The appeals from reassessments made under the Income Tax Act for the 1998, 1999, 2000, 2001 and 2002 taxation years, notices of which are dated May 3, 2005, are allowed and the reassessments are referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that, in computing income, the Appellant is entitled to deduct as interest all quarterly amounts paid to Bank Brussels Lambert from March 1998 to September 2002 inclusive.
The appeals from reassessments made under the Act for the 1998, 1999, 2000, 2001 and 2002 taxation years, notices of which are dated April 28, 2005, are allowed and the reassessments are referred back to the Minister for reconsideration and reassessment, but only for the purpose of cancelling the penalties assessed under subsection 227(8) of the Act.
Signed at Ottawa, Canada, this 29th day of April, 2009.
 The Appellant was incorporated in Canada in 1986 and has been resident in Canada at all relevant times. The Appellant is part of a group of construction entities which are all controlled, directly or indirectly, by Heidelburger Zement ("HZ") a German publicly traded company. The taxation years under appeal are 1998, 1999, 2000, 2001 and 2002. In each of those years, the Appellant was indebted to a related Belgian corporation (a member of the HZ group) in the amount of $140,000,000 (herein sometimes referred to as the "Loan Amount"). The Loan Amount is always expressed in Canadian dollars.
 Upon the direction of the related Belgian corporation, the Appellant paid the interest ($9,800,000 per year) on the Loan Amount to an arm's length Belgian bank. The Appellant deducted such interest payments when computing income for Canadian income tax purposes. By Notices of Reassessment dated May 3, 2005, the Minister of National Revenue (the "Minister") reassessed the Appellant under Part I of the Income Tax Act (the "Act") to disallow as a deduction a portion of the amounts paid each year as interest on the Loan Amount. The portion of the amounts paid as interest which the Minister disallowed as a deduction was in the range of 71% to 90% of those total annual amounts ($9,800,000) for the five years under appeal.
 By Notices of Reassessment dated April 28, 2005, the Minister reassessed the Appellant under Part XIII of the Act for failure to withhold tax in respect of amounts paid as interest on the Loan Amount. The Minister also imposed a penalty of 10% under section 227 of the Act. In each year under appeal, the Part XIII tax was $1,470,000 and the penalty was $147,000. (In 2002, those two amounts of tax and penalty were about 24% smaller).
 When making the reassessments described in paragraphs 2 and 3 above, the Minister relied on section 16 of the Act, Part XIII of the Act, and the general anti-avoidance rule ("GAAR") in section 245 of the Act. The Appellant has appealed from those reassessments. At the commencement of the hearing of these appeals, the parties filed as Exhibit 1 a Statement of Agreed Facts ("SAF") comprising 48 paragraphs. There are seven different corporations within the HZ group referred to in the SAF. The relationships and transactions among members of the HZ group are somewhat complicated, and so I shall set out the complete terms of the SAF.
1. The Appellant was incorporated on September 26, 1986 as "CBR Cement Canada Limited" and is a resident in Canada.
2. On October 1, 1998 the Appellant changed its name to "Lehigh Portland Cement Limited". The Appellant changed to its current name, "Lehigh Cement Limited", on February 1, 2002.
3. The Appellant was in the business of manufacturing cement as well as aggregates, ready-mix and other building materials.
4. Heidelburger Zemeni("HZ") was a German publicly traded company and served as the parent company for the CBR group of construction entities.
5. The direct shareholder of the Appellant was Sodexcar SA, a Belgian company, Sodexcar SA was a wholly owned subsidiary of another Belgian company, Cimenterics CBR SA ("CBR SA").
6. CBR Materials Corporation of Canada Limited ("Materials") was incorporated on September 26, 1986. It was a resident of Canada and was affiliated with the Appellant.
7. CBR International Services SA ("CBR IS") was a company located in Belgium and was ultimately owned by HZ. CBE IS was a Belgian Coordination Centre and was acting as the treasury centre for the corporations within the HZ group.
9. The borrowing was made for the purpose of acquiring certain cement, aggregate and construction business assets of Genstar Corporation located in Canada.
10. Included in that credit facility was a "Term Credit Facility" under which the Appellant received a loan of $140,000,000 bearing a fluctuating rate of interest (the "Loan").
11. Pursuant to an agreement called the "Participation Agreement", dated December 11, 1986, the right to reserve principal and interest on the Loan was assigned to Materials in consideration of the payment of $140,000,000. the principal owing under the Loan at that time was $140,000,000.
12. The sum of $140,000,000 was acquired by Materials by issuing 140,000 preferred shares of Materials to CBR SA on December 12, 1986. The source of the funds for that purchase was a loan from CBR IS the CBR group's treasury centre. The preferred shares were subsequently transferred to Industriele Deelneming Maatschappij (Idema) B.V. ("Idema B.V."), a direct subsidiary of CBR SA, on September 27, 1993.
13. By letter agreement dated September 29, 1987, between Materials and the Appellant, the maturity date under the Loan was extended, such that it would only mature upon demand.
14. After 1987, the only amounts owing under the 1986 Credit Agreement was the amount of $140,000,000 owed to Materials.
15. Pursuant to an "Assignment", dated September 15, 1994, and in consideration of the payment of $140,000,000, Materials sold, transferred and assigned to CBR IS the right to receive principal and interest under the Loan.
c) Idema B.V. was liquidated by CBR SA.
d) CBR SA used the $140,000,000 received on the liquidation to repay the loan it received from CBR IS in 1986.
17. Following these transactions, Materials and the Appellant amalgamated to form a new corporation which continued to be called CBR Cement Canada Limited (now the Appellant).
18. Pursuant to the same Assignment, the repayment provisions relating to the Loan were amended such that the loan was to be repaid in full on September 15, 2009, subject to an option given to the Appellant to extend the term for successive periods of five years.
19. The $140,000,000 owed by the Appellant to CBR IS remained outstanding in it entirety as of August 27, 1997.
20. Prior to August 1997, the Appellant withheld and remitted 15% tax on interest paid to CBR IS pursuant to s. 212(1)(b) of the Income Tax Act (the "Act"). By as early as January 1997, the Appellant began reviewing the Loan to determine if it could be restructured in order to avoid such tax. To do so would be an efficient way of repatriating funds to CBR IS because the interest would then be deductible in Canada and not subject to withholding tax.
21. At the time of implementation of the new structure, the interest rates were at some of their lowest in history in Canada but were expected to increase in the future.
22. Prior to the Amendment and Restatement of Credit Agreement, the interest rate under the Loan was at the Canadian Prime rate which, at the time was 4.75%. The Canadian Prime rate was expected to increase to 5%.
23. By an agreement title "Amendment and restatement of Credit Agreement in the Form of a Subordinated Note Due September 15, 2009", the 1986 Credit Agreement which included the Loan, was restated in the form of a subordinated note (the "Note").
24. Pursuant to the terms of the Note, the Appellant was not obligated under any circumstances (other than an event of default) to pay more than 25% of the principal amount of the Note within five years from the date of the issue of the Note.
25. The terms of the Note entitled the holder of the Note (in this case, CBR IS) to sell all or any portion of the rights to receive interest payments under it (sic) to a third party (individually, an "Interest Payment"). The ownership interest in an Interest Payment was evidenced by an "Interest Payment Receipt".
a) The interest rate changed from the Canadian Prime Rate to a fixed rate of 7% for the first five years.
to add any withholding tax payable to the interest payments such that the net interest payment to the holder of the Note would be unaffected.
27. In terms of the existing loan structure, the low interest rate was seen by the CBR group as a factor which diminished the benefits to the group. This was because there was a smaller interest deduction in Canada and less funds being repatriated to Belgium.
28. A new loan structure that would provide for a higher interest rate charged to the Appellant and eliminate the Canadian withholding tax interest payments was seen by the CBR group as an efficient method of repatriating Canadian profits to Belgium.
29. The CBR group assumed that the arm's length interest rate in Canada for a five-year period for such a note was 7%. This was confirmed as being reasonable through discussions with the group's bankers in the United States.
30. In issuing the reassessments, the Canada Revenue Agency assumed that 7% was the market rate of interest for a debt of this nature.
31. Based on an analysis in the spring of 1997, the savings that would be generated by the new loan structure over the life of the Loan were estimated to be approximately $11 million. Depending on the interest rate used, the net present value of the savings was estimated at $13.1 to $19.7 million for the CBR group of companies. Those savings were to be accomplished chiefly by avoiding the Part XIII tax in Canada.
32. On August 28, 1997, CBR IS sold to Bank Brussels Lambert ("BBL"), a Belgium corporation, the right to receive all interest payments on the Loan due prior to September 16, 2002 for $42,673,913.67 (the "Purchase Agreement").
33. BBL was a Belgium bank which dealt at arm's length with the Appellant.
35. After the completion of the above transactions, CBR IS continued to hold the "principal residue receipts" on the $140 million loan to the Appellant, while the Appellant made interest payments to BBL.
36. A determining factor in the decision by the BBL to become involved in this transaction was the necessity of a parent company of the Appellant to provide a Put Agreement to BBL.
37. Pursuant to a "Put Agreement" entered into on August 28, 1997, CBR SA agreed that in the event of a default under the Note, CBR SA may be required to purchases the "Interest Payments Receipts" from BBL for a defined purchase price.
38. As a further condition for acquiring the Interest payment Receipts, BBL required that CBR IS enter into a "Funding Indemnity" in favour of BBL that protected BBL from any hedging losses that could arise in the event of an early payout of interest.
39. On each interest payment date, the Appellant paid interest directly to BBL as stipulated in the Interest Payment Receipt and the Appellant deducted such interest payments in computing its income. The Appellant did not withhold Part XIII tax in respect of any of the interest payments to BBL.
40. As a result of the above described transactions, the Appellant did not access international capital markets but instead restructured an existing loan with a related corporation. No new accounts were borrowed by the Appellant.
43. From 1998 to 2002, as a result of a series of transactions, CBR IS avoided Part XIII withholding tax on the interest payments made by the Appellant on the Loan.
c) the payments made by the Appellant to BBL from 1998 to 2002.
45. Neither the Amendment and Restatement of Credit Agreement nor the Purchase Agreement were undertaken or arranged primarily for bona fide purposes other than to avoid Part XIII tax.
46. The principal purpose of the Appellant in entering into the above-described transactions was to cause the interest payments on the Loan to comply with the exempting provisions of s. 212(1)(b)(vii) of the Act.
47. The Series of Transactions resulted in a "tax benefit" as that term in defined in subsection 245(1) of the Act.
48. As a result of the facts specified in paragraph 42 of this Statement of Agreed Facts, the Series of Transactions resulted in there being an "avoidance transaction" as that term is defined in subsection 245(3) of the Act.
 There were no witnesses called to give oral testimony at the hearing of these appeals. Exhibit 2 is a Joint Book of Documents comprising 30 documents under separate numbered tabs. Exhibit 3 is a binder of the Appellant's Key Documents comprising five documents each of which is contained in Exhibit 2. Exhibits 4, 5, 6 and 7 are read-ins from portions of the Examinations for Discovery of both parties, plus a letter from the Appellant's counsel with respect to certain undertakings.
 In argument, counsel for the Appellant stated that the first 19 paragraphs of the SAF were simply background. That statement may very well be true but background facts are relevant. Those first 19 paragraphs describe certain transactions from September 1986 to August 1997 involving about six corporate members of the HZ group. At the risk of error in summarizing facts to which the Parties have agreed, I propose to condense the most relevant transactions described in those first 19 paragraphs using the abbreviated corporate names already identified in the SAF.
A. In October 1986, the Appellant borrowed $140,000,000 (the "Loan Amount") from a group of Canadian banks. The Loan Amount was used by the Appellant to acquire business assets. The borrowing/lending transaction between the Appellant and the group of banks is herein referred to as the "Loan".
B. In December 1986, Materials (within the HZ group) purchased the Loan receivable from the group of Canadian banks upon the payment of an amount equal to the Loan Amount.
C. Within the HZ group, CBR IS is the treasury centre. Materials acquired the funds to purchase the Loan receivable by issuing preferred shares for $140,000,000 to CBR SA (within the HZ group) which, in turn, had borrowed that amount from CBR IS.
D. In September 1987, Materials and the Appellant agreed to change the maturity date under the loan so that it would mature only on demand.
E. In September 1994, Materials sold the Loan receivable to CBR IS for $140,000,000.
(i) CBR IS paid the basic amount of $140 million to Materials in order to purchase the Loan receivable.
(ii) Materials used the basic amount to redeem the preferred shares referred to in C above.
(iii) CBR SA used the basic amount received upon the redemption of the preferred shares to repay the amount borrowed from CBR IS in December 1986 referred to in B and C above.
G. After the transactions in E and F above, Materials and the Appellant amalgamated; and the new amalgamated corporation continued as the Appellant.
H. When the Loan receivable was sold by Materials to CBR IS in September 1994 (see E above), the repayment provisions were amended so that the Loan Amount was to be repaid in full on September 15, 2009 subject to the Appellant's option to extend the term for successive periods of five years.
I. On August 27, 1997, the Appellant owed the full Loan Amount to CBR IS.
 Paragraph 6 above contains my summary of the first 19 paragraphs of the SAF. The remaining paragraphs of the SAF contain the more relevant facts on which the reassessments were based. It is not necessary to summarize those remaining paragraphs but I will refer to them later in these reasons.
(i) For the taxation years 1998 to 2002, do the facts and the law support the reassessments (May 3, 2005) which disallow, as a deduction in computing income, a portion of the amounts paid by the Appellant as interest with respect to the Loan Amount? These reassessments rely on paragraph 16(1)(a) of the Act. See paragraph 41 of the SAF.
(ii) For the taxation years 1998 to 2002, do the facts and the law support the reassessments (April 28, 2005) which deny to the Appellant the exemption from withholding tax otherwise permitted by subparagraph 212(1)(b)(vii) of the Act? These reassessments rely on the GAAR in section 245 of the Act. See paragraph 42 of the SAF.
 In the five taxation years under appeal, the Appellant paid quarterly amounts to Bank Brussels Lambert ("BBL") as interest with respect to the Loan Amount ($140,000,000). Those quarterly amounts are consolidated into annual payments and shown in the table below. The annual payment for 2002 is less than the prior years because there were only three quarterly amounts paid to BBL in that year. Also, in the table below are the amounts disallowed to the Appellant as deductions in computing income by the reassessments issued on May 3, 2005. And finally, in the same table is a statement of the percentage that the portion disallowed is of the total annual payment by the Appellant to BBL.
 The portion of the Appellant's annual payments to BBL disallowed as a deduction each year as shown in paragraph 9 above was determined by the Canada Revenue Agency ("CRA") based upon the transaction between CBR IS and BBL described in paragraphs 32, 33 and 34 of the SAF. In that transaction, CBR IS sold to BBL the right to receive all 20 interest amounts (payable by the Appellant) on the Loan Amount due in quarterly instalments from December 15, 1997 to September 16, 2002 inclusive. The total of those 20 quarterly instalments was $49,456,438.30. BBL paid to CBR IS in August 1997 a lump sum amount of $42,673,913.67 for the right to receive those 20 quarterly instalments.
Although the payments BBL received had the legal form of being $50 million of interest, in economic terms its true compensation is only $7 million because it had a cost of $43 million to purchase the interest coupons.
(i) BBL made a capital outlay of $43 million for the right to receive a stream of 20 quarterly payments over a five-year period.
(ii) The total of all 20 quarterly payments over that five-year period was $50 million.
(iii) Because the quarterly payments were all equal in amount, each payment contained part of the original capital outlay ($43 million) plus some interest earned on that capital outlay.
(iv) As in all amortized debt, the interest element in each successive equal payment decreased and the capital element in each successive equal payment increased.
(v) In the table in paragraph 9 above, this reassessment theory explains why the portion disallowed each year as "capital" increased from 78% in 1998 to 94% in 2002.
The letter from the CRA to the Appellant quoted above (Exhibit 2, Tab 15) contains an amortization schedule at page 18 showing how the "capital portion" of each quarterly payment was calculated. The total of the "capital portions" in the four quarterly payments in any particular year became the "portion disallowed" in the table in paragraph 9 above. Also, the total of the "capital portions" in all 20 quarterly payments was the $43 million capital outlay.
 As the table in paragraph 9 illustrates, the reassessments issued on May 3, 2005 disallowed as deductions in computing income a significant portion of the amounts paid as interest by the Appellant to BBL. Those reassessments are based on paragraph 16(1)(a) of the Act.
Certain words used in the SAF (see in particular paragraphs 35 and 39) indicate that the parties have agreed that the whole amount of each payment made by the Appellant to BBL had the character of "interest" and not "capital". In a letter to the Court, after the hearing, counsel for the Appellant conceded that any such words should not be construed as an admission by the Respondent. Such words were used in the SAF only to reflect the form of the relevant documents.
 The Amendment and Restatement of the Credit Agreement dated August 28, 1997 is Exhibit 2, Tab 1. Schedule "I" to that Agreement is the Subordinated Note due September 15, 2009. In paragraph 1(a) of the Subordinated Note, the annual interest payable on the Loan Amount is set at 7% for the period from August 28, 1997 to September 15, 2002. It is the 7% rate of interest on the Loan Amount ($140 million) which required annual interest payments of $9,800,000 and quarterly installments of $2,450,000 as seen in paragraph 34 of the SAF, and in the table in paragraph 9 above.
From those statements, I conclude that 7% was the "arm's length interest rate" and the "market rate of interest" for the principal amount and the first five years of the Subordinated Note when it was signed in August 1997.
What I am required to determine is whether each quarterly amount paid by the Appellant to BBL from December 1997 to September 2002 can reasonably be regarded as being in part interest and in part capital. This is primarily a question of fact. For the reasons that follow, I have concluded that no part of any quarterly amount paid by the Appellant to BBL can reasonably be regarded as being capital.
 Paragraph 34 of the SAF shows that the 19 quarterly amounts paid by the Appellant as borrower in the five taxation years under appeal were all equal at $2,450,000. The Subordinated Note (Exhibit 2, Tab 1, Schedule "I") states in paragraph 1(a) that interest at the rate of 7% per annum shall be paid on the Loan Amount ($140 million) for the period when those 19 quarterly amounts were paid. 7% of $140 million produces annual interest of $9,800,000 and quarterly interest of $2,450,000. Under the terms of the Subordinated Note, the Appellant as borrower was required to pay interest at the rate of 7% per annum on the Loan Amount. In the corporate mind of the Appellant, the whole of each quarterly amount ($2,450,000) was interest because it was the only way that the Appellant could discharge its obligation to pay 7% annual interest on the Loan Amount.
 Also, after September 2002 when the 20th quarterly amount had been paid by the Appellant to BBL, the Appellant still owed the whole Loan Amount ($140 million) to CBR IS as holder of the Subordinated Note. In other words, if any part of a quarterly amount could reasonably be regarded as being capital, then the Loan Amount ($140 million) would have been reduced by such capital part.
 A close look at the amortization schedule attached to the CRA letter (Exhibit 2, Tab 15, page 18) shows that the CRA was able to amortize BBL's recovery of its capital outlay ($42,673,914) only by imputing an interest rate of 4.929105% per annum to the 20 quarterly installment payments. In the corporate mind of the Appellant, an interest rate of 4.929105% was unknown. The only interest rate that the Appellant recognized was the 7% per annum which it was obliged to pay under the terms of the Subordinated Note.
 The CRA was able to impute a "capital" element to each of the 20 quarterly amounts because it looked at only the transaction between BBL and CBR IS in which BBL paid $43 million (rounded) in August 1997 for the right to receive $50 million (rounded) in quarterly installments ending in September 2002. Although the Appellant was a party to that transaction, the Appellant did not receive any part of the $43 million, and the Appellant remained obligated to pay the whole Loan Amount ($140 million) to CBR IS after September 2002.
 When the Appellant looks at the 20 quarterly amounts, it sees only 7% interest per annum because of (i) the terms of the Subordinated Note; and (ii) the whole Loan Amount ($140 million) still owing after September 2002. When BBL looks at the 20 quarterly amounts, it sees (in simplistic terms) 43/50 of each amount as a recovery of capital and 7/50 of each amount as interest. When the Minister issued the reassessments of May 3, 2005, the Minister was looking at the 20 quarterly amounts through the eyes of BBL. The Minister chose the wrong point of view because BBL is not before the Court. Only the Appellant is challenging the reassessments and it views the quarterly amounts as exclusively interest.
2. A blended payment can be described as an amount, the make-up of which is not definitely ascertainable. In other words there must be some uncertainty as to the portion of the payment that is capital and the portion that can reasonably be regarded as interest or some other type of income such as the profit on a sale transaction. However, if all the constituent elements of a payment are provided for in a contract or arrangement, and are reasonable, the payment is not a blended payment and subsection 16(1) does not apply.
Section 16 will sometimes apply in a contract of purchase and sale. If property having a fair market value of $100,000 is sold for a stated price of $120,000 payable by installments over a period of years with no provision for interest in the agreement of purchase and sale, a part of each installment payment may be regarded as consideration for the fair market value of the property (capital); and the remaining part may be regarded as interest to the vendor for the delayed payment of the fair market value.
 In the circumstances of this case, the original debt was restated to separate the principal amount from the agreed interest payments; and the right to receive the interest payments was sold in an arm's length transduction to BBL. I would have to ignore both the legal form and the economic substance of the relevant transactions in order to determine that the quarterly amounts paid by the Appellant to BBL are blended payments. I will not make that determination. The CRA created blended payments only by the use of a totally artificial interest rate of 4.929105% per annum.
 Paragraph 16(1)(a) does not apply to the quarterly amounts paid by the Appellant to BBL. The appeals from the reassessments issued on May 3, 2005 are allowed.
 Part XIII of the Act (sections 212 to 218) imposes a 25% tax on every non‑resident person who receives passive income (interest, dividend, rent, royalty, etc.) from a person resident in Canada. Under section 215, every person resident in Canada who pays passive income to a non-resident person is obliged to withhold and remit the tax payable by the non-resident. Section 215 is a necessary collection device. The Part XIII tax is thus commonly known as a withholding tax. In the tax treaties which Canada negotiates with many other countries, the 25% tax rate under Part XIII is almost always reduced to 15% or some lower rate.
 In the pleadings, the parties raised an issue as to whether the amounts paid by the Appellant as interest to BBL qualified for the exemption in subparagraph 212(1)(b)(vii). At the hearing, however, the parties were in agreement that the necessary conditions had been satisfied, and that such amounts paid to BBL did qualify for the exemption. I refer to paragraphs 24 and 39 of the SAF. In other words, if the GAAR does not apply, the amounts paid by the Appellant as interest to BBL would be free of withholding tax.
"transaction" includes an arrangement or event.
245(2) Where a transaction is an avoidance transaction, the tax consequences to a person shall be determined as is reasonable in the circumstances in order to deny a tax benefit that, but for this section, would result, directly or indirectly, from that transaction or from a series of transactions that includes that transaction.
17 The application of the GAAR involves three steps. The first step is to determine whether there is a "tax benefit" arising from a "transaction" under s. 245(1) and (2). The second step is to determine whether the transaction is an avoidance transaction under s. 245(3), in the sense of not being "arranged primarily for bona fide purposes other than to obtain the tax benefit". The third step is to determine whether the avoidance transaction is abusive under s 245(4). All three requirements must be fulfilled before the GAAR can be applied to deny a tax benefit.
The burden of proof is on the taxpayer to refute steps one and two, but the burden is on the Minister to establish step three. In this appeal, the Appellant concedes that it has received a "tax benefit" and that the relevant transactions meet the definition of "avoidance transactions" within the meaning of section 245. Therefore, the only question remaining on the GAAR issue is to determine whether the avoidance transaction was abusive under subsection 254(4).
(2) The Explanatory Notes elaborate that the GAAR is intended to apply where under a literal interpretation of the provisions of the Income Tax Act, the object and purpose of those provisions would be defeated.
(3) The Explanatory Notes specify that the application of the GAAR must be determined by reference to the facts of a particular case in the context of the scheme of the Income Tax Act.
In paragraph 49 quoted above, the "Explanatory Notes" are described in paragraph 15 of the Supreme Court reasons as notes issued by the Minister of Finance in June 1988 when introducing the legislation which became the GAAR.
 Because counsel for both parties relied heavily on the decision of the Supreme Court in Canada Trustco, I will quote those additional passages from the Supreme Court reasons which I find helpful.
57 … The central inquiry is focussed on whether the transaction was consistent with the purpose of the provisions of the Income Tax Act that are relied upon by the taxpayer, when those provisions are properly interpreted in light of their context. Abusive tax avoidance will be established if the transactions frustrate or defeat those purposes.
58 … When properly interpreted, the statutory provisions at issue in a given case may dictate that a particular tax benefit may apply only to transactions with a certain economic, commercial, family or other non-tax purpose. The absence of such considerations may then become a relevant factor towards the inference that the transactions abused the provisions at issue, but there is no golden rule in this respect.
60 However, abusive tax avoidance may be found where the relationships and transactions as expressed in the relevant documentation lack a proper basis relative to the object, spirit or purpose of the provisions that are purported to confer the tax benefit, or where they are wholly dissimilar to the relationships or transactions that are contemplated by the provisions.
In both Canada Trustco and Mathew, the taxpayers conceded that there was a "tax benefit" and an "avoidance transaction" within the meaning of section 245. Both cases proceeded to the Supreme Court on the single question of whether there had been abusive tax avoidance. In Canada Trustco, the taxpayer succeeded. In Mathew, the Minister succeeded.
The central question is, having regard to the text, context and purpose of the provisions on which the taxpayer relies, whether the transaction frustrates or defeats the object, spirit or purpose of those provisions.
 What is the text, context and purpose of subparagraph 212(1)(b)(vii) of the Act? Part XIII of the Act (sections 212 to 218) imposes a withholding tax on passive income (not derived from business or employment) paid by a person resident in Canada to a non-resident person. Section 212 is the charging section identifying the particular kinds of income to be taxed (e.g. management fee, interest, rent, royalty, dividend, trust income, etc.). Interest is taxed under paragraph 212(1)(b) but there are 12 exceptions in subparagraphs (i) to (xii) inclusive.
- the corporation is not obliged to pay more than 25% of the principal amount within 5 years from the date when the debt instrument was issued.
Counsel for the Appellant argued that the 12 subparagraphs are discrete in that each stands alone; and none of the subparagraphs informs the meaning of another. I am inclined to agree. Each subparagraph seems to provide for a particular set of circumstances.
 The text of subparagraph (vii) is clear. The parties agree that the qualifying conditions have been met, and that all amounts of interest paid by the Appellant to BBL from December 1997 to September 2002 qualify for the exemption in subparagraph (vii). The context is to tax passive income flowing from persons resident in Canada to non-resident persons. This kind of income would not be taxed under Part I of the Act; and so Part XIII creates a new tax and contains its own charging provision. I turn now to the purpose of subparagraph (vii).
The policy rationale behind the withholding tax exemption in subparagraph 212(1)(b)(vii) is to provide Canadian businesses with access to foreign capital markets for medium- and long-term debt. The withholding tax exemption is a key factor in enabling foreign lenders to make loans to Canadian businesses because, for a variety of reasons, the foreign lenders are often unable to mitigate the cost of withholding tax. Because of the long-term nature of the loans that are eligible for the subparagraph 212(1)(b)(vii) withholding tax exemption, foreign lenders often require a high level of certainty that the exemption will apply to a particular loan.
Later in the paper, the authors consider whether back-to-back loans could be used to avoid the arm's length condition.
The exception has been scrutinized with almost scientific rigour, but often without a sufficient appreciation of its fiscal policy basis. The announced purpose of subparagraph 212(1)(b)(vii) was functional to enhance the accessibility to Canadian corporate borrowers of foreign debt markets. Its enactment specifically recognized the almost contemporaneous withdrawal of foreign borrowing guidelines that in effect required Canadian corporate borrowers to exhaust available domestic capital sources before they turned to foreign markets.
This exemption was introduced as a temporary measure in 1975, to allow Canadians corporate borrowers increased access to international markets. The exemption was extended on several occasions, until it became a permanent feature of the Canadian tax system in the 1988 federal budget.
As noted earlier, withholding taxes on interest payments tend to be shifted to the borrower, thereby increasing the cost of capital. The exemption for interest payable on arm's length indebtedness provides Canadian businesses with increased access to global financial markets at competitive interest rates. The Committee supports the exemption, but has two recommended changes.
The Committee recommends that the withholding tax exemption for interest payments to arm's length non-resident lenders be extended to all indebtedness, regardless of its term.
We also recommend that the exemption be denied in circumstances involving back-to-back transactions and similar financial support arrangements in the same manner as discussed below under the thin capitalization provisions.
 Subparagraph (vii) is relatively straightforward. It is not drafted in the arcane hieroglyphics that so often decorate other parts of the Act. Left to myself, I might well have concluded that this exemption was intended to help Canadian corporations borrow from foreign arm's length lenders who would receive interest free from withholding tax. Having reviewed the articles quoted in paragraphs 37 and 38 above, I find that the purpose of subparagraph (vii) is to help Canadian corporations needing to borrow money by increasing their access to international capital markets. The cost of the withholding tax on interest paid to foreign lenders is often shifted to the Canadian borrower, thereby increasing the cost of capital. The exemption from withholding tax on arm's length borrowing from foreign lenders makes such borrowing more competitive with domestic borrowing in Canada.
 Referring to paragraph 33 above and the passage therein quoted from paragraph 49 in Canada Trustco, I ask whether the transaction between CBR IS (the holder of the subordinated note) and BBL frustrated or defeated the object, spirit or purpose of subparagraph (vii).
 The Appellant participated in only one borrowing transaction. I am referring to the loan of $140 million in October 1986 from a consortium of banks led by the Royal Bank of Canada. See paragraphs 8, 9 and 10 of the SAF. The text and context of the SAF indicate that the borrowing by the Appellant in 1986 was an arm's length transaction with the consortium of Canadian banks. That particular debtor/creditor relationship was short-lived because, in December 1986, Materials (a Canadian corporation related to the Appellant) purchased for $140 million the loan receivable held by the group of banks. Materials received indirectly from CBR IS the funds needed to purchase the loan receivable.
 Materials held the loan receivable from December 1986 to September 1994 when it was sold to CBR IS. No additional funds were needed or acquired within the HZ group to facilitate the sale of the loan receivable in September 1994 because the sale proceeds went around a corporate circle as described in paragraph 16 of the SAF and as summarized in paragraph 6 of these reasons.
 The significant restructuring of the loan and the sale of the interest receipts happened in August 1997. I will repeat selected paragraphs from the SAF.
 The Appellant never borrowed money from BBL. The Appellant was required to pay interest to BBL from December 1997 to September 2002 only because of the sale transaction between CBR IS and BBL in August 1997. Within the context of this appeal, CBR IS never borrowed money from BBL. The only money advanced by BBL was the purchase price ($42 million) paid by BBL to CBR IS for the right to receive quarterly interest payments from December 1997 to September 2002. At all relevant times from and after September 1994, CBR IS was the Appellant's creditor with respect to the $140 million principal amount.
In my opinion, the tax benefit in subparagraph (vii) of paying interest to a non‑resident person free from withholding tax applies only to the arm's length borrowing of capital from a non‑resident lender. That is the transaction "with a certain commercial purpose". In this appeal, the Appellant did not borrow any money from BBL or any other non-resident lender. The absence of a non-resident lender causes me to infer that the sale transaction between CBR IS and BBL abused subparagraph (vii).
I find that the relationship between CBR IS and BBL with respect to the sale of 20 quarterly interest amounts for $42 million; and the relationship between the Appellant and BBL with respect to the payment of those 20 quarterly interest amounts are wholly dissimilar to the arm's length borrower/lender relationship contemplated by subparagraph (vii). The sale transaction between CBR IS and BBL frustrated the object, spirit and purpose of subparagraph (vii).
 In my opinion, the Minister was justified in using the GAAR to ignore the exemption under subparagraph (vii), and to assess withholding tax under paragraph 212(1)(b).
 In argument, counsel for the Respondent abandoned the penalty assessed under subsection 227(8) of the Act for failure to withhold the Part XIII tax. Accordingly, the appeal from the reassessments based on the GAAR will have to be allowed but only for the purpose of canceling the penalty under subsection 227(8).
 After this case was heard in October 2008, the Supreme Court of Canada issued its decision in Lipson v. The Queen on January 8, 2009. Lipson is a case concerning the GAAR. The Supreme Court was divided in Lipson; one set of reasons from the majority of four judges, and two sets of reasons from the three dissenting judges. The facts in Lispon are very different from the facts in these appeals. In my opinion, the various reasons for judgment in Lipson do not qualify what the Supreme Court stated in its unanimous decision in Canada Trustco. Therefore, I did not invite further submissions from counsel on the more recent decision in Lipson. Also, counsel did not seek the opportunity to make such submissions.
 I do not recall any discussion of costs at the hearing. The Minister issued two inconsistent sets of reassessments. The reassessments of May 3, 2005 assumed that the greater part of each payment made by the Appellant to BBL was capital and not interest. The reassessments of April 28, 2005 assumed that all payments made by the Appellant to BBL were 100% interest. At the hearing, counsel for the Respondent made it clear that the reassessments were issued in the alternative, and that he could not succeed in defending both sets of reassessments.
 In the above reasons, the Appellant is successful in defeating the reassessments based on paragraph 16(1)(a); and the Minister is successful in defending the reassessments based on the GAAR, subject to the concession with respect to the penalty under subsection 227(8). I am inclined to allow no costs to either party in the judgment which is issued concurrent with these reasons. If either party wants to make submissions with respect to costs, I am willing to hear counsel in a teleconference if written notice is sent to the Court within 30 days of the decision herein.
Name: Warren J.A. Mitchell, Q.C.
In finding that the taxpayer was entitled to deduct the full amount of the interest coupon payments made by it on a periodic basis to a Belgian bank, Mogan, D.J. noted that although when the Belgian bank looked at the quarterly interest payments, it saw "43/50 of each amount as a recovery of capital and 7/50 of each amount as interest," this represented the wrong point of view. From the taxpayer's perspective, each interest coupon payment represented the payment in full of interest, given that $140,000,000 of principal remained outstanding after each interest coupon payment.


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You are here: Shop / Biking in Newport / Get Ready for the 10-Spot Ride 2023
Get Ready for the 10-Spot Ride 2023
Newport's most anticipated summer bike event is back!
Saturday, August 26, 2023, 11:00am – 4:00pm.
Ride to 10 beautiful private "Spots" around lovely Newport for live music & local food.
It's a magical combination that you simply must experience: 10 beautiful locations revealed on the morning of the ride, 10 great restaurants offering tasty bites and cool summer drinks, and 10 musicians completing the fun & festive vibe. We can't wait to reveal this year's 10 secret Spots that we have in store for you! Each "Spot" offers a beautiful garden, ambience, and personality – reflecting the host, the site, and the fare.
How it works: Each ticket-holder is assigned to a Starting Spot. On the evening before the event (Friday evening, August 25), you will receive an e-mail that reveals your assigned Starting Spot, which is where you'll arrive for Saturday morning check-in anytime after 11:00am. Additional riders that you purchase tickets for, as well as other riders by request, will be assigned to the same Starting Spot.
When you check in on Saturday morning, August 26, that's when the fun surprise of the remaining nine Spots will be revealed. You'll receive an event guide which includes a map, GPS codes, and descriptions of the 10 Spots. You'll also receive a commemorative cup and bamboo flatware for the day, to help minimize trash.
You can design and enjoy your own 10-Spot adventure
Choose your own routes and timing. From 11am to 4pm, you may visit each of the Ten Spots scattered around the city.
Tickets are limited – Reserve your Spot today!
Purchase your 10-Spot Tickets
Plan early and SAVE! Lock-in last year's ticket price now through March 1st, 2023. Early bird tickets for the 2023 10-Spot Ride are $120 if purchasing by mail or in person, or $123.60 if purchased online. After March 1st, tickets are $140 by mail or in person, or $144.20 online.
New this year: The online ticketing platform we used to use for the 10-Spot Ride charged our riders hefty handling fees on top of card processing fees. So this year we're streamlining. This year's online ticket costs reflect only card processing fees, whereas the old ticketing platform would have charged riders an additional $6-$7 per ticket.
Purchase by check: If you would like to pay the flat $140 per ticket (or $120 per early-bird ticket now through March 1st), please simply click here to complete and submit the "pay by check" registration form, and mail us a check in plenty of time or drop one off at Bike Newport headquarters at 62 Broadway.
Invite your friends and family: This is an experience you're going to want to share. You can purchase tickets for additional riders and enter their names and e-mail addresses in the registration form below. Or, you can encourage others to purchase tickets separately, and there's a corresponding box in the below form to enter the names of other riders that you would like assigned to the same starting "Spot".
All proceeds from the 10-Spot Ride support Bike Newport's mission to create the conditions that lead to more people biking more often, and to ensure that bicycling is a viable, safe, and comfortable primary choice for transportation and recreation. Lots more information at bikenewportri.org.
Glimpse photo highlights from last year's amazing 10-Spot Ride:
"6 Thumbs Up" from riders in our inaugural 10-Spot Ride in 2020:
If you cannot make the event, please consider a donation in support of bicycling education, advocacy, and community building. Thank you!
Rain date: there is no rain date for this event. If the event has to be cancelled due to weather, we will ask but not require our participants to please convert their ticket to a donation, as a tax-deductible contribution to Bike Newport. With gratitude.
About Bike Newport: Bike Newport promotes bicycling as a viable, safe, and comfortable choice for all, in the best interest of our community's health, economy, environment, and quality of life.
We offer educational programs for all ages, advocate for safer streets for all road-users, and provide access to restored bikes, donated by our supporters and refurbished by our team of bike mechanics. Our efforts to continue our work throughout the Covid-19 pandemic included the distribution of nearly 800 bicycles in our community and led to our being named the 2020 Advocacy Organization of the Year by the League of American Bicyclists.
2023 marks our second year of providing bicycle education in the Newport Public Schools, and our fourth year of providing six weeks of Summer Bike Camp to Newport Youth. If your bike needs basic help, bring it in during one of our Open Garage sessions and we'll help you make the repair, or for more involved tune-ups bring it to our expert mechanics at The Annex at 56 Broadway.
Thank you for supporting Bike Newport and our work to make it easier and safer for bicycling to be a choice – and a solution.
Purchase Your Tickets Here:
10-Spot Online Tickets
Related posts in 10-Spot Ride, Bike Newport, community, Events, Group rides, Newport

redpajama_set_name: RedPajamaCommonCrawl


Home/Best Master's Degrees FAQ/What Careers are Available with a Master's in Criminal Justice?
Law Enforcement is a career made popular by television programs and media, but what kind of jobs in law enforcement can you get with a master's in criminal justice? The diverse field includes everything from business forensics to actual crime scene investigation. Some positions can be obtained with a high school diploma and some additional training. Still others require an associate or bachelor's degree. Many exciting and lucrative positions in criminal justice require a graduate degree.
According to the website Career Profiles.info, criminology includes several different facets. For instance, a person with a graduate degree might become a criminalist. These professionals use scientific principles to analyze evidence that has been collected. They also write reports to be included in the investigations of other departments and sometimes testify in court. A criminologist studies criminal behaviors by doing research and analyzing data from populations of people to identify criminal behavior problems and possible causative factors. These are sociologists with concentrations in criminal justice. Forensic psychologists are professionals who utilize psychology to assist law enforcement in investigations. They sometimes do criminal profiling and counseling or work within the court system with juvenile victims as well as offenders. Also included in the field of criminology are penologists. These professionals may work to design rehabilitation programs for prisons and to help develop programs that will enable prisons, jails and other correction facilities to run smoother. Some penologists become administrators or policy makers at the state or federal level and some become prison wardens.
Numerous positions in the criminal justice field, such as a corrections officer or a policeman, do not require a graduate degree. These jobs are found at the local, state and federal level as community police officers and state patrolmen as well as investigators for the state bureaus of investigation and for the federal government as a CIA or FBI. To obtain an administrative position within these agencies however, applicants will be more successful if they have at least a master's in criminal justice. These professionals can become senior investigators and administrators for the Treasury Department, working as forensic accountants investigating fraud and designing secure computer systems to use in the investigation and presentation of cases.
Within the criminal justice field, there is also a need for probation and parole officers. Although entry-level and rural placements do not necessarily require graduate degrees, anyone desiring a supervisory or administrative position in these careers must have at least a master's degree in criminal justice. Judges and magistrates are careers in criminal justice that can be highly lucrative. Surprisingly, these professionals don't have to be attorneys, but most do require applicants to have advanced degrees. Along this same path are mediators and conciliators. Entry level positions require an undergraduate degree but those professionals with a master's degree earn more and have greater job security.
Criminal justice careers can be very rewarding and many positions in the field are high-paying. Although the portrayal of the careers on television is probably not accurate, there is diversity and excitement in many law enforcement jobs. As in most professions, people with the highest earning potential and job satisfaction tend to be those who have a master's in criminal justice.


If you had asked teenage Ngozi five years ago if she was a feminist, she would have vehemently denied the label. "Femi-who? Femi-what? No-o!-please I want to get married in the future and have children". I was fully convinced during my teenage years that feminists were women who had become sexually frustrated spinsters, or whose husbands had left them for much younger women, leaving them sour, bitter and thus very anti-men. Don't get me wrong, I was very much inspired by people I considered women activists, women who constantly fought for political equality in Sierra Leone, equal economic and property rights, and rallied against Female Genital Mutilation, Domestic and Sexual Violence .I was interested in Women' s Rights too, and would argue for hours on how gender roles should be examined and why women were expected to marry at a certain age and bear children, as if that was all there was to womanhood. At around the age of 16,I had started thinking very radically about my position as a young girl in what I considered (and still do) a predominantly patriarchal society where the bearers of witchcraft, evil and juju were mostly always characterized as women and unmarried middle-aged women were considered failures of true womanhood. So yes, 16-year-old Ngozi was passionate about Women's Rights, but feminism? That was another level! Too extreme! I was a feminist-but didn't know it.
A huge part of my denial to call myself a feminist is that I simply didn't understand what it meant and couldn't identify with it within my context. Could I be blamed though? I couldn't name up to three African women, who I could call feminists, because I had never been taught about them. People hardly made reference to African feminists like Wambui Otieno of the Mau-Mau Rebellion in Kenya , Huda Sharawi of Egypt, and Margaret Ekpo of Nigeria. Even now in college, I remember having a class about Race and Gender and all the feminists I studied were either American or British, like Margaret Fuller, Mary Wollstonecraft or Betty Friedan. So I was far removed from this idea of feminism-that was extreme and sort of foreign-I thought.
I did not want to be perceived as a "man-hater". Feminists have always been ignorantly labeled, as those who completely hated men, wanted what men had, and were jealous of the phallus, and I did not want not be associated with this. By society's popular lens, any woman who is not attached to a man and who is always vehemently calling out men's actions has to harbor some form of sexual repression or sexual "deviation"-neither of which I did.
Now to the deep explanations of why I didn't want to call myself a feminist.
Feminism has always been termed as an extremist concept. I wanted to fight for women's rights, for equal respect and equal access to opportunities, but I always thought feminism was on another level of extremism. There were certain sayings that feminists actually wanted women to start behaving like men and were trying to devalue the basic tenets of womanhood, like child bearing, motherhood and marriage.
Feminism seemed to be for the intellectual elites. The few women who openly identified as feminists in Sierra Leone were primarily from the elite. They were either politicians, successful lawyers, or had come from very wealthy families. Besides, the women who were feminists in the elite only seemed to interact with "grassroots " women and engaged in "grassroots activism" when it was convenient for them. I did not see myself in that picture; I did not like the attribution of feminism to elite, rich, women who intellectualized it.
I finally overcame my perceptions of feminism when I started to understand it better. However, when I finally embraced it, I retreated sharply again- there was a problem. I couldn't understand why African feminists were not included in the global feminism discourse! In fact, that was when I started to understand the general image of African women on the global platform. We were either 'NGO-ized', helpless and always in need of and receiving aid, or extremely empowered, and the images of these women were usually Presidents-(think Ellen Johnson Sirleaf.) There was no place for the regular African woman in between. That was when I decided to adhere to a type of feminism that was specific to our circumstances-African feminism. Feminism in Africa is not foreign and was not brought to us by our western feminist sisters, it had always existed, it had just not been always been called feminism. Women have historically found methods of resistance to patriarchal oppression within their societal contexts. In the global feminist discourse, it seems that African women or "third world" women in general, need to be informed of both their rights and how to fight for these rights, with a huge chunk of contextual adaptation and history of resistance to oppression, missing.
The goals of feminism somewhat diverse across contexts and cultures but still very clear in terms of two things: equality and fighting gender discrimination and oppression. Feminism is not just a concept or a label-it is a way of thinking, which is why it cannot just be limited to women. Men who support feminism do not perceive equality of rights and access to opportunities as a threat, but as a necessary step to the betterment of that society, because equality of rights and access to opportunities leads to economic empowerment and thus economic growth and innovation in a variety of ways.
It has been a long journey and I am still not quite there. However, I pride myself in the knowledge that I am finally comfortable being called a feminist. I specify my feminism as African because African women face four layers of oppression- oppression by gender, oppression by certain traditions and customs, oppression by race and negative stereotypical perceptions of African women, and oppression by the economic strata of coming from developing countries. I use "African" as a term not to ignorantly generalize and take away individual national agencies, but because women in African countries do face similar issues across cultures, contexts and countries. The specification of African feminism is not to shrug of alliances of western feminists, but to help them recognize that intersectionality is imperative when forming alliances-and mark my use of the word -ALLIANCE. Not an arrogant notion that we need to know our rights and thus have to copy methods of fighting oppression from western or "first world" feminists.
There is no shame in identifying oneself as a feminist, because the goals of feminism are very clear: fighting against patriarchal oppression and hegemony and for equal rights and access to opportunities. I reiterate, feminism is a way of thinking, and if you are still not comfortable being labeled as a feminist, then you can think of it as a gradual change in mentality. Anyhow, shying away from the term is reinforcing patriarchal and intra-gender impositions of what constitutes true womanhood thus reinforcing hegemony and sexual oppression. As I reflect on the second part of this piece,please watch this video by Chimamanda Adichie on why everyone SHOULD be a feminist.


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Shreveport is the third largest city in Louisiana. It is the principal city of the fourth largest metropolitan area in the state of Louisiana and is the 109th-largest city in the United States.
It is the seat of Caddo Parish and extends along the Red River (most notably at Wright Island, the Charles and Marie Hamel Memorial Park, and Bagley Island) into neighboring Bossier Parish. Bossier City is separated from Shreveport by the Red River. The population was 199,311 at the 2010 census, and the Shreveport-Bossier City Metropolitan Area population exceeds 375,910. The Shreveport-Bossier City Metropolitan Statistical Area ranks 117th in the United States, according to the United States Census Bureau.


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Simply Gujarati
Latest trends in home decor this season
Simply Gujarati brings you the latest trends in home decor for the season.
ISSUE DATE: February 27, 2012
UPDATED: February 28, 2012 11:50 IST
Want to give your home a make over this year? Bring outyour brightest cushions, polish those antique pieces, hang upyour steel thread curtains and pull out those vibrant rugs. Simply Gujarati brings you the latest trends in home decor for the season.
Living room: Understated chic
The living room is the face of your home. Today, home design is more about tailoring a space which reflects your personality, giving it your distinct stamp. The turn of the century witnessed minimalism at its best but a decade later, we have reached a point where it's no longer about a single trend. Styles have changed and people's spending power has increased.
Ahmedabad based interior designer, Ranna Parikh elaborates, "There is a trend of having two living spaces now. One to show off when guests come home and the other for the family to spend time in. But whatever styles may come and go, a typical Gujarati home can never let the old jhula go out of fashion. Whether in the traditional wood carved version, the modern wrought iron version or the edgy stainless steel version, the jhula is almost always mandatory in a Guajarati home."
Ahmedabad-based interior designer Errol Reubens Jr, owner of Errol Reuben Interiors Pvt Ltd says, "Keep the walls a neutral colour and save the colour for cushions and curtains."
He also suggests that one should go with white walls or muted shades because that gives you the liberty to play with other things around the house. But he also emphasises that today's home is not just about what is traditionally Gujarati, but more about fusion of the old and new. "Tastes vary in every city and define what is in vogue," he explains.
From intricately embroidered weaves to bold floral prints, the perfect juxtaposition of art and utility is something that everyone looks for in upholstery. Ariane Thakore Ginwala, of BoConcept design store says, "One should choose fabrics in subtle textures and patterns. And do not forget to pick material that is easy to clean and maintain."
This season go for bright colour tones such as pink and red. Add a bit of glamour and drama with jacquard weaves, opulent velvets and use sophisticated solids which can range from pristine whites to peacock colours.
Silver leafing and gold foiling with paints are simple techniques that can dress up walls and furniture.
Don't be afraid to change the positions of things in a room. That may be all that is necessary to create a brand new look.
If comfort is the key factor in your decor scheme, opt for downy, fabric-covered couches and chairs.
If you find a hole in the upholstery, trim the edge lest the loose threads get further ripped.
Natural fibres tend to absorb stains faster, while synthetics can be cleaned easily. You can opt for blended fabrics that give you the best of both.
Dining room: Delightful dinners
Conversations become livelier and smiles broaden when accompanied by heaped plates and refilled glasses; revelry is a dish best served at the dining table. Flavour it with tableware suited to your taste and it's a recipe for sure success. While some wares are reminiscent of an enchanted past, others have journeyed from across the world to India, to ensure diners here have a lavish spread.
According to Reubens Jr, the traditional formal dining room is still a hotseller in certain markets. "These look elegant and you can make it look brighter by painting one wall with bold colours like orange or red. Another way of making your dining space look livelier is by adding an artwork. Try and match the artwork with your furniture and tableware so that the space looks colour co-ordinated."
"You can also use tasteful plush fabric on the chairs. Upholstered fabrics are the best way to go as you can change them whenever you are bored of them," he adds. Colours in vogue this season are sophisticated beige and shades of brown complemented with bright tableware.
If your dining room is a space separate from the kitchen and living room, Parikh suggests using lights or wooden arches on the ceiling to add life to the room. People living in apartments tend to have less formal dining spaces. They can go for casual dining furniture in smaller sizes or with features that make better use of the limited spaces.
"Go for fusion tables, these are tables which can be used for multiple purposes when not used for dining. For example dining tables that turn into billiard tables are available and being used in many homes these days," says Reubens Jr. Storage consoles which are built into the walls can be great space savers. "It is wise to use expandable or low height tables with in-built pouffes for seating, which make the space look uncluttered," he adds.
Make sure there are enough plug points and table surfaces which allow you to play with low-level lighting.
Use reflective decorative plates instead of placemats for a chic look.
Old photo frames can be repainted and hung in an interesting arrangement to make for inexpensive wall art.
Dress up your chairs in colours of your choice-the brighter the better.
Keep the table stark by using a black glass top-this will add to the overall impact.
Kid's room: Happy days
Lions scare away smiling ducks and winking stars, only to be replaced by zooming airplanes and cars; Barbies and fairy dust are traded for some real world glamour and dressy tea parties. Children are not clingy, their troubles and fights are forgotten over a night of dreamy sleep as are their obsessions and heroes.
It doesn't take them long to replace yesterday's idol or change their favourite colour from blue to purple. When it comes to kids, rules are made to be broken. Stay away from classic colours like pink and blue and play around with decor ideas to create a space with an everchanging personality which your little one won't be embarrassed of in few years time.
Vadodara based interior desigener, Hiren Parikh suggests, "Pick an airy room for your child, and make sure that furniture in your child's room has rounded edges. If you want to base the room on some theme then go ahead because childhood is a time to savour fantasies." To give an instant facelift to your kid's room, change the bedding.
Linens, blankets and throws can be replaced from time to time to reflect what your youngster is 'digging', be it pirouetting ballerinas or tough ball games. Beds which double up as sofas or have pull outs are perfect to house the little women and young lads who come by for sleepovers.
Replace the monsters under the bed with storage space. Wool and wicker baskets are good for stashing away dumped books and clothes. A chest of drawers offers sufficient space for toys, and eventually clothes. Reinvent it into a teenage vanity by changing its colour and knobs and topping it off with a dainty mirror and other smart accessories that change its personality to match its occupants.
Decals or large graphic stickers are easy ways of expressing yourself in a room. These won't damage the paint and can easily be removed when your child outgrows them.
Sliding doors on wardrobes are a good idea as well as a space savers.
Putting labels on pull out baskets, boxes and trunks will help them keep the place neat.
Bedroom: Practically pretty
Are sensational bedrooms the stuff your dreams are made of? If so, there's help at hand. Interior designers are now creating glamorous bedrooms with exotic themes, vintage furniture and luxurious linen. While there's an emphasis on showcasing new and cutting-edge interior trends in this relaxing space, there are efforts to personalise it as well, with artworks, accessories and other statement pieces.
Start with the colour of your choice and think of unusual ways of bringing it into your space. For example, it could be something as simple as a bunch of flowers in your favourite colour or a selection of books bound in that hue. Lighting is another aspect that needs attention. Invest in good quality reading lights, mood lights and lamps.
Ginwala'advicis to retain antiques in the bedroom. "One should find a way to re-use old stuff in the house and spruce it up. For instance, instead of getting rid of an old door, you can turn it into a decorative wall piece," she says.
Ranna Parikh agrees. She advocates fusing the traditional with the modern. She recommends using vintage wardrobes and bookshelves that also work as utilitariain room dividers. Other than that she says, "Play with the space and create an atmosphere with a colourful bed spread and mood lights. But your laptops and television should be given a separate space in the bedroom away from your resting space," she asserts. Remember to have comfortable seating where you can enjoy your morning tea and breakfast.
Accent walls, or a wall that is a strikingly different colour from the rest of the walls can brighten a room. Use a high gloss paint for this.
Border wallpaper adds an interesting touch to a room.
If you want to replace the flooring, you can go for wall-to-wall carpets as they are less expensive than wood.
Invest in good quality reading lights, mood lights and lamps.
Furniture makes the bedroom look complete. So, it is wise to invest in pieces like beds with nice headboards, sofas, side tables, comfy seats and cocktail tables.
Bathroom: Luxury meets utility
Enlivened with animated colours, elaborate fixtures and wainscoting, this is a space that's being reinterpreted every day. So washroom snobs, you can surely do better than the clinical white number that was once a staple.
Design professionals are rooting for an over-the-top shade card as bold is big this season. Errol Reubens Jr says "These days the bathroom is getting bigger than ever, because everybody wants a spa-like bathroom with a Jacuzzi or a trendy bathtub."
New age bathroom materials take a cue from opulent decor schemes predominant in the rest of the house. Traditional notions of seclusion and privacy are slowly becoming obsolete and so one sees many glass separations and mirrors in bathrooms. For the truly inspired, customisation is taken to the next level with etchings on marble of decorative motifs, writings, logos and designs. Ranna Parikh says that windows are also of major importance, as they have an enormous influence on the aesthetics and tone of the room.
Embellishments, clearly, have come of age in this country. With their glorious sheen and texture, state-of-the-art bathroom fixtures are now a must-have in every fashionable address "Try to invest in good tiles that enhance the beauty of the bathroom. Floral designs and subtle patterns with a smart finish can make your bathroom pleasing to the eye," she explains.
Bathrooms have fancy designs now; tiles from all over the world have made their way into many Gujarati cities. High-end brand names are readily available. "However, there is only a select section of Gujaratis who are willing to spend on luxurious bathrooms," reveals Ginwala. "Vadodara is the exception to this rule-people have good taste there and are more aesthetically inclined," she adds.
For those who are willing to spend the time and money on their bathrooms, the decor needs to be perfectly calibrated to their needs and sensibilities rather than being a blind imitation of reigning global trends. It is no secret that adornments for washrooms are now being held in high regard. A host of materials ranging from Swarovski crystals and artistic mosaics to precious metal are now part of the luxury washroom repertoire.
Use anti skid patches in the bathtub and other wet areas, and floor mats with suction to prevent slippery surfaces.
Place flower stems in the bathroom with burning incense-the fragrance will add a wonderful feel to your space.
Install grab bars in the shower/tub areas, toilet area and near the sink.
Kitchen: Minimalist wonders
"But our waking life, and our growing years, were for the most part spent in the kitchen, and until we married, or ran away, it was the common room we shared." said English poet Laurie Lee, and his words still ring true in every Gujarati household. People have become accustomed to the idea of accommodating more people in the kitchen than in the dining room and it wouldn't be untrue to proclaim the kitchen as the heart of the home.
Parikh says, "The advent of the open kitchen in our homes has led to kitchens blending into dining spaces. The actual dining room is being used more for formal occasions."
She says that the shape of the kitchen often determines ease of use and convenience. "Choose a rectangular shape for your kitchen in order to enjoy family dinners and get-togethers," she advises. These days, you can choose from a range of chic kitchen appliances available that are bound to help you cook up a storm without breaking into a sweat.
There are new age yet practical kitchen goods like digital cook books and insulated coffee cups, which have recently been making their way into this space.
"If your kitchen is hi-tech, steer clear of bright and bold colours. Opt for granite or marble counter tops. Minimalism is the way to go for this kind of kitchen. Your kitchen walls should in earthy tones like beige or light brown," says Parikh.
However, a large kitchen may not work well if you have to run around a lot from cooking island to the refrigerator, hob or preparation shelf. In fact, multiple stations work well so that you can bake on one side and cook on another.
Consider a pantry with counter space for pots and pans and even a few extra drawers or a floor to ceiling cabinet with roll-out shelves to keep things handy but hidden. Another option is to have adjustable racks inside the drawers to hold objects in place. Large windows are always a good idea, whether you kitchen is a spacious one or a space starved one. "If you do not have much space, opt for floor-to-ceiling glass windows," says Parikh.
Glass panes on cabinets instead of solid wood make the room seem larger and give it a lighter feel.
Wipe glass panes with a wet cloth-use absorbent tissue and newspaper to bring a shine.
The countertop should be durable-try granite as opposed to marble, which stains easily.
Add ceramic tiles behind and around the stove to make cleaning spills and splatt-ers easier.
Ideally, you should not go beyond 2.5ft in length for drawers. If they're bigger, the weight may make them bend.
Garden: Breathe of fresh air
A home garden, like home decor is a reflection of the inhabitant's tastes and requirements. Gardens and landscape designs can give home owners peace and tranquillity, away from the chaos of daily life. Landscape artists and designers in the state suggest that adding the right lighting and various elements together can liven up your garden space unlike any set up you have had before.
Ginwala says that decorating your garden with ornaments like hanging baskets, stone sculptures, terracotta accessories, lotus ponds, fountains and rocks can make it look chic. A huge garden area in the entrance of the home is favoured by many Gujaratis. They want their gardens to be divided into orchard, fruits, flowers, green and many more sections of their choice.
"One can also add small water bodies in their gardens that can be maintained easily- this could be in the form of a cascade where water drops from a higher level to lower or even a small pool with water lilies and goldfish. Add a statue and you've got a lovely garden all set up," she says.
A garden in full bloom is a treat for the senses. Try perennials or Cestrum nocturnum, commonly known as Raat ki Rani, a shrub with sweetscented white flowers which bloom at night. The Jasminum, whose varieties include motia, chameli white and juhi are good options as well.
A brightly lit garden gives a new face to your green space at night. With a little creativity, sensible use of lights and careful selection of plants, one can turn the space into a charming patch that can sometimes be used for a party or barbeque as well.
Ginwala says, "A garden is the place where you can install wood fire pizza ovens and accessorise with stone figurines, stone benches and fountains. Decorating the space with pebbles and gravel is also a good option."
If flowers and plants are too much work, create a rock garden which requires much less maintenance.
In larger gardens, installing a gazebo acts as a great way to enjoy the space away from the sun.
Place lights by tall trees and along pathways to make the area beautiful at night.
Water plants with cool water in which neem leaves have been soaked overnight.create a brand new look.
-Text by Devika Chaturvedi (with inputs from India Today Home)
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Religion vs law: Big religious fight erupts over Ranchi court's order to distribute copies of Quran


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Q: Prevent MacOS from showing the accent selection popup in Flutter I'm developing a Flutter desktop app and I have to process raw keyboard input (custom drawn control that handles user input).
For this I'm using a TextInputClient and a TextInputConfiguration that gets registered via TextInput.attach(client, config).
I have everything working but when I long-press a key on MacOS then I receive one key press and then MacOS shows the accent selection popup.
Is there any way to prevent MacOS from doing that? I tried all different variations of TextInputConfiguration parameters but MacOS doesn't care.
The text handling is too much code to paste it here but when needed or not obvious I can create a small sample that shows the problem.

A: Ok, so after digging though the internet I found a solution.
I let it here so that other people can find it, too.
The solution is an application wide setting. I didn't find a solution to enable / disable that behaviour on a TextInput instance base.
In the end it comes down to setting a preference for your application that you don't want the tap-and-hold but the auto repeat behaviour.
You can do that in the MacOS integration layer of your Flutter application:
AppDelegate.swift

Add the following method to the already existing AppDelegate:
override func applicationDidFinishLaunching(_ notification: Notification) {
    UserDefaults.standard.set(false, forKey: "ApplePressAndHoldEnabled");
}

And that's all.

redpajama_set_name: RedPajamaStackExchange


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Your kidneys perform several important roles in circulation: including filtering toxins from the blood, regulating blood pressure and triggering the production of red blood cells. Needless to say, it is important to keep your kidneys healthy! In this blog I'll suggest 3 great drinks to help support these all-important organs.
What role do the kidneys play in circulation?
Your kidneys are responsible for various roles in the body, first and foremost filtering the blood. When blood enters the tiny nephrons of the kidney, waste products from digestion and other bodily processes are removed; at the same time, important minerals and water are reabsorbed back into the blood. This allows 'clean' blood to return to the heart and then circulate around the rest of the body, depositing oxygen and those vital nutrients to your organs and tissue.
The kidneys also contribute to the maintenance of healthy blood pressure. When blood pressure drops, the kidneys produce a hormone called renin which restricts urine flow and narrows the blood vessels to raise blood pressure back up to normal. On the other hand, when blood pressure is raised, the kidneys promote urination and dilate the blood vessels in order to bring it back down.
Additionally, the kidneys produce a hormone called erythropoietin which stimulates the production of red blood cells. As we know, red blood cells circulate in the blood carrying oxygen to your organs and tissues. Without the haemoglobin in red blood cells, your blood would struggle to absorb enough oxygen to carry around the body.
Solidago Complex can help to support the function of the kidneys. Solidago has been used for this purpose for hundreds of years; take 10-15 drops in a little water, 3 times daily.
Unfortunately, most people do not drink enough fresh, plain water. You should always make sure you drink plenty of water, as it is vital for so many processes within your body; your eyes, skin, bowels and brain are all affected by how much water you drink – and so are your kidneys!
Throughout the day, your blood is constantly travelling around your body, passing through the kidneys multiple times where the toxins are filtered out and minerals reabsorbed. Waste materials left over from processes like digestion leave the body through urine but, without sufficient water, the kidneys can't expel these toxins efficiently. So you might find yourself getting ill more often than normal if you're not flushing out waste products regularly enough. For instance, you may be more prone to urinary tract infections (UTIs) or cystitis if you don't drink enough water.
If your body becomes dehydrated, your kidneys will hold onto as much water as they can and this fluid retention can lead to unwanted bloating and swelling. Although it may seem like a counterintuitive remedy for excess fluid, drinking more water will help! Rehydrating your body (and your kidneys) will trigger urination as your kidneys get the signal that there is now enough water in the body to do so.
Plus, if your body becomes dehydrated, this can have an effect on your blood circulation too. When there is less water available in the body, your blood can become thicker and cause your blood pressure to rise. Untreated high blood pressure can result in various health issues, such as increased risk of heart disease and stroke.
You should also make sure to avoid drinks that can dehydrate the body; diuretics such as tea and coffee are common culprits here, as well as alcohol.
The kidneys are responsible for maintaining balance between fluid and electrolytes, such as sodium and potassium. These two minerals are constantly in competition with each other. Years and years ago, when the human diet consisted of lots of fresh fruits, roots and veg, potassium was easy to come by. Sodium, on the other hand, was scarce in our diet. Therefore, the kidneys are programmed to hold onto sodium and release excess potassium in order to keep this balance.
However, nowadays there are so many packaged, processed foods available, most of which contain high levels of salt; meanwhile, fresh fruit and vegetables are being consumed far less than they once were. Despite this, the kidneys are still inclined to conserve sodium and release excess potassium through the urine. When this balance is disturbed, the kidneys are forced to work even harder and nasty side effects can include swelling of cells and fluid retention.
A great way to replenish potassium levels is Balance Mineral Drink which contains a sensible dose of potassium, as well as vitamin D, magnesium and zinc. It comes in a handy sachet which you can add to water for a refreshing, strawberry-flavoured drink, or incorporate into a tasty fruit smoothie.
As well as this, you can up your intake of potassium-rich fruit and vegetables, such as bananas, avocados and sweet potatoes. Read more about the sources and benefits of potassium here.
The last drink I would recommend for supporting your kidneys is Golden Rod Tea. Also known as Solidago, Golden Rod has been used for centuries as a herbal remedy to support the function of the kidneys. It is a gentle blend of five herbs – Golden Rod, Birch leaves, Horsetail, Knotgrass and Wild Pansy – which work synergistically to flush out toxins and cleanse the system.
Golden Rod, Birch and Horsetail contain flavonoids, which help to tone capillaries and improve blood flow, as well as saponins which take anti-inflammatory action in the body. Horsetail and Knotgrass also contain silica, which helps to repair damage done to the bladder lining; Wild Pansy is another source of flavonoids which contribute to the toning of capillaries. This refreshing tea is a great addition to your diet in order to help support your kidneys and your circulation.
Golden Rod can also be found in our Solidago Complex, which is another good way of supporting the kidneys and detoxifying the body by diluting the urine. This reduces the concentration of infective organisms which can cause irritation to the urinary tract.


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Countdown #15 - rambling on
Broadcast March-24-2012 - podcast available here. All comments are lifted from Philip Random's notes. The full countdown list (so far) can be found here. Links are not necessarily to the exact same recordings we played on-air, but we tried.
Wire - ambitious
I missed Wire's first act completely, three albums culminating with 1979's 154 that (in retrospect) went a long way toward dragging British indie music out of the punk war zones and kicking it into the stratosphere. So it's a damned good thing all four original members came back again in 1987 to remind us how good they were. Ideal Copy was the album with Ambitious the closest thing to a title track, a tough number that did a smart job of touching on all manner of essential topics of the day, from paranoia to Cold War politics to competing competing intelligence agencies to, of course, the end of the world.
Negativland - the perfect cut [piece of meat]
Wherein the tape pirates from the California suburbs get busy with pretty much every shitty MOR pop song from the 1970s, and the secret tapes that prove the conspiracy that was at hand. That is, the deliberate reduction of the insurrectionary promise that was 1960s POP music to various pieces of meat. Stuff your faces, folks. And shut up! Stop complaining.
Buzzcocks - ever fallen in love
Pure pop with punk in its soul. Or is it the other way around? One thing is clear. The Buzzcocks were pretty much the first band to have it both ways, and I'll forever love them for that. Just because you're pissed off doesn't mean you can't be pretty, too.
Doors - not to touch the earth [randoEDIT]
I didn't really twig to this one until I saw the Doors movie, which I know, I'm not supposed to like, the whole thing just being so absurdly over the top, Val Kilmer chewing not just the scenery but also vast chunks of the Mojave desert. Except it's true. The psychedelic 60s were that weird, eruptive, explosive, WILD, kicking into overdrive in 1967, blowing through ozone by the end of 1968, which is where Not To Touch Earth comes in. Wherein Mr. Morrison is so high and wasted, he's not sure if he's a worm or a god, or maybe just some dead Indian shaman who snuck into a little white boy's fragile eggshell mind a couple of decades earlier.
Procol Harum - rambling on
I came across Procol Harum's second album sometime in the blur of the early mid-70s. My friend James had it, grabbed from his older sister who'd lost interest. We'd play it a lot (not having many albums to chose from), getting off on the "out there" lyrics and the not too shabby songs that gave them room to move. The aptly named Rambling On seems to be about a guy who sees a Batman movie and decides he can fly, which doesn't make much sense because Batman can't fly. Or maybe that's the whole point.
Julie Driscoll + Brian Auger + The Trinity - this wheel's on fire
It's an oft-told tale. Bob Dylan, having survived a nasty motorcycle accident retires for a while to upstate New York where he ends up hanging out in a basement with his buddies The Band, cranking out all manner loose, sloppy, sometimes brilliant songs that nobody had any clear plan for. Nevertheless, bootleg LPs started to proliferate, and inevitably cover versions. Julie Driscoll + Brian Auger + The Trinity were one of the first to release something, and they nailed it. So good, the TV show Absolutely Famous put it to work again thirty odd years later.
Bonzo Dog Band - we are normal
The Bonzos showed up in the Beatles TV special Magical Mystery Tour and otherwise served as sort of court jesters for the British pop scene through the psychedelic 60s and beyond. But sometimes the songs were so damned good you forget they were supposed to be funny. We Are Normal solved this problem by being mostly just weird. And it rocked.
Rainbow - a light in the black
I'd be lying if I said it wasn't the cover that hooked me – God's own arm thrusting from the waves of a boiling storm, grabbing a rainbow straight out of the sky. The cool part is, the music's up to it pretty much all the way through, assuming you don't mind a little full throttle metallic wailing. Richie Blackmore, recently ex of Deep Purple, leads the charge on guitar but Ronny James Dio's howling is never far behind, or Cozy Powell's drumming.
Jimi Hendrix - hey baby (the new rising sun)
The rumour I heard when I was maybe fifteen is that Rainbow Bridge (album and movie) was the reason Jimi Hendrix was killed. Because it revealed that a benevolent alien intelligence was connecting with us, steering us in the direction of the New Rising Sun. So Richard Nixon got his orders from the evil aliens that ran things. Stop this man. Use your best agents. Make it look like a typical overdose. And while you're at it, get Janis Joplin and Jim Morrison as well. 1970 sucked in that regard.
Linton Kwesi Johnson - bass culture
Skull rattling dub poetry that makes a very significant point. Reggae music is all about the bass, the way it makes a body and thus a whole culture MOVE. The drums just keep things rock steady. The guitars, keyboards, horns etc are just along for the ride. It's the bass that's going places. And sometimes the poetry -- like a frightful form, like a righteous harm, giving off wild like madness.
Clash - white man in Hammersmith Palais
Speaking of bass culture, White Man in Hammersmith Palais was The Clash's first reggae song, not to be confused with its best, though many have made that claim. Of course, they're the ones that never even heard all of Sandinista, having written off the-only-band-that-mattered for high crimes of artistry, experimentation, ambition before they'd even made it to side two. Punk was cool, punk was necessary, punk probably saved the world, but it also turned reactionary awfully fucking quick. Which might even be what Joe Strummer's singing about here.
Queen - seven seas of Rhye
In which Queen (their hair still long) unleash an astonishing mix of heavy licks and wild mood swings all in service of some high fantasy concerning a mythical Queendom called Rhye, which, if you were maybe fifteen, confused about pretty much everything, stuck in the mid-70s, was exactly the thing the Universe needed you to hear.
Melodic Energy Commission - song of the deletron revises the scene [randoEDIT]
Local Terminal City hippie-psychedelicists hook up with an-ex Hawkwind refugee, ignore all the punk rock that's raging around them, and instead go deep and high, and deliver an essential travelogue for those keen on exploring the beyond within via the local mushrooms that are so prevalent every autumn once the big rains start a-falling.
song of the delatron
Donovan - roots of oak
I didn't even hear this record until a good twenty-five years after its release, but man did it work in a solid, mystical sort of way. Yes, the drugs may have worn off by 1970, and the incense, and all the pretty flowers may have mostly wilted and died, but ever hip Donovan Leitch (who never got the credit or respect he deserved) was still definitely onto something both passing and eternal.
Renaissance - ashes are burning
There's a lot of so-called progressive rock from the so-called golden era (1970-74) that is quite stunningly awful – pretentious, over wrought, dense to the point of ridiculous, the antithesis of everything the likes of Buddy Holly, Jimi Hendrix, Janis Joplin, Brian Jones, Jim Morrison died for. And thus, over the years, it's earned a lot of well deserved HATE. But not here. Renaissance's Ashes Are Burning fully earns its eleven minutes plus running time as it explores mystery and beauty, highly, deeply, ultimately epically. And Annie Haslam has an amazing voice.
Countdown #14 - I lost my head
Countdown #13 - kill for peace
Countdown #12 - dead finks don't pop


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Q: How can I keep a Node script running on my server? I have a digital ocean server and I want to have a script run continuously. I am using node-scheduler inside this script so it runs a task every day (download images from the internet). The script doesn't stop until it is canceled, so that part works but how can I enable this to work inside my server?

A: You can use a process manager like PM2 or Forever.


text:
South Park: Post COVID: The Return of COVID (2021) review
Dir. Trey Parker
Rating: ★★½
After four specials revolving around the pandemic, South Park's approach to COVID-19 is starting to feel as redundant as news about a new variant. South Park: Post COVID: The Return of COVID — the second of 14 planned Paramount+ "exclusive events" — has the fewest laughs of any of these spontaneous specials yet. While underwhelming, a rocky first-half is rescued by an optimistic conclusion; something we don't normally get from Trey Parker and Matt Stone. Optimism in the land of South Park is a treat when it presents itself, and after two long, arduous years, we could use some in spades.
The Return of COVID follows South Park: Post COVID, last month's special, which flashed-forward 40 years into the future and saw the kids of South Park well-into middle-age. Kenny had passed away after becoming a renowned scientist; Stan was a cynical alcoholic with a family in shambles; Kyle displaced his best friend as the perpetually positive everyman; and Cartman inexplicably became a rabbi. The "film" left us on a cliffhanger as it teased the reveal of a character named "Victor Chaos."
Now, any seasoned South Park fan knew right away it was Butters Stotch, and his appearance in this futuristic version of our favorite animated locale doesn't disappoint. Stan and Kyle need his help, since he helped Kenny develop time-traveling technology. They feel if they can travel back to the past, like their friend was planning, they can stop the pandemic from ever happening. Butters complicates things, however. He's grown up to be an institutionalized snake-oil salesman who has made his riches convincing people to invest in NFTs. He escapes the asylum by tricking one of the guards into blowing his savings on them. "It's gone," he cries, "My savings, my house. But I have this little green panda on a skateboard!"
The plot would presumably take care of itself in about as much time as a conventional South Park episode, but Cartman of course has to go to great lengths to pull some shenanigans — the likes of which I won't spoil for your enjoyment.
South Park: Post COVID: The Return of COVID does an adequate job of building upon the world erected in the previous special. It still takes amusing jabs at anti-vaxxers, the strongest one coming when Cartman assures the unvaccinated Clyde with the zinger line: "You have to be strong and stand by your beliefs. Even if it means others will die." It also adds to the Blade Runner 2049-inspired dystopian hellscape that's become South Park, bolstered by a doomy soundtrack and the reoccurring presence of holograms and one seriously unnerving billboard.
But for some reason, the jokes aren't as pervasive here. Post COVID's humor derived from the slow-reveal of what came of the kids as they crept towards AARP memberships. The Return of COVID is far more dramatic in tone, trading humor for some unexpectedly dark undertones that squander the blackly funny satirical edge we expect. For whatever reason too, Trey and Matt simply won't let Randy Marsh's Tegridy Farms bit die. It's been a played-out plot-device for too long now, even if it does contribute to the aforementioned (mostly) wholesome finale.
The reassuring news is we still have a dozen of these Paramount+ South Park specials that will see the light of the day through 2027. That's an average of about two to three a year. There's enough runway for the duo to tackle other subjects. But given the ferociousness of COVID-19, and how the show stays married to the current news cycle like no other, I almost fear we haven't seen the last of this masked, quarantined Colorado mountain town. At the very least, we need a break.
Here's to new material in the future.
NOTE: South Park: Post COVID: The Return of COVID is now streaming exclusively on Paramount+.
My review of South Park: The Pandemic Special
My review of South ParQ: Vaccination Special
My review of South Park: Post COVID
Voiced by: Trey Parker, Matt Stone, Delilah Kujala, April Stewart, and Adrien Beard. Directed by: Trey Parker.