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Home » Box Office
Tanhaji: The Unsung Warrior Box Office Day 4 Morning Occupancy: Holds Its 'Fort' Well!
Today, being a partial holiday owing to the Lohri festivities in certain regions of the country, can turn out to be another beneficial day.
Tanhaji: The Unsung Warrior Box Office: Ajay Devgn, Saif Ali Khan and Kajol's period drama is shining bright at the ticket windows. The movie has witnessed a massive upward trend on each day since its release, but the real test begins today, which initiates the working days.
Tanhaji has added collections of whopping 61.75 crores in its first weekend, surpassing all trade expectations. Today, being a partial holiday owing to the Lohri festivities in certain regions of the country, can turn out to be another beneficial day. As per the trends flowing in, the Om Raut directorial has registered morning occupancy in the range of 20-25% across the country.
This remains equal to its Day 1 occupancy, which signifies the stronghold that Tanhaji has maintained. So far so good, and one expects the trend to follow considering the massive buzz and positive word of mouth flowing around. The negativity around Deepika Padukone's Chhapaak has also helped the period drama rise at some level.
Actor Ajay Devgn, whose "Tanhaji: The Unsung Warrior" hit the screens on Friday, also took to Twitter on the same day to comment on the violence at the Jawaharlal Nehru University (JNU) in Delhi that happened earlier this month.
Bunker: India's First Anti-War Film Focusing On Indian Soldiers' Mental Health Gets A Release Date
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"I have always maintained that we should wait for proper facts to emerge. I appeal to everyone – let us further the spirit of peace and brotherhood, not derail it either consciously or carelessly #JNUViolence," Ajay tweeted.
Ajay's tweet received mixed responses from netizens.
On January 5, several masked individuals entered JNU campus and thrashed students and teachers with wooden and metal rods.
At least 20 students were admitted to All India Institute of Medical Sciences (AIIMS) with severe injuries, including the Students Union President Aishe Ghosh, who was reportedly hit over the eye with an iron rod.
Morning Occupancy
Tanhaji: The Unsung Warrior
Tanhaji: The Unsung Warrior Box Office
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CAR Rebels Call Off Ceasefire, Launch Offensive Against Govt
The Coalition of Patriots for Change (CPC), which began an offensive against the government a week ago, said in a statement it had "decided to break the 72-hour truce it had imposed on itself and resume its unrelenting march towards its final objective".
By AFP	 On Dec 25, 2020
At the weekend, the government accused Touadera's ousted predecessor, Francois Bozize, of fomenting a coup with the rebels, a charge he denies.
A rebel coalition that has been fighting the government in Central African Republic said Friday it was calling off a three-day ceasefire ahead of a tense general election on the weekend.
In the statement, which was confirmed to AFP as authentic by two of the six groups in the coalition, the CPC said that it made the decision "faced with "the irresponsible stubbornness of the government".
The ceasefire's signatories had "invited the authorities to observe the ceasefire over the same period" and called on President Faustin Archange Touadera to suspend Sunday's presidential and legislative election.
But government spokesman Ange-Maxime Kazagui dismissed the ceasefire on Thursday, saying it was "a non-event" and that "we haven't seen these people stop what they're doing".
The rebel coalition said Friday the government had "cavalierly rejected" this "chance for peace".
"Several attacks followed on positions occupied by the patriots of the CPC," its statement said.
The authenticity of the statement was confirmed by two armed groups — the 3R and the Popular Front for the Rebirth of Central Africa (FPRC).
General Bobo, the leader of 3R, told AFP that "now either the government disperses us, or we march on Bangui, which is our final objective".
Fighting had resumed in Bakouma, about 250 kilometres (155 miles) east of the capital Bangui, according to Vladimir Monteiro, spokesman for the UN's MINUSCA peacekeeping force.
The CPC was created on December 19 by armed groups who accuse Touadera, the frontrunner in the Sunday's election, of trying to fix the vote.
Its components are drawn from militia groups that, together, control two-thirds of the country.
At the weekend, the government accused Touadera's ousted predecessor, Francois Bozize, of fomenting a coup with the rebels, a charge he denies.
Gunmen had sought to advance down the main highways towards Bangui, but were stopped, according to MINUSCA.

redpajama_set_name: RedPajamaCommonCrawl


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This action makes ga-965p-dq6 system reset to the default settings for stability. After installation of ga-965p-dq6 audio driver, ga-965p-dq6 should find an Audio Manager icon in your system tray you can also find the icon in Control Panel.
Extract the file and save the new BIOS file ga-965p-dq6. Disable DefaultEnable Status 1: Well, here is a quick run down and comparison: RightMark Audio Analyer Page They have consistently had good performing boards that ga-965p-dq6 feature rich and very ga-965p-dq6 friendly. Contact Us Please see the last page for details.
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Millennials snapped up $28 million worth of art inspired by the Simpsons television show, along with skateboarding shoes and cans of spray paint at a Sotheby's auction in Hong Kong as a new generation of collectors comes of age.
"The auction room suddenly got a lot hipper, with all these cool millennial buyers in hoodies,"
KAWS CLEAN SLATE 2018 UNBOXING + REVIEW!
Hey guys, Follow us through our journey as upcoming entertainers, dj\'s, visual merchandiser, fashion designers and also YouTubers! We will be releasing new videos EVERY DAY! Don\'t forget to comment below, we will try our best to reply to ever single one - hit the thumbs up button and subscribe!
Exclusive Footage of KAWS tearing it up on the streets of NYC and Tokyo in 1997. This is his first bus-stop in NYC, a bunch of pieces in Tokyo, along with some great commentary by fellow artist Ron English.


Your wedding day is one of the most important and deeply personal days of your life. If you are looking to make your ceremony a unique expression of your relationship, think about including some elements that speak to your relationship.
Below is a listing of some of the popular as well as less traditional rituals that couples include in their wedding ceremony to make it move from ordinary to extraordinary. Take the idea- use it as is or change and modify it to fit you on a more personal level. For each description, keep in mind that music can be played in the background and ceremony wording can be spoken by the officiant. There are many beautiful examples of wording that can be found or it can be written for you to have a more personalized meaning.
unity candle. These are set on a table off to the side of the ceremony.
taper candle before the ceremony starts. Later in the ceremony, often after the vows and exchanging of rings, the bride and groom use the two taper candles to light the larger pillar candle together, symbolizing the uniting of two lives and their individual families into one.
Another very popular wedding tradition signifying unity, which uses sand instead of candles. Three containers are placed on a table, two smaller ones, each filled with a different color sand, and a center larger container. When the ceremony is performed, the couple blends their individual containers of sand together into a larger vessel that blends the grains.
This ceremony lends itself easily to those who are blending families with children. The children can be part of the ceremony, each with their own container of sand, as the symbolism of the new blended family is created.
Again, a variation of the Unity Candle Ceremony, this uses wine. Often a red and a white wine are used, then blended together, followed by the couple sipping the blended wine.
in order to forgive each other.
Roses can also be presented to those special people who have played a significant role in the lives of the couple. What better way to say thank you, than during your ceremony! The presentation of roses shows both gratitude and respect for the major contributions these people have made. They can be given to your parents, or any person you would like to honor such as stepparents or grandparents.
Instead of using sand, salt becomes the combining element in this ceremony. This is the act of combining individual grains of salt into one vessel. The roots of the salt covenant go back to ancient times, with the meaning that the agreement made between the parties could not be broken unless an individual could retrieve their own grains of salt. Salt figures so prominently in this tradition because mankind has long considered salt to be a pure substance and representative of good luck.
This is one of my favorites to incorporate into a wedding ceremony. Stones are placed on everyone's seat. At the beginning of the ceremony an explanation is given. The stones are held by the guests, who think of well wishes and blessings for the couple as they hold the stone throughout the ceremony. They are collected on the way out, being placed in a special container. This becomes the first wedding gift they receive. It can later be displayed in their home. Every time they look at the container is a reminder of their wedding day and all those who were there to celebrate with them.
Handfasting involves binding the hands of the couple with ribbon or cord in a public to symbolize marriage vows. The tradition is believed to be ancient, deriving from Celtic tribes that were widespread in Europe before Christianity. This is where the term tying the knot evolved from.
The symbolic act typically involves fastening a couple's hands together with cording, ribbon, twine or a silk sash while prayers are recited and vows are exchanged. Although there are many ways to do this, couples can use a single string or braid three strings together to represent the intertwining of the two individual lives into one. Often four to six feet in length, the threads consist of any color or material and may contain specific gemstones or charms to bless the marriage.
Jumping the Broom has its roots in Aftrican culture. It is a ceremony in which the bride and groom, either at the ceremony or at the reception, signify their entrance into a new life and their creation of a new family by symbolically "sweeping away" their former single lives, former problems and concerns, and jumping over the broom to enter upon a new adventure as wife and husband.
Breaking the Bread comes from Eastern European tradition. Typically after a couple was married, upon arriving at their new home they were greeted by their parents with bread, salt, and sometimes wine. The bread represented the parents' hope that their children would never experience hunger; the salt reminded the couple that their life might be difficult at times and they must learn to cope with life's struggles. The wine symbolized the parents' hope that the couple would never know thirst and enjoy a life of good health and cheer in the company of good friends.
A homemade loaf of flat bread is presented to the couple often by their parents. The bride and groom each take a small piece which can be dipped into a little salt or honey before taking a bite. The bread is then passed along to family members who do the same, symbolizing the coming together of the two families.
The butterfly release symbolizes the celebrating of a transition, representing the idea of letting go and the start of a new beginning, recognizing a new chapter of life has opened. This creates a beautiful and spectacular ending to an enchanting wedding ceremony.
This is a ceremony that involves a bit of preparation ahead of time by the couple. A special box is selected, and a bottle of wine with two glasses is placed inside. The bride and groom then write a heartfelt letter to each other which is sealed.
Toward the end of the wedding the Officiant will state the purpose of the Love Letter & Wine Box Ceremony, explaining the reasons for the sealed letters. The box will then be nailed shut (or locked). The Officiant begins with the first nail, followed by the Bride and Groom sealing the box shut. If you like you can have each member of your wedding party step up and place a nail in the box as well. A predetermined anniversary is decided upon, at which time the box will be opened, unless there is a time that your marriage is going through a very challenging period, you may wish to open it then, and share your letters to each other as a reminder of all the reasons you chose to share your life together.
There are many more traditions and rituals that can be placed into your ceremony to make it unique and personal, but this is a start to give you some ideas to go with.
If you are looking for an officiant for your special day, and are in the area I serve, I would be delighted to help you plan the ceremony!


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Home >Companies >Vivo says layoffs at Greater Noida plant in line with business decision
Some workers at Vivo's Greater Noida plant protested and reportedly created ruckus when no clear reason was offered to them for the sudden layoffs. Photo: Bloomberg
Vivo says layoffs at Greater Noida plant in line with business decision
1 min read . Updated: 26 Jul 2017, 09:06 PM IST PTI
Vivo says layoffs of the contractual employees is in line with their business strategy to improve productivity at the Greater Noida plant
New Delhi: Chinese handset maker Vivo on Wednesday said the layoffs at its manufacturing unit in Greater Noida are in line with its business decision.
The statement comes amid reports that Vivo has laid off about 60 workers at its Greater Noida plant recently. Some workers protested and reportedly created ruckus when no clear reason was offered on the sudden layoff. "With continuous growth and strategic review, we look at staffing the right size in various divisions to improve productivity. The layoff of the contractual employees is in line with this business decision," Vivo said in an e-mailed statement.
It added that the company "strictly adhered" to the rules and regulations of the contract, and is taking "all the right measures" to ensure a peaceful transition keeping the best interests of the employees in consideration.
Vivo has been aggressively looking at expanding its presence in India, which is the world's second largest telecom market. The company has pumped in crores of rupees into various branding and promotional activities as it looks to strengthen its brand visibility in the hyper-competitive Indian smartphone market.
Vivo recently extended the title sponsorship deal with the Indian Premier League (IPL) cricket tournament by five years. Apart from the IPL, Vivo is also the title sponsor of the Pro-Kabaddi League.


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SADTU TO CONTINUE TO FIGHT FOR QUALITY PUBLIC EDUCATION, AGAINST CORRUPTION AND BETTER WORKING CONDITIONS IN 2013
We face the end of yet another dramatic and eventful year. 2012 has been marked by successes and challenges within the union and in the country as a whole. Some of the successes we experienced as a country included the ANC centenary, the celebrations, the elective congress and the election of the current ANC leadership led by President Jacob Zuma. We are confident the new leadership will ensure that stability continues within the ANC and the country.
SADTU NEC CALLS FOR THE BASIC EDUCATION DIRECTOR GENERAL BOBBY SOOBRAYAN TO BE FIRED
The National Executive Committee of the South African Democratic Teachers Union (SADTU) held its last meeting for the year on Friday, 7 December 2012 in Kempton Park Johannesburg and outlined its 2013 programmes. 2013 will be marked by the election of sites,
SADTU Eastern Cape media statement
SADTU in the Eastern Cape challenges education MEC on the teacher posts declared for 2013.
With only a month to go before the 2013 school year begin; SADTU in the Eastern Cape has taken to court the Provincial Department of Education in an attempt to stop the department from reducing the number of teachers in the province.
SADTU IN THE EASTERN CAPE CHALLENGES EDUCATION MEC ON THE TEACHER POSTS DECLARED FOR 2013
With only a month to go before the 2013 school year begin; SADTU in the Eastern Cape has taken to court the Provincial Department of Education in an attempt to stop the department from reducing the number of teachers
SADTU Western Cape media statement
SADTU in the Western Cape warns Education MEC Donald Grant not to use the Union as a scapegoat in the schools closures saga.
We are schocked at a teacher who allegedly raped and showed porn to a learner
The South African Democratic Teachers' Union (SADTU) would like to express shock at newspaper reports of a teacher who allegedly showed porn to two learners and sexually assaulted one of them at a primary school in Pimville.
SADTU in the Western Cape disappointed at Dr Mamphela Ramphele
On behalf of SADTU members in the Western Cape, we take umbrage at the child-like antics of Dr Mamphela when she called SADTU teachers alcoholics, drug addicts and indebted to no end. This is the most
Getting to zero: HIV Infections, Discrimination, Aids related deaths and disarming Gender Violence
The South African Democratic Teachers' Union (SADTU) will, on Saturday, join millions of people around the world to celebrate December 1, World Aids Day under the theme – Getting to zero: HIV infections, discrimination, Aids related deaths and disarming gender violence.
Society part of SADTU`S Core Strategy
The South African Democratic Teachers` Union (Sadtu) has always taken a keen interest in broader societal issues beyond the classroom – and unapologetically so.
Our core function has always been to advance and protect the rights of teachers and this includes ensuring that their work conditions are favourable
SADTU RESPONDS TO MAMPHELA RAMPHELE
Dr Mamphela Ramphele's derogatory and ill informed remarks cannot go unchallenged. To be labeled drunkards, hooked on drugs, we can't take care of ourselves and are deep in debt, is beyond insult. It is blatant defamatory.
Summary of the ELRC dispute - Collective Agreement 1 of 2011 (Remuneration of Markers)
On 7 April 2011, the Department of Basic Education and teacher unions signed collective agreement no 1 of 2011. In terms of the collective agreement the parties agreed to increase the remuneration of markers by 100%.
Click here to view the full document
SADTU in Limpopo is not convinced by Minister Motshekga's promise to deliver stationery and textbooks on time.
SADTU is not yet convinced about the department capacity to deliver learner teacher support material (stationery & textbooks) for 2013. The announcement of plans and actions by Minister on this matter is seen as a Public relations exercise. All what she said, was also said in 2012 and books were still not delivered.
SADTU condemns the leaking of papers
SADTU in Mpumalanga wishes to condemn, in the strongest terms, the leaking of Grade 10 and 11 question papers.
We call upon the Department and law enforcement agencies to thoroughly investigate this and those implicated be made to face the full might of the law.
Basic Education Director General Bobby Soobrayan should be investigated as a matter of urgency and as SADTU we condemn the killing of NUM members
The National Working Committee (NWC) of the South African Democratic Teachers' Union having held its ordinary monthly meeting on the 9th October 2012 to deliberate on a number of issues ranging from political developments in the country, education issues which included the release of the Presidential Task team report on the Limpopo workbooks' saga and the killings of the NUM members in the mines amongst others.
PSCBC Joins Millions To celebrate World Teacher`s Day
The PSCBC acknowledges the pivotal role played by teachers towards the developmentof our progressive South African nation.Teachers remain the pillars of our communities and work tirelessly, give unselfishly with
humility and dedication to transfer knowledge and values from generation to generation.
SADTU' World Teachers' Day message
World Teachers' Day was initiated by UNESCO to commend teachers for the contribution they make to education and development. SADTU would like to call on government, communities, business and civic bodies in South Africa to provide support to education, the teaching profession and organizations that represent teachers and educational staff.
SADTU express shock on the passing on of a Limpopo learner during boys under sixteen football matches in Bloemfontein
It is with great sorrow to be informed that one learner (Kutama Andani) from Benny's Care in Vhembe District passed away after collapsing during boys under sixteen football matches in Bloemfontein in the Metropolitan SASFA games. The Union would like to pass the message of condolences to the family; Benny'Care; SASFA; and the entire Vhembe district as well as people of Limpopo. May his soul rest in peace.
SADTU CALLS MALEMA TO ORDER
The South African Democratic Teachers' Union (SADTU) has added its voice in the call for expelled ANCYL Leader Julius Malema to stop his inflammatory statements against the National Union of Mineworkers (NUM) and its leadership. Malema has called on miners to boycott the leadership of NUM.
Malema and his friends show no respect for nurses and women
The South African Democratic Teachers' Union (SADTU) would like to echo Denosa's dismay and contempt at the attack of COSATU president Sdumo Dlamini by the so-called "Friends of the Youth League."
In a response to Cde Dlamini's speech delivered at the Young Communist's League public lecture in Katlehong where he sounded a warning that the Federation was under attack from Malema and others and warned him not to exploit the Marikana tragedy for his narrow political gains, the "Friends of the Youth League" have resorted to sexism and gender stereotyping to chide Cde Sdumo.
NATAL IS PLOTTING TO OUST COMRADE VAVI
In the article that appeared in Isolezwe of the 23rd August 2012, on page 11, the statement made by NUMSA KwaZulu Natal claims that SADTU is on a campaign to stop Comrade Zwelinzima Vavi from being re-elected as the General Secretary of COSATU. According to NUMSA Zwelinzima Vavi may falter plans for the re-election of Zuma in Mangaung.


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redpajama_set_name: RedPajamaGithub


The top SNPs for the suicide attempt analysis included two from DPP10, one from CTNNA3 and one from STK32B.
Genome-Wide Specific Selection in Three Domestic Sheep Breeds.
For meat traits, ALDOA, STK32B and FAM190A are related to marbling.
Identification of Human N-Myristoylated Proteins from Human Complementary DNA Resources by Cell-Free and Cellular Metabolic Labeling Analyses.
As a result, the products of 13 cDNA clones (FBXL7, PPM1B, SAMM50, PLEKHN, AIFM3, C22orf42, STK32A, FAM131C, DRICH1, MCC1, HID1, P2RX5, STK32B) were found to be human N-myristoylated proteins.
RESULTS: We found that CBX2, SCUBE2, and STK32B protein expression were associated with important clinicopathological features for OSCC (peritumoral inflammatory infiltration, metastatic spread to the cervical lymph nodes, and tumor size).
For CAD, we detected single nucleotide polymorphisms (SNP) pairs in three genes showing genome-wide significance: HFE2, STK32B, and DIPC2.
STK32B and EVC yielded consistent evidence from cleft lip, with or without cleft palate, trios in all four populations.
Long interspersed nuclear element-1 (LINE1)-mediated deletion of EVC, EVC2, C4orf6, and STK32B in Ellis-van Creveld syndrome with borderline intelligence.


The beach house lies concealed high on the cliff. Majestic views of the ocean, the spring sun sparkling on the waves. White seagulls whirl elatedly against the blue sky. A salty sea breeze brushes past the fjords. Spring beckons with Bloom, a collection as fresh as the first morning dew.
Cheerful field flowers contrast colourfully with the weathered wood. Bright northern light reveals a mix of natural materials. Light linen curtains, a rough wooden floor, grandmother's chest of drawers shows off against the wall. Gently, the watercolour brush strokes the hand-made paper.
Subdued powdery shades, frozen blues, frosted pastels in chalk paint and mineral gloss, combined with graphic black and white. Hand-painted and stylized flowers, eclectic stripes and a fine board pattern in a subtle range of colours. The fresh beauty of Bloom is authentic and pure, for a light and Scandinavian atmosphere.


We are excited to introduce six new pistols with Reduced Moon Shine Camo® grip frame patterns. The Toxic® and Harvest Moon® patterns are the perfect way for outdoor and firearms enthusiasts to show a new level of self-expression. Find the right configuration for you, or collect them all!


Freshly prepared home cooked food is one of the delights of a catered ski chalet holiday and a joy that we have perfected. During your stay we will serve you breakfast, afternoon tea and a 3 course dinner on 6 days to include our fantastic help yourself Savoyard dinner on one night … a real treat!
We cater to most dietary requirements, just let us know at the time of booking so that we can let our chalet staff know prior to your arrival.
If you are celebrating a special occasion during your stay with us, then let us know. A birthday or anniversary wouldn't be a celebration without a cake!
Your chalet staff have two days off each week. A self-service continental breakfast will be provided on both occasions.
On one of the evenings, a self-service Savoyard night is provided, it's great fun and it's yummy, our guests always love it! The other staff evening-off presents an opportunity for you to try our local restaurants. Our team will be pleased to recommend some favourites and get them booked for you to avoid disappointment. Why not try out the bars afterwards and catch some live music?
Book your catered ski chalet holiday in France today and let us do all the cooking!
We look forward to welcoming you to one of our charming ski chalets.
Enjoy a continental or a cooked option. Our breakfast also includes freshly baked baguettes and pastries, cereals, muesli, yoghurts and porridge made to order. Our daily cooked option is different every day alongside a plentiful choice of teas and freshly brewed coffee.
For afternoon tea you will delight in freshly baked cakes, biscuits, scones and brownies, complimented by a choice of teas, filter coffee or a mug of hot chocolate.
We are always happy to provide an earlier evening meal for our little skiers, which will be tailored to suit children's taste buds. Home from home cooking always goes down a treat, so just let us know their likes and dislikes and we will do the rest.
A delicious 3 courses with a selection of local cheeses on the last night to complete your holiday on a high is served on 6 nights of your stay including our fantastic help yourself Savoyard dinner on one night … our guests say its a highlight of their stay !
We are pleased to be offering a good selection of wines. Wine or beer is offered throughout dinner service and during your savoyard evening meal. Complimentary teas, coffee and juice are available in the chalet throughout the day.
Newly built for 2016/17, this chalet promises something special. Extremely spacious interiors, hot tub, sauna and 7 en-suite bedrooms. Situated right beside the slopes and just a short stroll to the village centre.
A smaller version of it's sister Alpinium 1 and newly built for this season, this lovely bright and airy 4 bedroom chalet will prove a popular choice for the family ski holiday. It has all the same high spec interiors and a wellness room with sauna.
In a ski in/ski out position, this pretty chalet has the most charming interiors with exposed wooden beams and large picture windows. Take a short traverse to the piste first thing in the morning and arrive at some of the finest skiing in the world.
A delightful little chalet perfect for families, in a great location just a minute's walk to the main cable car to take you up the mountain. Interiors are extremely comfortable and outside on the sunny balcony you'll find the hot tub.
Loads of space, loads of character and located just a few minutes walk to the resort centre or 25 metres to the nearest bus stop. The Bergerie is going to be one of our favourite chalets for next Winter.
With the village centre only a short stroll away and a free bus service to the chairlift on the doorstep, this chalet really is situated in a convenient spot in La Rosiere.
This lovely ski chalet has a wonderful home from home feel with feature wood burning stove and cosy feel living areas. Situated at 2100m in the popular village of Val Claret, it doesn't get much better than this.
Chocard was modernised a few years ago. The outside space is as large as the lounge area and is great for long, sunny afternoons watching the sunset ni the valley with a glass of vino or a vin chaud in your hand!
With an outdoor Hot Tub, (shared with our guests in The Penthouse), outdoor ski locker and a location on the nursery piste, Chalet Grace ticks so many boxes for your perfect holiday.
One of the largest catered chalets in our portfolio with 8 en-suite bedrooms and one of the most popular. A beautiful open plan living area with log burning fire, and mezzanine level with widescreen TV and games console.
The chalet has a superb location approximately 80 metres from the lift connecting you to Arcs 2000 (and it is often possible to pole this rather than walk). Snow conditions permitting you can ski back to the door.
Since the completion of its renovation in October 2015, Chalet Perle des Neiges in Villaroger has been delighting skiers and boarders of all ages.
Newly built for 2017/18, this chalet promises something special. Extremely spacious interiors, outdoor hot tub and 5 en-suite bedrooms. Situated right beside the slopes and just a short stroll to the village centre.
This chalet is ideal for families & groups. Built in the 1850's and formerly the village forge, with a water wheel on the millstream to provide power, this was the first house in Montriond to get electricity.
Built by local craftsmen with traditional materials and finished with modern interiors, there's nothing not to like about this extremely stylish chalet.
The Penthouse is just as ideal for friend groups and couples looking for a memorable ski escape as well.


Over the years I am aware that the Holy Spirit is moving and that the ladies are expecting to be moved and it moves up a gear each year.
One of the biggest things for me is the Worship!!
We start to sing and all the English words leave me and I sing in Albanian. At that moment It feels like I am singing in "tongues" and I come right into Gods presence.
It is so moving and so special.
It is so inspiring to be with the Albanian Ladies and girls to see how hungry they still are and how they have grown and move in their faith over the years.
I feel that God has opened a door in my heart that I did not know was closed.
I am changed by being on this journey to Albania and I am forever grateful for it.


Sunday, November 11, is traditional Veterans Day, although it will be officially observed on Monday, November 12. As I'm sure you know, this holiday is dedicated to those who served in the U.S. Armed Forces.
So we all need to make sure to honor the veterans for their great service to this great country!
Important! If you are a veteran, or if you know a vet, please make sure to take advantage of the many free or discounted meals and services for this holiday. See the links at the end of this blog posting.
As of 2014, three states have more than 1 million veterans among their population: California (1.8 million), Florida (1.6 million) and Texas (1.7 million).
Previous PostNCP Named One Of The Top Places To Work On Long Island!Next PostHoliday Shopping – In Store Or Online?


According to IBEF, the Indian chemical industry stands as the third largest producer in Asia and 12th in world, in terms of market volume. This industry could grow at 14% per annum from USD 160 billion in 2013 to reach a size of USD 350 billion by 2021. However, is this figure realistic?
The chemical industry is one of the oldest industries in India. Over the last decade, it has evolved from being a basic chemical producer to becoming an innovative industry. With investments in R&D, the industry is registering significant growth in the knowledge sector comprising of specialty chemicals, fine chemicals and pharmaceuticals. The Indian Chemical industry has had to face the brunt of the global slowdown in the past 2-3 years. Global economic uncertainties along with recent regulatory issues have resulted in low FDI inflows into the country. But, a large population, dependency on agriculture and strong export demand are the key growth drivers for the Chemical industry, which have resulted in the recent upswing, visible in the latest figures. The estimated size of the market is USD 144 billion, which accounts for about 3% of the nation's GDP. Per capita consumption of majority of finished products in the chemicals sector is far below the world average; this points out the vast potential for growth in the industry.
The largest segment of the Indian chemical industry are Base chemicals, which comprise of Petrochemicals, man-made fibres, industrial gases, fertilisers, chlor-alkali, and other organic and inorganic chemicals. This is followed by specialty chemicals, pharmaceuticals, agrochemicals and bio-pharma, bio-agri, and bio-industrial products. For instance, India accounts for approximately 7% of the world production of dyestuff and dye intermediates. The chemical industry is one of the most diversified sectors, covering more than 70,000 commercial products. Gujarat and Maharashtra emerged as the most favoured zones for the industry, mainly because of government policies, strategic location and availability of raw material.
Lured by the size and returns of the Indian market, foreign firms have strengthened their presence in India. From April 2000 to November 2014, the total FDI inflow into the Indian chemical industry (excluding fertilizers) was USD 10.1 billion. The share of the chemical industry in the total FDI inflow from April-October 2014 has been estimated to be 4%, which is a huge improvement compared to 1,3% in 2013.
The Government recognizes the chemical industry as a key growth element of Indian economy. In the Chemical Sector, 100% FDI is permitted and excise duty was reduced from 14% to 10% and later to 8%. Industrial licensing has been abolished for most sub-sectors. Import of certain organic chemical products to India requires the approval of the Directorate General of Foreign Trade. A number of initiatives have been proposed in the 12th 5-year plan (2012-2017) to boost the growth of the Indian chemical industry. Policies have been initiated to set up integrated Petroleum, Chemicals and Petrochemicals Investment Regions (PCPIR). PCPIR will be an investment region in India spread across 250 square kilometers for manufacturing of domestic and export-related products of petroleum, chemicals and petrochemicals. The Indian Chemical industry has the potential to grow significantly, if some of the key growth imperatives are taken care of. Securing feedstock, the right product mix and M&A opportunities are currently the key imperatives for the chemical industry in India.


text:
Posted inSchools
Oxford Principal to Thousand Oaks amid district shuffle
by Eden Teller July 01, 2013, 3:00 p.m. October 4, 2022
Jennifer Corn: the newly named Principal of Thousand Oaks Elementary School. Photo: BUSD
Update, 4:02 p.m.: The Principal of LeConte Elementary School announced she is resigning shortly after this story was published. In a statement issued today, Kathryn Singh said she would be moving back to Massachusetts due to family matters. BUSD Co-Superintendent Neil Smith said in a note to the LeConte community that Singh had been a great educational leader for LeConte and that "her bilingual and cross-cultural expertise served LeConte well in this year of transitions." He continued: "I am committed to making the process to hire LeConte's next principal as transparent and smooth as possible. The opening was officially advertised today both locally and through a well-regarded public education online search service."
Original story: A Berkeley elementary school principal has been asked to switch schools, opening up a new head-of-school vacancy in a field which has seen several changes recently.
Jen Corn, who has been Principal at Oxford Elementary for two years, will replace Gayle Hughes as the new principal of Thousand Oaks Elementary School. Hughes announced this summer that, due to the relocation of her husband's workplace, she will be moving to Southern California.
Neil Smith, co-Superintendent of the Berkeley Unified School District, made the announcement last week. In a statement, Smith wrote that during the search for a new principal, the district found that Corn's experience in bilingual education would greatly enhance Thousand Oaks' plans to expand its language programs.
Smith added in his email that though this change leaves Oxford without a principal, one of the candidates found in the search for Thousand Oaks school "could be a superb fit for Oxford."
Corn stated in a letter to the Oxford families that, though she never applied for the Thousand Oaks position and faced a difficult decision in leaving Oxford, she is excited about the opportunity to expand the bilingual program to the upper grades.
Meanwhile Washington Elementary School Principal Rita Kimball left at the end of the last academic year and is being replaced by Mel Stenger. And Willard Middle School has a new Principal after Robert Ithurburn left to take a new post. It was announced earlier this month that Debbie Dean has taken up that post.
Willard names new principal, Thousand Oaks on the hunt (6.14.13)
Berkeley school get recycling back on track (6.15.13)
Eden Teller, a graduate of Berkeley High School, is a summer intern at Berkeleyside. She will be attending Macalester College in St. Paul, MN, next year.
Would you like to have latest Berkeley news in your email inbox once a day? Click here to subscribe to Berkeleyside's free Daily Briefing.
Tagged: Berkeley Unified School District, Neil Smith, Oxford Elementary School, Thousand Oaks Elementary School
Eden Teller
eden@berkeleyside.com
Eden Teller is a freelance reporter, writer and amateur gardener. She began reporting for Berkeleyside as an intern in 2013 and continued her career with a B.A. in Media Studies from Macalester College... More by Eden Teller


text:
Joaquin Phoenix: Rap Bid Is No Hoax
Former Oscar-nominated actor says his hip-hop dreams are serious.
ByLUCHINA FISHER
Feb. 4, 2009 — -- Joaquin Phoenix: rapper?
For real.
The former Oscar-nominated actor, whose movie with Gwyneth Paltrow, "Two Lovers," will purportedly be his last, says his move into the rap music world is no hoax, as had been speculated in various media reports.
"There's not a hoax," Phoenix told The Associated Press. "Might I be ridiculous? Might my career in music be laughable? Yeah, that's possible, but that's certainly not my intention."
Phoenix's debut performance in January was less than auspicious: Three barely comprehensible raps concluded by Phoenix falling off the stage.
How did the audience respond?
"There was a mixture of people clapping," said Mike Snedegar, the head of entertainment marketing at Lavo, the Las Vegas nightclub where Phoenix performed Jan. 9, "and some with weird looks on their faces like, 'What is going on?'"
Phoenix contends the live show was much better than footage posted on the Internet.
"It sucks that, yeah, the footage is out there as like this incredibly bad sound, and you literally can't hear what's happening," he told the AP. "It was much better in the club, and I don't know who said that people were booing … because that was not happening."
"Unless, of course, it's a pretty big place, and maybe it was happening," Phoenix added with a laugh. "But it was not my experience. My experience afterward was I had a lot of dudes come up and say, 'We really respect you for doing it, putting yourself out there, and going with it.' Because I think true hip-hop heads know that it's hard, it's going to be a hard transition, and people are going to be lining up just to make fun of me."
After the performance, some wondered whether Phoenix was carrying out some kind of elaborate ruse. Phoenix's rep, publicist Susan Patricola, released a statement at the end of January saying the actor's rap-star dreams are real and he will continue to pursue them despite naysayers.
"The transition from one career to another is never seamless. It should come as no surprise to anyone that Joaquin came from a musical family, in addition to winning a Golden Globe for his portrayal of Johnny Cash," Patricola wrote in an e-mail. "He intends on exploring his musical interests despite speculative, negative or positive reactions."
Casey Affleck is helming a documentary about Phoenix's foray into music and was in Vegas, along with two other cameramen, shooting Phoenix's performance.
According to media reports, Diddy is producing Phoenix's rap album. At first his rep said she was unaware of his involvement but later she sent ABCNews.com an e-mail saying, "I cannot comment on this at this time."
Several other rappers contacted by ABCNews.com refused to go on the record commenting about Phoenix's new career path.
Snedegar told ABCNews.com that he had his doubts about Phoenix's intentions.
"I'm not sure, to be honest. There were moments when I looked at him and I thought, 'I can't believe he's doing this,'" he said. "Then, there were moments he seemed to be very serious."
Apparently Phoenix was prepared to not be taken seriously. He told People magazine before his performance: "Are there people out there who think I'm a joke? I'm sure there will be. Are there people who think it's going to suck? Probably, but I can't worry about that."
From the Silver Screen to the Music Scene
Snedegar said some of the raps' lyrics were about Phoenix leaving acting to become a rapper and growing up in San Francisco, but, for the most part, he had trouble understanding them.
"When he first got on, there was a small sound adjustment -- you had to wait 20 seconds before you could hear him," he said. "Then he started talking, the playback went in and he kept on rhythm. But you couldn't really understand what he was saying. I think he was holding the microphone too far away."
Stunt or not, Phoenix certainly appears serious about his new career. About to go on stage in October for a play benefiting Paul Newman's Hole in the Wall Camps, he told "Extra": "I want to take this opportunity ... also to give you the exclusive and just talk a little bit about the fact that this will be my last performance as an actor. I'm not doing films anymore. … I'm working on my music. I'm done. I've been through that."
The surprises did not end there. Next came Phoenix's bearded, bloated appearance at a party in December.
Hip-hop may seem like an odd fit for Phoenix, who, three years ago, received an Oscar nod for his portrayal of singer Johnny Cash. Not so, he explained to People magazine: "When I was young I liked punk rock music but then I discovered rap. I love the storytelling aspect of hip-hop."
"After all the years of reading scripts and reading lines, this is my chance to do something straight from the heart and put it out there," he told People. "This is me saying this is who I am. This is my story."
But will people want to hear what he has to say?
Snedegar thinks people will tune in, at least initially. About 500 people -- some fans, some skeptics -- turned out for Phoenix's first performance, he said.
"He's definitely going to make waves with his performance because people are curious," he said. "It just depends on how people accept him."
That includes his shaggy new look. "I was surprised by his appearance," Snedegar said, referring to Phoenix's bushy beard, dark shades, baggy sweater and torn gray knit cap. "Everybody was. He was dressed very laid back, a beachy vibe with loose pants, a big sweater and a cap on most of the time. He looked like he had gained a little weight."
Joaquin's Strange Behavior?
Phoenix's dramatically different appearance, coupled with reports of erratic behavior, have some worried that the former leading man is headed for the same self-destructive path as his older brother, the late actor River Phoenix.
"Given his actions, he [Joaquin] is starting to look a lot like his brother," Ian Drew, editor at large at US Weekly, told ABCNews.com. "It does make you question how his story is going to end -- or continue."
River Phoenix died of a drug overdose in October 1993 after collapsing outside the Johnny Depp-owned Viper Room nightclub in Los Angeles.
The then-19-year-old Joaquin, who was at the club along with their sister Summer, made the 911 call to try to save his 23-year-old brother's life.
"Joaquin is definitely on a course right now," E! Online gossip columnist Ted Casablanca told ABCNews.com. "I don't know if it's self-destruction or self-derailing. But he's obviously going through some sort of tortured episode in his life. It's a cry for help."
"He's obviously a deep guy with some dark reference points," Drew said. "There's obviously a shadow over his life. He's had problems played out on the public stage."
In 2005, after filming the Cash biopic "Walk the Line," Phoenix entered rehab for alcohol abuse. He told reporters afterward that he started drinking more while playing Cash.
"It was then that I became aware of my drinking. I wasn't an everyday drinker but didn't have anything else to do, anything to hold me down," he said. "I was leaning on alcohol to make me feel OK. That's what it really was."
Publicist Patricola quashed any rumors that Phoenix is self-destructing.
She told ABCNews.com, "He is fine and doing his music," but would not go into detail. "When Joaquin has more to say, I'm sure he will," she said.
Snedegar said Phoenix appeared fine the night he performed. "Every time I spoke to him he was coherent, polite. He was low key but open to the fans."
Phoenix's Rap Debut
Even though Phoenix's agent had booked the gig a couple weeks before, it was still undecided whether he would perform that night. The evening started with a specially prepared vegan dinner for Phoenix and 20 friends, including Affleck, at the Palazzo Resort Hotel and Casino.
The group then moved upstairs to Lavo, Snedegar says, where they sat at a table in front of a catwalk with a microphone, in case Phoenix decided to perform.
A member of Affleck's documentary crew gave the signal: Phoenix was ready to go on.
"I don't know if I would say he's a natural," Snedegar added. "He isn't horrible. He can keep on beat. He was kind of dancing and on rhythm and that was good."
Phoenix, who seemed tentative at first, Snedegar said, soon warmed up during the course of the three raps, strutting the catwalk and, by the end, jumping up and down and thanking his audience profusely. "You hold a very special place in my heart," he told the crowd.
Perhaps it was the adrenaline that made him miss a step as he was leaving the catwalk and fall into the audience, where he landed on his feet.
"He took pictures with fans, hung out another hour," Snedegar said. "His friends were hugging him. He seemed very happy."


text:
Team:UC Davis/Optimization
Cyantific: UC Davis iGEM 2016
Protein Discovery
Novel Expression
Expression in a GRAS Organism
CBCR Model
iGEMMatch.org
Safe By Design
Seeing Blue: Scenarios for SYNENERGENE
How to Conduct Ethical Interventions in iGEM Surveys
"Beyond Artificial" Policy Paper
Adventures in Human Practices: Integration from Day 1
Product Optimization
Given that our project focuses on how to bring GAF proteins into the food colorant industry and have large scale production, a primary concern is how GAF protein production can be optimized. Our team first focused on apoprotein production using our GAF protein constructs that were regulated by a pBAD promoter. We induced cultures with different concentrations of arabinose, and after harvesting we assessed pellet volume and color vibrancy to see if there was an optimal inducer concentration.
Next our team focused on optimizing the entire genetic circuit, now including the cofactor production pathway along with GAF protein expression, to produce the highest protein expression. With the results of our previous induction experiment, we hypothesized that changing the expression mechanism of the cofactor could affect overall production of the complete functional protein. While our team was not able to complete our genetic circuit work, we provide a detailed experimental design and our work thus far.
A main concern with biomanufacturing is how to maximize production of profitable product to offset manufacturing costs. By engineering the pathway at the cellular level, we can infer how we can optimize each step of the pathway to produce more protein using reasonable amounts of resources.
For our project, we take the first step by experimenting with and characterizing GAF protein production in E. coli. Although E. coli is not the optimal chassis to use for large scale production, our simpler, small scale experiments can produce sufficient data from E. coli. In addition, our parts can be used by future teams who wish to continue taking the next proper steps in advancing our protein towards large scale production.
Induction Experiment
After expressing our GAF protein our team observed visual differences in cell pellets depending on the amount of arabinose added to the cultures. In our construct arabinose induces the expression of the GAF. While it is widely known that the photosensory properties of the CBCR are dependant on the availability of the bilin cofactor (8), our team wanted to quantify that in regards to our genetic circuit and determine if there is a saturation point in which the arabinose is either 1) no longer effective or 2) harmful.
First we made 20mM, 10mM, and 1mM (following from left to right) cultures of our NpF2164g5 GAF construct. The 1mM culture had the largest cell pellet, but also lacked any vibrancy. The 10mM culture had a medium sized pellet, and appeared to be the most vibrant and the 20mM arabinose concentration culture was roughly as vibrant as the 10mM, but had a much smaller cell volume. Since the 10 mM solution produced the best results, our team repeated the experiment, but this time with 1mM, 3mM, 10mM, 33mM, and 100mM arabinose concentration in growth media.
After lysing the cells by sonication the lysate was used to take the absorbance spectra. Cells did not grow at 33mM and 100mM arabinose concentrations, likely because either the environment was no longer suitable for growth, or the cell was allocating more resources to GAF synthesis, but there was not enough cofactors to associate with the protein. Of the remaining three media concentrations that did produce cell pellets, the cells were lysed and the lysate used to take spectra. Surprisingly, the 3mM had a higher peak absorbance than the 10mM. This lack of correlation indicates that the higher induction levels do not correlate to higher peak absorbance levels meaning that there is an optimal production of the GAF. Based on our results our team estimates this is around 3mM arabinose concentrations of cell culture. While the induction of GAF synthesis obviously affected the protein vibrance and production efficiency, there could also be ways to improve the genetic circuit itself. For this reason, our team went on to design genetic circuit library that we would like to complete in the future.
Genetic Circuit Experiment Design
Because the GAF protein must associate with a bilin cofactor in order to be photoactive, an engineered cell must also be able to express the necessary enzymes that convert heme into the cofactor. Such an expression system that requires multiple coding genes has room for optimization in order to control the flux of the protein production. For example, upregulating expression of one of the heme-converting enzymes would theoretically increase bilin production and consequently affect overall production rate of the complete protein. Optimizing the pathway would be the next key step in advancing to industrial-scale mass production.
Our next step will be to design and test various operon structures for the key genes for protein production. From the iGEM registry, there are collections of promoters and ribosome binding sites of various strengths. We can design an operon library in which we swap promoters and RBS's used to regulate expression of each gene. Monocistronic and polycistronic variants can also be considered, as well as gene order. Such a library would have thousands of variations. Experimentally measuring overall protein production will provide insight of what structure, gene order, and regulatory components will produce the most efficient genetic circuit for protein production.
From the current registry catalog, we can use the Anderson collection of constitutive promoters since they span a wide range of relative strength. The community RBS collection can also be considered for their popularity. A single strong terminator (B0015) will be used throughout since we decided termination rate is not worth varying in our libraries.
We have designed three overarching hierarchical operon structures for our phycocyanobilin-dependent GAF proteins. These proteins require three genes: heme oxygenase (HO) to convert heme to biliverdin, PcyA to convert biliverdin to the PCB cofactor, and the coding for the actual apoprotein. HO and PcyA are already in the registry, as they are the oldest parts ever submitted from the very first iGEM (I15008 and I15009, respectively) and are available for all future teams. Our goal with the operon will be to provide insight to future iGEM projects on how HO and PcyA should be expressed in conjunction with the CBCR protein.
Our first design is completely monocistronic, with each of these three proteins under control of separate promoters.
Our second design is partially polycistronic, with HO and PcyA expressed under the same promoter while the apoprotein is under separate regulation. Our reasoning for this split is because PCB production is an independent metabolic pathway and it is worth exploring separately.
Our third design is completely polycistronic. This provides the most flexibility in gene order, as the three genes can have swapped positions with different strength RBS's while being regulated together under the same promoter.
In the future, our team would like to do a more thorough investigation into induction quantity. We found our results that different GAF proteins required different amounts of the cofactor to be quite interesting and would like to expand our experiment to include other GAF proteins and also GAF proteins which use biliverdin as their cofactor, unlike the ones used here which only use the PCB cofactor. If we find the trend that cofactor availability affects different GAF proteins differently we would like to investigate what three dimensional aspects to the protein are influencing this.
As for the genetic circuit design, our team would like to finish the last bit of the operon library to find if there is an optimal genetic circuit that significantly upregulates or downregulates GAF protein expression. Unfortunately, our team was not able to finish the operon construction over the summer but was able to get the almost the entire construct with only the first promoter,rbs, and plasmid not assembling.
Next: Expression in a GRAS Organism
Trotter, Greg. "Food Companies Are Phasing out Artificial Dyes, but Not Fast Enough for Some." Food Companies Are Phasing out Artificial Dyes, but Not Fast Enough for Some. Chicago Tribune, 24 June 2016. Web. 18 Oct. 2016.
"Konica Minolta - Products." Instrument Systems - Sensing Americans. Konica Minolta Sensing Americans Inc., Oct. 2016. Web. 18 Oct. 2016.
"Our Proposition on Artificial Colors - Colors Policy." MARS Incorporated, Oct. 2016. Web. 18 Oct. 2016.
"Kraft Mac & Cheese Says Goodbye to the Dye." Decision - 2016. NBC News, 20 Apr. 2015. Web. 18 Oct. 2016.
"Taste of General Mills." A Big Commitment for Big G Cereal. General Mills Cereal Incorporated, 22 June 2015. Web. 18 Oct. 2016.
"Nestlé USA Commits to Removing Artificial Flavors and FDA-Certified Colors from All Nestlé Chocolate Candy by the End of 2015." 150 Years of Good Food, Good Life. Nestle Incorporated, 17 Feb. 2015. Web. 18 Oct. 2016.
Alexandratos, Nikos, and Jelle Bruinsma. "World Agriculture Towards 2030/2050." Agricultural Development Economics Division - Food and Agriculture Organization of the United Nations. Global Perspective Studies Team, June 2012. Web. 18 Oct. 2016.
"Compound Summary for CID 19700." Brilliant Blue FCF. Pub Chem - Open Chemistry Database, 15 Oct. 2016. Web. 18 Oct. 2016.
"Summary of Color Additives for Use in the United States in Foods, Drugs, Cosmetics, and Medical Devices." For Industry - Color Additives - Color Additive Inventories. U.S. Food & Drug Administration, May 2016. Web. 18 Oct. 2016.
http://link.springer.com/article/10.1007/s00217-004-1062-7
http://www.instructables.com/id/Blue-Foods-Colorful-cooking-without-artificial-dy/
A Brief History of Phytochrome Nathan C. Rockwell and J. Clark Lagarias
Hirose, Yuu, et al. "Green/red cyanobacteriochromes regulate complementary chromatic acclimation via a protochromic photocycle."Proceedings of the National Academy of Sciences 110.13 (2013): 4974-4979.
Rockwell, Nathan C., and J. Clark Lagarias. "A brief history of phytochromes." ChemPhysChem 11.6 (2010): 1172-1180.
Bussell, Adam N., and David M. Kehoe. "Control of a Four-Color Sensing Photoreceptor by a Two-Color Sensing Photoreceptor Reveals Complex Light Regulation in Cyanobacteria." Proceedings of the National Academy of Sciences of the United States of America 110.31 (2013): 12834–12839. PMC. Web. 7 Oct. 2016.
http://www.nutritionaloutlook.com/food-beverage/coloring-spirulina-blue
Nature's Palette: The Search for Natural Blue Colorants
https://www.novozymes.com/en
http://www.dsm.com/corporate/home.html
http://prodata.swmed.edu/promals3d/promals3d.php
https://www.neb.com/products/e6901-impact-kit
Heim R, Cubitt A, Tsien R (1995)."Improved green fluorescence" (PDF). Nature. 373 (6516): 663–4.doi:10.1038/373663b0.PMID7854443.
https://www.ncbi.nlm.nih.gov/genome/browse/
http://pfam.xfam.org/
Red/Green Cyanobacteriochromes: Sensors of Color and Power - lagarias
https://en.wikipedia.org/wiki/Brilliant_Blue_FCF#/media/File:Blue_smarties.JPG
Fischer, A. J. and J. C. Lagarias (2004). "Harnessing phytochrome's glowing potential." Proceedings of the National Academy of Sciences of the United States of America 101(50): 17334-17339.
Stability of phycocyanin extracted from Spirulina sp.: Influence of temperature, pH and preservatives- R Chaiklahan, N Chirasuwan, B Bunnag - Process Biochemistry, 2012 - Elsevier
http://www.lightboxkit.com/Assay_dye.html
"Your Brain - A User's Guide - 100 Things You Never Knew." National Geographic Time INC. Specials 12 Feb. 2016: Print.
Sensing, Konica Minolta. "How Color Affects Your Perception of Food." Konica Minolta Color, Light, and Display Measuring Instruments. Konica Minolta Sensing Americans Inc., 2006. Web. 10 Oct. 2016.
"Center for Disease Control and Prevention - General Information Escherichia Coli." CDC 24/7: Saving Lives, Protecting People. Centers for Disease Control and Prevention, 06 Nov. 2015. Web. 10 Oct. 2016.
Olmos J, Paniagua-Michel J (2014) Bacillus subtilis A Potential Probiotic Bacterium to Formulate Functional Feeds for Aquaculture. J Microb Biochem Technol 6: 361-365. doi:10.4172/1948-5948.1000169
Zeigler, Daniel R. "Bacillus Genetic Stock Center." Bacillus Genetic Stock Center Website. The Bacillus Genetic Stock Center - Biological Sciences, Oct. 2016. Web. 10 Oct. 2016.
Vellanoweth, Robert Luis, and Jesse C. Rabinowitz. "The Influence of Ribosome binding-sites Elements on Translational Efficiency in Bacillus Subtilis and Escherichia Coli in Vivo." Molecular Microbiology 1105-1114, 15 Jan. 1992. Web. 9 Oct. 2016.
"Pveg (Plasmid #55173)." Addgene - The Nonprofit Plasmid Repository. Synthetic Biology; Bacillus BioBrick Box, Aug. 2016. Web. 10 Oct. 2016.
Gambetta, Gregory A., and Clark J. Lagarias. "Genetic Engineering of Phytochrome Biosynthesis in Bacteria." Section: Molecular and Cellular Biology. Proceedings of the National Academy of Sciences of the United States of America, 19 July 2001. Web. 9 Oct. 2016.
"Registry of Standard Biological Parts - B0015." Part: BBa_B0015. International Genetically Engineered Machine Competition (iGEM), 17 July 2003. Web. 9 Oct. 2016.
"Bacillus Subtilis - Indiamart." IndiaMART InterMESH Ltd., n.d. Web. 9 Oct. 2016.
Contact us at: ucdigem@gmail.com


text:
<?php namespace mnshankar\auth\Console;

use Illuminate\Console\Command;
use Illuminate\Filesystem\Filesystem;

class ScaffoldAuthCommand extends Command {

    /**
     * The console command name.
     *
     * @var string
     */
    protected $signature = 'scaffold:auth';

    /**
     * The console command description.
     *
     * @var string
     */
    protected $description = "Add authentication scaffolding for the framework";

    /**
     * Execute the console command.
     *
     * @return void
     */
    public function handle()
    {
        $files = new Filesystem;

        $files->copy(__DIR__.'/stubs/scaffold/Http/Controllers/HomeController.php', app_path('Http/Controllers/HomeController.php'));
        $files->copyDirectory(__DIR__.'/stubs/scaffold/Http/Controllers/Auth', app_path('Http/Controllers/Auth'));
        $files->copy(__DIR__.'/stubs/scaffold/Http/routes.php', app_path('Http/routes.php'));

        $files->copy(__DIR__.'/stubs/scaffold/Providers/AppServiceProvider.php', app_path('Providers/AppServiceProvider.php'));

        $files->copyDirectory(__DIR__.'/stubs/scaffold/resources/views', base_path('resources/views'));

        $this->info('Authentication scaffolding complete!');
    }

}


Prolific French Artist, Nathalie Lete, shares her inspirations with N2. After meeting in paris, Nathalie and the Amaddeo family decided to collaborate. Discover three adorable cat couples created by Nathalie with highly recognisable drawing technique, inspiring a collection for N2.
Materials: Gold plated brass (14k), print, beads, resin and hand-painted enamel. Nickel free.


text:
/**
 * Bean Validation TCK
 *
 * License: Apache License, Version 2.0
 * See the license.txt file in the root directory or <http://www.apache.org/licenses/LICENSE-2.0>.
 */
package org.hibernate.beanvalidation.tck.tests.constraints.invalidconstraintdefinitions;

import static java.lang.annotation.ElementType.METHOD;
import static java.lang.annotation.RetentionPolicy.RUNTIME;

import java.lang.annotation.Documented;
import java.lang.annotation.Retention;
import java.lang.annotation.Target;

import javax.validation.Constraint;
import javax.validation.ConstraintValidator;
import javax.validation.ConstraintValidatorContext;
import javax.validation.Payload;
import javax.validation.constraintvalidation.SupportedValidationTarget;
import javax.validation.constraintvalidation.ValidationTarget;

/**
 * @author Gunnar Morling
 */
@Documented
@Constraint(validatedBy = {
		ConstraintWithTwoCrossParameterValidators.Validator.class,
		ConstraintWithTwoCrossParameterValidators.AnotherValidator.class
})
@Target({ METHOD })
@Retention(RUNTIME)
public @interface ConstraintWithTwoCrossParameterValidators {
	String message() default "default message";

	Class<?>[] groups() default { };

	Class<? extends Payload>[] payload() default { };

	@SupportedValidationTarget(value = ValidationTarget.PARAMETERS)
	public static class Validator
			implements ConstraintValidator<ConstraintWithTwoCrossParameterValidators, Object[]> {

		@Override
		public boolean isValid(Object[] parameters, ConstraintValidatorContext constraintValidatorContext) {
			return false;
		}
	}

	@SupportedValidationTarget(value = ValidationTarget.PARAMETERS)
	public static class AnotherValidator
			implements ConstraintValidator<ConstraintWithTwoCrossParameterValidators, Object[]> {

		@Override
		public boolean isValid(Object[] parameters, ConstraintValidatorContext constraintValidatorContext) {
			return false;
		}
	}
}


Snow storms will make you change your plans.
Using a CARES on the plane is so much better than taking on a car seat.
Electronics and plane trips do not mix.
Being without electronics opens up your day for other activities.
We need one more time to play in the WV snow.


text:
Catalog > Photo & Video > Lighting > Lighting, Logistics, And Strategies For A Life In Photography > Gear Overview
There's, you know,(sighs) there's no way to get around the fact, that you need the gear, right? This was, I was at the Rio Olympics, last August, there's my bed in my hotel room, okay, early in the morning and sorting out what I needed for that day, okay, it's a lot of stuff, you know, this was an extraordinary kind of an event, the Olympics is the Olympics, you know, thank God they only come around every four years, 'cause it really beats up your body as a photographer. I've had a relationship with the Nikon company for many years, you know, I'm very happy of that, I bought my first Nikon camera in 1973. There's our equipment, that's my savings account, (laughs) I wish I had a savings account too, but this is basically my savings account, okay, there's the studio truck, we go on location, VAL, that's some of the T-shirts, that we wear on location, anybody know what a VAL stands for? Voice Activated Lightstand. Voice Activated Lightstand, so that's Callie up there in the studio, Su...
burban, this, we're going to have as a record of this class, basically these next few images are stuff, that we use and we will use on location and you'll have the benefit of all of this kind of downloaded for you in a PDF kind of deal, I think. So yeah, the speedlights we'll be using, we use MaHa chargers and PowerEx batteries, they're very efficient, we use a whole variety of different light shapers, grip and accessories, I use name-brand stuff, you know, like that's a Gitzo tripod back in there some place, I, you know, if you, you know, things like that stay with you, they won't fail on lo, I mean, you know, trust me, there's technical problems galore, when you get on assignment, but I give myself my best fighting chance and I use name-brand stuff like this, okay, so they wanted a shot and this was, I was very blessed last year, because Donna Collin came out with a whole bunch of new gear, so they wanted some extravaganza kind of done with the new speedlights, so I suggested instead of getting like, you know, a hipster or a ballerina or something, I said, let's do something a little different, why don't we get a barber shop quartet and these guys were lovely guys, wonderful, wonderful, a lot of fun and this is the Oakland Paramount Theater and it's an art deco jewel and it's big, okay and it's all done with speedlights, so they wanted me to sort of throw on into deep left field, so this is 19 speedlights, part of them are radio controlled, part of them are line of sight, so they were absolutely wonderful gentlemen to work with, they were funny and patient, oh my God, talk about patience, 'cause this was one of those things, where it was not a crescendo of activity, that occurred in 10 minutes, this was a day on location and they luckily had a green room, that was comfortable, get 'em off the set, relax, make sure they're taken care of, make sure they have lunch and water, your subjects are your most valuable resource, absolutely and completely, you know, you have to take care of your subject, that emotional relationship, how many folks are, I'm guilty of it, you know, who here is guilty of like diving so far into your F stops and shutter speeds back of the camera, that you forget there's a human being out there and you become mute, you become this little robot behind the camera and you're like, oh God, and then of course, guilty, right, LCD, like you shoot a picture of somebody, you shoot a picture of Bob right here and I look at my LCD, I'm like, oh, yeah, (laughs) you know, that don't make Bob feel good, you know, you know, (audience laughing) you know, Bob's like, "What, did I do something wrong? "Oh God, you know, I look," 'cause you're right there, you're connected to the LCD, the LCD is not an LCD, it's crack cocaine, (audience laughing) okay, 'cause once you start looking at your LCD, you can't stop and you interrupt the flow of a shoot, so get it right and then hit it hard, okay, shoot five, 10, 15, 20 frames, bang, bang, bang, get somebody in a rhythm and talk to them, encourage them, make 'em feel like they're the most beautiful person in the world and you are emotionally connected to them right at this moment and that, you have to, that, I have another kind of set of slides downstream, I'll show you tomorrow, our responsibility as photographers is to find the beauty in everyone, you know, so I once proposed to Sports Illustrated to do the 50 Most Beautiful Things in Sports on a Polaroid 20 by 24 and they actually went for it, provided Polaroid put up the money and I had Polaroid money and then it went to the CEO of Polaroid and he said no, so the whole thing went to hell in a hand basket, but I had the idea across, through the gateway and you know, you think, oh yeah, 50 Most Beautiful Things in Sports, oh, maybe one of those beautiful tennis ladies, you know, like elegant, no, I had idea, you know, one of the 50 Most Beautiful Things in Sports, one of them was Don Zimmer's head, that old bald guy, who was the you know, guru of baseball, you know and he was like, he had a, he was basically Mr. Potato Head, you know, basically, you know, but you loved it, because there was so much character and beauty and the lines were hard won, that's your celebration right there of the life that someone's lived and that's very important, so always remember, just don't, you know, you know, if things aren't going well on the set and they will not go well today periodically, they'll blink, oh, you know, I'll be like oh, you know, project confidence, project serenity, okay, project a feeling towards your subject like you are doing amazing, the problems that we have to solve here, they're my problems, trust me, oh gosh, you know, but you know, hang in there with me, I'm a trained professional, this is gonna be okay eventually, you know, you have to build the confidence of your subject, if you're confident, if your subject loses confidence in you, you're cooked, you're toast, it's over, you know, so take care of them at the camera. Yeah, rough approximation, there's my four guys, okay, live with an umbrella and a couple of skips off the floor, this near term lighting is fired by line of sight, so I have my line of sight commander on a cord up in here, firing here, these near terms are line of sight, everything in the background is radio controlled and it actually worked pretty well, those lights up in here, like none of this is lit, these walls are not lit, why would you do that? This unbelievably beautiful theater and you don't light the walls? Hello, you know, the ceiling was not lit, they had these lights over here, but you so you know, I have lights up in here, that are firing off the ceiling, these are my flashes, the blue lights, these are natural light from the theater, all these wing lights back in here, the background lights back in here, all my stuff, you know, and it actually worked pretty well, we really kind of hung it out there to see how well the radios would work and it worked quite well, so I was happy with that. Yeah, I had a question more about your team and how you initially started building your team, when you first hired your first assistant? First hires, yes, well, Lyn, believe it or not, who has been with me all these years answered an ad in her local town newspaper, Busy photographer seeks part-time help, 20 hours a week, flexibly arranged, I remember the, and I think Lyn is the kind of person, who becomes so indispensable so quickly, I think she worked 20 hours like one week in the early '90s, you know and after that, it just steamrollered forward and became a full-time job and much more than full-time, I mean, she is, literally she's the heart and soul of so much that we do at the studio and that was a dicey thing for me to do back then, because I was still primarily an editorial photographer, I was a one-man band, I had moved out of New York City, I had left any assistants, I had no assistant at that point, closed down my studio in New York, moved to the suburbs, we were about to, thinking about having our second child and if you know anything about New York, two children in New York City is a very expensive proposition, so we migrated northward, which is a classic trend, you know and then I was working heavy for the National Geographic and you know, younger people have a hard time getting their heads around this, but when I would go to Africa, say for the Geographic or some place like that, no cellphone, no computer, no FaceTime, nothing, zero, no email, nothing, you know, I was gone and I was working in the Interior at that point of Tanzania in a little village called Dodoma and you know, you're just gone, you know, at that point and so nobody was answering the phones, nobody was selling stock, nobody was generating invoices or anything at all, you know, so I realized I needed somebody to keep the lights on, you know, at least part-time and so that started it and then started to work again with full-time assistance, I've probably had, I dunno, maybe a dozen full-time assistants over the course of my career, you know, Callie, as I say, has been with us for seven years and it's actually a little bit of a mentoring program, 'cause our previous two assistants have gone on to become successful photographers, John left the studio and he's now a staff photographer at a very powerful, kind of small, but powerful company in New York City, that generates social media content for Fortune 500 companies, 'cause you know, the big companies, you know, they don't know how to do social media, it's like, "Buy our product, it's really swell," you know and so they employ younger, hipper companies to translate the language of social media for them, so John's full-time and he's shooting video and stills and he's making a good salary, he's fully benefited, he's got insurance and all that sort of stuff, it's really a job as a photographer, Drew Gurian, who was our full-time assistant for quite a number of years has gone on to be a very successful rock and roll photographer in New York City and he's hanging out there more precariously, he does not have a job, he's a freelancer, just like I am, you know, and he's working, you know, for magazines, Red Bull and places like that and he's doing quite well, so it is kind of a graduation, that we, you know, kind of put folks through, Lyn and I have seen many a young person off, you know, and then they never call, they never write, it's terrible, it's last... but yeah, so... so it's a responsibility, you know, I have a payroll. So, that's the, as I'll say tomorrow, there's actually a slide that says this, the unromantic part about photography is that you wake up in the morning and you have to figure out a way to turn your time and pictures into money, that's part of the equation, you know and it's not that wonderful thing of wandering the streets of Morocco in the late light, you know, it's hardcore, you know, ever wonder about this? The fact of being a photographer and running a photographic business, more accurate, the fact of running a photographic business, occasionally, maybe even more than occasionally, prevents me from being a photographer, 'cause instead of going out and maybe generating an image, I gotta hunker down on email, I gotta write a proposal, I gotta write a blog, I gotta do an Instagram, I gotta you know, it is full fledged across the board just, it's a 24/7 job, I, you know, I'm not bragging or anything like that, but I work real, real hard, you know. Victoria, did you have a question? I do, it was about lighting or timing actually with your lighting, you said it took five hours for that one setup, that you had for that one photo, are you usually generally offering one photo from these big shoots, or is it like, are you doing a bunch of different lighting per day, or is it, I mean, obviously it's situational, but are you, how much time are you allowing yourself, you know, to have multiple lighting situations for you know, a single shoot? Good question, it is about the nature of the day, in this situation, I was controlling everything, it was my budget, we had you know, we had the talent and we had the bar, we had a certain prescribed amount of time, kind of similar to what we're doing today, you know, but I've also done catalogs like for golf attire, where I've done literally 15, 16 setups in a day, you know, and those are brutal, absolutely brutal, you're out there, you're pushing on high rollers, you're pushing a 12-foot silk around a golf course, you know in just awful weather, 'cause those catalogs, I mean, there's no more romance associated with them, you're not waiting by poolside with a drink with an umbrella in it, you know and you know, waiting to see how the golden light develops, you're working your butt off right through the worst light of the day, so you're silking and you're moving and you're shooting and shooting and shooting and at the end of the day, you really do feel like you need to take a shower, 'cause you just like look at yourself and say, what have I done? I sold my soul today, I put a price on my soul today and the price was for a catalog, I don't know, maybe 3,000 bucks a day, something like that and I needed to do that, because I needed to keep my studio alive, was it fun? No.


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Non-Taxation of McDonald's: Illegal State Aid or Valid Loophole?
© Anthony92931
Short URL: http://kctl.uk/cS
İnayet Aydeniz Baytaş (Regular Writer)
İnayet is currently working as a Legal Assistant at Money Global finance company. She has recently completed her LLM programme at Durham University. She is originally from Turkey, and was registered with the Istanbul Bar Association in 2016. Her main areas of interest are competition law, investment law and arbitration. Outside the law, İnayet enjoys playing tennis, wind surfing, travelling and cycling.
Published 12:00, 6 November 2018
The McDonald's case shows that state aid challenges won't always work where multinationals end up paying tax nowhere - no matter how distasteful the Commission may find this.
Catherine Robins
A recent decision from the European Commission (EC) demonstrates its struggles with the application of the European state aid rules when it is faced with international mismatches between two different countries' tax laws. On 3 December 2015, the EC opened a formal probe into Luxembourg's taxation of fast-food titan McDonald's. According to the press release, the EC investigated whether McDonald's had received advantageous taxation treatment through the misapplication of a 'Double Taxation Treaty' between Luxemburg and the US.
Following an in-depth investigation, on 19 September 2018 the EC concluded that the non-taxation of certain McDonald's profits in Luxembourg resulted from a mismatch between Luxembourg and US tax laws, and so did not breach EU state aid rules. However, the EC warned the Luxembourg Government to take legislative steps to address the issue of 'double non-taxation' – whereby profits of companies like McDonald's are not taxed in either states party to a Double Taxation Treaty – in the future.
The McDonald's case is not a novelty in the field of state aid rules. The EC has investigated similar tax arrangements of Amazon and Fiat in Luxembourg, Starbucks in the Netherlands and Apple in Ireland. In each of these cases, the basis of the investigation was the potential misapplication of the EU's 'arm's length principle' through advance pricing arrangements (APAs). Behind these investigations, the EC was aiming to ensure a fair marketplace for corporations in the EU and to avoid the creation of international tax havens.
However, the McDonald's case is different from these other investigations mentioned above. This article will outline the important role fair taxation plays in competition law and the principles of EU state aid rules, before examining the McDonald's case itself in the light of criteria of 'selectivity' and 'advantage'; it will then analyse the implications of the EC's decision for EU State aid rules.
The Role of Competition Law
Advancing the integration of the Single Market is a fundamental goal for the EC. One of the most important initiatives for achieving this goal is enhancing tax transparency and ensuring a fair tax burden for all countries. Thus, the EU's state aid regime is designed to protect the integrity of the European internal market against Member State intervention by implementing measures favouring certain undertakings or goods. Such Member State interventions can include the granting of tax advantages or subsidies – collectively, they are referred to as 'state aid'.
In cases concerning state aid, the EC investigates whether tax measures can affect the ability of other corporations to compete in a Member State or affect intra-state trade. For instance, if a multinational company is granted undue tax benefits by a Member State, such that it shifts its profits to that country in order to reduce the tax burden, this practice would grant the company an unfair competitive advantage over other companies which pay their taxes on their actual profits.
The interaction between the EU's competition and tax policy is a vital one. As Commissioner Algirdas Šemeta described in a speech in 2014:
EU tax and competition policy really complement each [other] in pursuing a common objective. Both work to ensure a level playing field for countries and for companies, and to remove distortions in our Single Market.
Companies or states who are under investigation in state aid cases often try to defend themselves against allegations of receiving or granting selective tax advantages by asserting that a ruling against them would constitute a threat to future foreign investors and job creation. The strength of this argument is debatable: Member States can attract multinational companies by creating fair and undistorted competition in the market without acting as tax havens. All market players – whether large or small, local or global – want to compete under unfettered market conditions by trusting the State to avoid granting any special tax measures to certain undertakings.
Background of EU State Aid Rules
Member States have the sovereignty to set their own tax codes and laws, subject to Article 107 of the Treaty on the Functioning of the European Union (TFEU)'s prohibition on unlawful state aid. Thus, any tax regimes which confer a selective tax advantage to specific companies and distort competition within the Single Market are a breach of the TFEU.
Article 107 of the TFEU provides a four-prong test to determine whether a measure (whether it be a tax measure or otherwise) constitutes illegal state aid.
First, the aid must be selective and confer an advantage on the recipient, such as relief of tax burdens.
Second, the advantage must be given by a state or through state resources.
Third, the advantage must be capable of affecting trade between the Member States, regardless of the size of the aid, the market share of the recipient, or whether the recipient exports .
Finally, the advantage must be liable to distort or threaten competition by favouring certain undertakings or the production of certain goods.
It is worth noting, however, that even if these four criteria are met, a measure may be justified by relying on limited grounds listed in the TFEU or by reference to the nature or general scheme of the tax system.
The criteria of 'advantage' and 'selectivity' are typically the most important elements in examining whether a tax measure infringes state aid rules.
These two conditions are cumulative and require separate analysis; as stated in Commission v MOL [2015]:
the requirement as to selectivity under Article 107(1) TFEU must be clearly distinguished from the concomitant detection of an economic advantage.
Hence, an advantage conferred to the recipient would not constitute illegal state aid per se.
The 'advantage' criterion is met when a tax measure favours certain undertakings in comparison with other undertakings which are in a legally and factually comparable situation. The challenge of this condition lies in describing 'a legal and factual comparable situation' and in distinguishing the advantaged recipient from others.
A tax measure is 'selective' if it deviates from the 'common tax system' applied by a Member State. Hence, the EC will first identify what the common tax system applied by a Member State is. The process by which this is done has been the subject of recent debate:
the narrow approach holds that the 'common tax system' is a domestic tax system, and deviation from the domestic general system may be enough to constitute selectivity;
by contrast, the broad approach views the 'common tax system' as also encompassing international tax rules; selectivity might therefore also arise from deviations from both domestic and international rules.
Advocates of the narrow approach claim that adopting a broad understanding of selectivity undermines Member States' sovereignty to determine their own tax rules and that it is vague which international tax standards apply. Yet, at the same time, supporters of the broad approach claim that the narrow definition might unnecessarily justify illegal state aid and damage fair taxation. In the Starbucks case, the EC adopted the broad approach by treating the EU's 'arm's-length standard' as part of the common tax system ahead of a Dutch tax ruling. Because of this, the EC could hold that the Netherlands had granted selective tax advantages to Starbucks as a result of a breach of the arm's length principle.
What is Double Taxation and Double Non-Taxation?
Double taxation occurs when comparable taxes are imposed by two (or more) States on the same taxpayer in respect of the same income in the same periods. This occurs most often in relation to the cross-border activities of multi-national countries.
Businesses invariably want to avoid paying tax in the country of residence and then paying tax again in the country in which the gain was made: such double taxation can harm the international exchange of goods and services and cross-border movements of capital, technology and persons.
There are a number of ways to avoid double taxation; entering into a bilateral double taxation treaty is one of them. Such treaties usually prescribe that businesses must pay tax in their country of residence, and grant exemptions from paying tax to those same companies in the country in which the gain arises. Double non-taxation refers to instances where – because of the gaps in the tax systems of the parties to the treaty – tax is not being paid in either state.
The McDonald's Case
McDonald's Europe Franchising (hereafter 'the Company') is a subsidiary of McDonald's Corporation. The company is based in the US and is tax resident in Luxembourg. The firm has two branches: one in the US and the other in Switzerland. Royalty payments which the Company receives from franchisees operating McDonald's fast food outlets in Europe, Ukraine and Russia flow from Luxembourg to the US branch of the company.
In March 2009, the Luxembourg authorities issued a tax ruling holding that the Company did not need to pay corporate tax in Luxembourg, because the profits would be subject to American tax rules under the US-Luxembourg Double Taxation Treaty. According to the ruling, this conclusion was subject to the Company proving that the royalties transferred to the US branch were subject to taxation in the US.
However, shortly after this judgment the Luxembourg authorities re-examined the 'permanent establishment' provision in the US-Luxembourg Double Taxation Treaty and issued another tax ruling. In this ruling, it concluded that, because the US branch was a 'permanent establishment' under Luxembourg law, the Company was no longer required to prove that the royalty income was subject to taxation in the US.
The result of this second ruling was stark: under US law, the US branch was not considered a 'permanent establishment', such that its profits were not subject to taxation in the US.
As a result, the Company had paid no corporate tax on the royalties it was receiving in Luxembourg since 2009. Meanwhile, these royalties were being directed internally to the US branch, where the profits were not due to be taxed either. In other words, thanks to a discrepancy between US and Luxembourg tax law, McDonald's had avoided paying tax in both jurisdictions since 2009.
Clearly, by virtue of this, McDonald's was receiving an advantage over its rivals. The question thus arose: was the double non-taxation of McDonald's profits illegal state aid under the TFEU?
The European Commission's Assessment
Presenting the EC's decision, Commissioner Margrethe Vestager that:
the purpose of Double Taxation treaties between countries is to avoid double taxation – not to justify double non-taxation.
However, despite this, the EC found that the non-taxation resulted directly from a mismatch between Luxembourg and US tax laws, rather than from Luxembourg having granted a selective economic advantage to McDonald's in breach of EU state aid rules. Luxemburg's tax rulings did not give McDonald's more favourable treatment than other companies in the same 'factual and legal' situation. Therefore, the EC concluded that Luxembourg did not breach EU state aid rules by not taxing certain profits of McDonald's.
In this respect, the EC's decision is an important one. Indeed, while it accepted that – as Commissioner Vestager herself notes – 'the fact… that McDonald's did not pay any taxes in Luxembourg on these profits… is not how it should be from a tax fairness point of view', it also held true to the four-steps set out in Article 107 of the TFEU rather than concluding outright that double non-taxation does not amount to illegal state aid per se. This is significant: from now on, even if a company does not pay taxes in some jurisdictions – which is widely accepted to be immoral – the EC will nonetheless follow the four Article 107 steps to decide whether non-taxation leads to illegal selective tax treatment.
While there are arguments that the Double Taxation Treaty was designed to eliminate double taxation, in this case there was no double taxation; further, the Luxembourg authorities were aware that the US branch of the company was not paying tax in the US. Therefore, opponents of the EC decision claim that the non-taxation of McDonald's profits does grant a selective advantage to McDonald's.
However, the awareness of non-taxation may not be sufficient to change US and Luxemburg tax laws. It might be suggested that it would be beyond the EC's competence to overrule Luxemburg's tax authorities' interpretation of the permanent establishment provision. Moreover, if the EU did not stick to the Double Taxation Treaty, and instead tried to determine what the definition of the permanent establishment should be, the EC would be creating rules of international tax law, which it is incapable of doing. In the same vein, the EC concluded that McDonald's above activity was 'in line with national tax laws and the Luxembourg-United States Double Taxation Treaty'.
On 21 March 2018, the EC – in an attempt to adapt international corporate tax rules to the modern global economy – proposed new rules to regulate the taxation of digital companies which are not physically present in a country. Instead, the EC aims to tax digital media companies based on where they generate revenue, rather than where they have their regional headquarters, the latter often being in countries which grant 'sweetheart' deals, such as Ireland and Luxembourg. If these tax reforms are backed by the European Parliament and the 28 EU Members – though this would be difficult – the debate over the meaning of 'permanent establishment' will end for undertakings providing digital services.
As discussed above, European state aid rules are 'bound hand and foot' by the mismatches of two domestic laws. McDonald's Europe Franchising has paid no corporate tax since 2009 despite receiving hundreds of millions of euros in royalty payments – in excess of €250 million in 2013 – from across Europe and Russia. However, this does not mean that state aid rules are useless or impractical. The EC investigation in this case put pressure on the Luxemburg government to amend their tax code in order to prevent such double non-taxation in the future. Consequently, on 19 June 2018, Luxemburg drafted an amendment to tighten the conditions when determining whether there is 'permanent establishment'. This proposal is currently being discussed by the Luxembourg Parliament.
As such, it is clear that EU state aid rules can be used to strike a balance between sovereignty in relation to direct taxation and the EU's interest in preventing tax avoidance.
It is submitted that the crux of state aid cases is to determine whether a broad understanding of selectivity, in which international tax rules form part of the common tax regime, or the narrow scope of reference system, in which only domestic tax rules are part of the common regime, should be adopted.
In order to decide what the reference regime is, international tax rules should be clear. For example, it is ambiguous whether the OECD Model Tax Convention or the Transfer Pricing Guidelines create international standards of tax law. In addition, businesses want clarity on principles of tax rules and international standards to support jobs and prosperity.
The establishment of principles of tax rules could be achieved through national legislative action, rather than directly by the EC, by interpreting tax rules or imposing new legal standards. Consequently, the EC's conclusion on the McDonald's case may be entirely compatible with the EC's competence in the area.
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Tagged: European Union, International Law, Tax Law
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