Hunger, Hermann. 1992. Astrological Reports to Assyrian Kings. Helsinki: Helsinki University Press.
Parpola, Simo. 1993. Letters from Assyrian and Babylonian Scholars. Helsinki: Helsinki University Press.
Reiner, Erica and David Pingree. 1975-2005. Babylonian Planetary Omens. Vols. 1-4.
Rochberg-Halton, Francesca. 1988. Aspects of Babylonian Celestial Divination. Horn: Berger.
Verderame, Lorenzo. 2002. Le Tavole I-VI della serie astrologica Enūma Anu Enlil. Di.Sc.A.M.
Virolleaud, Charles. 1905-12. L'astrologie chaldéenne. Paris: Geuthner.


Does anyone here play Brawl Stars?
I'm just wondering because it is REALLY fun to play. This game is in Beta and is currently only in Canada (But you could make a Canada Apple ID to download) The Band I'm in is called Cryptic Wolves. If there are enough players here on Cemetech or Codewalr.us we could make a band all for ourselves. Let me know what you think of this game if you don't have it. It's a Supercell game too!
Supercell? i smell pay2win <_< I used to play CoC but stopped cause it was kinda boring and pointless.
There was an update last week and wondering if anyone is playing or may want to play in the future. Brawlstats.io contains all stats for all players, including mine. My user here is my tag, feel free to friend me if you like. I'm in one of the top bands in the world! My Band has changed since the first post so the website above contains all the info if you want to friend me if you look up my name.
Brawl Stars - Ways to add coins and gems?
I played Brawl Stars Game is reall good and dynamic. 3v3 with friends is super fun. Only thing that worries me is earning coins and gems. I hated this part in Clash of Clans and Clash Royale. Problem is that player thet buys coins and gems will have bigger chance to win. I think that is not fair. Do you guys know some alternative ways to earn coins and gems? I used online hack generators when I was playing Clash of Clans and Clash Royale but I did not test them yet for Brawl Stars. It is really hard do find any site that provide this kind of service becouse game is not yet released globally. only two sites that i found are brawlcheats and BrawlerKing . They look legit but still don't fully trust them. What do you guys thing about them? If you use this kind of service would you please share it with us?
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As the name suggests this Bustier has a sophisticated air of regality to it.
Front detailed stitching runs from the waist to the cups.
Boning in the top portion creates dramatic curves emphasizing your womanly virtues.
curving over the hips to the center back zipper.


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2008: Over the last year or so, I have started revisiting the churches of Suffolk which I originally wrote about at the start of the decade. Coming back with a digital camera to St John the Baptist was a delight. However, I have seen no reason to change the text of what I wrote seven years ago; or, at least, not much.
2001: Just as we go to Long Melford to find out about the 15th century, so future historians will come to St John the Baptist to chart the course of the century just ended. For this church is the definitive statement in Suffolk of the liturgy and practice of 20th century High Church Anglicanism. Neither as eclectic as Spooner's Ipswich St Bartholomew, or as provincial as Phipson's Ipswich St Mary le Tower, this mighty church, the last work of the great Sir Arthur Blomfield, is the nearest thing Suffolk has to the grand and uncompromising High Church temples of west London.
It has an unparalleled collection of 20th century stained glass; the best of this consists of a range of saints, spanning the century, from St Etheldreda in her high Victorian camp, to the modern images of Saints Hilda and Bede, both illustrative of the current Celtic revival in Anglican spirituality. Also worthy of note among them are the Arts and Crafts influenced James, Peter and John, the Lady Chapel glass east window of the Suffolk triumverate of Edmund, Felix and Fursey, and, as recently as 1982, St Thomas More, who exists elsewhere in a Suffolk Anglican Church at the extremis of Kettlebaston.
Father James Mather informs me that More is at last recognised in the Anglican calendar in the new Common Worship lectionary, but this was not the case in 1982. As the foundations of Anglicanism were bought at the cost of More's life, it is bold indeed that this window commemorates More's martyrdom. Much of the glass is by Powell & Co, and forms a document of that studio's work as well.
Felixstowe is the nearest thing Suffolk has got to a traditional seaside town, albeit not as brash as Walton-on-the-Naze and Clacton across the river in Essex, or Yarmouth over the Norfolk border. The town separates naturally into a number of areas, each with its own main churches: Felixstowe Ferry, Old Felixstowe, Felixstowe Town, Felixstowe West End, and Felixstowe Docks. Suburbs include the medieval parishes (and medieval churches) of Walton and the two Trimleys, but only Old Felixstowe has a medieval parish church in the town itself.
And only make my loneliness completer.
"The Little Sisters of the Hanging Pyx".
We built our orphanage. We built our school.
Now only I am left to keep the rule.
And so my memory of the winter dies.
And louder clang the waves along the coast.
And all the world goes home to tea and toast.
Bound for the red brick twilight of St.John's.
"Thou knowest my down sitting and mine uprising"
Edwardian Felixstowe lost its holiday industry long ago. It is now but the favourite destination for daytrippers from Ipswich, the urban sprawl of which lies a bare six miles from the edge of Felixstowe's. But this area still has a holiday town atmosphere. There is a steep descent down the wonderfully named Convalescent Hill to the beach below, with crowds thronging the shingle and the leisure centre; but up here, it is another age, with the comfortable spring sunshine baking the red bricks of the quiet three-storey houses.
St John the Baptist's concrete-white spire emerges above its lower stages, the redness of which intensify from a distance. Blomfield had built the rest of the church in the early 1890s, but the spire and the Lady chapel followed in 1899, the year of his death. You enter nowadays through Munro Cautley's 1940 south porch; the main entrance beneath the tower is no longer used. The first impression is of a dimness, the smell of incense, rich light from the coloured glass. Betjeman wrote of St John's red brick twilight, and the same is true today as then.
The windows previously referred to line the walls of the north and south aisles and Lady chapel. The last is in the south aisle, and is now partitioned off by glass doors to enable a prayerful silence when the rest of the building is in use, as at Ipswich St Bartholomew. The lowness of the aisles accentuates the over-arching nave roof, and draws the eyes to the 'Big Six' candlesticks on the high altar. No Vatican II altar in the nave here, for the chancel gates and Suffolk-style screen still contain clergy and choir stalls in front of the tiled and marbled sanctuary. So, as at Ipswich St Mary le Tower, High Church externals are maintained, whatever the liturgy. Either side of the high altar are gilded mosaics illustrating Christ's gift of peace.
To the west, a little screened baptistery in the north aisle. The window behind it is the oldest in the church, and illustrates St Felix baptising and preaching. It is dedicated in memory of a child called Felix, who died in the 1890s. One of Blomfield's hallmarks is the way his buildings appear to be a cluster of smaller buildings around the great nave, like a medieval city. That illusion is successfully created here by the way the rooflines contrast, particularly that of the Lady chapel with the nave. From the south east, the direction from which you would commonly approach, this is particularly striking.
The feeling of a citadel is further reinforced by the way St John the Baptist is shoe-horned into its site, with barely room to breathe except on the north side, where the former rectory lawn spreads towards the house. In the old days, it must have been pleasant to step from High Mass into a summer fete or garden party. But High Mass has gone, and the rectory is now derelict, alas.
More romantic still is the convent that sits to the west of the church, which instantly recalls Betjeman's poem. As one stands outside, with the 'crashing tide' below, the sisters come and go, and it would be romantic to imagine that they are a surviving relic of the extraordinary flourishing of Anglican religious orders at the turn of the 19th and 20th centuries. Indeed, you might almost imagine that this is the very convent that Betjeman had in mind, despite the fact that he suggested himself that these orders were withering away when he wrote this poem in the 1950s. But in fact, this is a Catholic convent, the house of the Religious of Jesus and Mary.
Postscript: wandering around my favourite east coast town over the years, I had often popped in to St John the Baptist to see how it was. I had never found it locked. In May 2007 I brought my new camera, and my daughter, and while we pottered about inside, the churchwarden came in. I don't know if he knew who I was, but he very kindly offered to take us both up the tower. Being mortally afraid of heights, but always wanting to conquer that fear, I accepted with enthusiasm. We climbed first to the ringing chamber, which has still its graffiti left by air raid wardens during the First World War. And then up and up, to the base of the spire, with the inside of the clock surreal beyond the belfry struts.
And then out onto the top of the tower, beneath the great hollow spire. Hanging on grimly for dear life, I gazed out over the rooftops of this enchanting red brick town to the deep blue of the sea beyond. Turning back inland, I could see Ramsholt church, and the BT research HQ at Martlesham, and the grey smudge of Ipswich in the distance. Looking back out to sea, I could see the unilaterally declared independent state of Sealand on a World War II fort.
Something was missing. And then it struck me. This is the only place in Felixstowe from which you cannot see its most beautiful building.


While I commiserate with you, it's probably pretty hard to reconcile spending 45 Mil on a bridge that has no "viable use". Being a ex-Pennsylvanian, I know I would find it hard to have my taxes spent that way.
At least this historical landmark was knocked down by a force of nature...Do you recall that a contractor mistakenly tore down Edgar Allen Poe's house in Philadelphia? Can't remember if Rendell or Goode was mayor at the time, so I can't draw any correlation.
Moving America into the 19th Century!
How very true,they've also removed Soldier Field here in Chicago despite Mayor Richie's(though some can claim his ego as a force of nature) claims that leaving the columnades at the base of that gawd awfull UFO still retained the historical integrity.
Man, I can not believe this, I was just there at the beginnig of this month. It will be sad to see the bridge taken off of the list.
Probably not...Unless of course the contractor was a friend of the Street family and/or contibuted a great deal of money to the correct political organizations.


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Home / Big Brother 20 / Feed Updates / Big Brother 20 – Friday Recap
Big Brother 20 – Friday Recap
Last Updated on August 25th, 2018 at 12:31 pm PST
Mel August 25, 2018 Feed Updates 43 Comments
Good morning! We had to wait all day for nominations to happen and once they did, Haleigh and Fessy were on the block. They were half surprised since they thought she'd be going up but not Fessy. They'd both agreed earlier in the day, no way Angela would put them up together. This was another example of Haleigh's bizarre game logic. I expect it from Fessy because he's never known what was happening.
Fessy is a terrible player but I get him as a person. He is who he is and it's exactly who he claimed to be from the start. There are things not to like but I do like that about him. He's the football star who wants to sit in the VIP section, loves his hair, knows he has great athletic ability and feels confident he'll always get the girl. He also doesn't feel the need to apologize for it. I was never going to admire his gameplay but he has made me laugh (at his expense) and not everyone can be remembered for their great game. Fessy will be the guy who never knew what was going on and the butt of JC's jokes.
Haleigh is a bit more confusing. I really liked her and her game the first weeks of the season. I'm not normally a fan of the flirt strategy but for someone so young, she seemed to have it under control. She was focused on the prize, funny and friendly with most of the house. I was more impressed that even though she liked Tyler, she wanted to go after him anyway. I'm tired of people going on the show looking for love. She's been compared to Nicole but for me, she's been the opposite of Nicole. (Yes, I know Nicole won but it took 2 seasons, poor jury management from Paul, some women wanting a woman to win no matter what and Nicole making a fool out of herself over "boys" in the process. Sorry, not that impressed) I said Haleigh's game was bizarre because unlike Fessy, she does have moments of clarity. I get that Fessy was shocked Angela put the two of them otb together but why was Haleigh? She wanted Angela and Tyler otb together so she should've seen it coming. She's figured out at least twice what was going on in the house but then she'd blink and simply move on from it. (Someone on Twitter described her as Dory and they weren't far off) The night JC convinced her Scottie should go otb, she'd just had a lengthy discussion with Scottie and the two of them correctly named every person left in the house that was in the L6 alliance. Maybe something will happen and she'll still get there. She could escape this week, L6 may start to turn on each other and Scottie could come back and win comps to help her. Anything could happen but her game's still a mess. I've been more critical of her in recent weeks but it's because she had the potential Fessy didn't have. I gave her too much credit and assumed she had more than flirting in her game bag but I was wrong. (I still like her more than Nicole)
I suppose we could give them credit for finally figuring out what's happening in the house but should we? It took 66 days, their entire alliance leaving except the two of them and them going otb together yesterday to get it. Is that really worthy of applause?
We didn't have the drama some of us expected after noms yesterday but here's what did happen:
Angela told Tyler she'd been nervous when she gave her speech and he told her she did a great job. She told them in her speech Hay was the target and Fessy was guilty by association and I don't know what else was said. She said her heart was beating so fast even after it was over.
Hay and Fessy took it pretty well imo. They bounced from being mad and bitter to making fun of how bad they'd played the game. Hay said she was bitter and would never vote for Angela. She said she'd give it to anyone over her and Fessy agreed. They both said they 'planned' to be bitter jurors. Hay said Angela was playing the game very well and that's what pissed her off the most. She also said there was no way Angela was smarter than her. This all sounds really petty and it is but it also just happened. I'll think a lot less of her if she keeps thinking this way but I'm going to give her the benefit of the doubt for now. They had a day of "you got, got" so, of course, they're pissed. (Was if Jeff who said "you got, got?" I'm tired and can't remember at the moment)
Hay had some "I told you so" and "so I was right?" moments with Fessy because originally she wanted Angela otb when Fes was hoh. Normally, I wouldn't begrudge her that either but she's forgetting she was completely on board with the 'get Scottie out plan' so she does need to take that down a notch.
It was strange to watch all the pieces fall into place for both of them in such a short time. Fes realized they (L6) used his hoh to get out someone they wanted out, only to put him otb right after. They figured out that Brett framed Scottie for the RS vote. Fessy said even if Scottie was flipping votes, it wasn't that big of a deal and he shouldn't have taken him out. He acknowledged he took out their last alliance member. Hay said she shouldn't have told people she was the hacker. She guessed the 4 (L6) and maybe Sam had been working together from the beginning. She guessed Brett was with them and was only pretending to be alone. She also said she realized that once the house divided, it had actually remained divided. (No, they didn't guess JC had worked against them but these are Foutte people)
Hay and Fes argued a little and also laughed at how dumb they were. They said maybe America would give them a power because they're so dumb and we'd feel sorry for them. Hay said she was the dumbest player in BB history and will probably be laughed at when she leaves. (no, we've seen worse) Fessy figured out Tyler was playing a good game and in a good spot too. (Ok, they're really bad at the game and that's not changing but strangely, last night was the first time in a while that they were enjoyable to watch. I almost wanted to root for them again…almost. I like people who can laugh at themselves so that was probably most of it)
Shortly after Hay and Fessy put everything together, Hay said she's convinced that Angela had been on board with the four of them (Hay, Fes, Ty, Ang) working together and only changed her mind today. (See? Dory)
Hay told Fes she was the target, not him. (Not true) She said he'd have Scottie if he came back in a battle back. (probably not true) Hay said she knows she's leaving and she's going to look nice Thursday, not wear athletic clothes and everyone can suck her d**k over it. Fessy can win comps but she doesn't consider him a target, at all.
L6 did a lot of studying and joking around in the hoh room. They were going over days and Brett was drilling everyone. I'm going to assume Tyler made a mental note of how well Brett knew the days. This study session also made it painfully clear how much trouble JC is in when they have these comps. Unless he just had slop brain last night, he's not looking good.
JC kept working on Brett trying to get him to become closer to Angela. I don't know if he's trying to cause friction with the group, separate Tyler and Angela or a completely different reason. I kind of think because Tyler now has Angela, JC wants to have Brett. He doesn't need to pit Tyler against Brett because JC knows from what Tyler told him, that's coming soon anyway.
Brett finally told L6 he's really a cybersecurity engineer. (It was similar to Fessys app reveal and Bronte's mathematician moment, not a big deal) Tyler told them about TKO and said that's where they found him for BB. (that's not true)
JC started pumping Fessy up to win the veto but he also messed with him a little. JC said the saddest thing about Fessy leaving would be if JC won the HOH and wasn't able to make him a have not. (he wants revenge for that, lol) Fessy wanted to know if JC would use the veto to take him down and JC told him maybe and it would depend on what Fessy would do for him. Fessy told JC it was funny because if Angela got to the end that none of them would vote for her and JC said "so you're going to be a bitter juror?" (Sorry Fessy, actual game players don't think it's as hilarious as you do) Fessy bragged about how no one would beat him in the veto comp. JC reminded him he came in 4th in OTEV and said that's not even bronze, not even a medal. (Ya, I still love JC)
Tyler checked in with Sam and filled her in on what happened. She was glad she didn't go up but obviously didn't know what was going on. He explained how Fes & Hay tried to get Angela to put Sam otb so the rest of the house, in order to protect Sam, tricked them and put them up instead. Sam asked if Fes & Hay were "really a thing" and Tyler said he didn't know but it didnt matter because they'd wanted her otb. Sam said she knew that and that's why she gave Tyler such a big hug once the ceremony was over. Sam asked about KC to make sure they were still good. She was concerned because KC didn't accept her tickets in exchange for safety during the comp. (I guess Sam did this with Hay and Brett during the comp. She offered them tickets if they didn't put her otb) Tyler said KC was still fine and just didn't want to make deals out in the open.
Sam sat on the stairs and tried to stay hidden. She talked to her coffee cup and said "ya'll think I'm crazy now, I'm just getting started."
Angela talked to Brett and KC about not wanting a relationship when she left the house. She doesn't want to be tied down and doesn't want to have to pass up on any work opportunities. I don't know if she said it so they don't worry about her and Tyler or if it's true.
Tyler is smitten and starting to act like an idiot so hopefully KC will tell him a little of what Angela said so he can get his head back in the game. He can say all he wants to JC and KC that it's no big deal and he has it under control and maybe he does but that isn't the point. It isn't about whether or not his heads in the game, it's about what it looks like to other people. I'm not even convinced he does have it under control. Tyler hasn't been much of a rule breaker this season but even though he's a have not, he's stayed in Angela's bed so much, he's got called out for it by production. He still plans on sleeping up there tonight, assuming have nots are over. He told JC it was good if the house saw Tyler and Angela as a couple because it would avoid anyone putting him and JC up together. I think this is complete bullshit because if he wanted somebody to go up with him that he didn't mind losing, he'd be ran up Bretts butt instead of Angela's.
Here's a few random things:
Eric Stein who played in BB8 (and really was America's player) does a "Summer of Stein" podcast on RHAP with Rob on Mondays. They basically make fun of everyone in the game and it's pretty funny. They've made jokes about SwaggyC and his Twitter acct. Swaggy loves to retweet (unrealistic) praise he gets from fans. Swaggy also talked about Eric when he was still in the house. Rob gave Eric the challenge of creating a tweet so flattering (and not sincere) to Swaggy that Swaggy would retweet it within 4 or 5 hours of it being sent out. I don't know if Eric made the cut off for the deadline but Swaggy did retweet it. I'm sure they'll discuss it this Monday and make fun of Swaggy too. This is the tweet:
Some of you may be surprised to know that Swaggy went to Kevin's house and stayed for a few days. Kevin thinks Swaggy is great.
This was Angela before nominations yesterday. Fessy was bugging the crap out if her. She was reassuring him about his great plan for the week while winking at the camera. She's been paranoid about what Zingbot said and has worried she's coming off as a bitch on tv. I wish she knew her ice queen moments are what many of us are loving about her. (I'm a Tyler fan but I hope she's using him and plans to cut him, I think it would be great) Fans love it when men are ruthless and game focused so they need to love it when a woman does it too.
Veto comp will be sometime today so Steve will get you those results after it happens. Have a great weekend!
Veto players: Everyone is playing except Brett and Tyler. Tyler is hosting. Haleigh chose Sam with hg's choice. Fessy told her not to pick Brett which was her plan last night. Maybe she didn't choose JC because he was already drawn??
Previous Big Brother 20 – Friday Night Feed Updates; Nomination Results
Next Saturday Afternoon Feed Updates

redpajama_set_name: RedPajamaCommonCrawl


Fed Minutes – Anybody Feel Smarter Today?
In a week where there wasn't much in the way of high-impact macro data, I along with other inflation hounds was left to pore over what were some very diffuse Fed minutes yesterday. There seems to be a communication breakdown – figuratively and literally – in what was the longest minutes report in recent memory (over 8000 words!) yet also the hardest to interpret.
After all, the bond markets have been moving crazily; it seemed the smell of inflation was in the air following a strong jobs report and a 35 basis point rise in the benchmark 10-yr over a two week period.
In a word, the FOMC minutes were dovish. Janet Yellen, her voting cohorts, and their staffs just can't find enough data points to make a strong case for either inflation or broad growth. We clearly identified this reality last week, noting that things were becoming "more opaque by the day". While there was a slight tickup in weekly pay, retails sales continues to print weak while headline and core CPI and PPI are well, well below the Fed's 2%-ish target.
The Producer Price Index (PPI) for January came in yesterday at a 0.8% drop after a 1.1% annualized growth pace in December. Most vitally, we're now on pace to turn in exactly zero growth Y/Y in the PPI. As with every inflation metric right now, it's being thrown off kilter by the fall in crude oil.
For now, macro analysts like Michael Hanson over at BofA Merrill are saying that while we may see negative headline inflation, it's "probably not deflation" as seen by the Fed. This is backed up by recent comments from Yellen, who has called the spike down in energy prices as "transitory", while Philadelphia Fed President Charles Plosser noted that "I don't see deflation as a risk in the U.S. economy".
I'm in the camp with most people who believe that the Fed would love nothing more than to get at least 1-2 rate hikes passed along this year. They would love to get the credit markets operating in a more normalized capacity, and they would certainly love to have the extra arrows in the quiver that a 0.5% – 1% Fed Funds rate would provide.
This stance doesn't require one to be a hawk or a dove; it's just good business for the Fed to have a full set of levers at their disposal. But there is real damage that could be done to the long-term viability of the Fed if they were to raise rates this summer, only to find that GDP growth has vanished and they're forced to re-cut rates.
And as I noted last week, there is a very fine line there. The PPI results will in many ways flow through to the CPI over the next few months, and as I write this crude oil is down another 4% or so today and we may see the largest crude inventory build in history later Thursday.
As it stands now, we are the only advanced economy on the planet that is forecasting a rate increase in 2015. Granted, we are also the healthiest, so there's a case to be made that we should be the first ones out of the gate. But for now, the Fed is admittedly (for the first time in over a year) looking overseas at risks in China and the Middle East, and even looking with some fear at the fixed income ETF market, of all places.
It's prudent for the Fed to be considering the near-term impact of falling commodities, just as it's prudent to see them within the context of stagnant global growth. Neither are tasks we wish the Fed was spending so much time on, but the times are what they are; there's not exactly a dog-eared playbook of what to do at this point. Just a compass.
Anybody that is out there with a strong opinion on whether the Fed is doing the right thing will have to cherry pick their metrics and indicators to prove their position. Fed Funds futures bettors scaled back their odds for a June rate hike, following the "let's punt the ball" tone of the January FOMC minutes.
I tend to agree with a couple of analysts that have suggested the surging U.S. Dollar is a de facto rate increase already, as it will push down our exports a bit. In the meantime, the Fed – like the rest of us – will sit and wait to see if GDP is hanging in there. This continues to look a lot like Goldilocks for equities, just like the past few years.


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Past and Present Team Up to Unlock Future of Army Medicine at AUSA
By Ramin A. Khalili, USAMRMC Combat Casualty Care Research Program Knowledge Manager
Lt. Col. Kyle Remick answers questions from the audience following his presentation at the Association of the U.S. Army, more commonly known as the AUSA, "Innovator's Corner" on Oct. 5. (Photo by Ramin A. Khalili, CCCRP)
Launching into a speech on emerging efforts to aid combat trauma victims at the packed Association of the United States Army event in Washington, D.C., on Oct. 5, Lt. Col. Kyle Remick spoke frankly about the human body and how it works.
"Your body is like a bucket," said Remick, the military deputy for the Combat Casualty Care Research Program. "If there's a hole in the bucket, then you need to fill the bucket with blood ... but you also need to plug the hole, too."
The AUSA is an annual comprehensive military exhibition and professional development event held exclusively for members of the Army and affiliate scientists, vendors and contractors. As part of the event's overall focus on the theme of "readiness," chosen speakers were asked to present material related to key innovations in their particular fields.
In his overview of the CCCRP's role in developing the Resuscitative Endovascular Balloon Occlusion of the Aorta, or REBOA, a tool designed to stop severe truncal bleeding by routing a small, inflatable balloon into the aorta, Remick also touched on the military's success in using similar emerging technologies to close key program gaps and save lives. Studies show that between 2005 and 2013, the number of U.S. casualties in Afghanistan decreased despite a substantial increase in the overall injury severity.
"That's a great amount of success," said Remick, who spoke to a crowd that included Surgeon General of the U.S. Army and Commanding General of the U.S. Army Medical Command Lt. Gen. Nadja West and U.S. Army Medical Research and Materiel Command and Fort Detrick Commanding General Maj. Gen. Barbara Holcomb, "but given that more than 80 percent of combat deaths occur in the prehospital environment, we now have to replicate that success for Warfighters in more austere conditions and far-forward environments."
For incoming Army Trauma Training Department Director Col. Kirby Gross, the future of resuscitation products can be found by looking back to the era of pin-up girls, wide-brimmed hats and Ava Gardner.
"We're finally realizing the value of something we first learned back in the 1940s," said Gross, speaking alongside Remick on the value of whole blood in the treatment of trauma patients. "We simply got away from the basics in the 1970s, 1980s and 1990s."
According to Gross, the culprit in those decades was an over-reliance on blood components and crystalloid therapy, the latter of which can cause notable side effects like edema. Therefore the actual "innovation," with regards to the use of whole blood, is not so much a technological advancement as it is a reassessment of known factors.
"The Army rangers now use Type-O blood for point-of-injury care while serving in-theater," said Gross, "which shows you just how far we've come back around."
Said Remick, "Despite these successes, we still have key gaps in several areas, so it's important to forge ahead for the good of the service and the country."


The FX-991EX advanced scientific calculator features a new high-resolution LC display with 192 x 63 pixels and a resolution that is four times higher than that of the FX-ES plus series. This calculator has over 550 functions, and has 47 scientific constants. Thanks to the QR code function, calculation results can be viewed on a smartphone or tablet, increasing your flexibility when working on the move. The spreadsheet function also allows the user to perform basic spreadsheet calculations on a scientific calculator for the first time.


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HomeBlogNews2016Free Webinar – Redirection Project: Career Development and Job Shifts for the 50+
Free Webinar – Redirection Project: Career Development and Job Shifts for the 50+
November 17, 2016By Ye Liu
CERIC will be offering a free webinar, Redirection Project: Career Development and Job Shifts for the 50+ on Thursday, January 12, 2017 (12:00 pm – 1:00 pm ET). A national CERIC-funded research initiative, Dr Suzanne Cook led the Redirection Project and will present her findings on later life career development among adults age 50 and older who shifted into second or third careers, as well as the experiences of career practitioners working with older adults.
Join us to learn:
What research tells us about the trend towards delayed retirement and the expansion of working lives
The diversity of paid work undertaken by those 50+ and their later life career needs
Best practices for working with older adults on employment and career development issues
Dr Cook is a social gerontologist and Adjunct Professor at York University in the Department of Sociology and York's Centre for Aging Research and Education. Her research bridges theory, research and practice.
Find out more and register.


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Home 2021 Tokyo2020: Enthralling opening day of women's Rugby Sevens
Tokyo2020: Enthralling opening day of women's Rugby Sevens
Australia, France, New Zealand and the USA finish first day of Tokyo 2020 women's rugby sevens competition with perfect records
Thrilling encounter between New Zealand and Great Britain saw the Black Ferns Sevens overcome a 21-0 deficit to win 26-21 in a scintillating match
Top two in each pool and the two best third-placed teams qualify for the medal quarter-finals, meaning every nation still has a last-eight spot to play for on day two
Fiji and Brazil take to the Tokyo Stadium pitch for the first match on Friday at 09:00 local time (GMT+9)
The medal quarter-finals will take place from 17:30 to 19:30 local time (GMT+9) on Friday
Four teams remain unbeaten at the end of day one of the women's Olympic rugby sevens tournament following two pulsating sessions at Tokyo Stadium.
Rio 2016 gold medallists Australia, France, the USA and top seeds New Zealand all got off to a perfect start at Tokyo 2020, winning consecutive matches on the opening day.
DAY ONE REVIEW >>
Defending champions Australia beat Japan and China in Pool C, while New Zealand, who won silver five years ago, beat Kenya and overturned a 21-point deficit to secure a narrow victory against Great Britain in a scintillating encounter of top quality rugby sevens.
France and the USA also won both their matches on Thursday but Rio 2016 bronze medallists Canada slipped to defeat against an impressive Fiji side in the second session at Tokyo Stadium.
France beat Fiji 12-5 with tries from captain Fanny Horta and speedster Séraphine Okemba in the first game of the tournament and Les Bleues head into day two unbeaten after they followed up their opening win with a comfortable 40-5 defeat of Brazil in the second session.
In the second match in Pool B, Canada opened their Tokyo 2020 campaign with an impressive 33-0 defeat of Brazil.
Canada's hopes of repeating their bronze medal performance at Rio 2016 took a hit in the second session on Thursday when they lost 26-12 to an inspired Fijiana side, who had seen their male counterparts claim the gold medal on Wednesday evening.
Emma Tonegato scored the first hat-trick of the women's tournament at Tokyo Stadium as defending champions Australia began their Pool C campaign with a 48-0 win against hosts Japan.
China became only the second team to score the first try of an Olympic match against Australia when the teams met in Thursday's second session, but Australia responded with tries from Sharni Williams, Charlotte Caslick, Faith Nathan and Madison Ashby to win the match 26-10.
Earlier, Kristi Kirshe provided a match-winning impact from the bench in the opening match of Pool C as the USA came from behind to see off China 28-14.
The USA made sure of their place in the medal quarter-finals on day three as they won their second match on Thursday 17-7 against Japan.
Great Britain had two tries from co-captain Abbie Brown to thank as they twice came from behind to win an enthralling Pool A opener against the Russian Olympic Committee team (ROC) 14-12.
In the final match of the first session, New Zealand began their quest for a first Olympic sevens gold medal with a 29-7 win against Kenya.
Michaela Blyde was the match-winner in New Zealand's second match of day one as the Black Ferns Sevens recovered from going 21-0 down to beat Great Britain 26-21 in a scintillating match.
Great Britain raced into a three-score lead in the first half as Helena Rowland, Megan Jones and Jasmine Joyce scored tries in the opening five minutes.
However, the New Zealand comeback started before half-time as Blyde scored twice, before Tyla Nathan-Wong scored a sensational solo try midway through the second half.
Great Britain led until the final minute, but Blyde found space again to score for a third time and secure a mammoth comeback win.
In the final match of Day One, the ROC held off a spirited comeback from Kenya to record their first-ever Olympic sevens victory, beating the Lionesses 35-12.
DAY TWO PREVIEW >>
The competition will intensify on Friday as the 12-team field is narrowed to four gold medal hopefuls by the end of it.
The four undefeated teams will now hope to finish their pool stage campaign with the win that would guarantee the top spot in their respective groups.
But, with the top two in each pool and the two best third-placed teams qualifying for the medal quarter-finals each of the competing nations has a last-eight spot to play for on day two.
Defending champions Australia will continue their pursuit of glory at Tokyo 2020 at 10:30 local time (GMT+9) when they take on Pool C rivals the USA, who were the only team they played and failed to beat at Rio 2016.
The two teams were drawn together in Pool A five years ago, and also met in their final match of the pool stage. On that occasion, Australia needed a late Emma Tonegato try to secure a 12-12 draw that sent both teams into the medal quarter-finals.
Tonegato is one of five members of Australia's gold medal-winning squad that have been selected for Tokyo 2020, and she was in fine form on day one, scoring a hat-trick against Japan.
Victory for either side would guarantee top spot in Pool C and set up a medal quarter-final against the team that finishes second in Pool A.
The teams have met 13 times since their first Olympic meeting, with Australia winning eight of those matches including the bronze final at Rugby World Cup Sevens 2018 in San Francisco.
Australia and the USA both recorded wins over China and Japan on day one, however, one of the Asian teams could still qualify for the medal quarter-finals with a victory in their match on day two, which kicks off at 10:00 local time (GMT+9).
France could exact Olympic revenge on Canada, and boost their Tokyo 2020 medal hopes, when the two teams meet in their final Pool B match at 09:30 local time on Friday.
Canada beat Les Bleues 15-5 in the medal quarter-finals five years ago and went on to earn their place on the podium, beating Great Britain in the bronze medal match at Deodoro Stadium.
But, the Canadians need to win when the two teams meet again at Tokyo Stadium to be sure of a medal quarter-final place, after they lost 26-12 to Fiji in Thursday's second session.
Les Bleues have won only one of the team's 17 World Rugby Sevens Series matches since Rio, but they did beat Canada in the RWC Sevens 2018 quarter-finals.
Should France win on Friday then their prize would be top spot in Pool B and a medal quarter-final against the best third-place finisher.
Fiji could seal their own progress to the last eight with a victory against Brazil when the teams meet in the opening match of day two at 09:00 local time.
New Zealand will top Pool A if they make it three wins out of three against the Russian Olympic Committee team (ROC) at 11:30 local time.
A Russian team has only ever beaten the Black Ferns Sevens once before — a 33-7 win at the Dubai Sevens in 2015 — although there have been two draws in their 27 meetings to date.
New Zealand will be keen to end their pool stage campaign on a winning note, meanwhile, and know that victory would set up a medal quarter-final against the second-best third-placed finisher.
Great Britain will want to rebound from their loss to New Zealand with victory against Kenya when the teams meet at 11:00 local time (GMT+9).
Whoever finishes top of Pool A will feature in the first medal quarter-final, which is scheduled to kick-off at 17:30 local time (GMT+9). The final last-eight match will kick-off at 19:00 local time (GMT+9).
Prior to the quarter-finals, the ninth-place semi-finals will take place at 16:30 and 17:00 local time. – WORLD RUGBY
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Posts Tagged 'Territorial Taxation'
Four Things to Understand about the Taxation of International Businesses
Posted in Corporate income tax, Corporate tax, Economics, Fiscal Policy, Harmonization, International bureaucracy, International Monetary Fund, Tax Increase, Taxation, Territorial Taxation, Worldwide Taxation, tagged Corporate income tax, Corporate tax, Economics, Fiscal Policy, Harmonization, IMF, International bureaucracy, International Monetary Fund, Tax Increase, Taxation, Territorial Taxation, Worldwide Taxation on September 10, 2019| 2 Comments »
A few years ago, I put together a basic primer on corporate taxation. Everything I wrote is still relevant, but I didn't include much discussion about international topics.
In part, that's because those issues are even more wonky and more boring than domestic issues such as depreciation. But that doesn't mean they're not important – especially when they involve tax competition. Here are some comments I made in March of last year.
The reason I'm posting this video about 18 months after the presentation is that the issue is heating up.
The tax-loving bureaucrats at the International Monetary Fund have published a report whining about the fact that businesses utilize low-tax jurisdictions when making decisions on where to move money and invest money.
According to official statistics, Luxembourg, a country of 600,000 people, hosts as much foreign direct investment (FDI) as the United States and much more than China. Luxembourg's $4 trillion in FDI comes out to $6.6 million a person. FDI of this size hardly reflects brick-and-mortar investments in the minuscule Luxembourg economy. …much of it is phantom in nature—investments that pass through empty corporate shells. These shells, also called special purpose entities, have no real business activities. Rather, they carry out holding activities, conduct intrafirm financing, or manage intangible assets—often to minimize multinationals' global tax bill. …a few well-known tax havens host the vast majority of the world's phantom FDI. Luxembourg and the Netherlands host nearly half. And when you add Hong Kong SAR, the British Virgin Islands, Bermuda, Singapore, the Cayman Islands, Switzerland, Ireland, and Mauritius to the list, these 10 economies host more than 85 percent of all phantom investments.
That's a nice list of jurisdictions. My gut instinct, of course, is to say that high-tax nations should copy the pro-growth policies of places such as Bermuda, Singapore, the Cayman Islands, and Switzerland.
The IMF, however, thinks those are bad places and instead argues that harmonization would be a better approach.
…how does this handful of tax havens attract so much phantom FDI? In some cases, it is a deliberate policy strategy to lure as much foreign investment as possible by offering lucrative benefits—such as very low or zero effective corporate tax rates. …This…erodes the tax bases in other economies. The global average corporate tax rate was cut from 40 percent in 1990 to about 25 percent in 2017, indicating a race to the bottom and pointing to a need for international coordination. …the IMF put forward various alternatives for a revised international tax architecture, ranging from minimum taxes to allocation of taxing rights to destination economies. No matter which road policymakers choose, one fact remains clear: international cooperation is the key to dealing with taxation in today's globalized economic environment.
Here's a chart that accompanied the IMF report. The bureaucrats view this as proof of something bad
I view it as prudent and responsible corporate behavior.
At the risk of oversimplifying what's happening in the world of international business taxation, here are four simple points.
It's better for prosperity if money stays in the private sector, so corporate tax avoidance should be applauded. Simply stated, politicians are likely to waste any funds they seize from businesses. Money in the private economy, by contrast, boosts growth.
Multinational companies will naturally try to "push the envelope" and shift as much income as possible to low-tax jurisdictions. That's sensible corporate behavior, reflecting obligation to shareholders, and should be applauded.
Nations can address "profit shifting" by using rules on "transfer pricing," so there's no need for harmonized rules. If governments think companies are pushing too far, they can effectively disallow tax-motivated shifts of money.
A terrible outcome would be a form of tax harmonization known as "global formula apportionment." This wouldn't be harmonizing rates, as the E.U. has always urged, but it would force companies to overstate income in high-tax nations.
Why does all this wonky stuff matter?
As I said in my presentation, we will suffer from "goldfish government" unless tax competition exiss to serve as a constraint on the tendency of politicians to over-tax and over-spend.
P.S. Sadly, America's Treasury Secretary is sympathetic to global harmonization of business taxation.
Will the Supreme Court Grant States Extraterritorial Tax Powers?
Posted in Sales Tax, States, Tax Competition, Taxation, Territorial Taxation, tagged Sales Tax, States, Tax Competition, Taxation, Territorial Taxation on April 23, 2018| 2 Comments »
On April 17, the Supreme Court heard oral arguments in South Dakota v. Wayfair, Inc., a case dealing with whether states should have the power to levy taxes on companies in other states.
Most observers see this issue as a fight over taxing the Internet, taxing online sales, or a battle between Main Street merchants and Silicon Valley tech firms. Those are all parts of the story, but I've explained that this also is a contest between two competing approaches to taxation.
On one side are pro-market people who favor origin-based taxation, which is based on the notion that sales should be taxed where the merchant is based.
On the other side are pro-government people who want destination-based taxation, which is based on the notion that sales should be taxed where the consumer lives.
Needless to say, I'm not on the pro-government side of the battle. Here's some of what I wrote when I was at the Heritage Foundation way back in 2001.
Requests to establish this destination-based tax authority should be denied. Such a regime would create an anti-consumer sales tax cartel for the benefit of profligate governments. It also would undermine privacy by requiring the collection of data on individual purchases. And it would violate important constitutional principles by giving state and local governments the power to impose their own taxes on businesses in other states.
All of that is still true today, but let's look at some more recent analysis of the issue, all of which is tied to last week's hearing at the Supreme Court.
George Will opines on South Dakota's revenue grab for the Washington Post.
South Dakota has enacted a law contradicting a 26-year-old court decision concerning interstate commerce, and a law Congress passed and extended 10 times. It wants to tax purchases that are made online from vendors that have no physical presence in the state. South Dakota wants to increase its revenue and mollify its Main Street merchants. …In 1992, in the Internet's infancy, the court held that retailers are required to collect a state's sales taxes only when the retailers have a "substantial nexus" — basically, a physical, brick-and-mortar presence — in the state where the item sold is purchased. Such a nexus would mean that the retailer benefits from, and should pay for, local government services. Absent such a nexus, however, states' taxation of sales would violate the Constitution, which vests in Congress alone the power to impose such burdens on interstate commerce. …Internet commerce…could not have flourished if vendors bore the burden of deciphering and complying with the tax policies of 12,000 state and local taxing jurisdictions, with different goods exempted from taxation. …the Internet Tax Freedom Act…is intended to shield small Internet sellers from discriminatory taxes and compliance burdens. …South Dakota is seeking the court's permission for its extraterritorial grasping. …Governments often are reflexively reactionary when new technologies discomfort established interests with which the political class has comfortable relations of mutual support. The state's sales-tax revenue has grown faster than the state's economy even as Internet retailing has grown. …Traditional retailing will…prosper or not depending on market forces, meaning Americans' preferences. State governments should not try to prevent this wholesome churning from going where it will.
The Wall Street Journal also has opined in favor of limits on the ability of states to impose their laws outside their borders.
The Supreme Court's landmark 1992 Quill decision protects small businesses across the country from tax-grubbing politicians across the country. …At issue in South Dakota v. Wayfair is whether governments can tax and regulate remote retailers that don't enjoy the state's representation or benefit from its public services. …Fast forward 25 years. States complain that online commerce is eroding their tax base. Brick-and-mortar stores grouse that remote retailers are dodging taxes, putting them at a competitive disadvantage. …Politicians would prefer to soak out-of-state retailers rather than their own taxpayers. But America's founders devised the Commerce Clause to prevent states from burdening interstate commerce and making long-arm tax grabs.
Here's a troubling tidbit from the WSJ editorial. The Trump Administration is siding with South Dakota politicians, using the same statist rationale as the European politicians who are trying to grab more money from high-tech American companies.
The Justice Department has filed a brief supporting South Dakota… Seriously? According to Justice, businesses that operate a website have a "virtual" presence everywhere. The European Commission has invoked the same argument to impose a digital tax on Silicon Valley tech giants, which the Trump Administration has denounced as an extraterritorial tax grab.
Wow, the incompetence is staggering. The Stupid Party strikes again.
Veronique de Rugy explains in her Reason column that state governments want to overturn Quill because they don't want tax competition.
If you think internet companies aren't paying any taxes for online sales and that's killing bricks-and-mortar retailers and states' budgets, you, my friend, have been duped. Nothing could be further from the truth. …Most state lawmakers want to see Quill overturned, allowing them to force out-of-state companies to collect sales taxes on their behalf. This argument was just heard by the Supreme Court… If the states were to win, they would be able to reach into the pockets of that mom selling her paintings on Etsy, even though she may live on the other side of the country, didn't elect other states' officials, and never agreed to those states' tax laws. …tax competition among states would also be lost if Quill were overturned. Under the new regime, online consumers—no matter where they shop or what they buy—would lose the ability to shop around for a better tax system. Without the competitive pressure and the fear of losing consumers to lower-tax states, lawmakers would not feel the need to try to rein in their sales tax burden. It's that pressure, which limits their tax grabbing abilities, that these lawmakers resent and want the Supreme Court to put an end to. …There is a lot to be lost in the Wayfair case. If Quill were to be overturned, compliance costs could skyrocket for many retailers, and good principles of taxation would be thrown out the window. Healthy tax competition is at stake. Let's hope the highest court in the land makes the right decision.
In a column for the Wall Street Journal, Chris Cox, former Congressman and former Chairman of the Securities and Exchange Commission, debunks the notion that states are suffering for a loss of tax revenue.
'Our states are losing massive sales-tax revenues that we need for education, health care, and infrastructure," South Dakota's Attorney General Marty Jackley told the U.S. Supreme Court… His state's Supreme Court opined that sales tax revenues have "declined." The state Legislature, citing its own "finding" to this effect, enacted a law requiring out-of-state retailers to collect sales tax on purchases shipped to South Dakota.
Here's the data debunking Jackley's claim about South Dakota "losing massive sales-tax revenues."
…the law is based on a false premise. The state's own data show that sales and use tax revenue grew from $787.7 million in 2013 to $974.7 in 2017—considerably faster than the state's rate of economic growth. The governor's budget for 2018 projects the state's sales and use tax revenue will be more than $1 billion, 4% higher than last year, with no change in rate. That's 29% higher than five years earlier. Sales-tax revenues have been booming in other states, too.
In other words, politicians are greedy and they're willing to prevaricate. They want more and more revenue and they don't want to face competitive pressure that might limit their ability to extract more money that can be used to buy votes.
Is anyone shocked?
P.S. The fight between "origin-based" and "destination-based" approaches to consumption taxation is very analogous to the fight between "territorial" and "worldwide" approaches to income taxation.
P.P.S. Given that it arguably has the best (or least-destructive) tax system of any state, it's disappointing to see South Dakota politicians taking a lead role in an effort that would undermine tax competition.
The Goal of Business Tax Reform Should Be Enhanced Competitiveness, not More Loot for Politicians
Posted in Competitiveness, Corporate income tax, Corporate tax, International Taxation, Territorial Taxation, Worldwide Taxation, tagged Competitiveness, Corporate income tax, Corporate tax, International Taxation, Territorial Taxation, Worldwide Taxation on October 5, 2017| 8 Comments »
The Republican tax plan is based on some very attractive principles.
Lowering the corporate tax rate.
Ending the tax bias against new investment.
Eliminating harmful loopholes.
Reducing double taxation.
Unfortunately, the GOP isn't planning to completely fix these policies, largely because there's no commitment to control government spending. But any shift toward better tax policy will be good for the nation.
Another goal to add to the above list is that Republicans want to create a level playing field for American-based firms by replacing "worldwide taxation" of business income with "territorial taxation" of business income.
For those who have wisely avoided the topic of international business taxation, here's all you need to know: Worldwide taxation means a company that earns income in another country is taxed both by the government where the income is earned and by the government back home. Territorial taxation, by contrast, is simply the common-sense notion that income is taxed only by the government where the income is earned.
In a column for the Wall Street Journal, two authors explain how America's anti-competitive system of worldwide taxation undermines U.S.-domiciled companies.
…earlier this month Iconix , the U.S.-based company that owns the rights to Charles Schulz's comic characters, announced it will sell them to Canada's DHX Media. That makes Charlie Brown America's latest expatriate. It's a clear signal that U.S. corporate taxes are nudging business elsewhere. …why? In part because the U.S. corporate tax system hampers U.S.-based businesses by subjecting them to world-wide taxation. Canada's aggregate corporate taxes are about 10 percentage points lower. …America's high corporate tax rate and its practice of taxing international income is out of step with the rest of the world. The solution is so clear even a cartoon character should grasp it: Cut tax rates and adopt a system for taxing international income that more closely resembles those used by the country's international competitors.
Indeed, it's worth noting that the entire "inversion" controversy only exists because of America's worldwide tax regime.
Simply stated, American-domiciled multinationals have a big competitive disadvantage compared to their foreign rivals. So it's understandable that many of them try to protect shareholders, workers, and consumers by arranging (usually through a merger) to become foreign companies.
That's the bad news.
The good news is that the Republican tax reform plan ostensibly will shift America to a territorial tax system. As explained above, this is the sensible notion of letting other nations tax income earned inside their borders while the IRS would tax the income earned by companies in the United States.
This would be good for competitiveness, particularly since the United States is one of only a handful of nations that impose a worldwide tax burden on domestic firms.
But not everybody likes the idea of territorial taxation.
One reason for opposition is that some people see corporations primarily as sources of tax revenue. So when there are discussions of international tax, their mindset is nations should compete on grabbing the most money. I'm not joking.
European Union regulators' tax crackdown on Amazon.com Inc. — like the EU's case against Apple Inc. — should spur U.S. policy makers to address companies' aggressive offshore tax-avoidance strategies before it's too late, experts said. …"Really, what we are seeing is a race by the different taxing jurisdictions to claim a share of the tax prize represented by the largely untaxed streams of income that U.S. multinationals have engineered for themselves,'' said Ed Kleinbard, a professor at the University of Southern California and the former chief of staff for Congress's Joint Committee on Taxation. "If the United States doesn't join the race, it will just lose tax revenue to more aggressive host countries around the world.'' The EU rulings "do make it clear that if we are not interested in protecting our corporate tax base, other countries will be more than happy to tax the income,'' said Kimberly Clausing, a professor of economics at Reed College in Portland, Oregon.
Call me crazy, but I think American policymakers should be in a race to create jobs, boost investment, and increase wages. And that means doing the opposite of what these supposed experts want.
Unsurprisingly, left-wing groups also are opposed to territorial taxation. Here are some passages from a report published by the Hill.
One hundred organizations, including a number of progressive groups and labor unions, are urging Congress to reject a major international tax change proposed in Republicans' framework for a tax overhaul. In a letter dated Monday, the groups speak out against the framework's move toward a "territorial" tax system that would largely exempt American companies' foreign profits from U.S. tax. …"Ending taxation of offshore profits would give multinational corporations an incentive to send jobs offshore, thereby lowering U.S. wages," they wrote.
Both assertions in that excerpt are wrong and/or misleading.
First, territorial taxation doesn't mean that profits are exempt from tax. It simply means that the IRS doesn't impose an additional layer of tax on income that already has been subject to the tax system of another country.
And other countries impose plenty of tax on American firms operating overseas.
Second, the incentive to shift job overseas is caused by America's high corporate tax rate. That's what makes it attractive for firms to operate in other nations.
Worldwide taxation is not the way to fix that bias since foreign-domiciled companies wouldn't be impacted and they easily can sell into the American market.
By the way, the Republican tax plan doesn't even create a real territorial tax system. Returning to the Bloomberg story cited above, the GOP proposal basically copies a very bad idea that was being pushed a few years ago by the Obama Administration.
…the GOP tax framework contemplates a so-called "minimum foreign tax'' on multinationals' future earnings that would apply in cases where a company's effective tax rate fell below a pre-determined threshold.
To be fair, the Republican approach is less punitive that what Obama wanted.
Nonetheless, I worry that if Republicans adopt some sort of global minimum tax, it will just be a matter of time before that rate increases. In which case a shift toward territoriality actually plants a seed for a more onerous worldwide system!
Without knowing what will happen in the future, there's no right or wrong answer, but I'm wondering whether the smart approach is to simply leave the current system in place. Yet, it's based on worldwide taxation, but at least companies have deferral, which creates de facto territoriality for firms that manage their affairs astutely.
Such a shame that the GOP isn't capable of simply doing the right thing.
Hillary Clinton's "Exit Tax" Is an Unseemly Example of Banana Republic Economics
Posted in Competitiveness, Corporate income tax, Corporate tax, Deferral, Economics, Hillary Clinton, Taxation, Territorial Taxation, Worldwide Taxation, tagged Competitiveness, Corporate income tax, Corporate tax, Deferral, Economics, Hillary Clinton, Taxation, Territorial Taxation, Worldwide Taxation on August 22, 2016| 8 Comments »
If you get into the weeds of tax policy and had a contest for parts of the internal revenue code that are "boring but important," depreciation would be at the top of the list. After all, how many people want to learn about America's Byzantine system that imposes a discriminatory tax penalty on new investment? Yes, it's a self-destructive policy that imposes a lot of economic damage, but even I'll admit it's not a riveting topic (though I tried to make it culturally relevant by using ABBA as an example).
In second place would be a policy called "deferral," which deals with a part of the law that allows companies to delay an extra layer of tax that the IRS imposes on income that is earned – and already subject to tax – in other countries. It is "boring but important" because it has major implications on the ability of American-domiciled firms to compete for market share overseas.
Here's a video that explains the issue, though feel free to skip it and continue reading if you already are familiar with how the law works.
The simple way to think of this eye-glazing topic is that "deferral" is a good policy that partially mitigates the impact of a bad policy known as "worldwide taxation."
Unfortunately, good policy tends to be unpopular in Washington. This is why deferral (and related issues such as inversions, which occur for the simple reason that worldwide taxation creates a huge competitive disadvantage for U.S.-domiciled companies) is playing an unusually large role in the 2016 election and concomitant tax debates.
Consider the tax controversy involving Apple. The CEO does not want to surrender money that belongs to shareholders to the government.
Apple CEO Tim Cook struck back at critics of the iPhone maker's strategy to avoid paying U.S. taxes, telling The Washington Post in a wide ranging interview that the company would not bring that money back from abroad unless there was a "fair rate."
Since the discussion is about income that Apple has earned in other nations (and therefore about income that already has been subject to all applicable taxes in other nations), the only "fair rate" from the United States is zero.
That's because good tax systems are based on "territorial taxation" rather than "worldwide taxation."
Though a worldwide tax system might not impose that much damage if a nation had a low corporate tax rate.
Unfortunately, that's not a good description of the U.S. system, which has a very high rate, thus creating a big incentive to hold money overseas to avoid having to pay a very hefty second layer of tax to the IRS on income that already has been subject to tax by foreign governments.
Along with other multinational companies, the tech giant has been subject to criticism over a tax strategy that allows them to shelter profits made abroad from the U.S. corporate tax rate, which at 35 percent is among the highest in the developed world.
"Among"? I don't know if this is a sign of bias or ignorance on the part of CNBC, but the U.S. unquestionably has the highest corporate tax rate among developed nations.
Indeed, it might even be the highest in the entire world.
Anyhow, Mr. Cook points out that there's nothing patriotic about needlessly paying extra tax to the IRS, especially when it would mean a very punitive tax rate.
…a few particularly strident critics have lambasted Apple as a tax dodger. …While some proponents of the higher U.S. tax rate say it's unpatriotic for companies to practice inversions or shelter income, Cook hit back at the suggestion. "It is the current tax law. It's not a matter of being patriotic or not patriotic," Cook told The Post in a lengthy sit-down. "It doesn't go that the more you pay, the more patriotic you are." …Cook added that "when we bring it back, we will pay 35 percent federal tax and then a weighted average across the states that we're in, which is about 5 percent, so think of it as 40 percent. We've said at 40 percent, we're not going to bring it back until there's a fair rate. There's no debate about it."
Cook may be right that there's "no debate" about whether it's sensible for a company to keep money overseas to guard against bad tax policy.
But there is a debate about whether politicians will make the law worse in a grab for more revenue.
Senator Ron Wyden, for instance, doesn't understand the issue. He wrote an editorial asserting that Apple is engaging in a "rip-off."
…the heart of this mess is the big dog of tax rip-offs – tax deferral. This is the rule that encourages American multinational corporations to keep their profits overseas instead of investing them here at home, and it does so by granting them $80 billion a year in tax breaks. This policy…defies common sense. …some of the most profitable companies in the world can put off paying taxes indefinitely while hardworking Americans must pay their taxes every year. …that system creates a perverse incentive to keep corporate profits overseas instead of investing here at home.
I agree with him that the current system creates a perverse incentive to keep money abroad.
But you don't solve that problem by imposing unconstrained worldwide taxation, which would create a perverse incentive structure that discourages American-domiciled firms from competing for market share in other nations.
Amazingly, Senator Wyden actually claims that making the system more punitive would help make America a better place to do business.
…ending deferral is a necessary step in making sure…the U.S. maintains its position as the best place to do business.
Wow, this rivals some of the crazy things that Barack Obama and Hillary Clinton have said.
Though I guess we need to give Wyden credit for honesty. He admits that what he really wants is for Washington to have more money to spend.
Ending deferral will also generate money from existing deferred taxes to pay for rebuilding our country's crumbling infrastructure. …This is a priority that almost all tax reform proposals have called for.
By the way, can you guess which presidential candidate agrees with Senator Wyden and wants to impose full and immediate worldwide taxation?
If you answered Hillary Clinton, you're right. But if you answered Donald Trump, that also would be a correct answer.
This is a grim example of why I refer to them as the Tweedledee and Tweedledum of statism.
Though to be fair, Trump's plan at least contains a big reduction in the corporate tax rate, which would substantially reduce the negative impact of a worldwide tax system.
The Wall Street Journal opines on the issue and is especially unimpressed by Hillary Clinton's irresponsible approach on the issue.
Mrs. Clinton is targeting so-called inversions, where U.S.-based companies move their headquarters by buying an overseas competitor, as well as foreign takeovers of U.S. firms for tax considerations. These migrations are the result of a U.S. corporate-tax code that supplies incentives to migrate… The Democrat would impose what she calls an "exit tax" on businesses that relocate outside the U.S., which is the sort of thing banana republics impose when their economies sour. …Mrs. Clinton wants to build a tax wall to stop Americans from escaping. "If they want to go," she threatened in Michigan, "they're going to have to pay to go."
Ugh, making companies "pay to go" is an unseemly sentiment. Sort of what you might expect from a place like Venezuela where politicians treat private firms as a source of loot for their cronies.
The WSJ correctly points out that the problem is America's anti-competitive worldwide tax regime, combined with a punitive corporate tax rate.
…the U.S. taxes residents—businesses and individuals—on their world-wide income, not merely the income that they earned in the U.S. …the U.S. taxes companies headquartered in the U.S. far more than companies based in other countries. Thirty-one of the 34 OECD countries have cut corporate taxes since 2000, leaving the U.S. with the highest rate in the industrialized world. The U.S. system of world-wide taxation means that a company that moves from Dublin, Ohio, to Dublin, Ireland, will pay a rate that is less than a third of America's. A dollar of profit earned on the Emerald Isle by an Irish-based company becomes 87.5 cents after taxes, which it can then invest in Ireland or the U.S. or somewhere else. But if the company stays in Ohio and makes the same buck in Ireland, the after-tax return drops to 65 cents or less if the money is invested in America.
In other words, the problem is obvious and the solution is obvious.
But there are too many Barack Obamas and Elizabeth Warrens in Washington, so it's more likely that policy will move in the wrong direction.
The "Race to the Bottom" and Global Minimum Corporate Taxes
Posted in Competitiveness, Corporate income tax, Corporate tax, Deferral, Fiscal Policy, Jurisdictional Competition, Obama, Tax Competition, Taxation, Territorial Taxation, Worldwide Taxation, tagged Competitiveness, Corporate income tax, Corporate tax, Deferral, Fiscal Policy, Jurisdictional Competition, Obama, Tax Competition, Taxation, Territorial Taxation, Worldwide Taxation on May 5, 2016| 18 Comments »
Imagine if you had the chance to play basketball against a superstar from the NBA like Stephen Curry.
No matter how hard you practiced beforehand, you surely would lose.
For most people, that would be fine. We would console ourselves with the knowledge that we tried our best and relish he fact that we even got the chance to be on the same court as a professional player.
But some people would want to cheat to make things "equal" and "fair." So they would say that the NBA player should have to play blindfolded, or while wearing high-heeled shoes.
And perhaps they could impose enough restrictions on the NBA player that they could prevail in a contest.
But most of us wouldn't feel good about "winning" that kind of battle. We would be ashamed that our "victory" only occurred because we curtailed the talents of our opponent.
Now let's think about this unseemly tactic in the context of corporate taxation and international competitiveness.
The United States has the highest corporate tax rate in the industrialized world, combined with having the most onerous "worldwide" tax system among all developed nations.
This greatly undermines the ability of U.S.-domiciled companies to compete in world markets and it's the main reason why so many companies feel the need to engage in inversions.
So how does the Obama Administration want to address these problems? What's their plan to reform the system to that American-based firms can better compete with companies from other countries?
Unfortunately, there's no desire to make the tax code more competitive. Instead, the Obama Administration wants to change the laws to make it less attractive to do business in other nations. Sort of the tax version of hobbling the NBA basketball player in the above example.
Here are some of the details from the Treasury Department's legislative wish list.
The Administration proposes to supplement the existing subpart F regime with a per-country minimum tax on the foreign earnings of entities taxed as domestic C corporations (U.S. corporations) and their CFCs. …Under the proposal, the foreign earnings of a CFC or branch or from the performance of services would be subject to current U.S. taxation at a rate (not below zero) of 19 percent less 85 percent of the per-country foreign effective tax rate (the residual minimum tax rate). …The minimum tax would be imposed on current foreign earnings regardless of whether they are repatriated to the United States.
There's a lot of jargon in those passages, and even more if you click on the underlying link.
So let's augment by excerpting some of the remarks, at a recent Brookings Institution event, by the Treasury Department's Deputy Assistant Secretary for International Tax Affairs. Robert Stack was pushing the President's agenda, which would undermine American companies by making it difficult for them to benefit from good tax policy in other jurisdictions.
He actually argued, for instance, that business tax reform should be "more than a cry to join the race to the bottom."
In other words, he doesn't (or, to be more accurate, his boss doesn't) want to fix what's wrong with the American tax code.
So he doesn't seem to care that other nations are achieving good results with lower corporate tax rates.
I do not buy into the notion that the U.S. must willy-nilly do what everyone else is doing.
And he also criticizes the policy of "deferral," which is a provision of the tax code that enables American-based companies to delay the second layer of tax that the IRS imposes on income that is earned (and already subject to tax) in other jurisdictions.
I don't think it's open to debate that the ability of US multinationals to defer income has been a dramatic contributor to global tax instability.
He doesn't really explain why it is destabilizing for companies to protect themselves against a second layer of tax that shouldn't exist.
But he does acknowledge that there are big supply-side responses to high tax rates.
…large disparity in income tax rates…will inevitably drive behavior.
Too bad he doesn't draw the obvious lesson about the benefits of low tax rates.
Anyhow, here's what he says about the President's tax scheme.
The President's global minimum tax proposal…permits tax-free repatriation of amounts earned in countries taxed at rates above the global minimum rate. …the global minimum tax plan also takes the benefit out of shifting income into low and no-tax jurisdictions by requiring that the multinational pay to the US the difference between the tax haven rate and the U.S. rate.
The bottom line is that American companies would be taxed by the IRS for doing business in low-tax jurisdictions such as Ireland, Hong Kong, Switzerland, and Bermuda.
But if they do business in high-tax nations such as France, there's no extra layer of tax.
The bottom line is that the U.S. tax code would be used to encourage bad policy in other countries.
Though Mr. Stack sees that as a feature rather than a bug, based on the preposterous assertion that other counties will grow faster if the burden of government spending is increased.
…the global minimum tax concept has an added benefit as well…protecting developing and low-income countries…so they can mobilize the necessary resources to grow their economies.
And he seems to think that support from the IMF is a good thing rather than (given that bureaucracy's statist orientation) a sign of bad policy.
At a recent IMF symposium, the minimum tax was identified as something that could be of great help.
The bottom line is that the White House and the Treasury Department are fixated at hobbling competitors by encouraging higher tax rates around the world and making sure that American-based companies are penalized with an extra layer of tax if they do business in low-tax jurisdictions
For what it's worth, the right approach, both ethically and economically, is for American policy makers to focus on fixing what's wrong with the American tax system.
P.S. When I debunked Jeffrey Sachs on the "race to the bottom," I showed that lower tax rates do not mean lower tax revenue.
Correcting White House Anti-Inversion Propaganda
Posted in Corporate income tax, Corporate tax, Economics, Taxation, Territorial Taxation, Worldwide Taxation, tagged Corporate income tax, Corporate Inversion, Corporate tax, Economics, Inversion, Taxation, Territorial Taxation, Worldwide Taxation on April 11, 2016| 15 Comments »
I wrote recently about the Pfizer-Allergan merger and made the case that it was a very sensible way to protect the interests of workers, consumers, and shareholders.
That's the good news.
Why? Because companies should be allowed to engage in a do-it-yourself form of territorial taxation to minimize the damage caused by bad tax policy coming out of Washington.
The bad news is that the White House, with its characteristic disregard of the rule of law, promulgated a regulation that retroactively changed existing tax law and derailed the merger.
Now the White House has produced an infographic designed to bolster its case against inversions, which I have reprinted to the right.
You can click on this link to see the full-sized version, but I thought the best approach would be to provide a "corrected" version.
So if you look below, you'll find my version, featuring the original White House document on the left and my editorial commentary on the right.
But if you don't want to read the document and my corrections, all you need to know is that the Obama Administration makes several dodgy assumptions and engages in several sins of omission. Here are the two biggest problems.
No acknowledgement that the U.S. corporate tax regime drives inversions because of high rates and worldwide taxation.
A bizarre and anti-empirical assertion that money is spent more productively by governments compared to the private sector.
And here's the entire "corrected" infographic.
The bottom line is there aren't any "loopholes" being exploited by inverting companies.
Instead, there's a very anti-growth American tax system that makes it very difficult for American-domiciled firms to compete in global markets.
The solution is a simple, low rate flat tax.
Corporate Inversions: Obama Fiddles While the Corporate Tax Burns U.S. Competitiveness
Posted in Corporate income tax, Corporate tax, Economics, Fiscal Policy, Tax avoidance, Tax Competition, Taxation, Territorial Taxation, Worldwide Taxation, tagged Corporate income tax, Corporate Inversion, Corporate tax, Economics, Fiscal Policy, Inversion, Tax avoidance, Tax Competition, Taxation, Territorial Taxation, Worldwide Taxation on August 17, 2015| 14 Comments »
The United States has what is arguably the worst business tax system of any nation.
That's bad for the shareholders who own companies, and it's also bad for workers and consumers.
And it creates such a competitive disadvantage that many U.S.-domiciled companies are better off if they engage in an "inversion" and shift their corporate charter to a jurisdiction with better tax policy.
Unsurprisingly, the Obama White House doesn't like inversions (with some suspicious exceptions) because the main effect is to reduce tax revenue. But the Administration's efforts to thwart them haven't been very successful.
The U.K.-based Economist has just published an article on American companies re-domiciling in jurisdictions with better tax law.
A "tax inversion" is a manoeuvre in which a (usually American) firm acquires or merges with a foreign rival, then shifts its domicile abroad to reap tax benefits. A spate of such deals last year led Barack Obama to brand inversions as "unpatriotic". …The boardroom case for inversions stems from America's tax exceptionalism.
But this isn't the good kind of exceptionalism.
The internal revenue code is uniquely anti-competitive.
It levies a higher corporate-tax rate than any other rich country—a combined federal-and-state rate of 39%, against an OECD average of 25%. And it spreads its tentacles worldwide, so that profits earned abroad are also subject to American taxes when they are repatriated.
And that worldwide tax system is extremely pernicious, particularly when combined with America's punitive corporate tax rate.
Given these facts, the Economist isn't impressed by the Obama Administration's regulatory efforts to block inversions.
Making it hard for American firms to invert does precisely nothing to alter the comparative tax advantages of changing domicile; it just makes it more likely that foreign firms will acquire American ones. That, indeed, is precisely what is happening.
If American policymakers really worry about losing out to lower-tax environments, they should get rid of the loopholes that infest their tax rules, drop the corporate-income tax rate and move to a territorial system. …jobs would be less likely to flow abroad.
In a companion article, the Economist lists some of the firms that are escaping from the IRS.
…companies have continued to tiptoe out of America to places where the taxman is kinder and has shorter arms. On August 6th CF Industries, a fertiliser manufacturer, and Coca-Cola Enterprises, a drinks bottler, both said they would move their domiciles to Britain after mergers with non-American firms. Five days later Terex, which makes cranes, announced a merger in which it will move to Finland. For many firms, staying in America is just too costly. Take Burger King, a fast-food chain, which last year shifted domicile to Canada after merging with Tim Horton's, a coffee-shop operator there.
I've previously shared lists of inverting companies, as well as a map of where they go, and this table from the article is a good addition.
So how should Washington react to this exodus? The Economist explains once again the sensible policy response.
The logical way to stem the tide would be to bring America's tax laws in line with international norms. Britain, Germany and Japan all have lower corporate rates and are among the majority of countries that tax firms only on profits earned on their territory.
But the Obama Administration's response is predictably unhelpful. And may even accelerate the flight of firms.
…the US Treasury has been trying to make it harder for them to leave. …Despite such speed bumps, inversions still make enormous sense for companies with large overseas operations. If anything, the rule changes have led to more companies looking to get out before it is too late.
The Wall Street Journal opined on this issue earlier this month and reached a similar conclusion.
…a mountain of evidence that an un-competitive tax system has made the U.S. an undesirable location for corporate headquarters and investment. …high tax rates matter a great deal in determining where a company is based and where it grows.
The WSJ also pointed out that taxpayers have a right and an obligation to legally protect themselves from bad tax policy.
Shareholders deserve nothing less from management than the Warren Buffett approach of paying the lowest possible legal tax rate.
But since the White House isn't very interested in helpful reform, expect more inversions.
Which is one more piece of evidence that punitive corporate taxation isn't good news for workers.
…absent American tax reform will end up pushing more U.S. companies into foreign hands. …The ultimate losers in all of this aren't so much the owners as American workers, who often lose their jobs when a company moves abroad. …It's well past time for our government to stop creating advantages for foreign competitors.
In looking at this issue, it's easy to be discouraged since the Obama Administration is unwilling to even consider pro-growth policy responses.
As such, the problem will fester until at least 2017.
But it's possible that there could be pro-reform legislation once a new President takes office.
Particularly since the Senate's Permanent Subcommittee on Investigations (which used to be chaired by the clownish Sen. Levin, infamous for the FATCA disaster) has produced a very persuasive report on how bad U.S. tax policy is causing inversions.
Here are some excerpts from the executive summary.
The United States has the highest corporate tax rate in the industrialized world, and (alone among its peers) has retained a worldwide system that taxes American companies for the privilege of repatriating their overseas earnings. Meanwhile, most other nations with advanced economies have adopted competitive tax rates and territorial-type tax systems. As a result, U.S. firms too often have a significant incentive to relocate their headquarters overseas. Corporate inversions may be the most dramatic manifestation of that incentive… The lesson policymakers should draw from our findings is straightforward: The high U.S. corporate tax rate and worldwide system of taxation are competitive disadvantages that make it easier for foreign firms to acquire American companies. Those policies also strongly incentivize cross-border merging firms, when choosing where to locate their new headquarters, not to choose the United States. The long term costs of these incentives can be measured in a loss of jobs, corporate headquarters, and revenue to the Treasury.
Those are refreshing and intelligent comments, particularly since politicians were in charge of putting out this report rather than economists.
So maybe there's some hope for the future.
For more information on inversions and corporate tax policy, here's a short speech I gave to an audience on Capitol Hill.
P.S. Let's close with some political satire.
I've written about Bernie Sanders being a conventional statist rather than a real socialist.
But that wasn't meant to be praise. He's still clueless about economics, as illustrated by this amusing Venn diagram.
Though I'm sure many other politicians would occupy that same space.


text:
Advocate Christ Medical Center (ACMC) is a 788-bed teaching hospital located in Oak Lawn, Illinois a suburb of Chicago                    Founded in 1960, Advocate Christ Medical Center is a part of Advocate Aurora Health. In the most recent year with available data, the hospital had 40,517 admissions, 3,738 deliveries, 102,279 ED visits, 334,958 outpatient visits, and 24,745 surgeries. The emergency room includes a level 1 trauma center. The hospital operates a primary stroke center and a pulmonary rehabilitation center. ACMC operates a number of residency training and fellowship programs for newly graduated physicians, pharmacists and podiatrists. Each year, more than 400 residents, 600 medical students, and 800 nursing students train at the hospital. In 2016, ACMC opened a new eight story patient tower.

History
The hospital was founded in 1960. Originally named "Christ Hospital," the hospital was renamed Advocate Christ Medical Center in 2001. In 2016, the hospital opened a new eight-story, 326,000-square-foot patient tower. In 2016, an emergency physician filed a lawsuit alleging the hospital wrongfully terminated his employment as retaliation for his reporting concerns that a colleague was sexually harassing female physicians in training (residents). The judge awarded the physician $1 million. In 2018, Advocate Healthcare merged with Wisconsin-based Aurora Health.  In 2020, the hospital treated patients with COVID-19, as the COVID-19 pandemic developed. The hospital planned to test for COVID-19 and provide treatment at no immediate cost to patients.

Services
The hospital operates a pulmonary rehabilitation center, and a primary stroke center. The hospital provides transplant services in cooperation with Gift of Hope, including organ procurement.

Graduate medical education
Advocate Christ Medical Center operates a number of residency training and fellowship programs for newly graduated physicians. The residencies train physicians specializing in anesthesiology, emergency medicine, family medicine, general surgery, internal medicine, obstetrics/gynecology, orthopedics, and pediatrics. The internal medicine residency is affiliated with the University of Illinois College of Medicine. The hospital also operates a residency for podiatry and pharmacy graduates. Fellowship training is offered in cardiology (adult and pediatric), cardiac surgery, and breast oncology. Each year, more than 400 residents, 600 medical students, and 800 nursing students train at Advocate Christ Medical Center.

The hospital is accredited for Clinical Pastoral Education by the Council for Higher Education Accreditation.

See also
 Advocate Lutheran General Hospital
 Advocate Sherman Hospital

References

External links

Hospital buildings completed in 1960
Hospitals in Cook County, Illinois
Teaching hospitals in Illinois
Oak Lawn, Illinois
Trauma centers

redpajama_set_name: RedPajamaWikipedia


Starting week two in the simulator for my new aircraft.
Partially because I have 5000 hours airline time and partially because I'm a geek....it's gonna very well.
My sim partner isn't having such a relaxed time.
My new aircraft, ERJ-175, is much more advanced than my last. At the end of the day an airplane is an airplane, but mastering the technology is a whole different story.
In the past I would fly a non-precision approach via the "drive and dive" method. It wasn't very accurate, and required a lot of work.....but well....it's how it was done.
The ERJ-175 has VNAV and can calculate a Flight Path Angle to have a constant rate of descent. Due to a myriad of issues I can only use the VNAV to the Final Approach Fix. From the FAF inbound I have to use FPA. Not terribly complex, but it must be done. I get it. My First Officer does not.
I feel bad for them, but they actually chose this aircraft. They could have gone to a more basic jet, but for whatever reason they chose the 175. The 175 is a lot of aircraft for a new hire being their first jet.
This week I have 3 simulator events then a Manuvers Validation then a Line Operating Experience ride. The MV is the actual "check ride" while the LOE is another phase check.
So far I'm feeling very well. There are some quirks to the 175 I don't like (I have to push down on the tiller to steer and the seat doesn't go back as far as the last jet), but overall it will be better than commuting.