The Federal health care law's (Affordable Care Act) requirement that you have insurance or pay a penalty-tax (see 26 United States Code Section 5000A, (d), (2), (B)), can be met by a different route than buying the normal health insurance. It specifically allows healthcare sharing ministries, which are substantially cheaper than standard health insurance. This is not health insurance, but unites together like-minded people to share medical costs. You will need to do some background work to see if this is right for you, especially if you have many pre-existing health problems. There are only three plans that were approved through the ACA: libertyhealthshare.org, mychristiancare.org/medi-share, samaritanministries.org.
Thank you Dr Williams for this information on the medical share plans. We are taking a serious look into them.


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Home » Bordeaux Profile Index » Château Les Carmes Haut-Brion
As is the case with Château Larrivet-Haut-Brion, Château Les Carmes Haut-Brion is another property that is distinct from, and thus should certainly not be confused with, the Domaine Clarence Dillon properties of Haut-Brion, the illustrious first growth, and the associated vineyards of La Mission Haut-Brion, the now defunct Laville Haut-Brion (rebranded as the white wine of La Mission Haut-Brion starting with the 2009 vintage) and La Tour Haut-Brion (which from the 2006 has been blended into the produce of La Mission Haut-Brion). Unlike Larrivet, however, the history of Château Les Carmes Haut-Brion is intimately intertwined with these properties, as the estate, which sprang into being in the late-16th century, was once part of Haut-Brion itself. Indeed, it lies very close to the first growth (unlike Larrivet-Haut-Brion which is a little way to the south-west), although today that is as far as the parallels can be drawn.
The Carmelites
The owner of Haut-Brion at the time of the creation of Les Carmes Haut-Brion was Jean de Pontac, who was reputed to have attained the rather grand age of 101, a notable feat even today, so four centuries ago it must have been remarkable. In his dotage he gave as a gift a portion of his estate to the Carmelites, a Catholic order founded in the 12th century. The gift included a water mill, pasture land and a vineyard; the latter was tended by nuns of the order for two centuries, and during this time the name morphed from Haut-Brion to Les Carmes Haut-Brion, reflecting the ownership of the property by the religious ascetics. Their tenure came to an end with the Revolution, when the property was confiscated as a bien national and sold off, nevertheless their presence here remains stamped on the region, both in the name of the property they tended, and in the name of the street on which it can be found, the Rue des Carmes.
The estate was acquired by Léon Colin and his descendants, in the shape of the Chantecaille-Furt family, retained control of the estate for slightly longer than the Carmelites had managed. The family held tenure here through the 20th century and into the early years of the 21st century, their most notable contribution to the estate being the erection sometime during the 19th century of the attractive and certainly distinctive château; it is not as impressive as some in terms of size, but it is charmingly composed and blessed with 3 hectares of attractively landscaped gardens designed by Fischer. And perhaps the most ignominious moment came in the 1950s, when the estate was in the hands of Philippe Chantecaille, a négociant. He saw little point in submitting his property for inclusion in the 1959 Graves classification, on reflection surely a mistake. Nevertheless, this reluctance explains the absence of Les Carmes Haut-Brion from the listing today.

redpajama_set_name: RedPajamaCommonCrawl


A big part of the science of physics involves measuring the motion of objects, from a ball to a steam train. This includes plotting an object's position, velocity, acceleration and other relevant data. The graphical representation of one form of motion can lead to the graphs of the other forms of motion. For instance, the velocity-time graph is derived from the position-time graph. Similarly, the acceleration-time graph is derived from the velocity-time graph. The slopes of each graph relate to the various graphical representations of motion.
The velocity-time graph is derived from the position-time graph. The difference between them is that the velocity-time graph reveals the speed of an object (and whether it is slowing down or speeding up), while the position-time graph describes the motion of an object over a period of time.
The position-time graph describes the motion of an object over a period of time. Time in seconds is conventionally plotted on the x-axis and the position of the object in meters is plotted along the y-axis. The slope of the position-time graph reveals important information about the velocity of the object.
The slope of a position-time graph reveals the type of velocity an object undergoes during its motion. A constant slope of a position-time graph indicates a constant velocity. A varying slope of a position-time graph indicates a changing velocity. The direction of the slope of the position-time graph indicates the sign of the velocity. For example, if it slopes downward, from left to right, the velocity is negative.
The velocity-time graph of an object reveals the speed at which an object is moving at a given time and whether it is slowing down or speeding up. Time in seconds is usually plotted on the x-axis while the velocity in meters per second is usually plotted along the y-axis. Objects moving at a constant rate have a straight-line velocity-time graph. Objects moving at variable speeds have sloping, linear velocity graphs.
The slope of the velocity-time graph reveals the acceleration of an object. If the slope of the velocity-time graph is a horizontal line, the acceleration is 0. This means the object is either at rest or moving at a constant speed, without speeding up or slowing down. If the slope is positive, the acceleration is increasing. If slope is negative, acceleration is decreasing.
Braybury, Luc. "Difference Between Velocity Time Graph & Position Time Graph." Sciencing, https://sciencing.com/difference-graph-position-time-graph-8472236.html. 04 June 2018.


Rügenwalder Mühle's range of vegetarian hams and salamis is meatless and made with free-range egg ingredients. Blended with natural herbs and spices, this vegetarian deli meat line includes a variety of tasty flavor options, including vegetarian hams spiked with chives, paprika. grilled vegetables and pepper along with a meatless mortadella that is a rich source of Omega-3s.
Rügenwalder Mühle's vegetarian-friendly deli meats are organically sourced, low in saturated fats and high in protein. The German food brand's products are reflective of a growing market desire for sandwich meat alternatives that don't skip out on flavor and protein. Featuring a broad range of flavors, these meatless deli slices are sold in 80-gram packs and are available for purchase at grocer locations across Germany.


The third installment of How To Train Your Dragon is all set to release in India on 22, March,2019. It's been five years since Hiccup and Toothless unified have battle against a mysterious Dragon rider. This time we all are going to discover the mystery of hidden world. Hiccup and Toothless will leave the home they've known and will get into a new journey to a hidden world which they believed to exist in myth. The secret will no longer be secret and truth will take them to their final adventure.
How To Train Your Dragon: The Hidden World, the third adventure is simply going to blow your mind with it's perfect visuals and animations. This series is again going to bring you the unique experience and 'Dreamworks' production will lead you to remarkable ending. The relationship between Hiccup and Toothless have out grown more and The Hidden World is going bring more emotions for their audience. The Last few years the animation have changed so much and added a lot of creativity and beautiful visualization in order to make screen beautifully worked upon.
The fans have been already warned to feel some string emotions as the film will roll down to sad ending. This adventure is going to be full of emotional roller coaster ride for the audience. The Movie Critic Taran Adarsh shared on his twitter account that this film is also going to release in other regional languages like Hindi, Tamil and Telugu. The climax of this conclusion going to involve solely Hiccup and Toothless. Yes, How To Train Your Dragon 3 will be end of the Franchise.


Gravity Forms is a premium WordPress forms management plugin. The Gavity Forms plugin allows you to easily create complex forms by way of a visual form editor with drag and drop functionality, and embed them into posts and pages. No HTML or coding experience is required.
However Gravity Forms is more than just a simple contact form plugin with a range of other cool features and uses such as: allowing users to automatically create and submit posts, create auto-responder emails, export form entry data to CSV files, and more. Take the video tour of the plugin and check all the features here.
Why would anyone buy a WordPress plugin like this when there are other contact/form plugins for free which can do the same thing? What makes this plugin worth the premium?
I'm just a shopper here and haven't used the product yet, but my guess is that its because Gravity offers very attractive templates, integrates easily with a number of related features (like PayPal and checkout).


Laura has had alopecia since she was 11, and wore wigs for 18 years after that. She was a bartender in Maimi's hot bar scene for several years until she was inspired to write the children's book "I Love You More". Since then Ms. Duksta has gone on to become a popular public speaker and is a co-creator and participant in the online empowerment site MpowerU.com. Laura also now owns her own publishing company I Shine, Inc. You can view Laura's video diary on YouTube, and you can visit her fun and playful children's site.


In a wide ranging interview with Rolling Stone, Bono shared his perspectives on the modern music industry. For a man that can afford to never sing another note in his life, the U2 frontman showed a surprising grasp of the limitations and opportunities presented to all musicians by streaming and the direct to fan era.
"If you are a teenager and you are listening to whatever the pop act is, you're probably listening to them 100 times a day. It's a teenage crush, but in a year's time you won't care about that. But artists that have a connection with you and your life, you pay for the subscription service. In fact, we are going to witness a revolution in the way artists and their fans interact. Chance the Rapper, who has a beautiful soul and a mind to match it, has no record label. He is doing it himself, and he is successful..."
"...if your music is on Apple or on Spotify, you can speak straight to people. What you need from record labels is advice and, you know, help with how you manage your band or brand or the artwork and the videos and all of that."
"I knew Spotify would come through for people, but a lot of my friends were angry for believing me because they said, "We are just getting micropayments." I said things were going to change once this gets to scale, and it is going to take a while. It is going to be unpleasant; not a good time to be Cole Porter right now..."
"As it gets to scale . . . if the record labels don't share out what they're receiving from Spotify, artists will bypass the record labels and go straight to Spotify or Apple."


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Centre for Intelligent Machines (CIM)
The Centre for Intelligent Machines (CIM) is an inter-departmental inter-faculty research group which was formed in 1985 to facilitate and promote research on intelligent systems.
Intelligent systems and machines are capable of adapting their behaviour by sensing and interpreting their environment, making decisions and plans, and then carrying out those plans using physical actions. The mission of CIM is to excel in the field of intelligent systems, stressing basic research, technology development and education. The members of CIM seek to advance the state of knowledge in such domains as -- robotics, artificial intelligence, computer vision, medical imaging, haptics, systems and control, computer animation and machine and reinforcement learning.
This is being achieved by collaborative efforts involving researchers with very different interests - CIM faculty and students come from the School of Computer Science, Department of Electrical and Computer Engineering, and the Department of Mechanical Engineering. Many of CIM's researchers are members of REPARTI, Regroupement stratégique pour l'étude des Environnements PARTagés Intelligents répartis - The Center for the study of distributed intelligent shared environments. It is this diversity of interests along with the spirit of collaboration which forms the driving force behind this dynamic research community.
CIM News
CIM member Tal Arbel among 9 new CIFAR AI Chairs selected from McGill 2019-12-10
CIM members join newly-launched coalition for responsible AI 2018-12-19
Research at CIM: How heart tissue combines mechanical strength and electrical reliability 2018-05-10
More CIM news…
CIM Honours and Awards
Bruno Belzile Awarded Best Research Paper in Robotics and Mechatronics at IFToMM World Congress 2019-07-10
Prof. Joelle Pineau wins Governor General's Innovation Award 2019-05-16
CIM alumnus Yoshua Bengio co-recipient of A.M. Turing Award 2019-04-02
CIM members and associates named Canada CIFAR AI Chairs 2018-12-05
More CIM Honours and Awards…
Upcoming Events & Seminars
Seminar: Image guided neurosurgery at the MNI 2020-01-24
All events… All seminars…
CIM25 Symposium
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MUTINY vs CT FUSION - Game Preview
The New England Mutiny host the Connecticut Fusion in a battle of the only remaining undefeated teams in the East Conference of United Women's Soccer. The Fusion (3-0) will feature several familiar faces as former Mutiny players will return to batte against their former club along with top collegiate and international stars. Connecticut comes off an impressive performance defeating the Rochester Lancers 4-0 last Friday. The Fusion left no doubt in this one scoring three goals in the game's first 12 minutes. The Muitny (2-0), coming off a bye week, defeated the Long Island Rough Riders on May 18th in front of a capacity crowd at Lusitano Stadium. Kate Howarth (Grand Blanc, MI) tallied a hat-trick in the match after Vermont native Breukelen Woodard entered the record books by scoring the first-ever goal at Lusitano Stadium, New England's only soccer-specific stadium.
The Fusion roster is composed of several players that used to play for the home side, including Brenna Brown - a first-team All-UWS selection in 2017; Chanel Johnson - who also played with the NWSL's Boston Breakers; Stephanie Santos - a member of the Portuguese National Team, Kylee McIntosh and Tori Sousa - key contributors in the Mutiny's Final four appearance in 2013. Alongside several top collegiate players, the Fusion pose the stiffest test to date for the Mutiny- celebrating its 20th season in 2019.
"The good news is that we are familiar with many of the players on Connecticut and we know what they can do. The bad news is that we know what they can do", stated Mutiny Managing Director Joe Ferrara. "We are hoping that the crowd that showed up last match will once again provide the energy and atmosphere in what is surely to be a great match", added Ferrara.
Kickoff is set for 7:00pm on Saturday at Lusitano Stadium with the bar and concessions opening at 6:00pm. Tickets may be purchased at the gate or online HERE for expedited entry.
MUTINY'S HOWARTH SIGNS WITH ORLANDO PRIDE OF NWSL
LUDLOW, MA - UWS Player of the Year, Kate Howarth, has signed a professional contract with the Orlando Pride of the National Women's Soccer League (NWSL). With the recent departure of US National Team star Alex Morgan to Tottenham Hotspur and Taylor Kornieck on loan to German club MSV Duisburg, Howarth is among a forwards group that includes Brazilian legend Marta and former USWNT member Sydney Leroux. [read more]
MUTINY MOVE ON TO EAST FINALS WITH 3-0 VICTORY
The New England Mutiny moved one step closer to the United Women's Soccer National Championship finals with a convincing 3-0 victory over the Long Island Rough Riders on Friday night. In what has been the by far the most incredible goal-scoring streak in the history of United Women's Soccer, Mutiny forward Kate Howarth scored in her 11th consecutive game for the team. The Mutiny captain netted her 19th goal of the season and what proved to be the eventual game-winner in the 17th minute. [read more]
MUTINY DOUSE INFERNO 3-0; HOST PLAYOFFS AT LUSITANO ON FRIDAY
The New England Mutiny defeated the Lancaster Inferno 3-0 on Saturday and assured themselves a home game in the East Conference playoffs beginning on Friday night at Lusitano Stadium. Kate Howarth (Grand Blanc, MI/Boston Breakers) continued her record-setting season in United Women's Soccer with her second consecutive hat-trick. The Mutiny's all-time leading scorer added to her total in the 31' when she received a long ball from Ellie Jean (Coventry, CT/Penn State University) [read more]
HOPE AND A PRAYER! MUTINY DEFEAT INFERNO 2-1
In front of another large crowd, the New England Mutiny defeated the Lancaster Inferno 2-1 at Lusitano Stadium on Friday night. On an evening that featured two former NWSL/WPS professionals, two National Team members and several collegiate All-Stars, it was a local high school phenom that would be the difference in this match. Hope Santaniello (Agawam, MA) potted the game-winner in the 78th minute. [read more]
© New England Mutiny 2015


Level 7 Mechanic with experience on all makes and models. Has an eye for detail and loves repairing and fixing cars.
Level 5 Mechanic with experience on all makes and models. Has an eye for detail and loves repairing and fixing cars.
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International Tax Form Summary Review Guide – Golding & Golding
IRS International Tax Forms – Gifts, PFICs & Foreign Corporations
When it comes to International Tax and the Internal Revenue Service, the IRS is not your friend.
On the one hand, they fail to make it clear which forms you are required to file — but on the other hand they are still quick to penalize you on your failure to do so.
The reality is, there are many different types of forms an individual may have to file when they have offshore or foreign income, accounts, businesses, or investments.
These are some of the most common:
1 International Tax Forms
2 Be Careful What You Read
3 FBAR (FinCEN 114)
4 Form 8938
6 Form 3520-A
10 Form 926
11 Form 8865
12 Additional International Tax General Penalties
13 Getting Back Into Compliance with Offshore Disclosure
14 Golding & Golding, A PLC
International Tax Forms
The U.S. Government has made International Tax (and timely filing and reporting International Tax Forms such as FBARs, Form 3520, 5471, 8621, 8938, etc. an enforcement priority).
As such, it is very important that individuals who have offshore or foreign accounts get into compliance as quickly and safely as possible to avoid potentially high fines and penalties.
Be Careful What You Read
As you conduct your research online you will find one fear-mongering website or scaremongering website after the next.
That is not the point of this article, and not a strategy we use at Golding & Golding. The reality is, it is impossible to determine whether you personally will be selected for an IRS audit or examination.
Moreover, even if you are audited, it is impossible to know what level of penalty the IRS will issue against you.
For example, in some audits or examinations the IRS does not even issue penalties, but rather issues a Warning Letter in Lieu of Penalties. The problem is, there is no real way to know what level of penalty you will receive, because there are many factors that are out of your control.
Namely, what type of auditor/IRS Agent were you assigned that is handling your case, and what level of knowledge do they have regarding international tax. In addition, since the IRS agents have leeway to determine what penalty they want to issue, there is a lot of unknown to deal with — if you are audited.
As such, there are some proactive steps you can take to get into compliance once you are ready to make that leap. In the meantime, we want to provide you a summary of some of the more common types of forms you may need to file involving international tax and what the potential penalties made.
FBAR (FinCEN 114)
We start off with the FBAR, because it is one of the IRS International Reporting forms that receives the most amount of press. The FBAR is used to Report Foreign Bank and Financial Accounts on an annual basis.
The form has a relatively low threshold requirement of $10,000. In other words, if you have an annual aggregate total of foreign accounts (including life insurance or retirement funds) that on any day of the year exceeds $10,000, then you are required to report this form. It does not matter if the money is in one account or spread over numerous accounts. And, it does not matter if the account is in your home country of citizenship or if you opened the account before relocating to the United States.
The US government does not look into the semantics that deeply; rather, if you meet the threshold requirement then you have to file the form. Starting in 2017 (to report 2016 maximum balance), the due date coincides with your tax return filing date (including extension).
When it comes to the FBAR, one of the main concerns are the FBAR Penalties.
FBAR Penalties
A penalty for failing to file FBARs. United States citizens, residents and certain other persons must annually report their direct or indirect financial interest in, or signature authority (or other authority that is comparable to signature authority) over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign financial accounts exceeded $10,000 at any time during the year. The civil penalty for willfully failing to file an FBAR can be as high as the greater of $100,000 or 50 percent of the total balance of the foreign financial account per violation. See 31 U.S.C. § 5321(a)(5). Non-willful violations that the IRS determines were not due to reasonable cause are subject to a $10,000 penalty per violation.
Form 8938 is a byproduct of FATCA (Foreign Account Tax Compliance Act). It is a form that is required to be filed with the tax return each year when a person meets the threshold requirements for filing. Unlike the FBAR, which is an electronic form which is submitted directly to the Department of Treasury (The FBAR is not submitted with your tax return), Form 8938 is part of your tax return.
Form 8938 requires you to provide extensive information regarding foreign accounts and specified foreign assets. For example, with the FBAR, reporting is limited to accounts and insurance policies (although those terms can have a very broad meaning). Conversely, with form 8938, the person must report Income — along with assets and accounts.
Therefore, if you were to own stock of a foreign company, that would be considered a Specified Foreign Asset that would need to be reported on a Form 8938 — but would not be reported on an FBAR.
Moreover, with the FBAR, a person is required to report the maximum balance in the account, but is not required to report any income that is generated from the accounts. The 8938 is more depth than that. Rather, with form 8938, a person must report the account balance along with the annual income that is generated from form 8938 accounts or assets.
Additionally, the income must be broken down by type of income earned (such as royalties, dividends, interest, capital gains) and/or whether the income was earned through a custodial or deposit account and/or it was earned through one of the specified foreign assets.
Form 8938 Penalties
Beginning with the 2011 tax year, a penalty for failing to file Form 8938 reporting the taxpayer's interest in certain foreign financial assets, including financial accounts, certain foreign securities, and interests in foreign entities, as required by IRC § 6038D. The penalty for failing to file each one of these information returns is $10,000, with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency, up to a maximum of $50,000 per return.
A Form 3520 is a relatively benign form, save for the fact that the IRS can issue extensive fines and penalties for failing to report it. The form is used to report the receipt of a foreign gift either from a foreign person, foreign business, or foreign trust distribution.
The threshold requirements for having to report the gift vary. For example, if a person receives a foreign trust distribution, then the distribution must be reported despite any threshold requirement. In sharp contrast, a person would not need to report the receipt of a foreign gift from a foreign person unless the value of the gift exceeds more than $100,000 in either one transaction, or a series of transactions within the same tax year.
A Penalty for failing to file Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Taxpayers must also report various transactions involving foreign trusts, including creation of a foreign trust by a United States person, transfers of property from a United States person to a foreign trust and receipt of distributions from foreign trusts under IRC § 6048. This return also reports the receipt of gifts from foreign entities under IRC § 6039F. The penalty for failing to file each one of these information returns, or for filing an incomplete return, is the greater of $10,000 or 35 percent of the gross reportable amount, except for returns reporting gifts, where the penalty is five percent of the gift per month, up to a maximum penalty of 25 percent of the gift.
Form 3520-A
Form 3520-A is a bit different than form 3520. Form 3520-A is required to be filed by a US person if the US person owns a foreign trust. A foreign trust with a U.S. owner must file Form 3520-A in order for the U.S. owner to satisfy its annual information reporting requirements under section 6048(b).
Each U.S. person treated as an owner of any portion of a foreign trust under the grantor trust rules (sections 671 through 679) is responsible for ensuring that the foreign trust files Form 3520-A and furnishes the required annual statements to its U.S. owners and U.S. beneficiaries.
The problem with this form is that if the owner/trustee of the trust does not report the form, then technically the trust may be subject to fines and penalties, which can be very substantial, depending on the facts and circumstances of the reporting.
Form 3520-A Penalties
A Penalty for failing to file Form 3520-A, Information Return of Foreign Trust With a U.S. Owner. Taxpayers must also report ownership interests in foreign trusts, by United States persons with various interests in and powers over those trusts under IRC § 6048(b). The penalty for failing to file each one of these information returns or for filing an incomplete return, is the greater of $10,000 or 5 percent of the gross value of trust assets determined to be owned by the United States person.
Form 5471 is generally used when a person has ownership in a foreign corporation. There are various threshold requirements regarding ownership versus control and voting rights as to when a person has to file, but generally a person will file a form 5471, when they own at least 10% of the foreign corporation.
This can become a serious problem for individuals who own foreign corporations in countries in which the purpose of the foreign corporation is more of an estate planning tool than a business tool. This is very common in many countries that utilize the Sociedad Anonima.
For example, many of our clients in Costa Rica may have formed one or multiple Sociedad Anonimas for the purpose of holding rental property instead of putting the property under their own name, because it eases estate planning transfers. Unfortunately, from a US perspective this type of corporation cannot be disregarded and therefore (even if it is dormant), the 5471 may need to be filed in part or whole.
A penalty for failing to file Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations. Certain United States persons who are officers, directors or shareholders in certain foreign corporations (including International Business Corporations) are required to report information under IRC §§ 6035, 6038 and 6046. The penalty for failing to file each one of these information returns is $10,000, with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency, up to a maximum of $50,000 per return.
Form 5472 is a bit different from form 5471. A form 5471 is filed when a US person has an interest, ownership or control in a foreign corporation. A form 5472 is used (generally) when a US corporation has more than 25% ownership by individuals who are not considered US persons.
This is typical when a foreign corporation, or group of foreign investors, come together to create a US corporation wherein in at least 25% of the corporation is owned by non-US shareholders.
These types of businesses are usually created to function solely in the United States regarding US source income and limited liability or tax liability on a bigger scale.
A penalty for failing to file Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. Taxpayers may be required to report transactions between a 25 percent foreign-owned domestic corporation or a foreign corporation engaged in a trade or business in the United States and a related party as required by IRC §§ 6038A and 6038C. The penalty for failing to file each one of these information returns, or to keep certain records regarding reportable transactions, is $10,000, with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency.
IRS Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund) is an IRS Form required to be filed by individuals who have any interest in a Passive Foreign Investment Company — whether or not they received an Excess Distribution, as long as they are not otherwise exempt from filing.
Unlike IRS Form 5471, there is no minimum ownership requirement. Technically, even if you have "fractional ownership," of a PFIC you are still required to file — unless you meet one of the very limited exemptions/exclusions.
Moreover, the mere ownership of Foreign Mutual Funds and other foreign passive investments (that you do not technically own in a PFIC company) requires you to file the form.
The form can be daunting, especially when the filer also has a tax liability in accordance with form 8621.
Notwithstanding Excess Distribution calculations, the "main non-numerical" penalty associated with form 8621 is completely unfair (you can read here about the sheer horror of the "Excess Distribution calculation").
Why? Because technically, while there is no specific numerical penalty included regarding non-filing of Form 8621, a tax return is still considered to be "open" until the 8621 is filed. In other words, the statute of limitations countdown for the IRS to audit your tax return (usually 3 years) does not even begin to tick if the 8621 hasn't been filed.
*Even if you try to argue the return only remains open as to the 8621, but in reality, the IRS will most likely take you to task as to the whole return. Even if you could convince the agent that a post statute audit should be contained to 8621 issues, the IRS would just need to show some relation from the 8621 to other parts of your return to avoid that issue.
A Form 926 is required to be filed when a person transfers property to a foreign corporation. The purpose of this this is so the U.S. can track assets that are being moved offshore, and help determine (now or in the future) whether those assets have previously been reported for tax purposes in the United States or are not subject to taxation (due to the relocation being deemed a "sale")
For example, does the asset already have a BIG (Built-in-Gain) or other inherent tax liability that the company may be attempting to circumvent or sidestep by shifting the asset offshore.
Form 926 Penalties
A penalty for failing to file Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation. Taxpayers are required to report transfers of property to foreign corporations and other information under IRC § 6038B. The penalty for failing to file each one of these information returns is ten percent of the value of the property transferred, up to a maximum of $100,000 per return, with no limit if the failure to report the transfer was intentional.
A Form 8865 is similar to a Form 5471, except that the form 8865 is used to report foreign partnership interest, whereas form 5471 is used to report ownership of foreign Corporation. If you know anything about partnerships, you know that the reporting requirements such as basis and proportionate shares is a very complex undertaking. That is because unlike the Corporation which has its own entity, a partnership is not an entity to the same degree that, for example, a corporation is an entity.
As such, as with a partnership the individuals still directly owned the assets, even though they are being owned through the partnership (in other words, there is no entity that distinguishes between the owners and the partnership aside from the "partnership" which is a pass-through for tax purposes, but is reported separately.)
The reporting requirements for a partnership can the intense and therefore it is very important to understand these reporting requirements when submitting a form 8865.
A penalty for failing to file Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships. United States persons with certain interests in foreign partnerships use this form to report interests in and transactions of the foreign partnerships, transfers of property to the foreign partnerships, and acquisitions, dispositions and changes in foreign partnership interests under IRC §§ 6038, 6038B, and 6046A. Penalties include $10,000 for failure to file each return, with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency, up to a maximum of $50,000 per return, and ten percent of the value of any transferred property that is not reported, subject to a $100,000 limit.
Additional International Tax General Penalties
Fraud Penalties imposed under IRC §§ 6651(f) or 6663
Where an underpayment of tax, or a failure to file a tax return, is due to fraud, the taxpayer is liable for penalties that, although calculated differently, essentially amount to 75 percent of the unpaid tax.
A Penalty for Failing to File a Tax Return imposed under IRC § 6651(a)(1)
Generally, taxpayers are required to file income tax returns. If a taxpayer fails to do so, a penalty of 5 percent of the balance due, plus an additional 5 percent for each month or fraction thereof during which the failure continues may be imposed. The penalty shall not exceed 25 percent.
A Penalty for Failing to Pay the Amount of tax shown on the return under IRC § 6651(a)(2)
If a taxpayer fails to pay the amount of tax shown on the return, he or she may be liable for a penalty of .5 percent of the amount of tax shown on the return, plus an additional .5 percent for each additional month or fraction thereof that the amount remains unpaid, not exceeding 25 percent.
An Accuracy-Related Penalty on Underpayments Imposed under IRC § 6662
Depending upon which component of the accuracy-related penalty is applicable, a taxpayer may be liable for a 20 percent or 40 percent penalty.
Possible Criminal Charges related to Tax Matters include Tax Evasion (IRC § 7201)
Filing a false return (IRC § 7206(1)) and failure to file an income tax return (IRC § 7203). Willfully failing to file an FBAR and willfully filing a false FBAR are both violations that are subject to criminal penalties under 31 U.S.C. § 5322. Additional possible criminal charges include conspiracy to defraud the government with respect to claims (18 U.S.C. § 286) and conspiracy to commit offense or to defraud the United States (18 U.S.C. § 371).
A Person Convicted of Tax Evasion is subject to a prison term of up to five years and a fine of up to $250,000
Filing a false return subjects a person to a prison term of up to three years and a fine of up to $250,000. A person who fails to file a tax return is subject to a prison term of up to one year and a fine of up to $100,000. Failing to file an FBAR subjects a person to a prison term of up to ten years and criminal penalties of up to $500,000. A person convicted of conspiracy to defraud the government with respect to claims is subject to a prison term of up to not more than 10 years or a fine of up to $250,000. A person convicted of conspiracy to commit offense or to defraud the United States is subject to a prison term of not more than five years and a fine of up to $250,000.
Getting Back Into Compliance with Offshore Disclosure
If you have not filed the necessary international tax forms and are worried about the ramifications, fines and penalties by the US government, you may consider getting into compliance with IRS offshore voluntary disclosure.
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A Beginner's Guide to Attending the Opera in Pittsburgh
Everything you need to know about where to park, what to wear and some suggestions on what to see at the opera.
Published on Monday, Apr 15th, 2019
by Amanda Reed
Opera is an art form that's been around for almost 400 years. Because of that, people assume that it's just for old people who own 10 fur coats and a precocious Shih Tzu named Molly. However, that couldn't be further from the truth: Opera is filled with more drama than "Temptation Island" — with better storylines and music. Pittsburgh has a fabulous opera scene that strives to lower the barrier of entry to attend. Here's what you should know:
Who are the big players in the Pittsburgh opera scene?
Two opera companies perform heavily in Pittsburgh: Pittsburgh Opera, helmed by general director Christopher Hahn and music director Antony Walker, and Pittsburgh Festival Opera, led by artistic director Jonathan Eaton. You can also catch operas performed by students at Carnegie Mellon University and Duquesne University.
What do you wear to the opera?
Pretty much anything. If you want to make it feel like a special night, go hard and wear your opera gloves, theater binoculars and floor-length fur coat. If you're running from work, business casual is fine. According to Pittsburgh Opera general director Christopher Hahn, the eclectic audience outfit choices add to opera's charm.
"I have people who wear Steelers garb and I have people who wear minks and black tie, often at the same performances," Hahn says.
Auditoriums and concert halls tend to be chilly, so bring a sweater just in case.
How long does an opera last?
Depends on the opera. Some last for three hours, and some are shorter. Typically, an opera lasts as long as a movie or sporting event.
Who are the big composers to know?
Mozart, Verdi, Rossini, Donizetti, and Wagner are all names you'll encounter, but don't knock anything by newer composers.
Do they always sing in Italian?
Nope. Opera can be in any language, like English, French, Spanish, Russian and Czech.
If they sing in a foreign language, how do I understand what's going on?
Know how there are subtitles on the bottom of your screen when you're watching a Netflix movie? Opera has supertitles, where the English translation is projected above the stage on a drop-down screen. The program usually includes a synopsis of the show to keep you filled in on important plot points.
Where do I park?
Depends on the venue. Pittsburgh Opera performs at three locations, all with different parking situations. Pittsburgh Festival Opera primary performs at Winchester Thurston School. Make sure you double check online — with the venue or the company — beforehand.
Is there alcohol?
Yes! Most of the time, however, it depends on where the opera is performed. For example, Pittsburgh Opera offers alcohol at its performances at the Benedum, but not at Pittsburgh School for the Creative and Performing Arts (CAPA).
Tell me more about where opera is performed in Pittsburgh.
Pittsburgh Opera has three venues: The Benedum Center downtown, its headquarters in the Strip District and at CAPA. Larger operas are performed at the Benedum Center, and smaller operas and performances are saved for the latter two.
Pittsburgh Festival Opera performs at Winchester Thurston School, but also perform at First Unitarian Church of Pittsburgh across the street at 605 Morewood Ave. for recitals.
Photo from a performance of "Turnadot" in 2017. Photo credit: Pittsburgh Opera.
How long does the opera season in Pittsburgh last?
Again, depends on where you're seeing it. Pittsburgh Opera's season lasts from October to the end of April/beginning of May, and Pittsburgh Festival Opera's season happens during June and July, with additional events during the rest of the year.
Is it expensive to go to the opera?
Nope. Pittsburgh Opera and Pittsburgh Festival Opera have price-friendly options, like CheapSeats for students. Pittsburgh Opera tickets typically start out at $14. Pittsburgh Festival Opera tickets range from $5 to $65. Compared to how much Steelers or Pens tickets can cost, going to the opera is a steal.
Check out Pittsburgh Opera's Don Pasquale, which reimagines the classic opera in 1950s Hollywood, at the end of the month. Over the summer, make sure to see Pittsburgh Festival Opera's Mister Rogers' Operas— "Windstorm in Bubbleland" and "Spoon Mountain," which originally appeared on "Mister Rogers' Neighborhood"—on July 13, 14, 20 and 25. Directed by Tomé Cousin, who performed as "Tomé the Ragdoll" on "Mister Rogers' Neighborhood," these two original one-act operas were composed by Fred Rogers and filmed for WQED.
If you're coming from work and lugging your laptop in your oversized bag, you might want to leave both of the items at the office — you can't bring them into the Benedum. The Benedum has a list of guidelines about what to bring — and what not to — on its site.
According to Pittsburgh Festival Opera artistic director Jonathan Eaton, you don't need to do a lot of research beforehand to enjoy opera.
"Music can touch the heart, and it can touch anybody's heart. It doesn't have to be someone who's an expert or an aficionado or anything like that," Eaton says.
Looking for more performances to attend? Check out our guide to all the best plays and musicals in Pittsburgh.


From SH 49, 3.0 miles east of Mt. Pleasant, southeastward and southward approximately 8.3 miles via Roeder to SH 11. (Titus County) Extended southeastward approximately 2.6 miles to end of FM 3288 combined adding approximately 2.5 miles.


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New Book Salon
Dipesh Chakrabarty
The Calling of History
Friday, October 30, 2015, 12:00pm
Chicago Center for Contemporary Theory, Wilder House
University of Chicago Professor and 3CT fellow Dipesh Chakrabarty will discuss his latest book, The Calling of History, which explores the life of Sir Jadunath Sarkar (1870–1958). Sarkar was knighted in 1929 and became the first Indian historian to gain honorary membership in the American Historical Association. By the end of his lifetime, however, he had been marginalized by the Indian history establishment, as postcolonial historians embraced alternative approaches in the name of democracy and anti-colonialism. Professor Chakrabarty demonstrates that historians in colonial India formulated the basic concepts and practices of the field via vigorous—and at times bitter and hurtful—debates in the public sphere. He furthermore shows that because of its non-technical nature, the discipline as a whole remains susceptible to pressure from both the public and the academy even today. Methodological debates and the changing reputations of scholars like Sarkar, he argues, must therefore be understood within the specific contexts in which particular histories are written.
Professor Chakrabarty will be introduced by 3CT Co-Director Lisa Wedeen. Bill Sewell and Martha Nussbaum will offer a brief commentary on the text.
Speaker Bio-+
Dipesh Chakrabarty is the Lawrence A. Kimpton Distinguished Service Professor in History and Department of South Asian Languages and Civilizations at the University of Chicago. He is also a Faculty Fellow at the Chicago Center for Contemporary Theory (3CT), where he is PI for 3CT'sClimate Change Project. Prof. Chakrabarty's research is currently focused on three areas: he is in the process of completing a book on the history of "historical truth" in colonial India; he is working on two long-term projects: one on democracy and political thought in South Asia and the other on a cultural history of Muslim-Bengali nationalism; and he also working on a book-project concerning the implications of the science of climate change for historical and political thinking. More detailed information on Prof. Chakrabarty's research and publications can be found here.
Thursday, February 9, 2023, 6:00pm Nancy Fraser
Cannibal Capitalism
William H. Sewell Jr.
History & South Asian Languages and Civilizations
Events Publications Courses Series Projects News People
The Climate of History in a Planetary Age
Friday, April 23, 2021, 10:00–11:30am Co-sponsored
Provincializing Europe: A Book's Postcolonial Itineraries (2000-2020)
Tuesday, March 16, 2021, 11:00am Co-sponsored
Towards a History of the National Archives in India, 1919-1940


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Having high standards in dating
Having high standards in dating Having high standards in dating
Can An Older Man Change Into a Committed Partner?
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For years, the Bachelor Franchise has been criticized for featuring men and women who are increasingly younger and not ready for marriage, so this appears to be the producers finally doing something about it! Now Casting a new show! We would love to hear from them! In the comment section of the Instagram post, the casting producer stated that, while a potential contestant must be at least 65 to apply, there is no age limit.
When a person asked if their year-old granny could apply, the casting producer encouraged her to help granny apply.
The Bachelor Casting Senior Citizens in Yet Another Spin-off For people in their 50s, 60s and up, the series may not be as inclusive as it should or could be. single men and women age 65 and up for a new exciting dating show! for mature users to find love among a sea of year-old subscribers.
However, most of the contestants are in their 20s and 30s. For people in their 50s, 60s and up, the series may not be as inclusive as it should or could be. That's why the new Bachelor spin-off show could be a ratings hit. Producer Lindsay Liles posted the notice to her Instagram page Monday. It highlights very exciting opportunities for people in their golden years.
The notice reads: " Are you entering your golden years and looking for romance? Now Casting a new show! We would love to hear from them! As of , baby boomers outnumbered m illennials
John Turner is what some women, in an earlier era, would have called a "catch. He lives in Marin County. He owns a business. He's whip smart, has an engaging laugh and can be quick with a quip. And — get this, ladies — he likes to date women near his age. But now, in the enlightened '00s, Turner occasionally feels as if he's a social outcast because he's never been married.
Some of these women completely forego dating while others opt for 'living When a guy chats up year-old Montrealer Rhoda Nadell at her.
Attractive men and women in their 20s and early 30s with Hollywood smiles and chiselled physiques constantly bombard the silver screen, clamouring for the affection of one another in a desperate quest for love and instant fame. Although this proposed new series is still in the casting phase, the idea of seniors taking centre stage on prime time television is refreshing to say the least.
And seeing older faces portraying leading roles and living meaningful lives on television definitely had an impact on the public perception of ageing and older people. Today, beauty is a term that is seemingly reserved for the youth who showcase botox filled lips and rippling bodies to hordes of Instagram followers, but 30 years ago, things were quite different. In , a then year-old Sean Connery was voted the sexiest man alive, and it was common place to see older people on TV pursuing romance and openly discussing their sexual desires.
Nowadays, the internet has given people the ability to seek out their own video content, which means that masses are rarely exposed to things outside of their interest and age demographic. Older people have been very much out of sight and out of mind for many young people who were born in the last 25 years and there is no doubt that this would help to shape their opinion on the value of older people.
Learn more. Everyone ages — if we're lucky — so it's time to get the aging story right. Don't get us wrong — we applaud a dating show aimed at bringing together people 65 and older.
ABC's venerable The Bachelor reality franchise may be getting another extension. the Grumpy Old Men feature franchise and The Golden Girls TV series. and women IN THEIR GOLDEN YEARS for a new exciting dating show!" There are plenty of single women and men age 60 looking for new love.
But some men — the single and unattached — may be asking themselves: Am I in the right place to meet the woman of my dreams? For those looking for love, NerdWallet crunched the numbers of the 50 largest U. Track your credit score with our mobile app Key takeaways Baltimore is best. Advantage, New York. Go Mid- and South- West. Many cities on our list have nothing to do with either coast.
How many widowers are looking for a dead ringer for a dead ex? Will those all-nighter rose ceremonies be broken up with naps? Is the fantasy suite ADA-compliant?
Waehler found that a group of to year-old bachelors displayed defense mechanisms that pushed others away. Identifying what camp your date falls into will.
It is not a term that I — nor, I suspect, anyone else not coupled-up in their fifties — is that keen on. It makes us sound like we spend our evenings forlornly signalling to each other across a creaky old dance floor by waving our Zimmer frames, while our hearing aids whistle shrilly. Being over 50 is not old, these days. I know fiftysomething women who are running marathons, starting businesses … I even met one recently who had just won her class in an Iron Man contest basically a triathlon on steroids for age But there is a definite demographic shift going on when it comes to our relationships.
New figures from the Office For National Statistics show that while the divorce rate continues to fall overall, the trend is not mirrored by the over-fifties. We are now the only group whose divorce rate is actually rising.
A man's dating patterns and relationship history can reveal a lot about the type of person he is. A woman may be reluctant to date a long-term bachelor, assuming that he is a heartbreaker who strings women along and ditches them when someone better comes along. The reality is that there may be various reasons for a man's confirmed bachelor status, and it is possible to enjoy a rewarding relationship with him.
Lowri Turner writes about how being unattached in her silver years What happens when a married woman takes over a single woman's dating apps? who celebrated her 60th birthday this year, says of her single status.
After six months, I have discovered the hard way! Do I even want him back? This may be shocking to you — or it may be utterly predictable. To me, this illustrates the tremendous power of wishful thinking. The idea that a man who is emotionally unavailable after three months will suddenly become emotionally available after six.
Or that the man who never talks about a future with you will suddenly see the light. Or that the guy who disappears for a week is secretly in love with you. Of course.
When I was younger I got my heart broken by an older woman. No matter what I said, or what nice things I did for Karen, she was out of my league since I was younger. Karen was a 17 year old junior, and I was an incredibly good looking and intelligent 16 year old. This is exactly what my mom told me every time I brought her cupcakes. The rejection was devastating until a bright light named Stephanie joined my high school as a freshman.
I'm old by the standards of today's youth culture: I am over prowled the major internet dating sites for six years in search of new love.
The following article from a popular magazine of offered a sociological survey of the more than one-third of adult American women whose lives did not fit this domestic norm. But 21,, others are women without men: women who have never married 11,, ; widows 8,, and divorcees 1,, This means that a little more than one third of the 62,, women in the United States are getting along without steady male companionship.
How do they adjust to this fact of life? How do they like their manless lot? What do they do about changing it? Do they want to change it? Here are a few conclusions that emerge from these interviews: 1. Although it is a world-wide and historic conviction that every woman wants to be married, a great many do not want marriage. Consciously or unconsciously, many of them spend a lifetime resisting it. Today, one out of every ten families in the United States is headed by a woman.
Many of these women were forced into this role by the death of their husbands or by divorce, while others are the sole support of elderly parents.
Dating a bachelor over Dating one, yet, owns and sociology. From the world.
I'm afraid that in my 60s, after two divorces, such love may be behind me, as the pickings But during the past month, I've talked to a dozen women, ranging from their late 40s to their For 25 years, Ellen Burstyn did not go out on a date. She'd known the house was a bachelor pad, but now she had to learn to live in it.
The misconceptions of a bachelor over 50 are now revealed. Bachelors, men that decide to be single and never get married openly speak out to SitAlong , and reveal many misconceptions about bachelorhood over Some people think that at the age of 55, Daniel a bachelor over 50, would loose hope, or that he just enjoys playing the field. They were too afraid to go out and find someone they enjoy being with, or felt they were too busy with their own personal life.
In this series of posts, we will take a look into the lives of bachelor men over 50 who continue to live the life of bachelorhood, and find out why they continue being bachelors. We will see what bachelors over 50 regret, and what advice these men can share with all single men and women over Marriage , is in fact a beautiful sacred act, and just like some people save themselves to have their first sexual experience with someone special, bachelors over 50, save themselves for that special someone says James, Waiting and eager to find love, single men over 50 are hopeful, but at the same time realistic.
The idea that because we are older and single men, we are not attracted to women is an unfortunate misconception. As the years pass, and you get older, people just assume you are not attracted to women.
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Paris - Ile De France Section
Paris 18th District - 18eme Arrondissement
Paris 18th District
Paris 18th District is located on the Rive Droite and is commonly known as Quartier de la Butte Montmartre.
Quartier des Grandes Carrières, Quartier de Clignancourt, Quartier de la Goutte d'Or and Quartier de la Chapelle.
A traditionally populous district, Paris 18th District was born from the merging of the arty Montmartre and working class Clignancourt and La Chapelle villages.
Clenini Curtis - Clignancourt developed after the Roman conquest at the junction of the actual Rue Marcadet and Rue du Mt-Cenis and belonged to St-Denis Abbey.
The actual Clignancourt is divided in two areas.
Haut Clignancourt spreads on the Montmartre hillside.
Bas Clignancourt stretches at the junction of the Rue de Clignancourt, Rue Ramey and Rue des Poissonniers.
It is the most populated Parisian district, where middle-class, working-class and artists live side by side.
Beautiful private gardens can still be found in a hidden yard or between old buildings.
La Chapelle village was named after a chapel erected in a natural depression located along the Gallic path that linked antic Paris to the north of France.
The site Pas de la Chapelle or La Chapelle-St-Denis belonged to Abbey of St-Denis.
In 1429 Joan of Arc set up her camp in this area when she attempted to free Paris from the English and prayed in the chapel before going to St-Denis' grave.
Clignancourt and La Chapelle were integrated into Paris in 1860.
Late 18th century, cabarets, inns, music halls and entertainment halls appeared by the toll gates (octroi) of the fiscal Mur des Fermiers Généraux.
The fiscal wall was pulled down after the French Revolution and later replaced by the Boulevard de Clichy and Rochechouart.
These boulevards have been the Mecca of night life since the late 19th century.
This is where you'll find the Moulin Rouge.
La Chapelle and Clignancourt attracted also the workers employed for the construction of the nearby railway stations Gare du Nord, Gare de l'Est and Gare St-Lazare.
The Quartier de la Goutte d'Or is today mostly inhabited by African immigrants.
It was renown as early as the 15th century for its vineyards that produced an excellent white wine, hence its name.
The Rue de la Goutte d'Or linked the hamlet to the Rue des Poissonniers.
The Quartier des Grandes Carrières is located by the Cimetière de Montmartre, at the foot of the Butte Montmartre.
It was named after the ancient gypsum quarries that were exploited until the 18th century and produced the renown plâtre de Paris - plaster.
Montmartre thrived under the protection of its influential abbey from the 11th century to the French Revolution.
It became the cradle of the insurrection known as Paris Commune in 1871 and became the haunt of the artists from the Belle-Epoque to WWI.
Its rich history is reflected in its many ancient ad recent tourist sites.
These include of course the Sacré-Coeur Basilica and St-Pierre de Montmartre, one of the oldest churches in Paris, but also the superb Art Nouveau St-Jean-de-Montmartre.
The latter overlooks Place des Abbesses where you'll find the stunning Art Nouveau Metro entrance Abbesses.
Two major modern art works, Le Mur des Je t'aime and Le Passe-Muraille, are also a Must See when in the district!
Abandoned and forgotten for decades, the once populous Paris 18th District is under total redevelopment and has become a well sought after area.
Metro stations serving Paris 18th District
Line 2: Place de Clichy, Blanche, Pigalle, Anvers, Barbès-Rochechouart, La Chapelle, Stalingrad
Line 4: Porte de Clignancourt, Simplon, Marcadet-Poissonniers, Château Rouge, Barbès-Rochechouart
Line 12: Porte de la Chapelle, Max Dormoy, Marcadet-Poissonniers, Jules Joffrin, Lamarck-Caulaincourt, Abbesses, Pigalle
Line 13: Porte de St-Ouen, La Fourche, Guy Môquet, Place de Clichy
Paris – Ile De France - Latest content
August	8 2020
Auvers-sur-Oise, Van Gogh's last place of residence
The small town of Auvers-sur-Oise, north of Paris, was once a quiet village where Van Gogh spent the last 70 days of his life and painted 78 canvases
Chateau de Raray, the setting for Cocteau's Beauty and the Beast movie
The elegant Classical Chateau de Raray, north of Paris, served as setting for the filming of Cocteau's movie Beauty and the Beast
July	23 2020
Saint-Blaise-des-Simples Chapel, Jean Cocteau's burial-place
The poet Jean Cocteau is buried in Saint-Blaise-des-Simples Chapel in Milly-la-Forêt, a chapel he decorated during the restoration work of 1959
June	5 2020
Sorbonne Chapel and Cardinal de Richelieu tomb
Sorbonne chapel, the college's private chapel, is a masterpiece of French classical architecture that houses Cardinal Richelieu's mausoleum
Filed under: Paris – Ile De France


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Drop-Box Magazine - An extra-deep magazine typical of large calibre rifles for dangerous game. The line of the underside of the wrist does not carry straight forward as with ordinary rifles. Rather the rear of the magazine aligns more towards the center of the forward edge of the triggerguard, typically allowing at least one extra cartridge to be carried.
Ordinary magazine. The line from the underside of the wrist carries more-or-less straight towards the underside of the forend.


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We welcomed our tubal reversal baby, Lyndsay Labanzat, to our family on 04/03/2012!
Thank you so much, Dr. Rosenfeld and nurses. In January of last year, I was looking for a doctor to have this surgery and be able to conceive, because I had my tubes tied, not just tied, but also cut and burned. I had no hopes to extend my family, then I looked on the internet and I found Dr Rosenfeld.
I looked at other options and there were too expensive around $15,000, $18,000, and $20,000. Tubal reversal was the most economic and with the most chances. I recommend Dr. Rosenfeld a lot!! His nurses are very clear on instructions and explain everything so helpful and caring; and they speak Spanish. I'm very happy for my extended family.
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When it comes to strategic issues on the boardroom agenda, there can be few online retailers that have yet to add Brexit to their "to do" list – and that goes for those in mainland Europe as well as in the UK.
According to Eurostat data, a third of EU shoppers bought goods or services online from other EU countries in 2017, almost a quarter shopped online outside the EU, while around 80% of cross-border purchases involved physical goods requiring some form of home delivery or collection*. In recent months the IMRG MetaPack UK Delivery Index has also reported steadily rising numbers of parcels sent to EU shoppers by the UK retailers it surveys – at times EU sales have accounted for up to 70% of their total cross-border business, thanks in part to the weakness of sterling.
A survey last year by the International Post Corporation also looked at where EU shoppers go for their cross-border purchases, with typically around 15-18% of them ordering from the UK. The exception is Ireland where 63% of cross-border orders are to UK sites. Traffic in the opposite direction is rather less significant with more UK buyers ordering from China or the USA, pushing Germany into third place, accounting for 10% of UK cross-border purchases.
Currently all these EU-to-or-from-the-UK purchases are within the single market, but after Brexit if, as expected, the UK is outside the customs union, then imported goods from non-EU countries on sale in the UK will no longer be subject to the EU's common external tariff (CET), potentially making them up to 15% or more less expensive than elsewhere in Europe – always assuming, of course, that the UK lives up to its free-trade reputation and does not impose new tariffs itself. As for those EU shoppers still buying from UK websites, then they could be faced with demands for duty or VAT on their purchases when the postman finally delivers them – even if they find the UK's weak sterling and tariff-free prices tempting.
For companies such as Asos, which made around 29% of its sales to EU shoppers last year, the impact could be significant. Small wonder then, that the company has opened a second EU-based distribution centre with its Eurohub 2 in Berlin. Once any non-EU sourced products are delivered to the DC – having paid the necessary CET – they are within the single market and can be sent to EU shoppers with no additional charges due. As CEO Nick Beighton, said in his annual review last year: "The local stockholding …will grow to around 9m units in readiness for peak trading this year," while Phase 2 of the project will "double the square footage of the fulfilment centre". By Brexit proper, Asos will have plenty of capacity to meet its EU orders from within mainland Europe with no need to worry about customs delays and tariffs involved in shipping from the UK – although not all UK etailers will be in a similar position.
Most EU etailers sell rather less to the UK than Asos manages to the EU, but with the prospect of a significant price differential caused by CET, it's possible that they will find it harder to do so post-Brexit. For those with a significant UK customer base then the same issues apply: is it worth using a UK-based DC with direct imports of, for example, fashions from the far east to thus avoid CET and offer British shoppers a more competitive price?
However, for many IREUTop500 retailers the UK is clearly not a target market as they do not provide an English language website: Polish retailer Empik, for example, provides no other languages but Polish, although it does offer international delivery, presumably for ex-pat Poles elsewhere in the EU. RetailX researchers working on behalf of Internetretailing find that Top500 retailers typically sell to between two and three markets in between two and three languages, but the analysis disguises a wide disparity in the strategic ambitions of the Top500. At one extreme are the likes of Empik focusing largely on their home markets with a single language site, while at the other is AliExpress – part of China's Alibaba Group – which presents visitors with a choice of 95 languages, including Scots Gaelic, Yiddish, Shona and Hawaiian, which is probably a trifle excessive but may represent some extremely ambitious global expansion plans.
Rather more realistic is the Inditex Group with brands – including Zara, Pull&Bear, Bershka, Stradivarius, all in the Top100 – that sell in 96 markets, with national websites currently in 49 of them in multiple languages. Perhaps not surprisingly for a Spanish company, it ensures its home market is completely covered with its domestic website available in Catalan, Galician, and Basque as well as Spanish and English.
The group has a strategic aim to increase its international presence and as well as 7,475 stores in those 96 countries, last year added national websites in Thailand, Malaysia, Singapore and Vietnam with Japan and South Korea among newcomers this year. Ultimately there will be national websites for all its operating markets. As Pablo Isla, Inditex CEO, said, when presenting the company's 2017 results "Online sales are becoming an element that is contributing significantly to the company's growth" – contributing rather impressively with a 41% increase in online sales last year and now accounting for 10% of total group revenue. Creating local websites in appropriate languages is clearly a winning strategy for Inditex.
While traditional retailers are embracing digital technologies, some pureplays are looking to innovative ways to bring their brands into the real world. Pop-up shops are proliferating both in shopping malls and vacant outlets. Last year Amazon opened a pop-up in London's Soho to promote Black Friday. For four days shoppers could browse the display while ordering goods via their mobiles as well as take part in workshops and contests. Missguided – which moved into the real world in 2015 with concessions in Selfridges stores, and now has its own standalone outlets at Westfield Stratford and the Bluewater shopping centre – opened a pop-up at Boxpark in Shoreditch to launch its Mennace "brother label" last autumn. According to Mintel the outlet reputedly has a 12-month lease, so a rather extended pop-up.
Researchers also looked at the delivery options offered by the Top500 with next-day delivery offered by one in five and almost two-thirds allowing shoppers to collect orders from stores. Delivery preferences also vary by geography: according to the IPC survey, 54% of French online orders are delivered to a courier's parcel shop while parcel lockers are most popular in Finland and Denmark. Others are looking for more innovative options with pure plays striking deals with bricks and mortar companies to enable collection from high street stores – as with the 50 brands, including Asos and Missguided, that can be collected from Asda.
A growing problem across Europe, however, is a shortage of lorry drivers. While some in the UK blame Brexit, the dearth is not confined to Britain – as Renaud Bouet, human resources director of STEF Transport France, told Les Echos earlier this year: "The skills pool is seriously inadequate. The profession is looking for around 20,000 drivers across France." Last year Ocado blamed a slowdown in its expansion plans and sales growth (down from 13.1% to 11.6%) on the driver shortage. "More people are buying products as soon as they want online and there is more demand for delivery services and a tight labour market," said cfo Duncan Tatton-Brown. Ocado's solution has been to raise driver wages and revise recruitment methods while other companies are paying bonuses of £100 a shift to attract and keep drivers.
Rather than focusing on solving the driver shortage with drones, Amazon has come up with an innovative way of avoiding repeated delivery attempts when there is no-one at home to receive the parcel. Amazon Key, which is now live in around 40 cities in the US, allows delivery drivers to leave packages inside the house rather than on the doorstep. It involves fitting a smart door lock and Amazon Cloud Cam so that when a courier arrives, householders are informed via a mobile app and can authorise the door to open. Once the parcel is placed inside, the door can be remotely locked again while the Cloud Cam relays the activity for additional security.
A more practical solution for Europe's retailers, may be to promote a greater range of collection options persuading shoppers to collect from stores or communal facilities – such as parcel shops or lockers – rather than expect a diminishing number of drivers to deliver their goods, and with fewer drivers the "next day" option comes at an even greater premium. Adding a review of fulfilment choices to the strategic "to do" list should perhaps be another priority?


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Sus Comics
Awkward Avocado
Teamwork makes the dream work
13 Feb 2013 Posted by etcetera
Sophomore guard Demarcus Metcalf scores two of his 10 points in the last moments against Richland.
BY KEVIN CUSHINGBERRY JR., EDITOR IN CHIEF
It's rare when a team can distribute points equally throughout its starting lineup. Such a team has to be composed of selfless individuals who have one common goal: winning.
Thanks to their team-first mentality, the Harvesters have accomplished that feat this season.
Led by sophomore point guard Semar Farris' 15.5 points per game, each of the starters is averaging double figures in scoring.
The Harvesters' trust in one another has grown with each passing game. Some of the players, including starters Farris, Andrew Maxie and Mike Love, have never played together before this season.
"We had some good pieces, but they helped complete the team to help us win, and that's what we needed," said sophomore shooting guard Demarcus Metcalf.
Metcalf is shooting 43.8 percent from behind the arc and 51.2 percent overall in conference play. He said he gains confidence with each shot he makes.
"I've just been taking what the defense gives me," he said. "Every time a shot goes in, it's like the goal gets bigger."
Metcalf, who didn't see much playing time last season, said this year has been more enjoyable because team goals come first.
"Last year it was more individuals who wanted their stats," he said. "This year we're willing to share the ball to get the win. That's what it's all about."
Coach Anthony Fletcher agreed that team chemistry has been one of the Harvesters' keys to victory.
"This is the best passing team I've ever had," Fletcher said. "They're a very unselfish group, and they like each other. I think that's the biggest key to chemistry and passing the ball. They like being around each other, they trust each other and they're willing to sacrifice for each other because of that."
Maxie, the only freshman starter, is averaging 15.6 points per game in conference games, second only to Farris' 23. He testified to the importance of each MAC game.
"There's a bump in intensity in conference," Maxie said. "As long as we stay focused as a team, it's going to come easy on the court. We'll keep doing what we've done all season."
Eastfield is undefeated and has a win over every team in the MAC, and Farris has been a big key to that success. Hes been contributing more on offense as the season progresses and has continued to lead the team on the defensive end. He leads the team in scoring, assists and steals.
Coming into the season, Farris needed just 23 steals to become the school's all-time leader in steals. He has achieved that goal, but still isn't satisfied.
"I'm going to keep trying to separate myself from the pack," he said, "make it harder for the next player that comes through"
Eastfield will need Farris to be at his best in their final two conference games against Cedar Valley on Feb. 13 and Richland on Feb. 16. Although they have a win over each team, both games were decided by just six points.
"We need to continue to share the ball more," Farris said. "If we continue getting good shots and forcing our opponents to take bad shots, then we can get W's."
In their most exciting game all season, Eastfield defeated arch rival Richland 86-80 on Jan. 26 following a war of words between players on Twitter. The game was tied with less than five minutes to go, but the Harvesters were lifted by key free throws from Maxie, Metcalf and team captain Brock Hunter.
For the Harvesters, there's less than a week left to prepare for the challenges of the postseason. Fletcher said the team must show the ability to fight through that adversity in order to accomplish the biggest goals.
"The biggest thing is keeping their eye on the goal," he said. "They have to be hungry. They can't get satisfied or think they're better than they are. You want to have a little swagger, but you respect your opponents and understand that they're aiming for you. They're trying to come and get you, and you have to be ready. If you're giving 110 percent, even if you make a mistake, good things can happen."
©2013-2019 - The Et Cetera


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State to pay NIS 120m to victims of Jerusalem hall collapse
Cash comes 15 years after 23 people killed and more than 350 injured at Versailles wedding venue
By Sue Surkes	30 September 2016, 10:28 pm 0 Edit
Sue Surkes is The Times of Israel's environment reporter.
The bride and groom after the collapse of a floor at the Versailles wedding hall, Jerusalem, on May 25, 2001. (Flash90)
A decade and a half after the collapse of a dance floor at the Versailles wedding hall in Jerusalem, which killed 23 people and injured more than 350, the state has announced that it will compensate the victims NIS 120 million ($32 million).
The cash will be distributed among 428 plaintiffs, the daily Yedioth Ahronoth reported this week.
The state says the payment is not an admission of guilt and that it plans to be repaid by the Jerusalem Municipality, the Israel Institute of Technology (Technion) and the Standards Institution.
These bodies, along with the state and the Jerusalem district and local planning committees, were among institutions sued for damages in a class action suit brought by those injured in the disaster.
"We welcome the decision to pay damages and we are sorry that the victims had to wait so many years for the state, Jerusalem Municipality, Technion and Standards Institution to agree to take responsibility for the physical and emotional damage caused by the disaster," attorneys Asaf Posner and Eti Libman-Offaim, who represent the biggest group of victims, told the paper in a statement.
This proposal had already been on the table in 2002, they said, and could have prevented years of suffering and allowed victims to move on. "We hope that if, God forbid, there are other disasters, lessons will have been learned and compensation will be delivered in an appropriate time," the lawyers said.
According to the deal, those not physically injured in the disaster will get NIS 50,000 ($13,300) plus interest, while those who were hurt will receive NIS 6,000 ($1,600) for every percentage of disability they incurred over 20%.
The sum of NIS 75,000 ($20,000) will be paid into the estates of those who were killed, along with an additional NIS 10,000 ($2,660) for each year of expected decrease in life expectancy brought on by the disaster. When the victims die, NIS 10,000 ($2,660) plus interest will be provided for funeral expenses.
Hundreds of people dancing at the May 2001 wedding of Keren and Asaf Dror plunged three floors when the third floor and parts of the three-story building collapsed.
The 23 dead included the groom's 80-year-old grandfather and his three-year-old second cousin. The bride suffered serious pelvic injuries that needed surgery.
The subsequent state commission of inquiry headed by the late Jerusalem District Court president Judge Vardi Zeiler found that the Pal-Kal light-weight concrete floor system used at the wedding hall had not been officially approved and did not meet safety standards.
Chaos after the collapse of a floor at the Versailles wedding hall, Jerusalem, May 25, 2001. (Flash90)
In October 2004, the three owners of Versailles were convicted of causing death by negligence and causing damage by negligence. Two of them were sent to prison for 30 months, while a third was sentenced to four months of community service.
In May 2007, Eli Ron — who developed the Pal-Kal system — received a four-year sentence. Three other engineers involved in the building's construction were jailed for between six to 22 months.
At a special session five years ago of the Knesset's House Control Committee to mark 10 years since the Versailles disaster, then State Comptroller's Office Director-General Shmuel Golan said "Ten years after the disaster and we're still in a situation where the quality of construction is left largely unchecked," Ynet reported.
The scene where 23 people were killed and hundreds injured after a dance floor collapsed at a wedding party at the Versailles wedding hall in Jerusalem, May 25, 2001. (Flash90)
He said that the Zeiler Committee recommendations — which ordered the immediate inspection, sealing off and possible demolition of dozens of building built using the Pal-Kal system — was never fully implemented and that therefore, "we have no way of knowing whether all the buildings built using Pal-Kal were inspected."
"The entire thing is riddled with indecisiveness and arguments over everything, instead of dealing with the fact that there is a high-risk factor involved here."
While other buildings have collapsed since then, bringing death in their wake, Versailles is still the worst civil disaster in Israel's history.
Earlier this month, six people were killed when a four-story parking garage being built in the northern Tel Aviv neighborhood of Ramat Hahayal collapsed on itself.
construction in Israel
Jerusalem municipality
The Standards Institution of Israel SII
Technion -- Israel Institute of Technology
Damaged but not drowned, Venice Jewish ghetto counts blessings after flood
By Giovanni Vigna
November's record deluge caused an estimated billion dollars in damage citywide, but the historic enclave central to a close-knit community got off relatively easy
Pentagon acknowledges 11 US troops were hurt in Iran missile strike
By TOI staff and AFP
Military says soldiers airlifted to Germany and Kuwait to be treated for concussion from blasts, despite US earlier saying no troops were injured in Jan 8 attack
Giuliani associate says president was fully aware of efforts to pressure Ukraine to investigate Joe Biden, 'knew exactly what was going on'
US synagogues should not arm ordinary congregants, Jewish security agency says
Reporter's notebookDamaged but not drowned, Venice Jewish ghetto counts blessings after flood
Alexander I. Poltorak
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Yael Shahar
Shemot - The mystery of a displac...
Moshe-Mordechai van Zuiden
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Panasonic BB-HCM381 IP Camera Review
Dave Mitchell, October 30, 2011 3:56 pm GMT
Page 1 Panasonic BB-HCM381 IP Camera Review
Page 2 Panasonic BB-HCM381 Review
Page 3 Screen Shots Review
Panasonic's range of IP cameras just keeps on growing and the latest to join this burgeoning family delivers a range of useful surveillance features including remote pan, tilt and zoom capabilities. The BB-HCM381 also compares very well on price with the competition, with (linkouthttps://www.trustedreviews.com/article.aspx?art=2297 Sony's SNC-RZ25P) , for example, delivering a similar feature set but costing around £100 more.
It's not as pretty as Sony's PTZ camera but is just as well built and at around half the height is a lot more discrete. A recess at the rear provides a standard Fast Ethernet port for network connection and a small I/O connector block alongside allows you to add up to two of your own external sensors. A single socket is also provided for two-way audio operations and the kit includes a splitter cable for connecting an external microphone and speaker to the camera. Pan and tilt functions are good as the lens has a horizontal range of 350 degrees while vertical movement covers 120 degrees which is reduced to 90 degrees when the camera is ceiling mounted. Zoom functions are also up with the best as the camera provides 21x optical and a further 2x digital. There's also a slot in the base that accepts SD Memory Cards for direct video recording.
Installation is helped along nicely by the bundled Easy Setup software which searches the network and displays the camera ready for initial configuration. Sensibly, the first thing it does is insist that you provide a new username and password to protect access. The home page of the browser interface is very easy to use and we liked the fact that you don't need to leave the main viewing screen to modify the more basic settings. The controls are laid out neatly down the left side and you can easily switch between quality, motion or standard picture settings and select resolutions of 640 x 480 pixels or 320 x 240. A casualty of the lower price is the lack of support for MPEG-4 compression. With only Motion JPEG in the frame the maximum 30fps is only achievable at the lower resolutions and selecting 640 x 480 will drop this to 12fps which does result in much jerkier feedback.
A keypad to the left of the image is provided for moving the lens and returning it to its home position while a couple of buttons above are used to initiate vertical or horizontal sweeps. However, you can dispense with these simply by pointing and clicking within the viewing area as this will move the lens to wherever the mouse is pointing. Zoom can also be controlled with the mouse wheel or by holding down the right button at the top or bottom of the picture. For picture quality Panasonic beats Sony easily as the image is much sharper and has a far more natural colour balance.
Panasonic BB-HCM381 Review


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Bria of River Oaks
Bria of River Oaks, 14500 South Manistee, Burnham, Illinois 60633
Bria of River Oaks has 309 certified beds that participates in both Medicare and Medicaid. The ownership of this facility is a for profit corporation. Its overall rating is below average. Bria of River Oaks is not in a Continuing Care Retirement Community. Bria of River Oaks has a resident council only.
The Illinois Department of Health and Human Services regularly inspects Illinois nursing homes on average every 18 months. The last issued report for Bria of River Oaks by the Department of Health and Human Services was on June 23, 2016. In addition, a complaint inspection was filed on March 25, 2016. This complaint inspection covered the period between December 1, 2015 and November 30, 2016. The health inspection revealed nine health deficiencies. The average number of health deficiencies in Illinois is 7.9. The average number of health deficiencies in the U.S. is 7.2. In this instance, deficiencies were found in quality care, resident assessment, resident rights nutrition and dietary and in environmental. The health inspection rating for this facility is below average.
The staffing rating for Bria of River Oaks is much below average. The registered nurse staffing rating is below average. The total number of licensed nurse staff hours per resident per day at Bria of River Oaks is 59 minutes compared to 1 hour and 33 minutes, which is the Illinois average and 1 hour and 41 minutes, which is the U.S. average. The registered nurse hours per resident per day at Bria of River Oaks is 26 minutes compared to 56 minutes, which is the Illinois average and the national average of 50 minutes. The CNA hours per resident per day at Bria of River Oaks is shown to be 1 hour and 27 minutes compared to 2 hours and 15 minutes for the Illinois average and 2 hours and 28 minutes being the national average. Physical therapy staff hours per resident per day at Bria of River Oaks is just 6 minutes. Both the Illinois and national averages in this category are 6 minutes.
The rating for quality measures at Bria of River Oaks is much above average. 19.5% of Bria of River Oaks short-stay residents were re-hospitalized after a nursing home admission. This percentage was lower than the Illinois average of 24.3% and the national average of 22.6%. 11.6% of the facility's short-stay residents had an outpatient emergency department visit. Again, this compared favorably to the Illinois and national averages which were 13.3% and 12.1%, respectively. 3.4% of Bria of River Oaks' short-stay residents developed pressure ulcers that were new or worsened. This percentage was substantially higher than both the Illinois and national averages which were 1.4% and 1.2%, respectively. The percentage of short-stay residents assessed and given the appropriate pneumococcal vaccine at Bria of River Oaks was 91.5% which was substantially higher than the Illinois average of 76.7% and the national average of 81.5%.
1.4% of Bria of River Oaks' long-stay residents experienced one or more falls with major injury. This percentage was lower than the Illinois average of 3.4% and lower than the national average of 3.3%. 12.1% of Bria of River Oaks' long-stay residents showed a worsened ability to move independently compared to the Illinois average of 17.5% and the national average being 18.2% in this category. 90.6% of Bria of River Oaks' long-stay residents displayed depressive symptoms whereas the Illinois average is just 18.2% and the national average being 5.4%. 95.3% of the facility's long-stay residents were assessed and given the appropriate pneumococcal vaccine compared to 91.8% for Illinois and 93.4% for the U.S. averages.
Bria of River Oaks has not received any federal fines in the last 3 years. It is possible that Illinois may have imposed a penalty under state law, but none are listed. To search for the Illinois state penalties, there is a separate website that would allow for an independent viewing of any such fines.
Much Below Average
RN Staffing Much Below Average
Description Bria Of River Oaks Illinois
Total number of health deficiencies:6
Bria of River Oaks | Burnham Nursing Home Neglect Lawyer Kreisman Law Offices


Our fleet of 13 turbine-powered aircraft provides support for executive charter, tours and excursions, and versatile utility operations, including forest firefighting, search and rescue, construction and external loads, and more.
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Our fleet of over 30 support vehicles, trailers, and equipment necessary to facilitate a variety of missions.


Born in Stockton-on-Tees, Will Hay worked as a book-keeper before beginning in the music halls in a schoolmaster sketch in 1909, later joining Fred Karno's troupe and becoming a star attraction from the mid-20s.
In private life he was an expert amateur astronomer who built his own observatory and wrote a book on the subject, a pilot and a linguist.
Will Hay died in Chelsea, London on 18th April, 1949 , aged 60.
Will Hay was born in Stockton-on-Tees on 6th December, 1888 .
An incompetent headmaster thwarts a jewel robber.


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Automakers Complain About Making Their Hybrids Sound Like Real Cars
Mar. 19, 2013, 12:29 PM
The famously quiet electric Tesla Model S will soon have to make more noise.
Automakers are not happy with rules set down by the National Highway Traffic Safety Administration that will soon require hybrid and electric vehicles to play car-like sounds.
The sounds are required under the Pedestrian Safety Enhancement Act of 2010, to alert the blind, visually impaired, other pedestrians, and cyclists to the approach of cars that are otherwise nearly silent.
U.S. car companies say the rules are overly complicated, and require sounds that are louder than necessary, which would annoy passengers and add cost to the cars.
The NHTSA estimated in January the changes would cost $30 per vehicle. It said they could could prevent 2,800 cyclist and pedestrian injuries over the life of each model year of the vehicles, and save 35 lives (a low number, as relatively few deaths are caused by low speed collisions).
In remarks sent to NHTSA Administrator David Strickland last week, trade groups Global Automakers and the Alliance of Automobile Manufacturers said the proposed rules are "too complicated" and "unnecessarily prescriptive."
Between them, the groups represent just about every automaker operating in the US. According to their remarks, the proposed sound levels are so "excessive and unrealistic," even a high-performance sports car would not meet them (though a non-hybrid one would not have to).
Manufacturers are supposed to begin phasing in the changes by September 1, 2014, which the trade groups say "is not possible."
If the final rule is substantially similar to the NPRM [notice of proposed rulemaking], we recommend foregoing the phase-in and going directly to full implementation on 9/1/2018. However, if the final rule approximates the Alliance-Global recommendations, then a phase-in period is feasible beginning with vehicles built on or after 9/1/2015.
They will have some flexibility in what sort of sounds their cars will make, but most will likely go with a whirring noise that fits within the NHTSA rules.
SEE ALSO: How America's Coolest Automaker Crashed So Hard, So Fast
More: Hybrid Vehicles Electric Cars Auto Industry