dissonant and unresolved chords etc. symbolize the particular dramatic word. Moreover, in case of Passion, Bach often, if not always employs simple images which are apparent from the particular phrase of the aria or chorale verse.
Bach’s love for polyphony and learned devices, such as stretto, augmentation,
diminution, retrograde, and inversion are most clearly displayed in the Musical
Offering. To notice that, one can only look at one of the ten canons which are
often notated so that the performer has to figure out the time and pitch interval, and the form of the canonic voice. Here Bach explores all the possibilities where not only accompanying voice but the Royal theme itself is in canon.
Ricercare a 6 from the Musical Offering displays another feature of Bach’s
music which makes him so unique, namely perfect balance between seemingly opposing and contrasting elements. Here polyphony and vertical chords are in perfect balance. In addition, symmetry and forward drive are in balance as well. Furthermore, his ability in this piece to combine emotions and mind are especially noticeable.
Another important feature of Bach’s music in general is his universality in style and influences. He not only uses models of various composers for his own compositions, but often expands them and tries to make them more advanced. In addition, he combined French, Italian, and German practices into one universal musical language. That is especially apparent in E flat major Prelude from the Clavierübung III where Italian ritornello, French overture (dotted
rhythms), north German virtuoso pedal part, and central German fugal writing is combined into one unified piece. Italian ritornello influence is always evident
in the chorale preludes of the collection and arias of Cantata 80 and St. Matthew Passion. Furthermore, influences on Bach range not only geographically but historically as well. Movement III from the Trio Sonata of Musical Offering shows various features the style galant, the most fashionable style of the day, while Aus tiefer Not from the Clavierübung III is an
example of the style antico which was a typical style of the Palestrina
music. Sometimes, these two contrasting styles are combined in one piece (Fugue in E flat major from Clavierübung III).
Among other composers, Bach is perhaps the only one who can be called musical scientist. His importance, influence, and greatness are often compared with his contemporary scientist Isaac Newton. Like Newton’s universal laws of gravity, Bach’s well tempered tonality is the universal product of reason. Bach, like a scientist works with the smallest musical idea and that way composes a piece of music. Bach’s worldview is still influenced by the classical quadrivium principle (traditional approach) but he also explores the newest tendencies and fashions.
For Bach, the ultimate goal and reason of all music is glory of God and recreation of the spirit. In the beginning of the piece, he usually would write
Iesu iuva (Jesus help) whereas at the end he would include Soli Deo Gloria (to God alone be Glory). His theological and pietistic statements are not only evident in his music, but in his own commentary to the Bible as well. Therefore, it is evident that Bach’s theological views deeply formed and
influenced his music. The features discussed above clearly show that Bach is
surely world’s greatest composer.
By the way, do you want to learn to play the King of Instruments - the pipe organ? If so, download my FREE video guide: "How to Master Any Organ
Composition" in which I will show you my EXACT steps, techniques, and methods that I use to practice, learn and master any piece of organ music.
|
cc/2019-30/en_head_0021.json.gz/line27422
|
__label__wiki
| 0.543705
| 0.543705
|
Games 16, 17, and 18 – We’re Injured, but We’re Still Hot!
I didn’t get to see or hear much Pirate baseball this weekend because I was in State College, PA for the Blue/White game, Penn State Football’s annual spring scrimmage. The weekend is really more about tailgating and enjoying the outdoors, but a reminder that college football season is on its way isn’t a bad thing either.
The Pirates were in San Diego for a 3 game series this weekend. Despite a mess of injuries, the Bucs found a way to win 2 out of 3 games and claim their third consecutive series win. Nate McLouth didn’t play at all this weekend due to an injured right oblique. It doesn’t sound like this injury will require a trip to the DL, but the team decided to keep McLouth out for precautionary reasons. Jack Wilson was sent to the DL because of the injured left middle finger that has been bothering him over the past week. Brian Bixler was called up to replace Wilson, and Bixler will likely split time at shortstop with Ramon Vazquez. Finally, Craig Hansen was sent to the DL because of neck spasms. Evan Meek was called up to replace Hansen.
Game 16 – The series opened with a tough loss for the Bucs. Pittsburgh used every pitcher that they had available before losing 4-3 in 11 innings. Ian Snell only lasted 5 and 1/2 innings. The relievers pitched 5 scoreless innings until Matt Capps walked 2 in the 11th and former Pirate, Brian Giles hit a game winning double.
Game 17 – Zach Duke looked strong once again to claim his 3rd win of the season. The Bucs dominated the Padres from start to finish in this game and took home the 10-1 victory. Duke pitched 8 and 1/3 inning, giving up 6 hits and 1 ER. He got plenty of support from his own batters with Freddy Sanchez going 3-5, Craig Monroe going 3-5, Eric Hinske going 2-3, Andy LaRoche going 2-4, and Jason Jaramillo going 2-4.
Game 18 – Ross Ohlendorf out-pitched Jake Peavy, and Adam LaRoche hit 2 home runs to lead the Bucs to an 8-3 win over the Padres. Ohlendorf pitched 7 innings, giving up 5 hits and 3 ER. John Grabow finished up the final two innings. Andy LaRoche went 2-5 to extend his consecutive game hitting streak to 10. So much for that slow start!
The Pirates are now 11-7, and they have already seen strong pitching performances from all of their starters. It sure looks like Pitching Coach, Joe Kerrigan is doing a lot of the right things.
With this series win, the Pirates are now 4 games over .500. That hasn’t happened since 2002. Also, the Pirates are now assured of a winning record in the month of April. That’s happened just twice in the last 15 years.
One final note from the weekend. Dave Davidson was claimed off waivers by the Florida Marlins. Only time will tell if this means anything.
A 3 game series with the Milwaukee Brewers is next. Let’s hope that our injury depleted Pittsburgh Pirates can find a way to keep the wins coming.
Monday – Jeff Karstens @ Braden Looper – 8:05 P.M.
Tuesday – Paul Maholm @ Dave Bush – 8:05 P.M.
Wednesday – Ian Snell @ – Yovani Gallardo 1:05 P.M.
Adam LaRoche, Andy LaRoche, Brian Bixler, Brian Giles, Craig Hansen, Craig Monroe, Dave Davidson, Evan Meek, Freddy Sanchez, Ian Snell, Jack Wilson, Jason Jaramillo, Jeff Karstens, Joe Kerrigan, Matt Capps, Milwaukee Brewers, Nate McLouth, Paul Maholm, Ramon Vazquez, Ross Ohlendorf, San Diego Padres, Zach Duke
Game 16 – Headin’ Out West
We’ll be turning on the lights at Petco Park tonight.
Ian Snell @ Kevin Correia 10:05 Eastern.
Ian Snell, Kevin Correia, Petco Park, San Diego Padres
Game 15 – Can We Sweep?
Taking all 3 against the Marlins would certainly make a statement. We’ll find out soon enough.
Ricky Nolasco @ Paul Maholm.
First pitch is at 12:35.
Update: Yes we can!
Paul Maholm wasn’t as magical as he was in his first 3 starts, but it was good enough. 6 IP, 8H, 4R, 4K
Adam LaRoche was on fire, going 4-5 with an RBI. Even with Doumit out of the lineup, things seem to be going the Pirates’ way.
Now for a day off before opening a 3-game series against in San Diego. Keep it up, Buccos!
Adam LaRoche, Florida Marlins, Paul Maholm, Ricky Nolasco, Ryan Doumit, San Diego Padres
|
cc/2019-30/en_head_0021.json.gz/line27426
|
__label__cc
| 0.570386
| 0.429614
|
Administrative Services -
City Clerk-
Departments » Administrative Services » City Clerk
The City of Plymouth posts legal notices on this page and in the local newspaper, the Plymouth Sun Sailor, for the purposes of informing the public of public hearings and meetings. Legal notices are removed from this page after the date of meeting.
Planning Commission Public Hearing - July 17, 2019
NOTICE is hereby given that the Planning Commission of the City of Plymouth will meet in the Council Chambers of Plymouth City Hall, 3400 Plymouth Boulevard, on Wednesday, July 17, 2019 at 7:00 p.m. to consider the following:
Request by Michael and Melanie Pemrick, under File 2019047, for a conditional use permit to allow an addition to their existing attached garage that would result in a total attached accessory/garage space of 1,325 square feet and a setback variance to allow a garage addition 21 feet from a railroad right-of-way where 50 feet is required for the property located at 12115 53rd Avenue North.
Public Hearing - July 23, 2019
NOTICE IS HEREBY GIVEN that the Plymouth City Council will conduct a public hearing on July 23, 2019 at 7:00 p.m. on a Resolution Dispensing with Statutory Requirements for Review by Planning Commission and Disposing of Real Property described as:
That part of the East 660 feet of the North 1/2 of the Northeast Quarter of Section 8, Township 118, Range 22, lying Northerly of a line 30 feet Northerly of, measured. radial to and parallel with the Northerly right of way line of the Soo Line Railroad (Minneapolis, St. Paul & Sault Ste. Marie Railroad Company), Hennepin County, Minnesota. EXCEPT: that part which lies westerly and northerly of the following described line: Commencing at the Northeast Quarter of Section 8; thence westerly, along the north line of said North 1/2 a distance of 372.93 feet to the point of beginning of said line; thence deflecting to the left 68°07'29" a distance of 230.37 feet; thence deflecting to the right. 57°25'15" a distance of 202.55 feet to the West line of said East 660 feet, and said line there terminating. (5335 Vicksburg Lane)
Planning Commission Public Hearing - August 7, 2019
NOTICE is hereby given that the Planning Commission of the City of Plymouth will meet in the Council Chambers of Plymouth City Hall, 3400 Plymouth Boulevard, on Wednesday, August 7, 2019 at 7:00 p.m. to consider the following:
Request by Augusta Development, LLC, under File 2019048, for a site plan and conditional use permit to allow construction of a four-story, 130-unit senior housing building to be known as “Plymouth Senior Living” for the property located at 3025 Harbor Lane North.
NOTICE is hereby given that the Planning Commission of the City of Plymouth will meet in the Council Chambers at Plymouth City Hall, 3400 Plymouth Boulevard, on Wednesday, August 7, 2019, at 7:00 p.m. to consider the following:
Request by Robbinsdale Area Schools (ISD #281), under File No. 2019 045, for a conditional use permit to allow a 610 square foot scoreboard to be installed at the northeast end of the football field at Armstrong High School, 10635 36th Avenue.
Request by Watermark Properties, LLC, under File No. 2019052, for a preliminary plat to allow Lot 1, Block 2 of the “Beacon Ridge” subdivision to be divided into two lots.
NOTICE is hereby given that the Planning Commission of the City of Plymouth will meet in the Council Chambers of the Plymouth City Hall, 3400 Plymouth Boulevard, on Wednesday, August 7, 2019, at 7:00 p.m. to consider the following:
Request by Wold Architects and Engineers, under File No. 2019055, for approval of a site plan amendment and conditional use permit amendment for the construction of a 44,000 square foot building addition for a two-story Wayzata Early Learning School and offices, new gymnasium and a parking expansion at Oakwood Elementary School located at 17340 County Road 6.
|
cc/2019-30/en_head_0021.json.gz/line27428
|
__label__wiki
| 0.873464
| 0.873464
|
14 Chinese companies worth $3.7 bn operate in Ebonyi — Umahi
Tuesday, March 19, 2019 2:30 pm
Gov. David Umahi of Ebonyi State
Gov. David Umahi of Ebonyi has said that about 14 Chinese companies with a trade volume of about $3.7 billion were operating in the state.
Umahi made the disclosure in Abakaliki when the Chinese Ambassador to Nigeria, Dr Zhou Pingjian, paid him a courtesy call.
Represented by his Deputy, Dr Kelechi Igwe, Umahi said that Ebonyi have several agreements and protocols with the China in its bid to become one of the best economies in the country.
“The desire to achieve this aim made the governor to visit you in Abjua as China that used to be one of the ‘poorest’ countries in the world suddenly skyrocketed to an enviable economy,” the governor said.
He thanked the ambassador for the visit, noting that he was the first public officer to visit him since his re-election.
Earlier in his remark, Pinjian projected that abject poverty would be eliminated in China by 2020 due to the sustained, rapid transformation of its economy.
Pingjian noted that by Oct. 1, 1949 when China was formed and up to 1978 during its acclaimed reforms, the country was one of the most backward countries in the world.
“Ninety-eight out of 100 Chinese then lived on the poverty line but I assure you that by the end of next 2020, abject poverty will be eliminated in China due to the rapid economic transformation witnessed since then.
“In the past four decades, according to world bank figures, China has lifted over 740 million people out of poverty and has an annual growth rate of 9.5 per cent,” he said.
The ambassador said that for the past 40 years since its 1978 reforms, China has attracted over $2 trillion in Direct Foreign Investments (DFI).
“The DFI keeps pouring, attracting over $138 billion in 2018 and is the largest from any developing country of the world.
“The country’s outbound investments have also attracted over $100 billion and we intend to grow with our friends such as Ebonyi, Nigeria and Africa,” he said.
He noted that the National Peoples Congress (Chinese legislature) recently passed the important Foreign Investment Law which entails China opening its doors for investment from the outside world.
“We believe that openness brings progress as some industries, especially the labour intensive ones, are relocating fast to neighbouring countries and outside world.
“We want to see more Chinese investment in Ebonyi, Nigeria and Africa for the needed mutual cooperation in the economy and other sectors of national life,” he said.
He congratulated Gov. David Umahi of Ebonyi on his re-election, noting that the country would partner Ebonyi, especially in the area of rice production.
|
cc/2019-30/en_head_0021.json.gz/line27429
|
__label__cc
| 0.737978
| 0.262022
|
New Zealand Property Guides
Starting a new life in Auckland
If we told you that you could enjoy city living in a place where the sun shines, you can pop to the beach after a day’s work at your very well-paid job, and where property prices and rent are reasonable, would you be on the next flight? Today, we’re taking a look at what the wonderful city of Auckland offers to overseas buyers.
10 best locations for your winter holiday home in New Zealand
The mention of New Zealand immediately summons up images of sunny days and sandy beaches. But did you know that there’s just as much to do in winter, from skiing to whale-watching? And, if it is warmer weather you’re after, escape to the mild climate of the Bay of Plenty. Find out our top ten spots for a winter holiday home in New Zealand.
Can you retire to New Zealand?
New Zealand is a wonderful place to retire. As well as sharing lots of history, traditions and that all-important sense of humour with us, it’s even greener and less crowded, and the climate is pleasantly mild. It’s an ideal spot to enjoy the relaxed pace of life the islands are known for. So, how can you retire to New Zealand?
How can you find land to build on in New Zealand?
Do you dream of building your own home? Chances are that if you’re the sort whose happy to move to the other side of the world, you’re probably game for the challenge that self-building presents. Many expats dream of building a home exactly how they want it. But how do you find the perfect plot of land to build on in New Zealand?
Buying in New Zealand, part six: the buying process
Buying a home in New Zealand isn’t too different to in the UK, but there are a few extra steps: how do you find a good solicitor when you’re in a new country, for instance, and how do you get your money across without losing out to changing currency markets? Find out in this week’s final part of Buying in New Zealand.
Should you move to Christchurch?
newzealand@propertyguides.com
|
cc/2019-30/en_head_0021.json.gz/line27434
|
__label__cc
| 0.714288
| 0.285712
|
Why do people rent instead of buy?
A new survey from Knight Knox has polled 2,000 UK renters and explored the reasons why people rent instead of buying.
As you would expect, affordability is a major factor. And indeed, most respondents said they were renting because they simply didn’t have the means to buy their own property. According to the numbers, 56.30% said that couldn’t afford a deposit and 29% said that they were unable to qualify for a mortgage.
Of those who are struggling to save for a deposit, 64.40% could only rely on their own funds for a deposit and only 22.45% said that they were actively saving up to buy a house.
When looking at age groups, the survey shows that those aged between 35 and 44 were struggling the most with buying their own home. Out of everyone surveyed in this cohort, 64.23% said they couldn’t afford a deposit, which was the highest percentage out of all cohorts surveyed.
This was closely followed by respondents aged between 25 and 34 (62.96%), however, this group had the most respondents saying that they were actively saving for a deposit (34.76%).
With 26.10% of respondents saying they rent because it suits their lifestyle, the convenience of the sector is clearly important. This was especially evident with the oldest and youngest age groups surveyed.
Out of all respondents, those aged 18-24 mostly said that renting suited their lifestyle (47.15%) and that they didn’t want to be tied down to one location (22.05%).
Respondents aged 55 and over had the second highest number of respondents saying that renting suited their lifestyle (34.66%), they also were the most likely to say that they didn’t want the commitment of maintaining a property (24.55%) and paying a mortgage (26.71%).
Younger respondents were holding off buying a property until they found a suitable home; those aged 18 to 24 were most likely to say that they are yet to find the right home to buy (16.73%), this was followed by respondents aged 25 to 34 (11.82%).
Andy Phillips, commercial director at Knight Knox said: “The survey has produced some extremely interesting results. Previous Knight Knox surveys have always seemed to indicate that millennials are the main group that are struggling to get on the housing ladder, backing up current industry data.
However, it now appears that this is increasingly becoming an issue for slightly older renters as well. It’s clear that many tenants are having to rent on a long-term basis because they simply cannot afford to save up for a deposit, alongside their regular monthly outgoings like rent and other expenses. It’s also fascinating to see that a lot of people are now renting out of choice rather than necessity. It indicates that renting is more suitable for the current market and it will be interesting to see if this trend continues.”
More from Landlords
|
cc/2019-30/en_head_0021.json.gz/line27435
|
__label__wiki
| 0.526003
| 0.526003
|
Jon Carapiet
Jean Anderson
Jean Anderson held administrative positions with a Charitable Trust responsible for the Engineering Industries Group Apprenticeship (EIGA) training scheme and at an engineering company in England. She and her husband, Bob, emigrated to New Zealand in 1968 where she held a teaching position in the founding year at the, then, Tertiary Division of the Gisborne Boys’ High School, which went on to become a technical institute. Later, she was a tutor in the Commercial Department at the Waikato Technical Institute, Hamilton. Jean subsequently owned her own business.
In retirement, Jean continues to write for children. She is founding member of Tauranga Writers for Children, established in 1990, which works towards encouraging children to write, and to develop their imagination and a joy of reading. The group works in schools and with the Bay of Plenty branch of the Children Literature Association, and is a member of the Children Literature Foundation of New Zealand.
Jean Anderson handles the administrative tasks and acts as a co-ordinator for PSRG. She has been a Trustee since its inception as a Charitable Trust.
See http://christchurchcitylibraries.com/Kids/ChildrensAuthors/list.asp
|
cc/2019-30/en_head_0021.json.gz/line27438
|
__label__cc
| 0.531692
| 0.468308
|
Happy Birthday to a Ballet Legend
Sir Anthony Dowell, principal dancer at The Royal Ballet from 1966 to 1984 and director of the company from 1986 to 2001, celebrates his 70th birthday this Saturday, February 16th.
A strong and masterful technical dancer, Dowell created the role of Oberon in Frederick Ashton’s masterpiece The Dream. Anotinette Sibley was his Titania, and the Dowell-Sibley team quickly became a legendary ballet partnership. Dowell also created dramatic dance poetry with Lynn Seymour in Ashton’s A Month in the Country and Natalia Makarova in Swan Lake, and as Solor in La Bayadère. American audiences got to know Dowell in the 1970s, when he danced with American Ballet Theatre and the Joffrey Ballet.
After retiring from the stage in the 1980s, he took the helm of The Royal, where he fostered the careers of Sylvie Guillen, Jonathan Cope, Carlos Acosta, Darcey Bussell and Alina Cojocaru, to name just a few. In the last program he directed, Dowell chose to feature The Dream and A Month in the Country, both left to him in Ashton's will.
It seems fitting that as he celebrates his 70th, Dowell is again paired with Sibley: The pair are coaching The Royal’s tribute to Ashton, which runs through February 23.
the royal ballet anthony dowell frederick ashton antoinette sibley this week in dance
|
cc/2019-30/en_head_0021.json.gz/line27439
|
__label__wiki
| 0.608716
| 0.608716
|
> William Comyn, earl of Buchan (d.1233)
You can cite this record using this snippet: PoMS, no. 16 (https://www.poms.ac.uk/record/person/16/; accessed 18 July 2019)
William Comyn, earl of Buchan (d.1233)
William Comyn was the son and heir of Richard Comyn (Cumin) (d.c.1178), justiciar of Lothian, and his wife, Hextilda, granddaughter and heiress of Donald Ban, king of Scotland. William was lord of Kirkintilloch and Lenzie by c. 1200 and also held lands in Tynedale, Peeblesshire, Roxburghshire, Dumfriesshire. His first wife is unknown, though with her, he had four sons (Richard, Walter, William, David) and one daughter (Jean). From this line were descended the lords of Badenoch. In 1212, he married Marjory, heiress to the earldom of Buchan, and was styled earl of Buchan from that year. With Marjory he had another three sons (Alexander, William, Fergus) and three daughters (Idonea, Agnes, Elizabeth). From this line were descended the earls of Buchan and brought to the family the vast estates of the earldom. William was also justiciar of Scotia and founded Deer Abbey. William died in 1233. (Young, The Comyns, 14-30)
William Comyn, earl of Buchan (d.1233) (1)
William Comyn, earl of Buchan (d.1233) (counterseal)
William Comyn, earl of Buchan (d.1233) (1A)
Family connections
» Gephi Visualisation
Grantor Beneficiary relationships
Total number of associated factoids: 368
Transaction factoids (50) Relationship factoids (43) Title factoids (123) Possession factoids (1) Witnesses factoids (151)
unavailable Gift of one oxgang of land in territory of Kirkintilloch (DNB) Grantor 3/167/14 (Camb. Reg., xxxi-ii)
unavailable Gift of Lenzie (DNB) Beneficiary 1/7/53 (RRS, iii, no. 53)
unavailable Command to hand over 13 acres of land Addressee 1/6/479 (RRS, ii, no. 513)
undated Renewal of Slipperfield (PEB) Sicut Clause John White; John, knight (PEB); Oliver, steward (PEB); Ralph de Ribeston; Ralph, chaplain (PEB); Robert, chaplain (PEB); Roland, knight (PEB); Walter of Congalton, knight 3/350/10 (Holy. Lib., App. II, no. 6)
unavailable Charter (confirmation?) of William Comyn concerning Slipperfield (PEB) Grantor 3/350/10 (Holy. Lib., App. II, no. 6)
unavailable Donation which William Comyn has made Grantor 1/6/338 (RRS, ii, no. 367)
unavailable Donation of church of Bethelnie (ABD) and one toft in villa of Bethelnie with common pasture Grantor 1/7/67 (RRS, iii, no. 67)
unavailable *Gift of William Comyn, earl of Buchan Grantor 1/53/54 (RRS, v, no. 48)
unavailable Pension paid from church of Dull (PER) Grantor 2/6/36 (St A. Lib., 297)
unavailable Agreement between William Comyn and Abbot of Kelso Party 1 1/6/338 (RRS, ii, no. 367)
unavailable Gift of one oxgang next to church of Kirkintilloch Grantor 1/7/120 (RRS, iii, no. 117)
unavailable Quitclaim of right in church of Kirkintilloch (DNB) Grantor 1/7/120 (RRS, iii, no. 117)
unavailable Command to hand over 13 acres next to church of Barry Addressee 1/7/6 (RRS, iii, no. 6)
unavailable Quitclaim of rights in land of Muckcroft (LAN) Grantor William I, king of Scots (d.1214) 1/6/397 (RRS, ii, no. 430)
unavailable Donation of half mark from St Monans (FIF) Grantor 3/12/27 (St A. Lib., 282-3)
unavailable Transfer of lands into abbey's hands Grantor 1/7/6 (RRS, iii, no. 6)
unavailable Donation of land in dispute Grantor 1/6/446 (RRS, ii, no. 480)
30 Oct. 1200 Correspondence concerning granting of safe conduct named person (transaction) Gilbert, son of Peter 1/25/2 (Arb. Lib., App., no. 2)
Feb. 1201 X 1 Mar. 1202 Quitclaim of the land called Muckcroft (LAN) Grantor David de Bonville, marischal (fl.late 12C-mid13C); Ingram Balliol (d.1239×44); John Graham, sheriff of Edinburgh; John of Wilton; Philip Colville; Philip de Mowbray; Richard de Prebenda, bishop of Dunkeld (d.1210); Richard Revel, lord of Coultra (d.1215×25); Roger de la Carneille, lord of Guthrie 3/167/3 (Glas. Reg., no. 90)
1 Mar., 1201 X 1202 Confirmation of quitclaim to Bishop William of Glasgow Sicut Clause Alan, lord of Galloway (d.1234); Bernard of Hadden, sheriff of Roxburgh; David de Bonville, marischal (fl.late 12C-mid13C); Gervase Avenel, lord of Eskdale (d.1219); Henry of Carmunnock; Herbert Maxwell (d.c.1202); Osbert, abbot of Kelso (d.1203); Patrick (I), earl of Dunbar (d.1232); Philip, marischal (TRW); Robert of London (d.1225); Thomas Colville 'Scot', lord of Keresban (d.1219); Walter Murdoch; William Lindsay (II) (d.c.1205) 1/6/397 (RRS, ii, no. 430)
17 Jun. 1208 X 4 Dec. 1214 Confirmation of land in dispute Sicut Clause 1/6/446 (RRS, ii, no. 480)
17 Jun. 1208 X 5 Oct. 1218 Grant in free feuferme of the land of Draffan and Dardarach (LAN), and the chapel in that land Sicut Clause Chapter of Kelso 2/73/21 (Kel. Lib., no. 103)
2 Oct. 1211 Concession to have burgh at Kirkintilloch Beneficiary Adam, son of Herbert de Camera; Alan, lord of Galloway (d.1234); Alexander, son of William, sheriff of Stirling; Herbert de Camera; Philip de Mowbray; Philip de Valognes, chamberlain (d.1215); William del Bois, chancellor (d.1232) 1/6/468 (RRS, ii, no. 501)
9 Oct. 1211 X 1224 Gift of Strichen and Kindroucht (ABD) Grantor Fearchar, judex (ABD); James, clerk (ABN); John, dean of Buchan; Margery, countess of Buchan (d.c.1244); Robert de Ponfun ; Robert, chaplain of William, earl of Buchan; William Comyn of Snitterfield (d.1223/24); William of Slains, knight; William Prat, sheriff of Aberdeen 3/12/13 (Abdn. Reg., 14-5)
9 Oct. 1211 X 1224 Gift of Blyth, Ingraston and 'le Halch' (PEB) Grantor Arkil, steward of Machen; John, son of Ralph the chaplain; Ralph, chaplain of Linton; Richard Revel, lord of Coultra (d.1215×25); Richard Trac; Robert Hastings (13C); Robert Sinclair; Robert, chaplain of William, earl of Buchan; William Comyn of Snitterfield (d.1223/24); William, son of Orm (Abernethy) (fl.1200s-10s), constable 3/12/14 (Mort. Reg., ii, no. 5)
9 Oct. 1211 X 1233 Gift of half of Gartshore (DNB) in exchange for half ploughgate and toft and croft in villa of 'Dunbernyn' Grantor Adam of Rule, clerk; Alan de St Mary, chaplain of William Comyn; John Sinclair; Laurence, fermento (for firmario?); Ralph Pantulf; Robert Mowat, knight, justiciar, sheriff of Forfar; Robert of Wilton (12/13C); Robert, son of Eadwulf, steward of William Comyn; William Fra' [Frendraught?] 3/12/12 (NRS, RH 1/2/32)
9 Oct. 1211 X 1233 Obligation to pay half mark from land of St Monans (FIF) Grantor Adam de Cheket/Theket, clerk; Donald of Mar, knight (13C); Elias, chaplain (Buchan, 13C); Lindores Abbey (fd1190); Philip of Meldrum/Feodarg, knight; Robert Comyn, knight; Robert Mowat, knight, justiciar, sheriff of Forfar; Robert, prior of Lindores 3/12/7 (St A. Lib., 250)
9 Oct. 1211 X 1233 Confirmation of church of Kennoway (FIF) Grantor Adam de Cheket/Theket, clerk; Adam of Rule, clerk; Elias, chaplain (Buchan, 13C); German, prior of Restenneth (fl.1218-24×); Michael Mowat, sheriff of Inverness; Philip of Meldrum/Feodarg, knight; Ranulf/Ralph of Bunkle; Restenneth Priory; Robert Mowat, knight, justiciar, sheriff of Forfar 3/12/8 (St A. Lib., 251)
9 Oct. 1211 X 1233 Confirmation of land of Kilmux (FIF) Grantor Adam de Cheket/Theket, clerk; Adam of Rule, clerk; Elias, chaplain (Buchan, 13C); German, prior of Restenneth (fl.1218-24×); Michael Mowat, sheriff of Inverness; Philip of Meldrum/Feodarg, knight; Ranulf/Ralph of Bunkle; Restenneth Priory; Robert Mowat, knight, justiciar, sheriff of Forfar 3/12/9 (St A. Lib., 251-2)
9 Oct. 1211 X 1233 Statement concerning distraining of Merleswain, son of Waltheof Grantor Adam de Cheket/Theket, clerk; Adam of Rule, clerk; Elias, chaplain (Buchan, 13C); German, prior of Restenneth (fl.1218-24×); Philip of Meldrum/Feodarg, knight; Ranulf/Ralph of Bunkle; Robert Comyn, knight; Robert Mowat, knight, justiciar, sheriff of Forfar 3/12/10 (St A. Lib., 252)
9 Oct. 1211 X 1233 Gift of stone of wax annually at Glasgow Fair Grantor Adam, son of Earl Fergus of Buchan; David Ruffus of Forfar; Richard Comyn (d.1244x49) (son of William); Robert de Montfort; Robert, chaplain of William, earl of Buchan; William, son of Robert Hastings 3/12/15 (Glas. Reg., no. 117)
9 Oct. 1211 X 1233 Quitclaim of right in church of Kirkintilloch (DNB) Grantor Adam of Rule, clerk; Hugh, master, rector of Kirkintilloch; P. of the Castle, master; R. of Hibestoter; Robert Mowat, knight, justiciar, sheriff of Forfar; Robert of the Wardrobe; Roger of Wilton, knight; Theodore Elias, priest; William, chaplain of Countess Marjory 3/12/20 (Camb. Reg., xxx)
9 Oct. 1211 X 1233 Renewal of church of Kilrenny (FIF) Grantor 3/12/16 (Dryb. Lib., no. 18)
9 Oct. 1211 X 1233 Gift of Wester Coull in Mar (ABD) Grantor Elias, chaplain (Buchan, 13C); John Hay (I), lord of Naughton (d.×Oct.1266); Philip of Meldrum/Feodarg, knight; Robert de Montfort; William of Frendraught (son of Duncan); William Sinclair, knight (d.c.1270); William, chaplain of Earl William of Buchan 3/12/11 (NRS, RH 1/2/31)
17 Aug. 1214 Gift of a stone of wax to light the church of St Cuthbert at Coldingham Grantor David Graham (I) (TRW); Richard Comyn (d.1244x49) (son of William); Roger, persona of Rule 3/167/4 (ND, App., no. 175)
1219 X 1233 Gift of lands of Barry (BNF) Grantor Adam, son of Earl Fergus of Buchan; Magnus, son of Earl Colban; Margery, countess of Buchan (d.c.1244) 3/12/17 (A.B. Ill., ii, 426-7)
1219 X 1233 Gift of land of Fechil on the Ythan (ABD) Grantor Adam, son of Earl Fergus of Buchan; John, son of Uhtred; Magnus, son of Earl Colban; Margery, countess of Buchan (d.c.1244); Merleswain, son of the earl of Buchan (early 13c); Nicholas, chaplain of William Comyn; Robert of Inverkeilor, chaplain of William Comyn; William of Slains, knight; William, son of Orm (Abernethy) (fl.1200s-10s), constable 3/12/18 (A.B. Ill., ii, 427-8)
15 Jun. 1220 Statement concerning Alexander II's marriage named person (transaction) 1/7/51 (RRS, iii, no. 51)
22 Sept., 1220 X 1221 Renewal of Lenzie (DNB) Beneficiary Geoffrey, son of Richard, of Inverkunglas, sheriff; Henry Balliol (d.1246); John Hay (I), lord of Naughton (d.×Oct.1266); John Maxwell, chamberlain, sheriff of Roxburgh (d.1241); Robert of London (d.1225); Thomas of Galloway, earl of Atholl (d.1231); Walter Stewart (II), son of Alan (d.1241); William del Bois, chancellor (d.1232); William Malveisin, bishop of St Andrews (d.1238) 1/7/53 (RRS, iii, no. 53)
2 Nov. 1220 X 22 Feb. 1222 Gift of the church of Bethelnie (Oldmeldrum, ABD), with a full toft in the villa of Bethelnie Grantor Alan de St Mary, chaplain of William Comyn; Alexander, abbot of Coupar Angus (fl.1209-40); Alexander, dean of Aberdeen (fl.1211×39); Andrew Murray, bishop of Moray (d.1242); Denis, dean of Angus and Forfar (fl.1211×14-1225×39); Geoffrey Crawford; John of Calder, clerk of Bishop Adam of Aberdeen; Malcolm, persona of Auchterless; Ralph Pantulf; Robert Mowat, knight, justiciar, sheriff of Forfar; Robert of Wilton (12/13C); Robert, abbot of Kinloss (fl.1220); William del Bois, chancellor (d.1232); William of Slains, knight 3/12/21 (Arb. Lib., no. 130)
22 Feb. 1222 Confirmation of church of Bethelnie (ABD) and a toft in villa Sicut Clause John Bisset; Peter Bisset; Robert, king's chaplain (TRA2); Thomas of Stirling, clerk, archdeacon of Glasgow (d.1227); Walter Bisset (13C); William Bruce (son of William); William de Vescy (II) (d.1253) 1/7/67 (RRS, iii, no. 67)
Jan. 1224 X 1233 Gift of fourth part of Drumry in Lennox (DNB) Grantor Philip of Meldrum/Feodarg, knight; Ralph Pantulf; Robert de Montfort; Robert Mowat, knight, justiciar, sheriff of Forfar; Roger, clerk (Buchan); Walter Comyn, earl of Menteith (d.1258); Walter, abbot of Deer (d.1234); Walter, clerk (earls of Buchan); William Comyn, clerk, son of Earl William 3/12/19 (NLS, Ch. 15532)
9 Feb. 1224 Recognition of perambulation between Cloquhat (PER) and Drimmie (PER) Judge 4/39/4 (C.A. Chrs., no. 34)
19 Apr. 1225 X 6 Jan. 1230 Confirmation of annual pension from church of Dull (PER) named person (transaction) Adam de Prebenda, dean of Dunkeld (fl.1229×36-45); Gervase (Dunkeld); Hugh, chaplain of Bishop Hugh of Dunkeld; Hugh, chaplain of Bishop Hugh of Dunkeld; John of Heiton, precentor of Moray (d.1249×63); John of Heiton, precentor of Moray (d.1249×63); Simon Lindsay, canon of Dunkeld; William of Ednam, master, archdeacon of Dunkeld (d.1251×57); William of Ednam, master, archdeacon of Dunkeld (d.1251×57) 2/6/36 (St A. Lib., 297)
27 Mar. 1226 Confirmation of quitclaim of rights to church of Kirkintilloch (DNB) Sicut Clause David Comyn, lord of Kilbride (d.1247); David de Bonville, marischal (fl.late 12C-mid13C); Maurice or Murdoch, younger, earl of Menteith (d.1231×34); Robert, king's chaplain (TRA2); Thomas of Stirling, clerk, archdeacon of Glasgow (d.1227); W. Bisset (Walter or William); Walter Comyn, earl of Menteith (d.1258) 1/7/120 (RRS, iii, no. 117)
10 Mar. 1229 Gift of Tynedale in marriage named person (transaction) Adam of Harcarse, abbot of Melrose (d.1245); Bernard Fraser, sheriff of Stirling; Matthew Scott, bishop-elect of Dunkeld (d.1230); Patrick (I), earl of Dunbar (d.1232); Walter Comyn, earl of Menteith (d.1258); Walter Oliphant, justiciar of Lothian (son of Walter) (d.1242); Walter Stewart (II), son of Alan (d.1241); William Comyn, earl of Buchan (d.1233); William Malveisin, bishop of St Andrews (d.1238); William, abbot of Dunfermline (II) (d.1238) 1/7/151 (RRS, iii, no. 148)
7 Jun. 1244 X 1289 Renewal of half mark from St Monans (FIF) Sicut Clause Gilbert or Gilla Brigte Scott, knight (fl.1244×89); James de Lascelles; John Crook, clerk; Philip of Meldrum/Feodarg, knight; Reginald Bustleir, master; Robert de Wauchope, knight; William Comyn, clerk, son of Earl William 3/12/27 (St A. Lib., 282-3)
circa 1250 X 1277 Renewal of the gift of one stone of wax yearly to light the church of Durham Sicut Clause John Comyn, lord of Badenoch (d.1302); Robert Neville; Robert, son of Robert Neville 3/167/11 (ND, App., no. 176)
circa 1250 X 1277 Gift of one stone of wax yearly at the feast of St Cuthbert in September to light the church of Durham Grantor 3/167/11 (ND, App., no. 176)
circa 1277 X Renewal of oxgang in territory of Kirkintilloch (DNB) Sicut Clause Adam Scott (late 13C); Christina, daughter of persona of Kippen; David de Gartenocht ; Fergus mac Cinn Éitig (Kennedy); John, brother of Fergus Kennedy; Malcolm, constable; Robert of Coulton, knight; William Ruffus, knight (13C) 3/167/14 (Camb. Reg., xxxi-ii)
undated Steward of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/247/1 (Kel. Lib., no. 187)
undated Son of Richard Comyn (d.c.1179) (Familial relationship) subject (relationship) 3/350/10 (Holy. Lib., App. II, no. 6)
24 Aug. 1198 X 16 Oct. 1198 Son of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/83/6 (Arb. Lib., no. 89)
1202 X 7 Sept. 1206 Justiciar of William I, king of Scots (d.1214) (Employment relationship) subject (relationship) 3/101/3 (Arb. Lib., no. 74(bis))
1204 X 17 Aug. 1214 Justiciar of William I, king of Scots (d.1214) (Employment relationship) subject (relationship) 3/245/4 (C.A. Rent., 340-1, no. 60)
2 Jun., 1208 X 1211 Justiciar of William I, king of Scots (d.1214) (Employment relationship) subject (relationship) 1/6/464 (RRS, ii, no. 497)
9 Oct. 1211 X 1224 Chaplain of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/12/13 (Abdn. Reg., 14-5)
9 Oct. 1211 X 1224 Chaplain of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/12/14 (Mort. Reg., ii, no. 5)
9 Oct. 1211 X 1224 Sister of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/12/14 (Mort. Reg., ii, no. 5)
9 Oct. 1211 X 1224 Man (homo) of William Comyn, earl of Buchan (d.1233) (Tenurial & lordship relationship) object (relationship) 3/12/14 (Mort. Reg., ii, no. 5)
9 Oct. 1211 X 1233 Vassal (vassallus/cliens) of William Comyn, earl of Buchan (d.1233) (Tenurial & lordship relationship) object (relationship) 3/12/20 (Camb. Reg., xxx)
9 Oct. 1211 X 1233 Chaplain of William Comyn, earl of Buchan (d.1233)(Employment relationship) object (relationship) 3/12/12 (NRS, RH 1/2/32)
9 Oct. 1211 X 1233 Heir of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/9 (St A. Lib., 251-2)
9 Oct. 1211 X 1233 Priest of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/12/20 (Camb. Reg., xxx)
9 Oct. 1211 X 1233 Clerk of William Comyn, earl of Buchan (d.1233)(Employment relationship) object (relationship) 3/12/12 (NRS, RH 1/2/32)
9 Oct. 1211 X 1233 Wife (uxor) of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/12/16 (Dryb. Lib., no. 18)
9 Oct. 1211 X 1233 Steward of William Comyn, earl of Buchan (d.1233)(Employment relationship) object (relationship) 3/12/12 (NRS, RH 1/2/32)
9 Oct. 1211 X 1233 Lord (dominus) of William Comyn, earl of Buchan (d.1233) (Tenurial & lordship relationship) object (relationship) 3/12/16 (Dryb. Lib., no. 18)
9 Oct. 1211 X 1233 Daughter of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/11 (NRS, RH 1/2/31)
9 Oct. 1211 X 1233 Wife (uxor) of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/7 (St A. Lib., 250)
9 Oct. 1211 X 1233 Son of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/12/15 (Glas. Reg., no. 117)
9 Oct. 1211 X 1233 Heir of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/7 (St A. Lib., 250)
9 Oct. 1211 X 1233 Chaplain of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/12/15 (Glas. Reg., no. 117)
9 Oct. 1211 X 1233 Wife (uxor) of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/9 (St A. Lib., 251-2)
circa 1212 X 4 Dec. 1214 Son of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/167/5 (Scone Lib., no. 98)
25 Feb. 1213 Sheriff of William I, king of Scots (d.1214) (Employment relationship) subject (relationship) 1/6/479 (RRS, ii, no. 513)
17 Aug. 1214 Son of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/167/4 (ND, App., no. 175)
17 Aug. 1214 Heir of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/167/4 (ND, App., no. 175)
1219 X 1233 Chaplain of William Comyn, earl of Buchan (d.1233) (Employment relationship) object (relationship) 3/12/18 (A.B. Ill., ii, 427-8)
1219 X 1233 Bride/betrothed (f.) (sponsa) of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/12/17 (A.B. Ill., ii, 426-7)
1219 X 1233 Wife (uxor) of William Comyn, earl of Buchan (d.1233) (Familial relationship) object (relationship) 3/12/17 (A.B. Ill., ii, 426-7)
2 Nov. 1220 X 22 Feb. 1222 Lord (dominus) of William Comyn, earl of Buchan (d.1233)(Tenurial & lordship relationship) object (relationship) 3/12/21 (Arb. Lib., no. 130)
2 Nov. 1220 X 22 Feb. 1222 Bride/betrothed (f.) (sponsa) of William Comyn, earl of Buchan (d.1233)(Familial relationship) object (relationship) 3/12/21 (Arb. Lib., no. 130)
2 Nov. 1220 X 22 Feb. 1222 Chaplain of William Comyn, earl of Buchan (d.1233)(Employment relationship) object (relationship) 3/12/21 (Arb. Lib., no. 130)
Jan. 1224 X 1233 Sons of William Comyn, earl of Buchan (d.1233) (Familial relationship) None 3/12/19 (NLS, Ch. 15532)
7 Jun. 1244 X 1289 Father of Alexander Comyn, earl of Buchan (d.1289)(Familial relationship) subject (relationship) 3/12/27 (St A. Lib., 282-3)
circa 1250 X 1277 Predecessor of John Comyn, lord of Badenoch (d.1277) (Tenurial & lordship relationship) subject (relationship) 3/167/11 (ND, App., no. 176)
15 Feb. 1315 Bride/betrothed (f.) (sponsa) of William Comyn earl of Buchan (d. 1233) [Familial relationship] object (relationship) 1/53/54 (RRS, v, no. 48)
circa 1199 X 17 Aug. 1214 Dominus (Lord/Sir) 3/386/2 (Newb. Reg., no. 88)
22 Jun., 1199 X 1214 justice 1/6/459 (RRS, ii, no. 493)
1202 X 7 Sept. 1206 justiciar 3/101/3 (Arb. Lib., no. 74(bis))
24 Aug., 1203 X 1207 justice 1/6/432 (RRS, ii, no. 465)
1204 X 17 Aug. 1214 justiciar 3/245/4 (C.A. Rent., 340-1, no. 60)
14 Jan., 1205 X 1210 justice 1/6/456 (RRS, ii, no. 490)
18 Aug., 1205 X 1207 justiciar 1/6/441 (RRS, ii, no. 475)
22 Mar., 1206 X 1207 justiciar 1/6/438 (RRS, ii, no. 472)
6 Mar., 1208 X 1210 justiciar 1/6/462 (Hodge, SHR 86, 317)
2 Jun., 1208 X 1211 justiciar 1/6/464 (RRS, ii, no. 497)
18 Apr., 1209 X 1211 justice of Scotia 1/6/451 (RRS, ii, no. 485)
23 May, 1209 X 1211 justice of Scotia 1/6/458 (RRS, ii, no. 492)
7 Jan. 1210 justice of Scotia 1/6/455 (RRS, ii, no. 489)
9 Oct., 1211 X 1213 justice of Scotia 1/6/469 (RRS, ii, no. 502)
9 Oct. 1211 X 1224 earl of Buchan 3/12/13 (Abdn. Reg., 14-5)
9 Oct. 1211 X 1224 earl of Buchan 3/12/14 (Mort. Reg., ii, no. 5)
9 Oct. 1211 X 1233 justiciar of Scotia 3/12/7 (St A. Lib., 250)
9 Oct. 1211 X 1233 earl of Buchan 3/12/8 (St A. Lib., 251)
9 Oct. 1211 X 1233 earl of Buchan 3/12/9 (St A. Lib., 251-2)
9 Oct. 1211 X 1233 earl of Buchan 3/12/15 (Glas. Reg., no. 117)
9 Oct. 1211 X 1233 earl of Buchan 3/12/10 (St A. Lib., 252)
9 Oct. 1211 X 1233 earl of Buchan 3/12/20 (Camb. Reg., xxx)
9 Oct. 1211 X 1233 justiciar of Scotia 3/12/10 (St A. Lib., 252)
9 Oct. 1211 X 1233 earl of Buchan 3/12/16 (Dryb. Lib., no. 18)
9 Oct. 1211 X 1233 earl of Buchan 3/12/11 (NRS, RH 1/2/31)
17 Aug., 1212 X 1214 earl of Buchan 1/6/488 (RRS, ii, no. 522)
8 Sept., 1212 X 1214 earl of Buchan 1/6/489 (RRS, ii, no. 523)
8 Sept., 1212 X 1214 justiciar of Scotia 1/6/489 (RRS, ii, no. 523)
25 Feb. 1213 sheriff of Forfar 1/6/479 (RRS, ii, no. 513)
12 Feb., 1215 X 1221 earl of Buchan 1/7/5 (RRS, iii, no. 5)
12 Feb., 1215 X 1221 justiciar of Scotia 1/7/5 (RRS, iii, no. 5)
17 Feb. 1215 sheriff of Forfar 1/7/6 (RRS, iii, no. 6)
17 Mar. 1215 earl of Buchan 1/7/10 (RRS, iii, no. 10)
17 Mar., 1215 X earl of Buchan 1/7/9 (RRS, iii, no. 9)
18 Apr. 1215 earl of Buchan 1/7/18 (RRS, iii, no. 18)
28 Jun., 1215 X 1219 justiciar of Scotia 1/7/23 (RRS, iii, no. 23)
28 Jun., 1215 X 1219 earl of Buchan 1/7/23 (RRS, iii, no. 23)
23 Jul. 1215 justiciar of Scotia 1/7/25 (RRS, iii, no. 25)
23 Jul., 1215 X 1221 earl of Buchan 1/7/26 (RRS, iii, no. 26)
23 Jul., 1215 X 1221 justiciar of Scotia 1/7/26 (RRS, iii, no. 26)
circa 22 Oct. 1215 earl of Buchan 1/7/27 (RRS, iii, no. 27)
24 May, 1216 X 1219 earl of Buchan 1/7/29 (RRS, iii, no. 29)
24 May, 1216 X 1219 justiciar of Scotia 1/7/29 (RRS, iii, no. 29)
26 Mar., 1217 X 1219 earl of Buchan 1/7/35 (RRS, iii, no. 35)
1219 X 1233 Barry (BNF) Holder (possession) 3/12/17 (A.B. Ill., ii, 426-7)
18 February 1175 X 17 August 1214 Renewal of land of 'Balnebuth' (MLO) 3/254/4 (Newb. Reg., no. 9)
1178 X 1187 Gift of ferry-boat of Montrose with land belonging to it 1/6/204 (RRS, ii, no. 228)
1178 X 1 August 1189 Confirmation of donation made by Turpin, bishop of Brechin 1/6/205 (RRS, ii, no. 229)
6 January 1179 X 2 March 1189 Renewal of customs and dues in time of King David, and marches which he granted to them 1/6/221 (RRS, ii, no. 244)
1182 X 17 August 1214 Gift of fisheries on Tweed near Berwick (BWK) 3/387/2 (Melr. Lib., no. 21)
1185 X 1190 Gift of Madderty (PER) 1/6/233 (RRS, ii, no. 258)
15 March 1187 X 23 March 1189 Confirmation of agreement between Ingram, bishop of Glasgow and Robert de Brus 1/6/235 (RRS, ii, no. 260)
1189 X circa 1193 Confirmation of two ploughgates (Ardlair, ABD) 1/6/319 (RRS, ii, no. 348)
1189 X 1194 Confirmation of donation by Robert of Berkeley and his wife, Cecily 1/6/313 (RRS, ii, no. 342)
1189 X 1194 Gift of church of Panbride (ANG) 1/6/298 (RRS, ii, no. 327)
1189 X 1194 Gift of church of Monikie (ANG) and common pasture in parish of Monikie 1/6/299 (RRS, ii, no. 328)
1189 X 1194 Gift of church of Inverlunan (ANG) 1/6/326 (RRS, ii, no. 355)
1189 X 1194 Gift of Fowlis Easter (ANG) and two tofts 1/6/273 (RRS, ii, no. 302)
1189 X 1194 Gift of church of Fyvie (ABD) 1/6/327 (RRS, ii, no. 356)
1189 X 1194 Gift of annual rent of 3 marks 1/6/275 (RRS, ii, no. 304)
1189 × 1194 Gift of church of Inverness (INV) 1/6/328 (RRS, ii, no. 357)
1189 X 1195 Gift of churches of Forres and Dyke 1/6/332 (RRS, ii, no. 361)
1189 X 1195 Gift of full toft in Forfar (ANG) 1/6/312 (RRS, ii, no. 341)
1189 X 1195 Concession to build mill and to have easements in forests 1/6/333 (RRS, ii, no. 362)
1189 X 1195 Donation of lands of Ederpolls (Grange, PER) 3/276/2 (C.A. Rent., 336-7, no. 46)
1189 X 1195 Confirmation of donation of Muiravonside (WLO) 1/6/291 (RRS, ii, no. 320)
1189 X 1195 Command of payment of teinds 1/6/345 (RRS, ii, no. 374)
1189 X 1195 Gift of Fowlis Easter (ANG) 1/6/346 (RRS, ii, no. 375)
1189 X 1195 Gift of four ploughgates in Conveth (Laurencekirk, KCD) 1/6/315 (RRS, ii, no. 344)
1189 X 1195 Succession of Kinkell, Pitkenny and Pitsporgy 1/6/318 (RRS, ii, no. 347)
1189 X 1195 Gift of church of St Cyrus (KCD), with apdaine, chapel of St Regulus, half a ploughgate, church of Inchture (PER) 1/6/304 (RRS, ii, no. 333)
1189 X 1195 Confirmation of church of St Cyrus (KCD), chapel of St Regulus, half ploughgate, land of apdaine of Ecclesgreig, common pasture 1/6/323 (RRS, ii, no. 352)
1189 X 1195 Quitclaim of right to patronage of church of Abernethy (PER) with named chapels, lands and teinds 3/42/1 (Arb. Lib., no. 35)
1189 X 1195 Gift of church of Abernethy (PER) with certain chapels and teinds 1/6/310 (RRS, ii, no. 339)
1189 X 1195 Confirmation of donation which Hugh Giffard and William, his son, have made of church of Tealing with tofts 1/6/329 (RRS, ii, no. 358)
1189 X 1195 Gift of Strachan (KCD) 1/6/311 (RRS, ii, no. 340)
1189 X 1195 Concession of fair at Glasgow 1/6/279 (RRS, ii, no. 308)
1189 X 1200 Confirmation of half mark from fishery of Meikleour (PER) 1/6/387 (RRS, ii, no. 419)
25 September, 1189 X 1198 Gift of toft in burgh of Kintore (ABD) 1/6/363 (RRS, ii, no. 393)
29 September 1189 X 1190 Confirmation of chapel of Park, and buildings of Colmslie, Buckholm and Whitelee 1/6/272 (RRS, ii, no. 301)
1 April 1190 X 1193 Confirmation of agreement between Kelso Abbey and Robert of Kent, Robert Hunaud, Roland, son-in-law of Nicholas de Côtentin 1/6/290 (RRS, ii, no. 319)
1191 X 15 February 1198 Quitclaim from subjection 2/73/11 (Lind. Cart., App. I)
1194 X 15 January 1200 Agreement between Richard, bishop of Moray, and Duncan, earl of Fife 4/15/2 (SEA, i, no. 114)
13 January, 1195 X 1199 Gift of toft in Montrose (ANG) 1/6/377 (RRS, ii, no. 409)
16 April, 1195 X 1196 Confirmation of donations of grandfather and father of Earl Patrick, and Earl Patrick himself 1/6/357 (RRS, ii, no. 386)
31 August, 1195 X 1198 Confirmation of land (i.e. Raeshaw) in feu of Hownam (ROX) 1/6/353 (RRS, ii, no. 382)
19 September, 1195 X 1206 Donation of Persey (PER) and part of Cally (Monks Cally?) 1/6/367 (RRS, ii, no. 397)
13 October, 1195 X 1214 Gift of land in Fife, as perambulated, common pasture and a toft in Crail and freedom from multure 1/6/435 (RRS, ii, no. 469)
circa 1196 X 4 November 1203 Renewal of land of Ogilface (WLO) 3/590/7 (Holy. Lib., no. 44)
12 January, 1196 X 1199 Gift of church of Guthrie (ANG) 1/6/376 (RRS, ii, no. 408)
10 March, 1196 X 1201 Confirmation of Kinninmonth (FIF) with the three Magasks (FIF), 'Inchalc' (in Ceres, FIF), Ladeddie (FIF), 'Incherech' and Baldinnie (FIF), and toft in burgh of St Andrews 1/6/379 (RRS, ii, no. 411)
2 May, 1196 X 1197 Concession of liberty to undergo trial by oath rather than trial by combat 1/6/359 (RRS, ii, no. 388)
31 July 1196 Gift of Strathisla (BNF) 1/6/362 (RRS, ii, no. 391)
20 August, 1196 X 1200 Confirmation of part of Beath (FIF) which Waltheof (Waldef) held 1/6/366 (RRS, ii, no. 396)
|
cc/2019-30/en_head_0021.json.gz/line27443
|
__label__wiki
| 0.541625
| 0.541625
|
Home / Books / The Apocalypse Book Club: April Selection—‘The Man in the High Castle’
The Apocalypse Book Club: April Selection—‘The Man in the High Castle’
Tea Krulos May 4, 2017 Books
(Penguin Books)
The Apocalypse Blog Book Club picks a different dystopian-themed novel to read each month and has an online discussion, as well as an in-person meeting in Milwaukee. Different club members will write reports on our selections each month for Pop Mythology. You can find more on the club and join here: teakrulos.com/the-end/
When I was in my early twenties I went through a Philip K. Dick phase, largely inspired because I loved the film Blade Runner, which was based on his novel Do Androids Dream of Electric Sheep? I read a dozen or two of his books consecutivelyand thought I was pretty badass sitting at the local café reading dog-eared copies of Flow my Tears, the Policeman Said and A Scanner Darkly. I loved his ideas that played with reality and identity. With that out of my system, I moved on and haven’t picked up a Philip K. Dick book for close to 20 years, although I have watched film versions of his work that have popped up.
Dick’s Hugo award winning novel The Man in the High Castle, first published in 1962, is one of Dick’s many creative visions, the first (as far as I know) alternative history that imagines a simple but frightening question: what if the Axis forces won World War II? Dick’s dystopia imagines Imperial Japan controlling the West Coast of America as the Japanese Pacific States, Nazi Germany commanding the Greater Nazi Reich on the East Coast of America, with a neutral no man’s land zone separating the two in the mountain states.
What a time to read this story again! You might dismiss the cries of the USA becoming a fascist state as hyperbole, but you can’t ignore the writing on the wall. There’s the fearmongering and scapegoating of Mexicans and Muslims, the self-described “war” on the Fourth Estate, the cabinet of white power toadies like Steve Bannon, and the narcissistic supreme leader, obsessed with his own imagery and with degrading his never-ending list of enemies. Fascism didn’t literally come goose-stepping down Pennsylvania Avenue, but rose through an election buoyed by a certain population of xenophobic and downtrodden Americans bamboozled by an egotistical character actor who charmed them with the skill of a conman selling timeshares. “Let me fool you twice,” he invited.
Have we somehow entered a parallel universe where “the good guys” lost? Alas, if only it were so simple an explanation. The real one, of course, is that this was the sad evolution of America.
Back to Dick’s 1962 novel. The storylines Dick follows take place in the neutral zone and in an alternate version of San Francisco, familiar territory for Dick to work with as he lived in the Bay Area. Dick’s cast—Japanese trade official NobusukeTagomi, Americana antique dealer Robert Childan, desperate metalsmith Frank Frink, his wife Juliana, who has defected to Canon City in neutral Colorado, and the spy she meets there, Joe Cinnadella—weave paths around a powerful banned book. The Grasshopper Lies Heavy is an alternate history within this alternate history in which the Allies have triumphed, penned by the mysterious author Hawthorne Abendsen, aka the Man in the High Castle.
I will say that with my brain rewired for modern ACTION! ACTION! ACTION! I found the book to be slow placed at all times. I was like, “we got a whole alternate world to explore here, Dick, why is there such a high page count talking about jewelry making and antique forgery?”
This leads me to talk about the TV adaption. Renewed interest in the book, of course, has come from Amazon’s Emmy award winning The Man in the High Castle series, which has two seasons available and is signed up for a third. The character and their storylines are significantly different, but I believe it’s a good expansion of the book. You get to see a couple of things I had hoped would happen in the book (which I read before viewing the show) such as an appearance by old man Hitler, a character travelling from one parallel reality to another, and some action scenes of the Resistance fighting back. But all of that is just extra frosting on the cake—it’s Dick who laid down the solid foundation of this disturbing look at a fascist USA.
The Apocalypse Book Club: July Selection - ‘The Dispossessed’
The Apocalypse Book Club: May Selection - ‘The Sirens of Titan’
The Apocalypse Blog Book Club: March Selection - 'The Handmaid’s Tale'
About Tea Krulos
Tea Krulos is a freelance journalist and author of the new book 'Heroes in the Night' available from Chicago Review Press, which documents the Real Life Superhero (RLSH) movement. He also runs a blog with RLSH news and profiles.
|
cc/2019-30/en_head_0021.json.gz/line27445
|
__label__cc
| 0.709672
| 0.290328
|
I had a very close friend who passed away almost three years ago. He was such a dear friend to me that I think of him everyday, several times a day, and I miss him terribly as I go through a new phase of my life. He, of all people who could tell me not to complain (he had one of the most tragic lives of anyone I've ever known), would always listen patiently to me and with love.
He had a song (has? ...songs do live on) called "Lost in Transition" and it's been playing through my head a lot lately. His song was about being lost between being a boy and a man, as he struggled to find himself after his father's early death (when my friend was only 17). My friend David was so smart and talented, and although the verses sing about all the particulars, the chorus sang the universals, as the best songs have both those elements as part of the DNA in the lyrics.
In a world where people post all the good things, the happy things, the things that can spur on feelings of inadequacy in so many people... I just long for a world that is real. Real everywhere... online too. Right now, I feel like I'm apologizing for this post and I don't want to apologize for it. I don't want to apologize anymore...
Here is David Lang's song "Lost in Transition" (I'm sure he wouldn't mind me posting). He recorded all the parts himself on a 4-track cassette-recorder, ping-ponging all the tracks down to get more than four. He was the first person to show me how to record and even gave me his 4 track recorder years ago... over 20 years ago.
He was quite young when he wrote and recorded this, without all the home technology people have today (there I go, apologizing again! But it's true, listen to the song beyond the recording quality). This may be circa 1994 or 1995...
Thank you, David, for being a wonderful friend. I miss you.
dave, me and his dog, sweetie pie II
In music Tags friendship, death, early death, music, songwriting, tragedy, love, miss, friend
|
cc/2019-30/en_head_0021.json.gz/line27451
|
__label__wiki
| 0.848186
| 0.848186
|
History - Ancient/General
Religion - Antiquities & Archaeology
Honor and Personhood in Early Modern Mexico
Osvaldo F. Pardo
An examination of the concept of honor as essential to both colonial Spaniards and indigenous Mexicans
Osvaldo F. Pardo examines the early dissemination of European views on law and justice among Mexico’s native peoples. Newly arrived from Spain in the sixteenth and seventeenth centuries, mendicant friars brought not only their faith in the authority of the Catholic Church but also their reverence of the monarchy. Drawing on a rich range of documents dating from this era—including secular and ecclesiastical legislation, legal and religious treatises, bilingual catechisms, grammars on indigenous languages, historical accounts, and official reports and correspondence—Pardo finds that honor, as well as related notions such as reputation, came to play a central role in shaping the lives and social relations of colonists and indigenous Mexicans alike. Following the application and adaptation of European ideas of justice and royal and religious power as they took hold in the New World, Pardo sheds light on the formation of colonial legalities and long-lasting views, both secular and sacred, that still inform attitudes toward authority in contemporary Mexican society.
“The author shows the polyphonic nature of the notion of persona by devoting chapters on material possessions, restitution, honor, and punishment as conceived and discussed by the missionaries. In doing so, the author opens a fascinating window into the tense and complicated relationship between religious conversion, cultural mediation, and political authority in early colonial Mexico.”
—Javier Villa-Flores, University of Illinois, Chicago
“This work provides a unique compendium of evidence that should prove exceedingly useful to social and cultural historians of colonial Spanish America.”
—David Tavárez, Vassar College
Osvaldo Pardo is Associate Professor of Spanish at the Department of Literatures, Cultures and Languages of the University of Connecticut. He is the author of The Origins of Mexican Catholicism: Nahua Rituals and Christian Sacraments in Sixteenth-Century Mexico (University of Michigan Press, 2006).
"Pardo makes an important contribution to the understanding of how regular clergy served as the first line of education for many native peoples. He persuasively impels the reader to consider the importance of ecclesiastical voices for understanding the legal and social structure of empire."
--American Historical Review
"Basing his book on a vast array of archival documents, bilingual catechisms, ecclesiastical and secular treatises, legislative treatises, bilingual grammar treatises, historical accounts, letters, and a rich secondary literature, Pardo has produced a complex and intriguing cultural study of colonial Mexico."
--The Catholic Historical Review
"Impressive in the scope of its research, this study will be of interest to a wide range of scholars of early modern Latin America."
--Renaissance Quarterly
"This study is well worth reading...Pardo provides a rare look at the ways that clerics shaped the viewpoints of indigenous peoples not so much in religious terms but in their sense of self and moral values. The book should find audiences among specialists but also with any scholar interested in colonial studies."
--Hispanic American Historical Review
"Essential reading for anyone interested in the religious orders, colonial pedagogy, material culture, and the
many discursive trajectories of honour and personhood in early modern Mexico."
--Itinerario
"An essential book for those students and researchers interested in these processes, in addition to scholars and certainly researchers of history from Mexico. They will be treated to a scholarly and well documented book."
--Rechtsgeschichte
The Most Noble of People
Medieval Women and Their Objects
The Mirror of Spain, 1500-1700
Conflict and Coexistence
The Jesuit and the Incas
A Network of Converso Families in Early Modern Toledo
The Neapolitan Recipe Collection
Making the World Safe for Existence
16 images.
Spain, New World, Mexico, law, justice, Catholic Church, Mendicant orders, criollos, Mexican, medieval, renaissance, Latin America, Latin American studies, religion, religious studies, ancient history, antiquity, Mexican history, colonial, colonialism, Spanish, indigenous people, material possessions, restitution, honor, punishment, Spanish America
|
cc/2019-30/en_head_0021.json.gz/line27453
|
__label__wiki
| 0.837908
| 0.837908
|
OTCBB:LSTG
Lone Star Gold to acquire 65% stake in Mexican tailings facility
14:15 04 Jan 2012
Lone Star Gold (OTCBB:LSTG) late Tuesday signed a definitive agreement to acquire a 65 percent interest in a tailings facility located in the city of Hidalgo Del Parral, in the state of Chihuahua, Mexico.
According to the current owners, the facility represents a resource of about 1.2 million tons of mine tailings, which show potential for silver recovery and additional bi-products such as gold, zinc, and lead.
The company had originally signed a letter of intent to purchase the undivided 65 percent interest in late November 2011. Following the company's due diligence, which included positive results from 40 undisturbed samples, Lone Star opted to move forward with the deal.
The definitive agreement will be signed by the company's president, Daniel Ferris, in mid-January, during his upcoming visit to Chihuahua, Mexico.
Ferris commented: "From the moment we first identified this opportunity it was clearly an ideal fit with our goal of rapidly becoming a mid-tier producer in the short term.
"Once we've signed the Definitive Agreement in mid-January, we'll effectively be in the position of potentially beginning 6-8 years of production as soon as February 2012."
Under the terms of the agreement, Lone Star will issue a total of 600,000 shares of its common stock over a one-year period, upon signing of the agreement. The deal also outlines up to $1.55 million in cash commitments over the first two years for initial and secondary project work, including equipment and plant construction.
Lone Star said that it plans to form a Mexican subsidiary, which will hold the 65 percent interest in the tailings project. Once the 1.2 million tons of mine tailings have been processed, the company will forfeit its interest in the Mexican company, including the plant and the equipment.
The initial stage of the tailings project will see Lone Star move 100 tons per day (tpd) in tailings to a processing plant in Parral for the first four to six months, starting next month. After that, throughput will be increased to about 200 tpd for the next six to 12 months.
The secondary stage of the project will see the construction of a heap leach pad and possibly a float plant. The expected maximum cost for both these projects would be about $1.5 million.
The plant, which would take between four and six months to construct, is expected to boost capacity to between 200 and 300 tpd, before ramping up to about 600 tpd after the first six months. This onsite plant is expected to liberate over 85 percent of the resources in the tailings pile, Lone Star said.
Based in Albuquerque, New Mexico, Lone Star has a 70 percent working interest in the La Candelaria project, located to the west of the tailings facility, as well as an option to purchase a 70 percent interest in the Ocampo project, located to the northwest of the tailings facility.
RA International's rush of contracts reflects growing presence in remote location infrastructure
Register here to be notified of future LSTG Company articles
View full LSTG profile View Profile
Lone Star Gold Timeline
King River Resources remains focused on world-class Speewah vanadium development
The company is progressing a pre-feasibility study which will help determine the best commercialisation strategy for development of the Speewah Specialty Metals Project.
Chase Mining Corporation planning Quebec drilling campaign kick-off at Lorraine
Contractors have been drawing up quotes this month, with drilling at the historic mine project set to start later this quarter.
Pantoro’s gold production at Halls Creek exceeds feasibility study target
Pantoro ended the December 2018 quarter with $20.8 million in cash and gold. The company remains debt free.
Lone Star Gold
Lone Star Gold, Inc., an exploration stage company, engages in the acquisition, exploration, and development of gold and other precious metal properties in Mexico and the United States.
Market: PINK
EPIC: LSTG
Latest Price: $0.80 (77.78 % )
52-week H/L: $2.12 / $0.05
|
cc/2019-30/en_head_0021.json.gz/line27454
|
__label__wiki
| 0.949271
| 0.949271
|
Credits: The War of the Roses, Matilda
DANNY DeVITO is one of the entertainment industry’s most versatile players, excelling as actor, producer and director.
The award-winning performance as Louie De Palma on the television show Taxi was what propelled DeVito to national prominence. He won both an Emmy and a Golden Globe. In a 1999 readers’ poll conducted by TV Guide, DeVito’s Louie De Palma was voted number one among “TV’s Fifty Greatest Character’s Ever.”
On television, he was most recently seen in a guest role in Netflix’ The Kominsky Method.
In 2018 he returned as Frank Reynolds in FXX’s acclaimed cult comedy It’s Always Sunny in Philadelphia, for its thirteenth season. He will film season fourteen this year. DeVito has been reunited with director Tim Burton for Dumbo, in theaters now. He will subsequently been seen in the highly anticipated Untitled Jumanji: Welcome to the Jungle Sequel set for a December 2019 release. The next movie DeVito will film is a role in the biopic Harry Haft, directed by Barry Levinson.
In 2016, he was seen in Sony Classics’ The Comedian, with Robert De Niro and Leslie Mann, directed by Taylor Hackford. DeVito directed, starred in and co-produced short film Curmudgeons, which premiered at the 2016 Tribeca Film Festival and was later seen at the 2016 Seattle Film Festival and 2016 London Film Festival.The same year, De Vito also co-starred in the Todd Solondz’ dark comedy Wiener-Dog.
DeVito will be heard voicing the character Bob for Walt Disney Pictures The One and Only Ivan in 2020. In 2018, he was heard voicing Dorgle in Warner Bros.’ animated Smallfoot. Other recently voiced characters include the Lorax in Universal Pictures’ animated feature The Lorax, based on the book of the same name by Dr. Seuss. His voice was also heard in the German, Russian, Spanish and Italian versions of the film.
In 2012, DeVito and Richard Griffiths received rave reviews in the London stage revival of Neil Simon’s comedy The Sunshine Boys. The following year, DeVito reprised his critically acclaimed role together with former Taxi co-star Judd Hirsch in Los Angeles. DeVito made his Broadway debut in 2017 in Arthur Miller’s The Price in the role of Gregory Solomon, earning him his first Tony Award nomination. He won a Drama Desk Award, Outer Critics Circle Award and Broadway.com Audience Choice Award for the role.
In 2015, DeVito was executive producer on the biographical documentary Harold and Lillian: A Hollywood Love Story. In 2014, he co-produced Universal Pictures’ crime drama A Walk Among the Tombstones and starred in All The Wilderness. In 2012, DeVito starred in Sebastian Gutierrez’s black and white crime drama, Hotel Noir.
Throughout his career, DeVito has directed more than 25 projects, including Matilda, Death To Smoochy, The War of the Roses, Hoffa, Throw Momma From the Train, The Ratings Game and numerous short films, TV movies and episodes of television, including Taxi. He is also the principal of Jersey Film’s 2nd Avenue, a successor company of Jersey Films. Jersey Films has produced over 20 motion pictures, including Freedom Writers, Be Cool, Garden State, Along Came Polly, Man on the Moon, Pulp Fiction, Out of Sight, Get Shorty, Hoffa, Matilda, Living Out Loud and Erin Brockovich, which was nominated for an Academy Award.
Apart from his work with Jersey Films, DeVito has starred in such films as The War of the Roses, Junior, Batman Returns, Twins, Romancing the Stone, Jewel of the Nile, Ruthless People, Throw Momma From the Train, Tin Men, Anything Else, Big Fish, Renaissance Man, The Big Kahuna and Heist.
He also starred in The Good Night, Deck The Halls, Relative Strangers, The OH in Ohio, Be Cool, Nobel Son and Even Money.
DeVito attended Our Lady of Mt. Carmel grammar school and Oratory Prep School in Summit, N.J., but appeared in only one school play, as St. Francis of Assisi. After graduation, he pursued several odd jobs, always with the idea of acting in the back of his mind. He finally entered the American Academy of Dramatic Arts in New York. “They had fencing and a speech class,” he said mockingly, “So you don’t talk funny.” Unable to get work, Danny bought a round-trip ticket and headed to Hollywood. After years of unemployment, he returned to New York. He called an old friend and former American Academy professor who, coincidentally, had been seeking him out for a starring role in one of three one-act plays presented together under the title of The Man With the Flower in His Mouth. Soon Danny was into big money ($60 a week), and other stage performances followed.
Among his credits were Down the Morning Line, The Line of Least Existence, The Shrinking Bride and One Flew Over the Cuckoo’s Nest. In 1975, under a grant from the American Film Institute, Danny and his wife, actress Rhea Perlman, wrote and produced Minestrone, which has been shown twice at the Cannes Film Festival and has been translated into five languages. Later they wrote and produced a 16-millimetre black-and-white short subject, The Sound Sleeper, which won first prize at the Brooklyn Arts and Cultural Association competition.
In 2018, the mayor of Asbury Park, NJ — the town in which he was raised — declared November 17 (DeVito’s birthday) as Danny DeVito Day in the city of Asbury Park, in perpetuity.
DeVito carries his success well. Never forgetting that there were more difficult times, he maintains a healthy sense of perspective. As Taxi character Louie DePalma, would say, “If you don’t do good today, you’ll be eatin’ dirt tomorrow.”
All Sessions By Danny DeVito
Conversation With: Michael Douglas and Danny DeVito
Saturday, June 8, 2019 11:15 AM – 12:30 PM
|
cc/2019-30/en_head_0021.json.gz/line27455
|
__label__wiki
| 0.866767
| 0.866767
|
October 20, 2011 / 2:20 AM / 8 years ago
Ideology trumped science at Texas agency, two lawmakers say
Erin Mulvaney
BEAUMONT, Texas (Reuters) - Two Democratic state senators from Texas accused the state’s environmental agency of letting ideology trump science when it deleted information about the implications of global warming from a draft report.
The dried south fork of Lake Arlington is seen near Bowman Springs Park, where park personnel indicated the water level was nine feet below normal, in Arlington, Texas August 5, 2011. REUTERS/Mike Stone
The leaders of the agency, the Texas Commission on Environmental Quality, are appointed by Republican Governor Rick Perry, who said in a recent presidential debate that the science of climate change was “unsettled.”
At issue is “The State of the Bay 2010” report commissioned by the Texas Commission on Environmental Quality, which has come under scrutiny after Rice University Professor John Anderson said that an article regarding sea-level changes he contributed was censored for political reasons.
Democratic state Senators Rodney Ellis of Houston and Leticia Van de Putte of San Antonio wrote to Perry appointee Bryan Shaw, chairman of the commission.
In his letter, Ellis said he concluded from the deletions that “the facts simply proved inconvenient to the agency and other state leadership, and thus they were excised.”
The commission said on Monday it would remove Anderson’s article on sea-level rise in Galveston Bay from the report, ending a standoff with Anderson over the deleted information.
Commission spokesman Andy Saenz said Anderson prematurely revealed the draft report to the media without prior approval, and that the commission did not want to include controversial implications about global warming in the report.
“Why would we include things we don’t agree with? That’s ridiculous,” Saenz said. “We were looking at not including very controversial things that are unsettled science.”
Two co-editors of the project, Jim Lester and Lisa Gonzalez, scientists with the Houston Advanced Research Center, a nonprofit research facility contracted for the report, asked the agency to remove their names, fearing their own credibility.
Lester, the center’s vice president, called the deletions “scientific censorship.” He said Anderson’s statements in the article were not political and were reviewed by lower-level staff at the agency before upper management made its own edits.
“As a scientist, my main concern is about the availability of objective science for decision-making in agencies,” Lester said.
Saenz denied the claims of scientific censorship.
“Using a word like censorship is very powerful,” he said. “It isn’t censorship to accurately report in our document what we believe. That’s being responsible. That’s being accurate.”
Saenz said the agency was preparing a response to the senators. The agency, which is embroiled in a lawsuit with the Environmental Protection Agency over greenhouse gas emissions, has been working on the report for more than two years, the agency said.
Editing by Corrie MacLaggan and Cynthia Johnston
|
cc/2019-30/en_head_0021.json.gz/line27457
|
__label__wiki
| 0.961589
| 0.961589
|
Big Story 10
George and Amal Clooney on justice mission for women and gay people
Belinda Goldsmith
EDINBURGH (Thomson Reuters Foundation) - Celebrity couple George and Amal Clooney said on Thursday they wanted to use their star power to push for justice globally for women, children, LGBT+ people, religious minorities and journalists.
The 57-year-old Hollywood actor said some countries were using courts to do “really rotten things” and it was important to “shine a light” on where this was happening.
The couple’s Clooney Foundation for Justice, set up in 2016, plans to this year launch, TrialWatch, a project to monitor trials and create an index to track which countries are using courtrooms to oppress minorities and government critics.
Amal Clooney, an international human rights lawyer, said it was important to expose injustices and the countries using courts to target vulnerable people, human rights defenders and press freedom.
“We now have the highest number of journalists in jail in the world since records began,” she told a charity gala organized by the People’s Postcode Lottery in Edinburgh.
The Clooneys, who married in 2014, said they were both committed to using their fame to raise awareness about human rights abuses and corruption.
Amal Clooney, 41, said her job was less glamorous than it might seem as it mainly involved piling through vast amounts of paperwork but their fame could be used to their advantage.
“It helps when we want to engage governments to act or business leaders,” said the British-Lebanese lawyer.
Her actor husband also played down the glamor of fame, joking about being the father of one-year-old twins, but acknowledged that he had always been determined to use the public spotlight to do good.
“I didn’t grow up wealthy,” he said.
“If you end up getting lucky, you should share that luck.”
The Clooneys were in Scotland to collect an award from the People’s Postcode Lottery for their humanitarian work.
Britain’s People’s Postcode Lottery is one of several charity lotteries set up in Europe since 1989 by the Netherlands-based social enterprise Novamedia.
The lottery awards cash prizes and also donates about 32 percent of sales to charity, which has totaled more than 400 million pounds ($530 million) since 2005.
The organization has given money to some of George Clooney’s other charities and has also made a grant to the Thomson Reuters Foundation, the charitable arm of Thomson Reuters.
Reporting by Belinda Goldsmith @BeeGoldsmith; Editing by Katy Migiro. Please credit the Thomson Reuters Foundation, the charitable arm of Thomson Reuters, that covers humanitarian news, women's and LGBT+ rights, human trafficking, property rights, and climate change. Visit news.trust.org
|
cc/2019-30/en_head_0021.json.gz/line27458
|
__label__cc
| 0.653169
| 0.346831
|
Noi!se – “The Real Enemy”
Album Reviews | By Creature of War on Nov 14th, 2016
Record Label: Pirate Press Records
Genre: Streetpunk/Oi
Band Link: Noi!se on Facebook
Noi!se are a four-piece punk rock band hailing from Tacoma, Washington that sound one part Sick Of It All and one part Cock Sparrer.
It’s difficult to just describe the band’s sound as punk rock or streetpunk, etc. when they have a unique blend of American punk rock and British oi. You can compare them to early Dropkick Murphys or Bad Religion just as much as you can compare them to Stiff Little Fingers or the Business but it just doesn’t work. Noi!se have a sound that is heavily influenced by all of the aforementioned bands but a sound that manages to take those influences and put them all in a blender for something completely their own. It’s raw, energetic, powerful and full of punk rock spirit.
“The Real Enemy” is my first experience listening to Noi!se and I can’t believe that I haven’t heard them up until now. I can’t really compare their early sounds with what the band has to offer on “The Real Enemy” so I’ll just point out what I like about it instead. First off, two members of Noi!se are in active duty in the US military. Hats off to them! Secondly, topics like depression and the reality of post-traumatic stress disorder are the focus of some extremely honest and well written tracks on “The Real Enemy”. I’m certain that those songs are some of the most honest tracks that one will find on those subjects. Top that off with a furious oi-influenced punk rock soundtrack throughout the course of the albums’ twelve songs and you have yourself one kick ass album that will hit you in the heart as much as it will kick you in the balls.
Last but not least, overall “The Real Enemy” is one hell of a record. It’s on a different level than some of the dystopian streetpunk and melodic hardcore that you’ll find nowadays. While on other albums you’ll hear a band singing about the state of the nation about wanting to do something about it but with Noi!se, those guys are actually out there doing something about it on multiple fronts. That reverberates through their music on many levels. It’s one thing to sing about making a difference and another thing to put your life on the line while making a difference. It’s the old adage of putting your money where your mouth is. Don’t just say it, do it. And do it well. Noi!se does it very well.
Bottom Line: Fast and furious, poignant and striking…”The Real Enemy” is an album that the punk rock community needs to take note of.
Notable Tracks: The War Inside, Passing Time, End Of Days, Sea Of Apathy
Active Duty, Bad Religion, Cock Sparrer, Dropkick Murphys, hardcore, noise, oi!, Pirate Press Records, PTSD, punk, Sick Of It All, Stiff Little Fingers, streetpunk, Tacoma, The Business, The Real Enemy, US Army
Previous: Pulley – “No Change In The Weather”
Next: Metallica – “Hardwired to Self-Destruct”
Reel Big Fish & The Aquabats @ Roxian Theatre McKees Rocks, PA
P-Funk North – “Don’t Even Ask”
Nick Jonas of the Jonas Brothers is adopted!
Really Bad Songs To Annoy Your Friends With
Insulting Pick-Up Lines
ReadJunk Podcast – Travis Nelson (Hub City Stompers)
|
cc/2019-30/en_head_0021.json.gz/line27460
|
__label__wiki
| 0.771224
| 0.771224
|
REB Top 50 Women in Real Estate: Helen Yan number one again
27 August 2018 Tim Neary
Ray White Group’s Helen Yan has been announced as the top female agent nationally for the third year running in the REB Top 50 Women in Real Estate ranking for 2018.
The list ranks female real estate agents across Australia according to a range of metrics, including total sales volume, total number of deals and average sales price.
As director of Ray White Balwyn in Melbourne, Ms Yan completed 83 property transactions at a value of nearly $200 million for the 2017–18 financial year.
Ray White CEO for Victoria and Tasmania Domenic Belfiore said that Ms Yan was “an inspiration” and that he was delighted she had been recognised again.
“She’s an absolute star and we’re delighted to have her here. She’s a first-class agent who delivers first-class customer service and she’s someone who genuinely loves what she does,” Mr Belfiore said.
“Helen is a real advocate for women looking to break into the real estate industry and she demonstrates the commitment and professionalism needed to succeed.”
Ms Yan said that hard work and dedication was key to her recognition.
“I’m proud to be named number one woman in real estate again. It means a lot to me to be honoured for my hard work and commitment,” Ms Yan said.
“Customer service and delivering positive results for my clients is something close to my heart, and I’ll continue working the 15–17 hours a day to make people’s real estate dreams come true.”
The data collected for the REB Top 50 Women in Real Estate 2018 was verified by a senior member of the agency/network or the office’s accountant.
Click HERE to see the full REB Top 50 Women in Real Estate ranking for 2018.
Click HERE to see Friday’s Facebook Live reveal of the top 10 placed women.
Tim Neary
Last Updated: 27 August 2018 Published: 27 August 2018
|
cc/2019-30/en_head_0021.json.gz/line27461
|
__label__wiki
| 0.879666
| 0.879666
|
Real talks start with talking
On March 29, 2002, an 18-year-old woman walked into a Jerusalem supermarket and blew herself up. One of her victims was a woman just a year younger than herself. The two women looked so much alike, Palestinian and Israeli, and their mortal wounds were so similar, that the pathologist had trouble reassembling the two girls. They had so much in common.
So it was perhaps understandable that the mother of Rachel Levy would try to contact the mother of Ayat al-Akhras because they, too, had so much in common. They were both mothers. They had both lost daughters. They were both victims of the ongoing war for this little patch of earth and they lived, as it happened, a mere four miles from each other — Avigail Levy in Jerusalem and Um Samir al-Akhras in the West Bank refugee camp of
Deheishe. Still, it took them four years to talk — and then only by closed-circuit TV hookup.
Avigail Levy's attempt to reach an understanding with Um Samir al-Akhras is told in an HBO documentary called "To Die in Jerusalem." It is a frustrating film, lacking the snapping flags and sleek limos of the Middle East peace conference convened in Annapolis. But more than the communiques sure to be issued and the statements sure to be made, the inability of two mothers just to meet — not to mention understand one another — gives you a true and depressing picture of why no peace agreement is on the horizon. God is not in these details. The devil is.
It is the little issues that concern the two mothers. Avigail is controlled by fear. Four years after the bombing, she finally made it within a block of where Um Samir lives. But her car with its film crew was detained by the officious and suspicious Palestinian police. Daylight was gone. A guide told her how close they were. Avigail flinched. "No, it is too dark. I'm afraid to go there right now. It's too dark."
As for Um Samir, she will accept only some of the mother-to-mother rhetoric. The reality of her life is the repressive Israeli occupation. "We are living in misery," she tells Avigail. "My people are living in a camp. We have nothing."
Um Samir says she does not understand why Jews from all over the world have taken her country from her. Avigail, who is a second-generation Israeli, cannot accept such language. "She has to realize that there are two nations here," she says. "Palestine and Israel."
Avigail tries to salvage a shred of meaning from her daughter's meaningless death, but Um Samir thwarts her. The Palestinian's daughter valiantly resisted the Israeli occupation, her mother says. Avigail isn't buying. "You didn't get nothing and I didn't receive nothing," she says.
"For you it was nothing," Um Samir responds firmly. But for her daughter, it was enough. "For her cause and her honor, it was something." She returns again and again to the conditions imposed by the Israeli occupation. Avigail hardly hears what Um Samir is saying. She just wants the killing to end.
Having seen this documentary and read the transcript, I am transported to the lobbies of Washington's nice hotels where I have met over the years with the representatives of this or that Middle Eastern state, Israel included. No one is ever angry. Everyone is always reasonable. No one seeks to exterminate anyone. They all crowd the middle ground, say the same words. Formulaic phrases fall from their mouths like crumbs onto their laps — the "road map," "right of return," "Taba," "Camp David." You would think that the essentials for peace are bottled water and an ashtray.
But the facts on the ground are represented by these two mothers. The deaths of their daughters do not unite them. They talk past each other. They are virtual neighbors, but the distance between them is huge — roadblocks and checkpoints and mentalities ossified by 100 years of bloodshed. One is obsessed with the Israeli occupation. The other is preoccupied with the terrorism. One is right. The other is right.
Israel must relent. That's for sure. The Palestinians must forswear terrorism. That's for sure, too. The occupation has to end. Suicide bombings have to end. A Palestinian state has to be created. Gaza cannot remain a terrorist base. The West Bank cannot become a terrorist base. It's all so sensible. It's all so logical. But, really, down where it counts, the mothers of two dead daughters cannot even talk to each other.
"I didn't understand anything," Avigail says after four years of trying to establish a dialogue. "She didn't understand anything."
They issued no communique.
Richard Cohen's e-mail address is cohenr@washpost.com.
|
cc/2019-30/en_head_0021.json.gz/line27463
|
__label__cc
| 0.543591
| 0.456409
|
1940, Abner Biberman, Alma Kruger, Billy Gilbert, Cary Grant, Clarence Kolb, Ernest Truex, Frank Orth, Gene Lockhart, Helen Mack, His Girl Friday, Irving Bacon, John Qualen, Pat West, Ralph Bellamy, Regis Toomey, Reviews, Roscoe Karns
March 23, 2014 des 16 Comments
Cary Grant and Rosalind Russell among others in His Girl Friday (1940)
Wearing an outrageous, wacky suit with matching hat, the pattern zig zag, while holding her head high as she marches matter-of-factly into the “news room” was Rosalind Russell in the opening scene of the quintessential screwball comedy His Girl Friday. Her character, Hildy Johnson, is a woman that both men and women are wont to like. To women, she is that strong woman who is smarter, wittier, and more talented than the men around her, and that’s a woman to admire!
Ralph Bellamy, Cary Grant, and Rosalind Russell in His Girl Friday (1940)
To men, besides her intelligence and wit, she is also an incredibly beautiful woman who can keep up with anything a man does. Even though in 1940, this might be deemed as a threat to men, I think it is ridiculous to believe all men would be threatened by a woman like Hildy Johnson, much less the actress who plays her, who was very much like her in many ways. His Girl Friday paved the way for other “career women” roles in the 1940s, which was a character that Rosalind Russell in particular perfected to the point of being typecast.
Cary Grant and Rosalind Russell in His Girl Friday (1940)
It was announced that Rosalind Russell would play the part of Hildy Johnson, who was actually a man in the original play, but the character was now a woman in this version. However, when Miss Russell first discovered she’d been chosen, but after many other actresses had turned it down for various reasons, that sassiness in her came out. She was angry that she “was everybody’s fifteenth choice,” as she put it, so she took a dip in her pool the first day of work and walked right into the studio with her hair and clothes completely soaked. Even though her next movie job had started off with some bad behavior on Rosalind’s part, after her breakout role in The Women, His Girl Friday further cemented her place as a brilliant comedienne.
Even though she was typecast as a career woman, I cannot think of any other classic actress better at this type of role, and Hildy Johnson is arguably her best one. Tell me, can anyone possibly think of anyone but Rosalind Russell in the part? I certainly cannot. It was fate that she should land this role after so many top actresses turned it down.
Rosalind Russell and Cary Grant in His Girl Friday (1940)
Sassy Roz aside, she had a ball working with Cary Grant for the first time (and sadly the only time) because they were both very adept at ad libbing and extremely talented in the art of comedy. Many Rosalind Russell fans know this story, but I will briefly mention it: Cary Grant played matchmaker in Rosalind’s life as well. He had a friend, Danish-born Frederick Brisson, who was dying to meet Roz after he heard that Cary would be working with her. Although it took a long time for him to get that coveted date and Rosalind played rather hard to get during much of their courtship, they did fall in love and get married. And who was best man at their wedding? Nobody but Cary Grant, of course! And so a 37-year-long friendship blossomed between Rosalind and Cary.
Ernest Truex, Roscoe Karns, Rosalind Russell, and Regis Toomey in His Girl Friday (1940)
When the film opens, we (the viewers) see a barrage of reporters in the offices of the Morning Post, where Walter Burns (Cary Grant) is editor. The way the writers talk all at once, constantly overlapping each other, sets the scene for the entire movie. Rapid-fire and overlapping dialogue is a very important element of His Girl Friday and it goes on from beginning to end. I find this kind of movie to be awe-inspiring and absolutely brilliant, the two leads being the source of most of this brilliance. In fact, the film is so saturated with dialogue that there is only time and space for music during the opening and closing credits!
Rosalind Russell, Cary Grant, Billy Gilbert, Clarence Kolb, and Gene Lockhart in His Girl Friday (1940)
The first important character that makes her appearance is the one and only Hildy Johnson (Rosalind Russell), who enters in her ziggety-zaggety suit, which I expect would be even more insane in color. She comes in with Bruce Baldwin (played by Ralph Bellamy), her fiancé. She is about to go in to talk to Walter, who is also her ex-husband besides being her boss. She saunters through the office, talking to everyone she passes. Everyone is happy to see her, cheerily saying “hello!” to her. One woman starts walking with her and informs her that her cat just had kittens again. Hildy’s response? “It’s your own fault.” Finally, she arrives at Walter’s office and knocks on the door. Grumpy, he barks at whoever is there: “What do you want?”
Rosalind Russell, Abner Biberman, and Cary Grant in His Girl Friday (1940)
When he looks up and sees it’s Hildy, he changes his tone and my favorite scene has begun. As she stands there, Walter discusses with Duffy (Frank Orth), one of the men who works for him, about what they will do for the Earl Williams story in the paper. We can all see that he will do anything for a great story, even double-cross people in the process. As Duffy leaves, Hildy smirks and says, “Well, Walter, I see you’re still at it.” She tells him she needs to talk to him, but first she wants to sit down. The very subtle sexual tension and romantic chemistry becomes unmistakable as Walter pats his lap, motioning her over, and says, “There’s been a lamp burning in the window for you, honey. Here.” She barely glances at him before responding, “Oh, I jumped out that window a long time ago, Walter.” It is fun to watch as Hildy and Walter hurl insults at each other during this entire scene without Hildy able to tell him the news she intended.
Hildy: I am fond of you, you know. I often wish you weren’t such a stinker!
Hildy: Big, fat lummox like you hiring an airplane to write, “Hildy, don’t be hasty. Remember my dimple. Walter”
It is evident that Walter was not a model husband, not even showing up for their honeymoon because his work always comes first. But even so, I think many women can understand why Hildy would fall in love with him… he looks like Cary Grant! As Walter continues to rattle off words, not allowing Hildy to get to the point, she utters a very famous line and my favorite in the film: “Oh, Walter, you’re wonderful in a loathsome sort of way.”
Rosalind Russell and Gene Lockhart among others in His Girl Friday (1940)
And that chemistry intensifies as he approaches her, touching her arms, trying to get her to stay on the paper with him. “Will you take your hands off me? What are you playing, osteopath?” “Temper, temper!” At one point, he mocks her, putting his hand on his hip effeminately, saying she kept making goo-goo eyes at him for two years in order to make him marry her. This causes a fun ad lib to erupt: Hildy throws her bag at him, which was an ad lib on Roz’s part; very quick on his feet, Cary immediately ducks and says “You’re losing your eye. You used to be able to pitch better than that!”
Rosalind Russell and John Qualen in His Girl Friday (1940)
There are so many elements of this beautiful first scene that make the movie. It has just the right amount of back-and-forth witty repartee, romantic chemistry, and even the more subtle dramatic reactions as Hildy shoves her engagement ring in his face and he suddenly has to think of a plan to get her not to marry this fellow, which goes to show that he still loves her.
Irving Bacon, Cary Grant, Ralph Bellamy, and Rosalind Russell in His Girl Friday (1940)
Hildy: Scram, Svengali.
After Walter is going on and on and won’t stop talking, Hildy hits the desk with the palm of her hand, mumbles something incoherently, and cries out, “Sold, American!” a reference to a “tobacco auction,” advertising the cigarettes Lucky Strike, which always ended with this phrase being yelled out.
Rosalind Russell in His Girl Friday (1940)
Hildy: Listen to me, you great, big, bubble-headed baboon!
And at this point, he is informed of her engagement and he walks out with her, intent on meeting the man. In one of those “so funny, it just about cracks your ribs” moments, Walter walks right up to an old man who may even be missing some teeth, taking him for Bruce Baldwin. The man is confused, trying to tell him his name is Pete Davis. The real Bruce Baldwin taps him on the shoulder and tells him he has the wrong man.
And with a couple hilarious lines, Cary Grant has me clutching my sides: “Who are you?” “Well, I’m Pete Davis.” “Well, Mr. Davis, is this any concern of yours? From now on, I’ll thank you to keep your nose out of my affairs!” He immediately turns around and shakes Bruce’s umbrella instead of his hand and says, “Oh, that’s wrong, isn’t it?” What a funny man he is!
Right away, Walter invites them to lunch and off they go. As they get on the elevator, Hildy talks expertly out of the corner of her mouth: “You’re wasting your time, Walter. It won’t do you a bit of good.” They eat lunch at a favorite place of Hildy’s and Walter’s, but the funny thing is that Bruce is the only one who really gets any eating done. Hildy and Walter are too busy talking their heads off to satisfy their hunger. Walter keeps trying to get Hildy to stay at least a few hours in town to write an article on Earl Williams, a timid man who shot a cop dead. Both Hildy and Walter do little things directed at each other to show the kind of relationship they have. When Hildy tries to light her cigarette, Walter immediately grabs her hand and lights his own cigarette before she gets a chance.
Rosalind Russell and Ralph Bellamy in His Girl Friday (1940)
Something else that needs no words and that I just love: she has one fist up against her mouth and her right hand, she lays next to the fist and opens her fingers, thumbing her nose at Walter in a way. It’s perfect! But this wasn’t an ad lib she came up with on her own. Just like in The Women, she did something she shouldn’t have and she mentioned that she never did it again. She secretly hired a writer from her brother-in-law’s advertising firm to help her punch up the script.
Rosalind Russell and Alma Kruger among others in His Girl Friday (1940)
Walter gets an idea, so he pretends to spill water on himself. He gets up, has Gus (Irving Bacon), the proprietor, help clean him up, and tells him to call him to the telephone when he gets back to the table. Once he is in the telephone booth, he speaks to Duffy and tries to think of an idea to get Hildy to stay. As Walter is talking on the telephone, at the table, Bruce, just sweet as pie, tells Hildy that Walter seems nice, to which Hildy responds, “Yeah, he ought to make some girl real happy,” then under her breath, “Slap happy.” (That was an addition by Rosalind’s hired writer).
Bruce also mentions that Walter has a lot of charm. “Yeah, he comes by it naturally. His grandfather was a snake.” When Walter comes back to the table, he tells Hildy about the Earl Williams story and how he needs “a woman’s touch” for the interview. The Morning Post is on Earl Williams’ side and also in opposition to the politicians, who keep reprieving Earl Williams for no reason other than to make his hanging closer to election time. As Hildy says about the mayor, “He’d hang his own grandmother to get re-elected.” Walter tries a few ploys to get Hildy to write the interview, but she refuses. But suddenly, she gets an idea that if she writes the interview, Walter will take out a life insurance policy with Bruce, who is an insurance salesman. “See what they’ll allow on that old carcass of his.” “Say! I’m better than I ever was.” “That was never anything to brag about.”
Cary Grant, Ralph Bellamy, and Rosalind Russell in His Girl Friday (1940)
Next scene, while Walter is off getting a physical for the insurance policy, Hildy enters the press room at the criminal courts building, which will be pretty much the only place she will be for the rest of the film. She has on a new outfit, but still decked out in stripes with a not-so-crazy hat. This is the second and last outfit she wears in the film. Some men are outside, testing the hanging contraption for Earl Williams’ execution. One of the reporters, McCue (Roscoe Karns) tells them to keep it down because they’re all trying to work up there. A man shouts, “Ah, shut up!” Hildy’s reaction is “Very little respect for the press around here.” She gets the lowdown on Earl Williams so she has a bit of a backstory to work with before going to interview him. Bruce calls up, saying he has the check from Walter.
It is always obvious when Hildy is on the phone with Bruce because although she often speaks in a hard-boiled way, her tone changes to sugary sweet when she is talking to Bruce. Not trusting Walter at all, she tells Bruce to put the check in the lining of his hat because she knows exactly what Walter would do. Then she is off to the jail to talk to Earl Williams (played by John Qualen). After bribing the warden, Cooley (Pat West), with $20, she takes a seat next to Earl’s cell and starts to talk to him. While in other scenes, we can hardly keep up with Hildy and what she’s saying, this is by far her most toned down scene. She speaks quietly, methodically, softly.
Earl Williams is the timid sort of fellow who might be easily scared. She starts talking to him about “production for use,” which was something a person was speaking of in the park that Earl frequents. She asks him, “What’s a gun for, Earl?” “Why, to shoot, of course.” “Maybe that’s why you used it. It seems reasonable.” “That’s what a gun’s for. Maybe that’s why! Production for use!” Hildy only talks like this for Earl, for with anyone else, she speaks in her usual manner. It is a short interview, but she has her story.
His Girl Friday poster
When Hildy comes back to the press room to start typing up her interview, Mollie Malloy (Helen Mack) is there, trying to give the reporters a piece of her mind. They have been making up stories, lying about her having a “love nest” with Earl when all she did was be nice to him. As the “typical reporter” is painted in this scene, they don’t pay her any mind and keep on with their card game. When Mollie starts crying and yells out, “They ain’t human!” Hildy helps her out of the room while saying, “I know. They’re newspapermen.” In one of the only silent moments in the film, the reporters hang their heads in shame until Hildy comes back, simply addressing them as “Gentlemen of the press” in disgust.
When she gets a call from Bruce that he’s been arrested for stealing a man’s wallet (and the man is the shady little Louie [Abner Biberman] who works for Walter, of course), she suddenly bolts out the door with all the force she has, running right into Peter B. Hartwell, the sheriff (Gene Lockhart), causing him to cry out in pain.
The newspapermen read Hildy’s story and realize she can’t leave the newspaper game—she’s just too talented. As they start making bets how long her marriage will last, an angry Hildy comes back into the room, telling them she’ll take that bet. “It’s getting so a girl can’t leave the room without being discussed by a bunch of old ladies.” She immediately gets on the phone, emphatic about leaving the newspaper business and getting married and having babies.
She asks for Walter and as soon as she is connected, she starts in on him: “Now get this, you double-crossing chimpanzee. There ain’t gonna be any interview and there ain’t gonna be any story. I wouldn’t cover the burning of Rome for you if they were just lighting it up!” She puts the phone down, grabs her story out fresh out of the typewriter, and rips the pages up into little pieces within earshot of the phone. “Hear that? That’s the story I just wrote. I just said I’d write it. I didn’t say I wouldn’t tear it up!”
Cary Grant, Rosalind Russell, and Ralph Bellamy in His Girl Friday (1940)
With that, she hangs up and gets ready to leave, expressing her pity for the other reporters in the room. The phone starts ringing again and mad as hell at this point, she uses all her strength to pull the phone right out of the wall. She speaks into the receiver: “And another thing, I… Oh!” Realizing she just pulled it out, she is a little frazzled. Just as she is about to leave, there are loud noises of gunshots across the street. Earl Williams has shot his way out and escaped! What is Hildy to do as her fellow reporters scramble around her, trying to get the scoop? Her newspaperwoman instincts kick in, of course, and out the door she goes.
She runs out of the building and yells at the top of her lungs at Cooley, who is running away: “Hey, Cooley! Hey!” As she struggles to run across the street as scads of motorcycle cops and other cars zoom down the street, she runs after Cooley, finally tackling him to the ground, wanting to get the story straight from his mouth. When she comes back with the story in her memory, she calls up Walter. She makes him promise to send $450 down because it’s Bruce’s money that she used to get the story from Cooley. He assures her, “I swear it on my mother’s grave.” She responds, “Wait a minute, your mother’s alive.” “On my grandmother’s grave. Don’t be technical, Hildy.” She informs him that when the doctor was examining Earl Williams, he wanted to re-enact the crime scene, and Sheriff Pete B. (B for Brains) Hartwell stupidly handed over his gun to Earl.
Earl shot the doctor with said gun and escaped. Their conversation over, Walter gets another of his minions to go over and delay Hildy by getting Bruce arrested again. He sends over Evangeline (Marion Martin), a tall blonde, to get him in trouble for “mashing.” When she asks Walter what Bruce looks like, Cary’s ad libbing skills once again come in handy: “He looks like, you know, that fella in the movies… Ralph Bellamy.” “Oh, him?” When Bruce calls up Hildy once again to tell her what happened, she knows exactly who is behind it (again). She tries to get a hold of Walter, but they can’t locate him.
Meanwhile, the mayor and the sheriff are discussing the Earl Williams escape when a man comes in to deliver a reprieve, Mr. Pettibone (played to brilliant perfection by Billy Gilbert). The man constantly brings up his wife, even when the situation doesn’t call for it. He is one of the most memorable characters with a smaller role in the film. The mayor (Clarence Kolb) tries to bribe him into a fancy job so he won’t deliver the reprieve. As he leaves, the mayor asks him, “What’s your name?” “Pettibone.” “Pettibone?” Mistaking the mayor for saying his name is also Pettibone, he grins and shakes his hand, “Not really!”
In the press room, Hildy is suddenly surprised by Earl Williams coming into the room, pointing a gun at her. Shocked, she puts on her low, soothing voice again, only reserved for Mr. Williams. She tells him, “You don’t want to kill anybody.” The man is a little mentally disturbed and nervous and when he hears a noise, he shoots at the window. She immediately takes the gun from him and tells him to sit down. After she locks the door, she calls up Walter, and at the same time, Bruce calls her, wondering what will be done with him. She wants to help him, but more importantly, she wants to get on this story of the escape. In one of Rosalind Russell’s most dazzling comedic moments, she expertly talks to Bruce on one phone in her right ear and then switches to talking to Walter on another phone with her left ear.
It is amazing to watch her go back and forth between phones without missing a beat. When someone starts knocking on the door, she ends the call with Bruce with so much gusto that she knocks the telephone over. At first, she tries to keep Mollie from knowing that Earl is in there, but he calls out for her. Hildy rolls her eyes and allows her inside. However, when the writers are back, wanting inside the press room, they have to hide Earl in the desk in the back of the room. Mrs. Baldwin (Alma Kruger), Bruce’s mother, comes into the room and mentions that Hildy said there was a murderer locked up in there. Hildy tries to reassure the reporters that she was only looking for the murderer, not that she was trying to scoop them. The men start ganging up on her until Mollie comes to her rescue by stating she’s the only one who knows anything. She starts acting hysterical and right after she screams, she jumps out of the window.
on the set of His Girl Friday (1940)
Walter finally makes another appearance (this film really belongs to Rosalind) and has Louie pick up Mrs. Baldwin over his shoulder and carry her out of the room, screaming. Walter starts trying to persuade Hildy to get to what she should be doing—writing—by backing her into a corner, calling her all sorts of odd names (“drooling idiot,” “brain of a pancake”) and telling her that if she writes this story, there will be billboards of her everywhere. He stops when she tells him to stop acting, which he is really doing throughout the entire film (over-the-top, hammy, which is how it should be).
Ralph Bellamy and Rosalind Russell in His Girl Friday (1940)
As Hildy starts pounding out a story on the typewriter, Bruce suddenly comes in and tries to get Hildy to go back with him. However, she’s so invested in her story that she barely notices him there. This is another scene of note because it contains two different conversations between three people occurring at the same time. At one point, Walter even says, “I’m trying to concentrate!” (You’re telling me, Walter!). Eventually, Bruce leaves the room, telling her he will be taking that 9 o’clock train.
Bruce: I’m taking the 9 o’clock train!
Hildy: The 9 o’clock… Oh, Bruce, I put it in here! (She snaps the papers out of the typewriter and starts over again)
Hildy doesn’t even realize he’s leaving as she shouts out, “You have to take me as I am. I’m no suburban bridge player. I’m a newspaperman!” It doesn’t take long for Hildy to notice that Bruce is gone without her and that Walter has got her again.
Rosalind Russell, Cary Grant, Billy Gilbert, and Clarence Kolb in His Girl Friday (1940)
Walter: (on the phone) Diabetes! I ought to know better than to hire anybody with a disease!
Hildy gets ready to leave again when all of a sudden, all the reporters, as well as the sheriff, grab her, preventing her from going anywhere. They know she knows something. She says to Hartwell: “What do you want me to say?” “What do you know about Williams?” “’What do you know about Williams?’” “Now we’re getting somewhere!” But he doesn’t get anywhere with her and Walter goes on to call him an “insignificant, square-toed, pimple-headed spy.” Unfortunately, Walter makes a mistake when he calls Mrs. Baldwin, who has come back to spill everything, a “cock-eyed liar!” and on each syllable, he bangs on the desk.
Helen Mack and Rosalind Russell in His Girl Friday (1940)
Knowing that Walter’s three taps on the desk is his signal, Earl taps three times back. As Earl is taken away, the reporters, true to form, immediately start exaggerating their stories on their telephones. Hildy and Walter get handcuffed together for hiding a convict. But when Pettibone comes back in with the reprieve, accusing the mayor and sheriff of bribery, Hildy and Walter suddenly have something to laugh about. It is absolutely indisputable how much fun both Cary and Rosalind are having with this scene. They can’t help smiling, no matter what is said. Knowing what trouble he will be in if this gets out, the mayor makes Sheriff Hartwell take the handcuffs off.
John Qualen and Rosalind Russell in His Girl Friday (1940)
Walter: Out of the mouths of babes!
Pettibone: Hi, babe!
What happens then is something that happened with most of Rosalind Russell’s “career woman” characters after this as well. She has gone from tough and businesslike to sweet and gaga for the man in the room. She has fallen for Walter again and wants to stay with him, not giving Bruce a second thought.
Rosalind Russell with some of the reporters in His Girl Friday (1940)
But he urges her to go back to Bruce and gives her one kiss… the only kiss in the entire film, but somehow a powerful one at that. When she is told that Bruce has been arrested again because of Walter’s doing, she just breaks down in tears, having almost believed Walter was being noble for once. But he really does love her and they decide to get married again.
Hildy is excited to finally go on a real honeymoon when suddenly, Walter gets the call that there is a strike in Albany and he must cover it. Work comes first! As Hildy goes out the door, carrying all her bags with no help from the “gentleman” beside her, he says, “Albany… what a coincidence! Wonder if Bruce can put us up? Why don’t you carry that with your hand?”
IMDB page for His Girl Friday
TCM overview of the film
The entire film for your viewing pleasure!
cary granthis girl friday
Previous PostRound 3 Matches To Take Place Tomorrow!Next PostRound 5 Starts Tomorrow! We will know the winner of the 1930s era by next week!
16 thoughts on “His Girl Friday (1940)”
Bird says:
little angel!
Bricka bricka blee blee
Rocky C says:
Incredible review. I loved the part where Rosalind Russell spoke fast.
Great insight, baby!
Skim says:
G I O?
Monty Hawes says:
OK I am probably biased since His Girl Friday is my all time favorite movie but what the hell….that was the best review I have read in awhile Desiree! A phenomenal job and I love all the tidbits you threw in there about the back stories and such. I may have been one of the few who didn’t know about Cary playing matchmaker for Rosalind.Sweet. Loved all the photos you chose and placed through-out your review. Excellent work Desiree! Just amazing! I think I will run out of superlatives here in a minute but I really did love this review. And I can tell you enjoyed writing it too!
And i must say, that’s the best comment I’ve received in a long time!!! Thank you, all your lovely adjective made me feel very happy about it. I enjoyed writing it because it’s certainly one of the best comedies that ever existed! I’m glad you learned something new, too.. .and thank you as always for READING! 🙂
Hellraisin says:
Your reviews keep getting better and better! I love your description of Hildy’s “ziggity-zaggity” suit. Poor Hildy. She wanted her life to go one way, but it went another, just like the lines on that outfit. You’re 100% right–I can’t imagine anyone else playing Hildy with such heart and charisma.
Aw thank you kindly! If they’re getting better, then I must be doing something right 🙂 I’m glad you liked the ziggity zaggity. Totally made up word, but that’s how I roll. Yes, I feel Roz was born to play Hildy… she was amazing! Thank you for reading 🙂
Vickie Dorris says:
I love this movie.True comedy .Love the stars .
It’s a great one, Vickie!
10hdt says:
Wow, you really out did yourself this time. Your lead photo set up your review beautifully. The quotes beside the wonderful pictures brought the movie to life. The back stories are so interesting and make Roz even more memorable.
His Girl Friday is such an iconic film and the casting of Rosalind Russell and Cary Grant is inspired. These two actors are so well matched. They both are great in comedy, drama, and suspense roles. Carey & Roz are each tall, slim, good looking and they both look great in suits, what more could you want.
Keep em coming Des, I love your blog. Holly
Thank you!! I’m glad that once again, you enjoyed my review. I had been looking forward to your comment. If I outdid myself, I must be doing something right! Thanks for your comment, much appreciated! And don’t worry, they’ll keep comin’ 🙂
From the suits to the versatility to their great looks, Roz and Cary were a perfect match. It’s such a shame they were never paired up again. Katherine Hepburn just had to go and be a Cary hog, I guess!
|
cc/2019-30/en_head_0021.json.gz/line27467
|
__label__wiki
| 0.868551
| 0.868551
|
Pilot Travel Center coming to Woodhull
Sherrie Taylor
The economic forecast in Woodhull underwent a significant improvement this week with the announcement and details of the proposal for a Pilot Travel Center, to be constructed on the site of the former Woodhull Plaza.
The Plaza business, part of the village for more than 30 years, has been closed for several months. The site is west of Woodhull on Illinois 17, adjacent to exit 32 off Interstate 74.
Catherine A. Adkins, senior project manager for Pilot, met with Mayor Dave Holmes, Trustee and Economic Development Chairman Mary Engholm and Trustee and Public Works Chairman, Lloyd Carlson, Tuesday afternoon at the municipal building in Woodhull.
“We’re really excited about the property here and want to know what we need to get done to start (construction) in April,” Adkins told the mayor and trustees.
The 10,000-square-foot business will include a McDonald’s restaurant, with drive-through facility as well as dining room seating, a gas bay for trucks and another for vehicles, restrooms and convenience store.
The business building at the site will be demolished and a completely new building constructed, Adkins said.
“I’m ninety-nine percent sure the restaurant will be a McDonald’s,” she said.
The construction can be completed in 130 days for an opening in September, village officials learned, though a proposed off-site road will need approval from the Illinois Department of Transportation.
Adkins and engineer Kevan Cooper said the additional roadway will be constructed on the east side of the business, to separate the truck travel from other vehicles.
“Will you use the existing roadway if IDOT permits aren’t ready?” Holmes asked.
The business will open when construction is complete and prior to the new roadway, if necessary, Adkins said.
Cooper said a traffic study has been done and preliminary findings have been submitted to IDOT.
The existing Illinois 17 will include a left turn lane, with truck parking on the west side of the business, cars on the east.
Adkins shared tax revenue information, listing estimated sales tax for Illinois of $463,925. Fuel tax was estimated at $2,335,500 for Illinois with property tax for Henry County of $106,230.26.
A detailed listing of property tax, based on current rates, projected revenue for the following taxing bodies:
- Henry County — $12,861
- Black Hawk College — $6,523
- Clover Fire District — $5,707
- Oxford/Clover Multi-AS — $446
- Oxford Road District — $5,499
- Village of Woodhull — $5,430
- AlWood School District — $65,186
- Clover Library — $2,137
- Oxford Township — $2,442
The 24-hour, seven-day-per-week business will employ 75 people, with an annual payroll of $1,050,000, according to Adkins.
Officials discussed permits, water and sewer service, lift stations, easements and other details as well.
Adkins said the estimated investment in the project is $5.7 million, not including the cost of the land.
The Register-Mail
|
cc/2019-30/en_head_0021.json.gz/line27468
|
__label__wiki
| 0.797827
| 0.797827
|
‘US designation of N. Korea as terrorism sponsor is backdoor for military action’
North Korean leader Kim Jong Un © KCNA © Reuters
By designating Pyongyang as a state sponsor of terrorism, US President Donald Trump has opened a backdoor for a potential military option to denuclearize the Korean Peninsula, under the pretext of “not talking to terrorists,” experts have told RT.
Announcing the news Monday, Trump stressed that this designation “will impose further sanctions and penalties on North Korea and related persons and supports our maximum pressure campaign to isolate the murderous regime.”
The expert community, however, disagrees that further punitive measures against Pyongyang will help foster dialogue between the US and North Korea, considering that the North was removed from the terrorist sponsor list in 2008 as part of the George W. Bush administration’s push for progress in denuclearization talks.
“This is going to make the diplomatic pathway that much further away... and I'm afraid it is not going to help the situation,” Sourabh Gupta, an Asia-Pacific strategic and economic policy specialist, told RT. “It is just a little further step more which is paving the way for military action. It just makes the path to diplomacy that much more harder to get to. Even talks about talks regarding talks to get to the negotiating table are stuck at this point in time. These sort of labels will provide no assistance whatsoever.”
Trump declares North Korea state sponsor of terrorism
“I believe the reason why we’re seeing this it at this point in time is more connected to the fact that the United States is frustrated that it can’t effectuate the change it wants to see in North Korea without the military action. Military action isn’t an option, and so it wants to appear like it is taking further action, but this idea of additional sanctions is probably a bit hollow because there are so many actions now in place that I don’t see it adding that much more to the depth to make a difference,” Eric Sirotkin, a human rights lawyer, told RT.
Experts also dispute Washington’s claim that North Korea sponsors international terrorism. The only case that could arguably back up this claim, Gupta believes, could be the assassination of Kim Jong-nam – the half-brother of North Korean leader Kim Jong-un – who was killed on February 13.
“I assume he has done so primarily because of the attack Kim Jong-un coordinated on his half-brother, regarding killing him in Malaysia airport using a banned chemical agent,” Gupta said, at the same time stressing that this was “something that has been in the works for quite a long time... There has been the political desire in Washington to move down this route.”
READ MORE: N. Korean state media blames Malaysian govt for Kim Jong Nam’s death
Sirotkin meanwhile believes there’s no evidence which would justify the Trump administration placing Pyongyang on its blacklist.
“The banter about the term terrorism a lot because it gets people afraid. It is the buzz word since the Cold War to justify certain military actions and other actions. But frankly, the designation violates the very law that it said to be based upon, which requires there to be repeated support for state-sponsored international acts of terrorism,” Sirotkin told RT. “By doing that we’re faced with a situation where there is not that kind of evidence against North Korea. We can disagree with their human rights; we can believe in non-proliferation of nuclear weapons but in reality that does not meet the definition.”
While Pyongyang has not yet formally responded to Washington’s designation of it as a state sponsor of terrorism, experts believe that the tensions on the Korean Peninsula will only get worse.
N. Korea may have ICBM capable of reaching US this year – Seoul https://t.co/mPnL5vMFQEpic.twitter.com/jeVuBgTVnl
— RT (@RT_com) November 20, 2017
“I feel in the next couple of months the situation is going to get very, very hard, simply because the current Trump administration believes that its leverage gets negated when North Korea has an ICBM with a deliverable nuclear warhead,” Gupta told RT. “So there is the belief, and I would say a wrongful belief, that there is still a military option left.”
READ MORE: US to ‘pay dearly’ if it re-includes N. Korea in terrorism sponsors blacklist – official
“It is a backdoor way to try to prevent dialogue and diplomacy... and to maintain the instability that is going on there,” Sirotkin said. “It is not constructive; it does not lead to dialogue. You don't do name calling and labeling and then say, 'hey, do you want to talk?' It is an effort to demean and isolate, and perhaps just not talking to them, because, 'We don't talk to terrorists.'”
|
cc/2019-30/en_head_0021.json.gz/line27469
|
Subsets and Splits
No community queries yet
The top public SQL queries from the community will appear here once available.