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Geek News on the Radio for September 28, 2020
James Cameron Says 'Avatar 2' Filming Is 100% Complete
James Cameron provided his Terminator star Arnold Schwarzenegger with an update on the Avatar sequels during a recent chat for the 2020 Austrian World Summit. Speaking by video conference from New Zealand, Cameron said, "We're 100% complete on Avatar 2 and sort of 95% complete on Avatar 3." He added that the team is currently working on shooting the remainder of the live action. Cameron explained that the production lost "about four and a half months" owing to COVID-19, which "hit us like it hit everybody, it hit us hard." Avatar 2's release, as previously announced, "rolled around a full year" because of the pandemic lockdowns, Cameron added. In July, Disney moved all the Avatar sequels, setting Avatar 2 on December 16, 2022 and Avatar 3 on December 20, 2024. The fourth and fifth pictures are due in 2026 and 2028.
Aldis Hodge to Play Hawkman in DC Films' 'Black Adam'
Aldis Hodge will soar as the DC Comics superhero Hawkman in the New Line production of "Black Adam," Variety has confirmed. The actor — who most recently starred in "The Invisible Man" and won acclaim for his upcoming performance as Jim Brown in "One Night in Miami" — is in negotiations to join the film, starring Dwayne Johnson as the titular anti-hero, and Noah Centineo as the superhero Atom Smasher. Jaume Collet-Serra ("Jungle Cruise," "The Shallows") will direct; Rory Haines and Sohrab Noshirvani ("Informer") wrote the latest draft of the script, from a previous draft by Adam Sztykiel ("Rampage"). Johnson is also producing with Dany Garcia and Hiram Garcia through their Seven Bucks Productions, and Beau Flynn is producing through FlynnPictureCo.
Samuel L. Jackson to Play Nick Fury in New Marvel Disney Plus Series
Samuel L. Jackson is set to reprise the role of Nick Fury in a new Marvel series currently in development at Disney Plus, Variety has learned exclusively from sources. The exact plot details of the show are being kept under wraps, but multiple sources say Jackson is attached to star with Kyle Bradstreet attached to write and executive produce. Like all the other Marvel shows at Disney Plus, Marvel Studios will produce. Reps for Jackson, Bradstreet, and Disney did not immediately respond to Variety's request for comment
'The Boys' Spinoff in Development at Amazon Following Massive Season 2 Launch
"The Boys" could soon be getting a spinoff. Variety has learned that Amazon is fast-tracking development on a new iteration of the popular comic book series adaptation. The news comes just under three weeks after the premiere of Season 2 of the series, which is based on The New York Times best-selling comic of the same name by Garth Ennis and Darick Robertson. The second season is airing weekly, while the first dropped all at once, with the finale set to air Oct. 9. According to Amazon, the second season had the most-watched global launch of an Amazon original series ever, with the episodes to date having grown the audience from Season 1 by 89%. It was renewed for a third season ahead of the Season 2 premiere while also adding an aftershow hosted by Aisha Tyler.
Syfy gets festive with adult animated comedy series The Pole
Syfy has announced that it is expanding its late-night adult animation block TZGZ with The Pole, a six-episode festive comedy featuring Bobby Moynihan and Jillian Bell as Santa Claus and Mrs. Claus. The official synopsis for the series reads:
In THE POLE, after a scandal involving "Saint" Nick (Bobby Moynihan) rocks the holly jolly foundations of the North Pole, all hell breaks loose as the future of Christmas turns into a twisted power struggle for the Red Suit. As Nick, the 20th to wear the Suit, struggles with the age-old question of naughty vs. nice, his wife Mrs. Claus, aka Gretchen (Jillian Bell), works to keep the political machine that is toy production afloat. It isn't easy as they juggle the factory elves, including Nick's head elf Matilda (Nicole Byer) and the political activist Helenor (Sasheer Zamata), as well as parenting two sons – Nick's mini-me Harry (SungWon Cho) and the crown prince, Jack (Tim Simons), who's not only next in line for the Suit, but also looking to rebrand it. Reporting on all the drama in THE POLE? Cocoa (Colin Jost), host of the North Pole News Network Program, "Morning Cocoa."
Related Items:Aldis Hodge, Avatar 2 done filming, Bill, Black Adam, geek news, Geek News on the Radio, gina, Hawkman, James Cameron, Kerry, Nick Fury, Radio From Hell, rfh, Samuel l jackson, The Boys Spinoff, The Pole, X96
Boner Fight for September 28, 2020
All Time Low Announce "Basement Noise Concert Series"


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Dance Group Moves Summer Festival Online with Help from Butler Student
By: Mikaela Schmitt '22 | July 21, 2020
As much of the world moved online over the last several months, arts organizations largely lost the ability to host programming as they know it. No more concerts, gallery exhibitions, theatre performances, or film festivals—at least not in person. Just a lot of time sitting at home and looking at screens.
Chicago Human Rhythm Project (CHRP) was one of many organizations forced to adapt, but they had help from Butler University senior Katherine Cackovic.
Cackovic, a Dance Arts Administration major, has spent the summer completing a virtual internship with the nonprofit tap dance organization. CHRP focuses on building a community around tap dance and other percussive art forms through education and performance. Each summer, they host Rhythm World, Chicago's annual festival of tap and percussive dance. Cackovic was hired to work as the Rhythm World intern, but due to COVID-19, the festival has been shortened and made fully virtual.
Cackovic says the opportunity to assist with navigating the COVID-19 crisis and moving the festival to an online space has helped her develop real-time problem-solving skills that will allow her to better serve other arts organizations in the future.
Throughout 2020, arts communities around the world have been forced to cancel programming and figure out how their organizations, typically centered around gathering the community together, will function as the world continues to fight COVID-19. Staff members are collaborating to keep their organizations alive and to ensure their work stays relevant during this difficult time, bringing art into homes as a form of comfort, conversation, and entertainment.
"Since COVID-19 has caused everything to be reworked, creativity, communication, and teamwork are key," Cackovic said. "My supervisor is the festival coordinator, and since his job has diverted from what it usually is, even he is learning new things and taking on new tasks."
During a normal year, The Rhythm World festival occurs throughout July, featuring classes and performances at different venues around Chicago. This summer, the shortened festival will take place virtually in mid-August, with three days of classes followed by three days of performances. CHRP is working to find new opportunities unique to their online platform, such as including international teachers in the program faculty.
Cackovic is still working on the Rhythm World festival, doing registration and ticketing work, developing livestreams for virtual classes, and creating social media posts for the organization. Her work is far more technology-driven than originally anticipated, pushing her outside her comfort zone and helping her to expand her skill set.
"While it's a strange time for internships and organizations, I think we are getting prepared to be extremely flexible and easily adaptable employees in the future," Cackovic said. "Our class will be graduating into an unstable and uncertain world, and we will need to bring creativity to the table to navigate the tough times ahead."
Butler's Arts Administration major serves students interested in the arts, nonprofit organizations, and management, integrating art with business. The program focuses on offering opportunities for students to learn and develop skills through experiential learning, including internships and special projects with arts organizations.
A Shared Mission: How Butler's College of Education and Special Olympics Work Together for Inclusion
The ongoing collaboration has evolved into a relationship that was recently formalized through a three-year memorandum of understanding
Following Pandemic Freeze, Polar Plunge Returns to Butler
The annual fundraising event is just one of many ways Butler students support athletes from Special Olympics Indiana
Four Ways to Stay Active Near Butler University
Butler Team Preserves, Improves Access to Artifacts through 3D Digital Replicas

redpajama_set_name: RedPajamaCommonCrawl


This was a week of contrasts. We fed 2 different groups of kids 2 very different meals.
Last Saturday, we were very involved with a formal dinner for the high school youth group from church. The event was held at my sister's house and our 2 families did all the cooking.
We ended up having about 24 youth, and 12 college-aged and adult helpers. My brother-in-law rearranged their house so that there were 3 large tables in the living area and all the youth were able to sit down.
We had gluten free and dairy free students coming, one that was allergic to fish and one that was allergic to shellfish, so needed to make it allergy friendly. We had at least one vegetarian as well. It was quite a challenge.
We served the meal in courses. We had the "waiters" take orders, noting special dietary needs and kept all questionable food completely separated from the other food, even on the grill. Rob used foil and separate pans/dishes to do this.
Our waiters kept really good track of what each student needed using sticky notes.
The first course was appetizers. Rob barbecued shrimp skewers with peppers and onions threaded on in between the shrimp. We made 2 kinds of potato skins–one with olive oil, green onions and rosemary and one with cheese, bacon bits and green onion. We had purchased mozzarella sticks, served with marinara and ranch. The last appetizer was cheesy bread sticks. The bread sticks were purchased and cheese was sprinkled on top and they were baked to melt the cheese.
There were fancy drinks. They had sugar around the rims of the glasses and the kids could choose their favorites. Unlike a restaurant, they could have free refills and some had several!
Salads were next. They got their choice of dressings and customized salads without cheese or bacon if requested or needed.
The main course consisted of risotto, teriyaki chicken or salmon topped with mango-peach chutney sauce, garlic green beans and was decorated with spiralized zucchini and cilantro. Rob was able to cook the beans, chicken and salmon on the big grill outside, which helped the kitchen prep tremendously.
We dipped strawberries in chocolate and made gluten-free mini-cheesecakes with cherry topping and chocolate decorations for dessert. It was so pretty and tasted so good. We dipped a few berries in dairy-free chocolate, but did not make dairy-free cheesecakes. The student was still happy because he could have a yummy strawberry and some extra chocolate candy we got for him.
That event turned out very, very well. It was so fun to see the kids and some adults dressed up and they ate SO much food! We had a ball doing the event. The kids were delighted to have this experience and were happily talking about it the next day at church, I've heard. They went off ice skating afterwards, but we collapsed! It was worth it, though.
The second event this week was feeding the college aged kids their Tuesday night dinner. It was just coincidence that our turn for that was this week as well. It was kept quite simple.
We got ham for 77c/lb at Winco and Rob barbequed 2 of them. He sliced them and put them in our big roaster. I made southwestern beans with soaked pink beans, onion, green salsa verde and ham broth. We used 6 heads of romaine and one head of head lettuce to make a huge bowl of salad. Then, we put toppings such as olives, cheese, tomatoes, and tortilla salad toppers out so they could create their own southwestern salads. Some canned corn, oranges and brownies and made from a boxed mix finished out the dinner. There were around 35 people there–more than expected, but the food held out! Hallelujah! Those kids are a cheerful, appreciative bunch every time we feed them. It makes it fun to do.
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Tell us more about this self-hosting? Gosh, I have enough trouble keeping up with the Blogger changes much less learning something new. Good for you.
I'm changing from a WordPress.com blog to a WordPress.org blog. I have watched hours and hours of tutorials, watched U-Tube videos and read book after book telling me how to do this over the past few months. I'm still spending time feeling pretty frustrated, but I'm learning so much, and then I feel triumphant!
WordPress uses themes when you set up a blog. I changed themes a few weeks ago, and studied what could be done with the new one. There was lots I could have done with the old one, but I didn't know how until now. Then, I practiced what I was learning. Finally, although I was terrified, I made the switch to the WordPress.org blog, using CloudAccess as a host, the same one Brandy over at the Prudent Homemaker uses. It does cost a little money, but the ads won't be there unless I put them there. Since I don't know how to do that, there won't be any for a while, anyway:). They were able to tell me what to do so that this site could be moved over to the new one at beckyathome.com. It has taken most of the past 2 days, with me up until midnight each night, going back and forth with the customer service workers. They helped so much. I don't know how hard it would be to move a Blogger blog to WordPress, but that would be a question to ask. It might be expensive. I had determined that I would start all over if it was too much, but that was not an issue in my case. My blog is quite small at this point, compared to many.
All new posts will generate from there, so everyone will need to find that site and re-subscribe. I won't lie–it has been very hard for me because I'm not very computer literate, but the customer service has been awesome and we are getting somewhere. When it got moved over there, it looked very different. I've worked on it, and it's looking better. I could have paid money to get them to do that but thought I'd mess around a while first and see what happened.
Congrats on your new blog, looks great. Always enjoy reading what you write.
Thank you, Jacki. I am still on such a huge learning curve that I'm sure things are going to flex and change a bit as I get things figured out. It's kind of exciting to me, though, now that I and the support team got the old blog moved over here. I was quite worried!
You did a great job switching over! The meal looked really good! I love how you guys do this!
I enjoyed the pictures of the meal! It was worth the wait.
Your new blog looks great and I understand how hard it is to make changes. I, too, am not computer literate and it is extremely hard to learn something new. The instructions will say go to "so and so" and do "such and such." I won't know what" so and so" is or where "such and such" is located.
Thanks, Jeannie! It's still a work in progress. They say it keeps your brain young to learn new things. My brain must be getting close to being a baby again:). Or it's going to pop one of these days! Either way, I'm sure learning a lot! I cannot tell you how many times I've read or listened to some of those tutorials before I "got" it and could do what they asked!
The link you gave me in the comments section worked great. I've bookmarked it so will come here now. Way to go in learning all you needed to learn to make it happen. I'm quite impressed. My computer skills are at best 'beginner' at this point in time.
Great post about the two dinners.
I'm so glad the link worked for you! Trust me, I'm a beginner when it comes to this. I cannot tell you how much my hair has been sticking up on end with me running my fingers through it whenever I get frustrated! But, it's coming together. I've been studying for months to learn how to make this move.
I was able to access your new blog from the first link you provided on the other one.
The meal you served was a fancy one! I love the presentation of the plated main course! So elegant!
I'm glad that one worked for you, as well! The meal was super fancy. It was fun to give the kids a taste of something they don't get every day. The kid who "ordered" that meal didn't want green beans, but those plates were very cool, also, as the beans were kind of plated to stick up a little and added more texture to the plate. I was wishing I had more pictures, but we were so busy getting things cooked, plated and out there that I couldn't get more:). It was a pretty wild evening!
So glad I was able to find your new blog. Everything looks great on the blog and the kids at the parties. I would have skipped ice skating too and gone right to bed after.
Thank you! I was suffering quite a bit of anxiety until everything transferred over, but it did! And, now, I get to continue to explore, and read tutorials until I get it how I want it, but it will likely take a while more.
Those kids are full of energy, that's for sure! I will say that Rob took Jake home, and fed him bagels and things until 10:30 (he was starving!), and my sister, brother-in-law, and I flopped on the couches like slugs until the kids came back, I got Patsy and came home….It was a long, but rewarding day!


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With all the latest Toyota models, 100s of used vehicles in stock we are sure to have to perfect car for you. We also offer Motability sales, Business sales, aftersales care and accident repair - come and see us on Wheatley Hall Road & we'll have a coffee waiting for you!


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Five fast facts from the world's largest brewhouse
Not only is Grupo Modelo's brewery in Zacatecas, Mexico, the largest brewery in the country, it's home to the world's largest brewhouse. Enjoy these five fast-facts about this destination that should be on every beer-lovers bucket list.
What's a brewhouse? The room in a brewery that houses vessels called tuns or kettles, usually made of stainless steel, where the 'hot' steps in the brewing process (mashing, filtration, boiling) take place.
1. Our Zacatecas brewery produces six million cans and 20 million bottles of beer every day, including flagship brand, Corona, as well as Victoria, Negra Modelo, Pacifico, Bud Light and Michelob Ultra.
2. All told, our team of 3,000 people will brew 24 million hectoliters of beer annually - that's more than 5 billion pints - enough to fill nearly 1,000 Olympic sized swimming pools.
3. The silos where malt is stored each stand 15-stories (45 meters) tall – equal to one of Mexico's most recognizable landmarks, the Angel of Independence in Mexico City, or almost 200 bottles of Corona stacked on top of each other.
4. To empty just one of the brewery's 140 cylindrical conic tanks (where the fermentation and maturation steps of the brewing process take place) 126 people would have to drink one liter of beer a day, every day, for 40 years!
Cylindrical conic tanks (yellow striped), exterior and interior
5. Sustainable brewing practices are also not in short supply in Zacatecas. The brewery was the first in Mexico to reach prestigious level 2 certification from the National Environmental Audit Program, was recognized for environmental excellence by the Ministry of Environment and Natural Resources. And in 2019, Grupo Modelo reduced water consumption by 11% across all of its breweries in Mexico!
While much has changed at the Zacatecas brewery since opening in 1997, one thing that never alters is the team's commitment to its proud brewing heritage. No matter how much the operation grows, Grupo Modelo remains true to the traditions that ensure its iconic and natural beers will continue to be enjoyed as they have since 1925.


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Q: Bootstrap multiselect only works on first use I'm using Bootstrap v3.0.0
The multiselect control's generated markup is comprised of a <select> and a
 containing a <button> and a
.
The
 seems to be what's actually displayed to the user. The problem I'm having is that everything works fine for the first time the user interacts with the control, but once the control has been opened, regardless of whether any selections have been made, after the control closes it can never be reopened unless you refresh the page.
I looked at the markup the control is generating and I noticed that before the control has been interacted with the
 looks like the following:

<input type="checkbox" value="multiselect-all">  Select all

<input type="checkbox" value="A"> Active

<input type="checkbox" value="D"> Disability

<input type="checkbox" value="P"> Pending

<input type="checkbox" value="T"> Terminated

But once the control has been interacted with, regardless if a selection was made, the markup changes to:

<input type="checkbox" value="multiselect-all">  Select all

<input type="checkbox" value="A"> Active

<input type="checkbox" value="D"> Disability

<input type="checkbox" value="P"> Pending

<input type="checkbox" value="T"> Terminated

display: none; is being added to the
 style attribute. I'm not sure where it's coming from. None of my javascript touches the generated markup. If I use the dev console in chrome to remove the display: none; attribute the control works again for one interaction before it adds display: none; back to the
 causing the control to no longer open again.
The multiselect still behaves as if everything was working, with the onDropdownShown and onDropdownHidden events still firing.

redpajama_set_name: RedPajamaStackExchange


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Q: VB.Net  - how to support implicit type conversion as well as custom equality Fixed:  See notes at bottom
I am implementing a generic class that supports two features, implicit type conversion and custom equality operators.  Well, it supports IN-equality as well, if it does that.
1) if ( "value" = myInstance ) then ...
2) Dim s As String = myInstance
3) Dim s As String = CType(myInstance,String)

The problem I am having is that if I support #2, implicit conversion, then I can't get my equality operators to work, since they complain about no conversion being the most specific.
The error I get is this (simplified a bit for brevity):
Overload resolution failed because no accessible '=' is most specific for these arguments:
    'Public Shared Operator =(obj As MyClass, data As String) As Boolean': Not most specific.
    'Public Shared Operator =(data As String, obj As MyClass) As Boolean': Not most specific.
    'Public Shared Operator =(obj1 As MyClass, obj2 As MyClass) As Boolean': Not most specific.

What is the best way of implementing this.  Just as importantly, what should I leave out?   I have implemented the following conversions
Operator =(ByVal data As String,    ByVal obj  As classType) As Boolean (and <>)
Operator =(ByVal obj  As classType, byval data As String) As Boolean (and <>)
Operator =(ByVal obj1 As classType, ByVal obj2 As classType) As Boolean (and <>)
Equals(obj as Object) as Boolean
Equals(compareTo as classType ) as Boolean
Equals(compareTo as String) as Boolean
Widening Operator CType(ByVal source As String) As classType
Widening Operator CType(ByVal source As classType) as String
Narrowing Operator CType(ByVal inst As classType) As dataType

In my widening operator I do some reflection, which is why I wanted to be able to do an implicit convert DOWN to String when I do a comparison or assignment with the string on the left side.
A) SomeObject.StringPropertySetter = MyClass

Fix (edit)
I went way overboard in what I implemented, because I didn't understand what was happening.  Comparison between the base types (ie string/double/guid) takes place via the widening ctype(...) as String (or Guid,etc) operator.  In the end, i just implemented these functions and all my test cases still pass, in addition to assignment from the class to a base type instance
Public Class MyClass(Of BaseType)

    Widening Operator CType(ByVal source As dataType) As MyClass
    Widening Operator CType(ByVal source As MyClass) As dataType //conv between inst & base
    Equals()  // for datatype, classType, object
    Operator <>(MyClass,MyClass) // for comparison between two instances
    Opeator   =(MyClass,MyClass)

comments are c style, but code is vb.net
Of course the class is a little more complicated than that, but that give me everything I needed :)

A: You should not override the = operator. If you have implicit conversions to types such as string or int, then let the default equality operator take over.
As a general rule, if you need to customize equality for a class you should override the Equals(object) method.


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"S" Corporations and the Built-In Gains Tax
Taxation is an area that most practitioners find intimidating because of the intricacies of the Internal Revenue Code, Treasury Regulations, and the technical jargon used to describe transactions and situations. While taxation is undoubtedly complex, it is important for an attorney to understand the fundamental concepts that can affect a corporate client.
Over the years, the Subchapter "S" Corporation ("S Corporation") has played an important role in choice of formation for a business. However, if the S Corporation has had any history as a "C" corporation ("C Corporation"), a concept known as the built-in gains tax may surface. This article will briefly explain the important aspects of S Corporations and offer an overview of the associated built-in gains tax.
Overview of "S" Status
To understand the implications of the built-in gains tax, it is important to have some familiarity with "S" status. An S Corporation is essentially a C Corporation that elects "S" status.1 Electing "S" status combines the formal structure of a corporation under state law with a tax regime similar to that of a partnership or limited liability company. Thus, income, deductions and tax credits "pass through" to the shareholders of the S Corporation as opposed to being taxed at the entity level, creating only one level of tax for the shareholders.2
To be eligible for "S" status, the entity must meet some basic requirements. The electing entity must be a domestic corporation with only one class of stock.3 Additionally, the entity cannot have more than 100 shareholders.4 These shareholders must also be natural persons5 and US citizens or residents.6 Lastly, the IRC excludes insurance companies, financial institutions, and domestic international sales corporations from electing "S" status.7
Major Differences Between S Corporations and C Corporations
S Corporations differ from C Corporations, particularly with respect to the entity-level tax. The C Corporation will pay tax on income it generates, then, when the business distributes cash or property to its shareholders, the shareholders will also pay tax on the receipt of that cash or property. Since an S Corporation is a "pass through" entity, one layer of that "double tax" is removed. Accordingly, the shareholders of the S Corporation will only have to pay tax on the "passed through" income.8 Each shareholder will report the income based on his or her pro rata share of ownership.9
Another major difference is the treatment of distributions made to the shareholders. Cash distributions made by a C Corporation, are normally taxable.10 In this regard, C Corporations have limited flexibility in distributing cash to shareholders, which promotes shareholders to distribute cash through other means. For example, the owners of a C Corporation may be motivated to classify cash distributions as rent, salary or interest. While this strategy may be successful, the IRS scrutinizes these "distributions" and may classify them as taxable.
Conversely, an S Corporation provides a more flexible approach to distributing cash to its shareholders because cash distributions are generally not taxable.11 Furthermore, when a C Corporation distributes appreciated property to its shareholders, the IRC treats this distribution as if the corporation sold the property to its shareholders for the property's then fair market value.12 This type of transaction results in taxable income for the corporation and the shareholders. An S Corporation, however, is generally not taxed on such a transaction.13
The Built-In Gains Tax
Hypothetically, if a C Corporation converts its status to an S Corporation, it may avoid immediate tax consequences. In that case, all C Corporations should convert if the shareholders are willing to relinquish C Corporation status to avoid the entity-level tax. However, the built-in gains tax prohibits such gamesmanship.14 The built-in gains tax was enacted by the 1986 Congress as part of the overhaul to the IRC. Since S Corporations are not taxed on the distribution of appreciated assets,15 Congress was concerned that some C Corporations would convert to S Corporations, circumventing a layer of double tax in distributing assets. Under URC § 1374, an S Corporation that was formerly a C Corporation is subject to an entity-level income tax, at the highest C Corporation tax rate,16 on disposition of appreciated assets.17 Notably, the tax will only result on the pre-conversion gain lurking in assets.
The threat of the built-in gains tax is not interminable because it only applies to the 10-year period starting from the date of conversion, known as the "recognition period."18 In recent years, Congress reduced the recognition period for the built-in gains tax.19 This shortened recognition period is set to expire at the end of 2013 if Congress takes no action.
As an example of how the built-in gains tax applies, suppose that XYZ, Inc., holds an asset that has a value of $10,000 and a basis of $5,000 and converts from a C Corporation to an S Corporation in Year 1. In Year 3, XYZ, Inc. sells that asset for its then fair market value of $15,000. There is a total gain of $10,000 resulting from the sale of the asset; however, part of that gain, $5,000, is considered built-in gain because it is the excess of the fair market value over the basis at the time of conversion. Assuming that the highest corporate tax rate is 35%, XYZ, Inc. shareholders will pay $1,750 in built-in gains tax on the sale of the asset. The calculation for determination of built-in gains can be quite complex. The applicable Treasury Regulations provide a rigorous formula for determining built-in gains. The goal of this calculation is to determine the net tax consequences to the corporation in a hypothetical liquidating sale of the entire business.20
Navigating the Built-In Gains Tax
One significant issue that arises with conversion is the appraisal of the business' assets. A higher fair market value at the time of conversion risks greater potential for built-in gains to arise. To reduce the tax liability associated with conversion, it is imperative to obtain a proper appraisal of the assets at the beginning of the recognition period.
Proper appraisal will ensure that the IRS cannot dispute amounts relating to the appreciation of assets and increase the built-in tax gains tax. The onus is on the taxpayer to establish that a portion of the gain on the sale constitutes post-conversion appreciation.21 To achieve a proper appraisal, the appraiser should possess the relevant qualifications for valuing assets in similar businesses and should also be familiar with the IRC and the Treasury Regulations. This will ensure that the IRS has little room to dispute pre-conversion fair market value. Another issue that emerges in the conversion is the sale of inventories. Surprisingly, the built-in gains tax applies to the sale of inventory during the recognition period.22 Since the built-in gains tax may apply to individual sales of products during the recognition period, day-to-day operations may trigger the built-in gains tax.
This can create a serious problem for an S Corporation not utilizing the "last in-first out," or LIFO, inventory system. Generally, if the S Corporation does not use LIFO, the corporation will be required to treat the inventory items on hand at the beginning of the recognition period as the first items sold during the recognition period. This means that if inventories generally turn over at least once each year, the gain lurking in inventory may be subject to the built-in gains tax.23 Yet another important concern that arises in the conversion is the use of favorable tax attributes. Throughout its lifespan, a C Corporation may accumulate a number of tax attributes that can be carried forward or back to lower its tax liability. These tax attributes include net operating losses, excess charitable contributions or certain tax credits.
However, an S Corporation generally cannot carry forward or back favorable tax attributes.24 This is contrary to the underlying policy of the built-in gains tax, which is to treat the S Corporation as if it remained a C Corporation. To reconcile this disparity, the IRC allows an S Corporation to use some of those favorable tax attributes obtained as a C Corporation to reduce the built-in gains tax.25 However, it is important to note that the IRC does not permit full use of all favorable tax attributes, such as excess charitable contributions.26 Practitioners advising a converted S Corporation should be fully aware of the favorable tax attributes that may reduce potential built-in gains tax.
The conversion to an S Corporation may seem simple from a mechanical standpoint, but the built-in gain lurking in the corporation's assets may complicate matters and subject the S Corporation to an additional tax. Attorneys representing business owners wishing to convert or that have converted in the past should take care in planning dispositions of assets to minimize the potential for built-in gains tax.
Jon H. Ruiss, Jr. is an associate at Ruskin Moscou Faltischek, PC, in Uniondale, and is also a Certified Public Accountant.
1. See IRC 1362(a).
2. See IRC § 1366.
3. IRC § 1361(b).
4. IRC § 1361(b)(1)(A).
5. IRC § 1361(b)(1)(B). See IRC § 1361(c)(1)(A), (B) for exceptions.
6. IRC § 1361(b)(1)(C).
7. IRC § 1361(b)(2).
9. See IRC § 1366(a)(1).
10. See IRC § 301 et. seq.
11. Some distributions to S Corporation shareholders may be taxable. See generally IRC § 1368 and Treas. Reg § 1.368-3.
12. IRC § 301(b)(1).
13. See IRC § 1368.
15. See discussion, supra.
16. IRC § 11(b).
17. IRC § 1374(d)(7)(A).
18. IRC § 1374.
19. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111–5, 123 Stat. 115 (2009), and Small Business Jobs Act of 2010, Pub. L. No. 111–240, 124 Stat. 2504 (2010).
20. IRC § 1374(b. See also Treas. Reg. §§ 1.1374-1 & 1.1374-2.
21. IRC § 1374(d)(3).
22. Treas. Reg. § 1.1374-7(a).
23. See Treas. Reg. § 1.1374-7(b).
24. IRC § 1371(b)(1).
25. IRC § 1374(b)(2), (3).
26. See IRC § 170(d)(2).


It is expected that in the next 10 years the biotech/pharma field will be greatly affected by the rapid development of gene therapy applications, as these make their way to complement or replace traditional approaches.
In this section of biohive.net recent developments and news from this exciting field will be presented and discussed.
If you would like to suggest a gene therapy-related link, article or development that you would like to see on BioHive, please send an email to info@biohive.net.
For a complete list of all "Gene Therapy" posts, please click here.
I currently work at a Strategy Consulting firm supplying services to various pharmaceutical and biotechnology companies. The views expressed in this website are my own. I am not speaking officially for, or representing in any way, any company or corporation.
You can connect with me on LinkedIn here and you can follow me on Twitter here.
You can also join my LinkedIn groups: Gene Therapy Network, Life Sciences Investment Network, Life Sciences/Pharmaceuticals/Biotechnology Consulting and AIDS/HIV Vaccine.
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This thirty year old military wife and mother from Virginia Beach consulted with me about breast surgery and also an abdominoplasty. She was unhappy with the shape and symmetry of her breasts. Upon exam, it was revealed that her left breast was larger and also lower than the right. She wanted to be more symmetric with less sag and more fullness at the top. After a thorough discussion, together we decided that her best result would be to perform a full breast lift with removal of some tissue and placing implants to give her the fullness she wanted. To make her more even, we removed more breast tissue on the left and also filled her right implant slightly more. You can see from the after photos that she looks more symmetric and she achieved the fullness she wanted at the top. Because she had a full lift, the safest way to perform her abdominoplasty was a separate surgery 3 days later. This Virginia Beach woman is thrilled with the results of her "Mommy Makeover" and the fact that her safety was our top priority.


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Who Is Ari Melber Married To? A Look Into His Bio, Married Life, And Net Worth
Ari Melber ( Images source: Instagram )
Ari Melber is an Emmy award-winning American attorney, journalist, news anchor, and writer. He hosts The Beat with Ari Melber on MSNBC which draws the largest audience for any 6 pm show in the history of MSNBC.
He works as the network's Chief Legal Correspondent, reporting across all platforms. These platforms include MSNBC, NBC News, The Today Show, and Nc Night, Y News. He received the prestigious Emmy Award for his reporting on the Supreme Court in 2016.
He covers news, politics, law, and culture and interviews a diverse spectrum of guests on the show The Beats.
A post shared by Ari Melber (@arimelber)
Ari Melber Bio
Ari Melber was born in Seattle, Washington on March 31, 1980, to his parents Danie M. Melber and Barbara D. Melber. His family is a European Jewish immigrant from Israel. His grandparents were the survivors of the Holocaust.
He was often bullied as a child for his Jewish family's middle-class status. Nevertheless, Ari was a bright student who consistently scores the highest marks in his academics. He attended Garfield High School in Seattle, Washington. He graduated from the University of Michigan with an A.B. degree in political science.
He first got interested in politics while he was in high school. The reason he pursued a degree in Politics at the University of Michigan was to explore his passion. Ari moved to Washington, D.C., and worked for Senator Maria Cantwell after college.
Ari started his media career as an intern at the office of a well-known public defender in New York City. He worked for First Amendment lawyer Floyd Abrams at Cahill Gordon & Reindel for 4 years from 2009. He also started writing political columns for various news outlets such as The Nation, The Atlantic, Reuters.
In April 2015, Melber was named as the chief legal correspondent of MSNBC. The journalist currently resides in Carroll Garden Brooklyn, New York City. Ari is also a member of the New York State Bar Association.
His career has been treating him quite well. He has established a fanbase as a public persona. His Instagram profile has accumulated 327k followers.
You May Also Like: Who Is Elsaaababy? Find Out The Real Name, Age, Net Worth Of The YouTuber
Is Ari Melber Married?
Ari is not married at the moment. He got married to Drew Grant in 2013 in a very intimate wedding. Drew and Ari were together for three years before getting married. The two did not welcome any children from their marriage.
Ari And Drew ( Source: Biography Mask)
They called off their marriage three years later for undisclosed reasons.
Who Is He Dating?
He is rumored to be dating the When We First Met actress, Alexandra Daddario. The two were spotted having lunch together at Café Habana in Malibu. They seemed very affectionate which further escalated the speculation.
Ari And Alexandra (Source: SuperbHub)
Ari prefers to keep his personal life private. It is difficult to tell for sure if he and Alexandra are still dating or not. Even his social media accounts don't let anything about his dating life slip past.
Ever since the release of Baywatch on May 17, fans had been shipping Alexandra with her co-star Zac Efron. But there has been no information on Alexandra and Ari's relationship at the moment.
Who Was Drew Grant?
The ex-wife of the journalist Drew Grant is a pop culture reporter for the New York Observer. The two apparently got along due to the common nature of their work.
Source: The Famous People
There have been rumors that Drew has a relationship with a new boyfriend at present.
What Is The Net Worth Of Ari Melber?
Ari makes a decent salary each month with such an important job. Most of the MSNBC employees reportedly get around $64,000 on average. He earned a good amount of money from NBC as well. NBC pays its employees about $72,000.
Given his experience ad excellence, he makes around $2 million per year. Many sources have estimated his net worth to be not less than $12 million. Ari has also bought a house in Washington DC.
Ari Melber Drew Grant


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News, Startups
PITB and Sweden-based Nutty Ventures sign MoU for promotion of local startups
Written by Usman Aslam Dec 31 · 1 min read>
Punjab InformationTechnology Board (PITB) and Sweden based Nutty Ventures AB signed an MoU today, committing to providing increased exposure to Pakistani startups in Sweden, creating tailor-based coaching opportunities for Pakistani startups, strengthening acceleration programs, and creating opportunities for international Investors and Venture Capital funds to consider investing in Pakistani startups.
While speaking at the ceremony, Punjab's Provincial Minister for Higher Education & Information Technology Raja Yassir Humayun Sarfraz said,
"Government of the Punjab envisions technology as an engine of economic growth as IT is opening new frontiers every day and our aim is to provide best-in-class coaching to startups, so they can compete at an international level for visibility and necessary funding for accelerating growth. I value this partnership because it will provide exciting opportunities to our local startups and will further strengthen PITB's existing programs in entrepreneurship and freelancing domains".
Chairman PITB Azfar Manzoor said,
"Pakistani startups have made their mark in the global arena which is manifested through an increase of over 300% funding raised by local startups during the last year. In line with the vision of the government, PITB's entrepreneurship and freelancing programs are not facilitating the youth of Punjab through incubation and skills development programs but are also helping them in creating the much-needed linkages with the foreign investors and venture capitalists."
It is worth mentioning that PITB is running a range of successful incubation and freelancing programs not only in Punjab but in other provinces as well. As a result of this partnership, all local startups will stand to benefit.
Nutty Ventures AB, which is currently running a Sweden-wide accelerator program, has extensive experience and network in the Swedish startup, impact, and funding ecosystems. Its Founder and CEO, Mehkar Sheikh said,
"Today, change is happening faster than at any other time in human history. We need bold new ideas, at an accelerated pace, cutting through the traditional hierarchies and structures. Nutty Ventures will leverage the power of global best practices to create meaningful impact for PITB-backed startups."
Sweden is one of the leading countries in the world in innovation, startup activity, and more recently in impact. According to the latest report, Stockholm currently has the highest number of tech unicorns per capita in the world after Silicon Valley.
Nutty Ventures Pakistani startups PITB
Written by Usman Aslam
A tech enthusiast, writer, researcher and strategist working on the latest technologies and making an impact. Usman has been heavily focused on building communities, empowering people through technological trends and advancements for over 3+ years including many notable names such as IEEE Region 10, TEDx, Google Developers, United Nations Programmes, Microsoft Partner Program and much more. Reach out: usman.aslam@techjuice.pk Profile
Up Next: Ericsson brings $31 million investment to Pakistan: IT Minister


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Q: How can I configure clipboard as Windows? Windows 7, XP... maintains the copy text if you close the application.
How could I configure Ubuntu for this behavior?
Thanks in advance!

A: According to this wiki, whether the clipboard contents are remembered after the source application is closed depends on the application but several programs in X11-based operating systems do not ensure that the clipboard is remembered.
The user may want to install a clipboard manager to deal with this issue. Some common ones available from the software center are Parcellite, Clipit, xfce4-clipman, and Klipper. A longer list is available here.


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Bunny Wailer, last surviving founding member of reggae group The Wailers, dead at 73
Israel Vibration | Entertainment | Jamaica Gleaner
Been given Jamaica's highest honours
Singer, songwriter, farmer
Bunny Wailer, a reggae luminary who was the last surviving founding member of the famous team The Wailers, died on Tuesday in his indigenous Jamaica. He was 73.
Wailer, a baritone singer whose delivery title was Neville Livingston, was also recognised as Jah B. He fashioned The Wailers in 1963 with late superstars Bob Marley and Peter Tosh when they lived in a slum in the cash of Kingston. They catapulted to worldwide fame with the album, Capture a Hearth and also served popularize Rastafarian society between much better-off Jamaicans starting up in the 1970s.
"Jah-B was a vanguard, generally pushing the boundaries of expression, no matter whether in song, in design or in spoken term," claimed Brian Paul Welsh, manager for the reggae musician regarded as Blvk H3ro. "There was and can only ever be a person Neville Livingston."
Credited with popularizing reggae new music, the Wailers toured the world and experienced various strike music in the ska and rocksteady styles, like Simmer Down, Lonesome Emotion, and Thank You Lord.
Along with Tosh, Livingston sooner or later remaining the team to grew to become a solo artist, though Marley started touring with new band associates as Bob Marley and the Wailers.
Wailer performs at the 1 Really like live performance to rejoice Bob Marley's 60th birthday, in Kingston, Jamaica, on Feb. 6, 2005. (Collin Reid/The Related Press)
Wailer recorded 10 albums, winning Grammys for Best Reggae Album for Time Will Tell: A Tribute to Bob Marley in 1991, Important! Roots Basic in 1995, and a tribute to Marley in 1997. As a solo artist, his hit music provided Amazing Runnings and Bald Head Jesus.
He been given many of Jamaica's maximum honours, which includes the Purchase of Merit and the Buy of Jamaica.
Wailer died at Andrews Memorial Medical center in the Jamaican parish of St. Andrew of problems from a stroke in July, supervisor Maxine Stowe advised The Connected Press.
His demise was mourned around the globe as persons shared songs, reminiscences and photos of the renowned artist.
"The passing of Bunny Wailer, the previous of the authentic Wailers, delivers to a shut the most lively interval of Jamaica's musical expertise," wrote Jamaica politician Peter Phillips in a Fb submit. "Bunny was a fantastic, aware Jamaican brethren."
Jamaica's Key Minister, Andrew Holness, also paid tribute to Wailer, calling him "a highly regarded elder statesman of the Jamaican songs scene," in a series of tweets.
"This is a great loss for Jamaica and for Reggae, unquestionably Bunny Wailer will always be remembered for his sterling contribution to the music sector and Jamaica's society," he wrote.
While Wailer toured the planet, he was a lot more at dwelling in Jamaica's mountains and he relished farming whilst composing and recording songs on his label, Solomonic.
"I think I really like the region actually a little little bit more than the city," Wailer advised The Linked Press in 1989. "It has more to do with lifestyle, wellbeing and energy. The town takes that away often. The state is superior for meditation. It has fresh meals and clean atmosphere — that retains you likely."
A year prior to, in 1988, he experienced chartered a jet and flew to Jamaica with food to assist individuals impacted by Hurricane Gilbert.
"From time to time individuals shell out fewer focus to people items (meals), but they flip out to be the most critical things. I am a farmer," he advised the AP.
He was the third and final remaining founding Wailer. Marley died in 1981 of a brain tumour at 36 decades old and Tosh was fatally shot in Jamaica in 1987 at 42 years outdated.
Posted in Original ArtsTagged #Bunny #Dead #founding #Group #member #reggae #surviving #Wailer #Wailers
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Storm Reid Teases Her Character's Journey in 'Euphoria' Season 2 (Exclusive)


Josh and Jess are mortgage brokers that would like to buy a large home with character outside of Chicago. Josh has his heart set on a Prairie style house in his hometown of Evanston. Jess would prefer a Victorian style home, and she thinks living outside of Evanston would be wiser since you can get a better deal on a place.