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The UK Patent box – will it come back in through the back door, accompanied by Germany?
Posted by Nicholas Shaxson in EU on November 14, 2014
Cross-posted from the Tax Justice Network, with permission:
We've just written a blog about the UK's nasty, disingenuous and hypocritical patent box regime, and how recent moves announced in a joint UK-agreement to reform it have successfully been spun as a "watering down" of the rules under pressure from Germany.
The blog points out that the joint UK-German announcement, which is quite short, is cryptic. It explicitly states that "IP regimes" (which is what patent boxes are) are out: well and good.
But, as we asked, will some sort of equivalent to or variant of the Patent Box be brought back in through the back door? Sources have alerted us that there seems to be some skulduggery involved here. Read the rest of this entry »
What Luxembourg's tax haven business looks like
Posted by Nicholas Shaxson in EU on November 6, 2014
Following the huge Luxembourg Leaks story that's emerged this morning, I thought I'd post a little reminder of what the tax haven business in Luxembourg actually looks like.
This short one-minute video, from the Treasure Islands website, was created in 2011. The offending Apple Itunes mail box address has since been moved, but we think the video still gives a good indication of just how artificial the whole business is.
(The embed code isn't working today for some reason; click on the link to see it.)
Go, as they say in the U.S., figure. (Full disclosure: yes, it was filmed on an, er, Apple Iphone)
There's lots more to say about this. First, recent EU efforts to tackle certain tax deals from the likes of Apple and Fiat are not going to significantly crack down on the problem. This needs much bigger international action.
Second, it is incorrect to say, as many have done, that this concerns 'perfectly legal' behaviour. It does not, as the TJN blog explains clearly.
Third, in my view there hasn't been nearly enough attention paid to PWC, the Big Four accountancy firm at the centre of these revelations. The same TJN blog notes, via Prem Sikka, some recent testimony in front of the UK Public Accounts Committee:
"The committee received evidence from a former senior PwC employee stating that within the firm the policy was that it would sell a tax avoidance scheme which had only a 25% chance of withstanding a legal challenge. As the committee chairperson put it "you are offering schemes to your clients – knowingly marketing these schemes – where you have judged there is a 75% risk of it then being deemed unlawful".
Fourth, it's interesting to note that the Luxembourg Prime Minister who oversaw and defended all these nasty schemes for many years – along with a lot of the still more unpleasant secrecy business – was none other than Jean-Claude Juncker, who has just started a new job as . . . President of the European Commission. He has promised not to meddled to defend Luxembourg's interests, but couldn't help adding:
"I have some ideas on the topic but I'll keep my counsel."
Does that sound like someone who will resolutely not intervene on his country's behalf? Only time will tell. But we shouldn't forget these words of his, as reported:
"In this conference he admitted to often have lied in his career to prevent rumors spreading and said that monetary policy was too important to be discussed in public, but should instead be discussed in "dark secret rooms, behind closed doors". Juncker furthermore stated: "I'm ready to be insulted as being insufficiently democratic, but I want to be serious […] I am for secret, dark debates".
Some are worried that Luxembourg would suffer from the blowback from this. I quite like the quote from this senior G20 official, via a Guardian story:
"Asked recently if such a crackdown risked damaging the economy of Luxembourg, one senior figure closely involved in the G20 reform programme said: "I don't care. It is like saying: 'If you fight drugs there will be no jobs in certain parts of Mexico.' "
Quite so. There are victims, and then there are victims.
The main Luxembourg Leaks site is here, and the Luxembourg database is here. Also see TJN's Financial Secrecy Index report on how Luxembourg became a tax haven.
Tax haven Panama: it's time to think about sanctions
Posted by Nicholas Shaxson in EU on October 15, 2014
Adapted from the Tax Justice Network (TJN) Blog, with permission
Ten years ago Jeffrey Robinson published a book about tax havens called The Sink, where he quotes a U.S. Customs official as saying of Panama:
"The country is filled with dishonest lawyers, dishonest bankers, dishonest company formation agents and dishonest companies registered there by those dishonest lawyers so that they can deposit dirty money into their dishonest banks. The Free Trade Zone is the black hole through which Panama has become one of the filthiest money laundering sinks in the world."
Apple's tax shenanigans finally come under serious fire from the EU
Posted by Nicholas Shaxson in EU on September 29, 2014
"Apple will be accused of prospering from illegal tax deals with the Irish government for more than two decades when Brussels this week unveils details of a probe that could leave the iPhone maker with a record fine of as much as several billions of euros."
European Commission preliminary findings from the probe into Apple's Irish tax affairs, where the FT reports it had a rate of less than two percent, reportedly show Apple benefiting from illicit state aid via backroom deals with Irish tax officials. Read the rest of this entry »
IMF report heavily criticises the OECD's tax consensus
Posted by Nicholas Shaxson in EU on June 26, 2014
The IMF has a major new Policy Paper out entitled Spillovers in International Taxation, looking at the effects that one country's tax rules and practices can have on others.
Reading between the lines, this report constitutes a major attack on tax havens. "Spillovers" in international tax are all about tax haven activity, particularly when those spillovers are deliberately crafted. It also savages a significant part of the prevailing OECD tax consensus that has dominated international tax for the last century or so.
This is a really important document, and though it focuses on developing countries it has important implications for European countries as they consider the urgent matters of tax reform.
We are delighted to see the IMF convincingly takes the side of developing countries: not only taking sides in big current political fights (such as India vs. Vodafone)
but peppering the report with suggestions how developing countries can fight against all the erosion.
This makes a really refreshing change from the standard (often well-justified) stories about IMF programmes laying waste to developing countries.
The IMF says the aim of this exercise – which, by the way, is clearly written and should be palatable to interested non-experts – is to complement the OECD's BEPS (Base Erosion and Profit Shifting) project to help countries protect themselves from tax abuses, by looking at the spillovers. However, buried deep in the text are some devastating criticisms of BEPS too – notably that it doesn't properly address crucial issues of unfairness towards developing countries. The report notes:
"New results reported here confirm that spillover effects on corporate tax bases and rates are significant and sizable. . . . Spillovers are especially marked and important for developing countries. . . . The amounts at stake in a single tax planning case now quite routinely run into tens or hundreds of millions of dollars."
And, in terms of the tax base (that is, which part of cross-border income that developing countries get to tax), there's some startling quantification:
"The spillover base effect is largest for developing countries. Compared to OECD countries, the base spillovers from others' tax rates are two to three times larger, and statistically more significant. . . . The apparent revenue loss from spillovers. . . is also largest for developing countries."
Our emphasis added. Wow. And we'd agree with the next bit, of course:
"The institutional framework for addressing international tax spillovers is weak. As the strength and pervasiveness of tax spillovers become increasingly apparent, the case for an inclusive and less piecemeal approach to international tax cooperation grows."
That may be a gentle dig at the OECD, for not being ambitious enough. And there's plenty more: the IMF notes.
"[a] concern sometimes expressed that the system allocates too little tax base to developing countries"
In other words, considering all the different bits and pieces of income that flow from a cross-border investment from a rich country to a poor one, most of them get taxed by the rich country, leaving relatively little on the table for the poor country. What a surprise. And it notes the harmful effects of tax 'competition':
"The pervasiveness of the tax incentives that the IMF and others have long stressed as significantly undermining revenue in developing countries may to a large extent be a spillover reaction to policies pursued in other countries: a clear instance of tax competition."
Tax competition is the widely used term; but Tax Wars is the less economically illiterate term. The IMF also notes that – unlike the global trade system – the tax system is an uncoordinated and pretty disastrous hodge-podge. It contains an interesting statistical nugget: "the increased importance of intra-firm transactions (about 42 percent of the value of U.S. goods trade in 2012″ (consistent with the idea that about half of world trade happens inside multinational corporations)
The IMF report takes a swing or two at the OECD's BEPS process. For instance, in a section on tax treaties which allocate taxing rights among countries, the IMF notes that not only are the OECD models (that are generally the basis for these treaties) skewed in favour of richer countries, as we and other have often remarked, but it also adds:
"At issue here are deeper notions as to the 'fair' international allocation of tax revenue and powers across countries (which current initiatives do not address)."
That is a small sentence buried in the text, but it's devastating. And the IMF notes that defending the OECD consensus may even end up not serving the self-interest of OECD countries:
"Arrangements that seem to contradict broad perceptions of fairness, even if those are imperfectly articulated, may increasingly give rise to unilateral domestic measures to change them—with a consequent risk of uncoordinated defensive measures even further undermining the coherence of the international tax system."
Treaty reform, it seems is essential, as it notes in its key messages for developing countries:
The "sign treaties only with considerable caution" reminds us of a recent fiery intervention by Lee Sheppard, in which she urges developing counties not to sign these kinds of tax treaties.
Now here's something else that's fascinating. The IMF appears to be taking India's side in its recent tax tussle with Vodafone. Get a load of this:
"The tax treatment of gains on indirect transfers of interests in assets is a controversial issue—and one of particular importance to many developing countries."
This is where a multinational has an asset in a developing country, and that asset rises in value. It wants to sell the asset – but if it just sells it straight, it may have to pay capital gains tax on those gains. So instead the multinational sets up a shell company in a tax haven, to own the asset. This time it merely sells the shell company (which owns the asset). The sale is recorded in the tax haven, which doesn't tax capital gains. Bingo! Wealth is transferred from a poor country to wealthy shareholders of the multinational.
This is exactly the issue in the India-Vodafone fight – which the IMF explicitly mentions, along with billion-dollar cases in Mauritania and Mozambique (p70). And the IMF's conclusion on this?
"The laws of many developing countries need strengthening if they are to tax gains on such indirect transfers."
Go get 'em!
On the crucial issue of the OECD's Arm's Length Method (otherwise known as the Arm's Length Principle, or ALP), which we and many others have criticised extensively, the IMF recognises that it is badly broken though it does not fully endorse a move towards the main alternative, unitary taxation with formula apportionment (FA). Such an approach would tackle many of the existing problems, it argues, but would introduce new difficulties – and would not necessarily shift tax bases towards developing countries. Yet it adds:
"this approach, rather than one based on ALP, is so common at subnational level—indeed there seems to be no subnational CIT that does not use some form of FA—suggests that it has at least some merit in taxing firms operating across highly integrated economies."
(That bit in bold is our emphasis, because we (or at least today's TJN blogger) didn't know that.)
Whether or not developing countries would benefit from application of formula approaches internationally, the IMF notes that it depends on which kind of formula were applied:
The IMF urges 'closer study' of partial approaches based on formula apportionment, however, including hybrid approaches and 'profit split' methods which involve allocating taxable income between countries on a formula basis, but at a transaction level rather than at the level of the multinational group.
To finish, here's another little bomblet:
"[it has been argued that] low tax and conduit countries can improve the efficiency with which capital is allocated. These considerations generate heated dispute, but remain essentially uninformed by empirical knowledge."
It is almost funny how the IMF savages some of the tax havens' central arguments in their self-defence (see more here). The 2006 paper they cite in this respect (Desai, Foley and Hines) and earlier iteration by Hines in particular have become totemic for tax havens in their defence. "Uninformed by empirical knowledge" is perhaps as damning a statement as you will get from the scrupulously polite IMF.
There is plenty more in this report, but these are probably the main points, tax justice-wise.
To summarise: the IMF seems to be carving out new space in this arena with more time for the interests of developing countries, in some contrast to the OECD – which is, after all, a club of rich countries, and experience shows tends ultimately to bat for the interests of its member states.
A welcome addition to the literature.
Endnote: this article is cross-posted (in adapted form) with the Tax Justice Network and Financial Transparency Coalition blogs.
Switzerland fights to curb scope of global transparency moves
Posted by Nicholas Shaxson in EU on May 23, 2014
Cross-posted with the Tax Justice Blog.
The Swiss Federal Council on Wednesday issued a statement making it all too clear what it thinks "the new global standard for the automatic exchange of information in tax matters" should look like. This concerns the OECD's ongoing project to create a new framework for international financial transparency, which we've written about before: while we found shortcomings, we welcomed the project overall. The OECD is expected to finalise its global standard in June.
The Swiss position is a direct threat to global moves on transparency. A private tax adviser tells TJN:
"My view is that they are trying to wriggle out of it."
The Swiss statement is yet more evidence of what has been called a "circle the wagons" strategy: when under pressure from a world that's moving forward, give ground only inch by inch, if at all; hold on to secrecy where possible – and particularly exploit the weaknesses of weaker and more vulnerable countries.
Meanwhile, trumpet to domestic and international media and anyone who will believe them how, ahem, clean, well-regulated and transparent the historic haven for thieves and abusers has suddenly become!
The Swiss statement says, for instance:
- Negotiations on the automatic exchange of information with other selected countries are to be examined. In an initial phase, priority would be given to the introduction of the automatic exchange of information with countries with which there are close economic and political ties and which, if appropriate, provide their taxpayers with sufficient scope for regularisation and which are considered to be important and promising in terms of their market potential for Switzerland's finance industry.
- The introduction of the automatic exchange of information with foreign countries would be conducted by means of separate bilateral agreements with the partner countries. Moreover, implementing legislation would be required in national law. Existing legislation excludes the automatic exchange of information."
Our emphasis added (thanks to Koen Roovers for bringing this up). The private adviser notes:
"They are trying to choose who to exchange with, and under what conditions. The OECD system was not set up so that countries can add whatever riders they like onto it. They [the Swiss] want to turn this to their advantage, maybe to even move backwards from where they are now."
As we have noted, multilateral negotiations with intransigents like Switzerland are always more fruitful, but Switzerland wants to make sure it has maximum leverage over vulnerable developing countries.
The Swiss statement goes further. It insists that:
- the exchanged information should be used solely for the agreed purpose (TJN: that's an effort to keep the scope of transparency as narrow as possible; only let information be used for tax investigations, but – please! – not for corruption, embezzelement, and so on),
- the information should be reciprocal, i.e. should flow in both directions, (TJN: as we've noted, this 'reciprocity' is unnecessary and unfair for many poorer countries)
- data protection must be ensured and (TJN: a motherhood-and-apple-pie statement that in itself is fair enough but can be abused to restrict the scope of information exchange drastically)
- the beneficial owners of trusts and other financial constructs should also be identified. (OK, as far as it goes)
- Moreover, the Federal Council stated that, where appropriate, the issues of regularisation of the past and market access are to be incorporated into negotiations on the automatic exchange of information. (playing hardball: hanging on to secrecy for past assets, trying to gain advantage wherever possible.)
Mark Herkenrath of Alliance Sud in Switzerland adds:
"The Swiss government will stick to a bilateral approach to AIE and engage in "cherry picking". That is, it will try to exclude developing countries from AIE for as long as possible – despite opposition by various NGOs and Left-wing members of parliament and a lively debate within the federal administration (I do not think the Swiss development agency SDC is in favor of excluding developing countries from AIE).
The problem is that the Swiss government is not expecting any external resistance to this strategy of cherry picking. Neither the OECD nor the G20 have made a clear statement in favor of a multilateral approach to AIE. Nor have they asked for the inclusion of developing countries in such a multilateral approach. Nor have LIC/LDC governments made it clear that they wish to be included."
Koen Roovers of the Financial Transparency Coalition summarises:
"This is the moment where Switzerland, likely with the silent support of other rich nations, show what all this is really about: countries with which there are close economic and political ties will cooperate to not hurt each other economically (or in any case less), but that less fortunate populations of the world won't benefit from this international drive against large-scale tax evasion.
Meanwhile, they have created great spin and to some extent, were rehabilitated by mainstream media stating that 'Switzerland (& Singapore) joining the ministerial agreement meant the end of banking secrecy'.
He is quite right: the credulous nature of so many media reports about Switzerland is breathtaking. He adds:
"In April, the Swiss development cooperation agency published a briefing calling for "systemic inclusion of the issue developing countries in Switzerland's internal strategy work in the field of automatic exchange of information and effective implementation of the multilateral OECD Convention on Mutual Administrative Assistance in Tax Matters."
It seems that voice hasn't been taken on board when the federal government communicated its position yesterday."
Indeed. Switzerland isn't the only country to lack such joined-up thinking, of course.
Endnote: Switzerland currently holds the top position in our Financial Secrecy Index.
Why Russia no longer fears the West. It's the offshore, stupid
Posted by Nicholas Shaxson in EU on March 3, 2014
Cross-posted with the Tax Justice Blog:
If there's one story you read today make it this one, from Politico Magazine. It's triggered by the crisis in Ukraine, but it's been a long time coming.
The point of this short story is clear: Western leaders are waking up to the fact that Russia no longer fears or even respects them. Why? Well:
"Russia thinks the West is no longer a crusading alliance. Russia thinks the West is now all about the money." Read the rest of this entry »
Show trial of Swiss whistleblower Elmer now in 9th year
Posted by Nicholas Shaxson in EU on January 28, 2014
Cross-posted with the new Tax Justice Network blog.
This month a Swiss court fought back against efforts by the United States to tackle criminal activity and tax its wealthy citizens properly. As Worldwide Tax Daily reports:
"A Swiss court on January 6 held that Switzerland's Federal Tax Administration
(FTA) "unlawfully granted" a U.S. request for client data from private banking group Julius Baer, saying it did not meet the requirements for an administrative assistance request under the Switzerland-U.S. income tax treaty."
This is the latest episode in a long-running saga which began in 2008 when Swiss bankers were caught red-handed trying to flog tax evasion schemes to wealthy U.S. taxpayers – and the U.S. responded with a crackdown, As a result, the two countries began working on new information-sharing protocols between the two countries that have had the effect of penetrating Swiss banking secrecy – though only up to a point, and only for the U.S.
As this episode unfolds, it's worth remembering the long-running and fascinating case of Rudolf Elmer, former Chief Operating Officer with the Cayman affilate of the high-society Swiss bank Julius Baer. Elmer became fed up with what he was seeing and was involved in – and blew the whistle, first in 2005. He began by telling the Swiss tax authorities of tax evasion by Swiss taxpayers, and later provided information to Wikileaks and the world's media.
This is not just yet another story of human rights abuses by a secrecy jurisdiction against someone who would challenge the financial establishment. It touches on deep contradictions at the heart of the Swiss model of offshore finance. As tax expert (and TJN Senior Adviser) Professor Sol Picciotto says:
"His story casts fascinating light into the `offshore' system, constructed by lawyers and other professionals, which has been central to the emergence of transnational corporate capitalism."
The main legal charge against Elmer is that he breached Swiss banking secrecy laws which make it a criminal offence to reveal secrets obtained as an official of a bank. The main part of Elmer's defence is that the information (which he admits he revealed) came from an affiliate of Julius Baer in the Cayman Islands, which is separate from its Swiss parent and therefore not governed by Swiss law.
Switzerland's efforts to use Swiss laws to go after secrets revealed elsewhere contradicts the underpinnings of Switzerland's own liberal use of offshore principles to help corporate and other tax cheats. For example, the Swiss tax authorities claim that profits earned by foreign affiliates (such as in the Cayman Islands) cannot be taxed in Switzerland, under the widely used 'separate entity' principle. As Picciotto notes:
"That is the essence of Elmer's case, and is why the prosecutors are finding it hard to nail him."
Since the first whistleblowing in 2005 he and his family have been hounded by the Swiss judicial authorities – which we would argue are 'captured' by the financial services industry: a classic feature of the so-called Finance Curse that afflicts finance-dependent economies. Of Elmer's 28 encounters with the courts, 27 decisions have gone against him, and he has been imprisoned twice: once for 187 days, and once for 30 days, under an archaic Swiss law that allows lengthy spells of detention for police interrogation. In a twist reminiscent of the Soviet era, Elmer said Zurich prosecutors requested psychological evaluation of him in 2009 and in 2011 but he declined to cooperate – mainly to avoid the risk of ending up in a mental institution. Elmer's long-suffering wife, would you believe it, is still under investigation for assisting in the breaking of Swiss banking secrecy.
Elmer also argues that the prosecution's case is full of errors and inconsistencies. He told us, via separate emails, in the past a few days:
"At the moment the judges of the High Court of Zurich have to find me guilty. They have invested too much in the matter and cannot lose face! If I do not win – which is likely – I might have to take the entire case to the European Court of Human Rights.
. . .
We can demonstrate that the law has been bent and stretched, in order to serve the bank and not to lose face. This is about politics in the courtroom, and not about the law of a democratic society.
. . .
The case is an opportunity to show that a secrecy jurisdiction needs a morally corrupt judicial system in order to survive."
Elmer's whistleblowing is in its ninth year now, and they still haven't dropped it. A truly independent judiciary, it seems, would have stopped trying to flog this horse long ago. But they haven't: the campaign of intimidation continues, and there are still two cases pending against him.
As an aside, Switzerland's decision to probe another Swiss banker who has provided information to U.S. tax authorities may be, as a recent article noted, designed as:
"a message to bankers: Keep quiet or else."
It's not just the Swiss authorities that seem to be in the pocket of the offshore banks. Much of the Swiss media seems substantially 'captured' too. While the rest of the world has focused on the big story: the exposure of large-scale criminality by wealthy élites around the world, much of the Swiss media has responded instead by focusing on questioning or smearing the whistleblower, with accusations (among many other things) that he is a 'thief and a blackmailer".
But it is the big story that interests us. Here's the whistleblower support site Liberté Info, with some interesting questions posed in a recent letter to the Zurich High Court:
- Why has the prosecution not performed a criminal investigation of Julius Baer Bank & Co. AG, Zurich on the facts provided by Mr Elmer, information which has been widely published and is publicly available on the internet?
- Why have the judges of the High Court, who do have the lead in this matter, not requested that such a criminal investigation be performed in order to evaluate the entire case and to understand whether Mr Elmer had good reasons to make this information public?
- Why have the assets of (a Mexican drug lord) and other alleged criminals, which have been exposed in this case, not been investigated by Zurich's authorities?
One can only wonder.
Netherlands admits shame in being tax haven, pledges limited reforms
Posted by Nicholas Shaxson in EU on September 6, 2013
Cross-posted with the Tax Justice Blog:
We have long criticised the Netherlands for being a particularly important European tax haven helping multinational companies escape taxation. As, increasingly, have many others in Europe, the United States, and elsewhere. We recently noted, too, how some developing countries have been kicking back at some of the abuses that have been perpetrated upon them with the help of the Netherlands and other tax havens.
We are now delighted to see a Financial Times interview Netherlands' deputy finance minister, Frans Weekers, making an admission that his government is uncomfortable with, and perhaps even ashamed of, the Netherlands' role in this pernicious trade. The Financial Times reports:
"A proposal by the Netherlands to renegotiate its tax treaties with 23 least-developed countries marks a turning point for a country that has until now deflected accusations that it is a key player in tax avoidance by multinational corporations.
The initiative, which comes as the G20 meeting in St. Petersburg is putting tax harmonisation issues high on the agenda, is the most concrete move yet by the Netherlands to address the criticisms. Tax justice advocates say the country's network of treaties with over 90 countries makes it a nexus for tax avoidance, allowing multinationals to reroute their profits through Dutch "letterbox companies" that do no real business in the Netherlands and exist largely for tax purposes."
This comes in the context and the spirit of today's G20 leaders' declaration, which includes a statement that:
"We call on member countries to examine how our own domestic laws contribute to BEPS [TJN: Base Erosion and Profit Shifting, OECD-speak for corporate tax dodging] and to ensure that international and our own tax rules do not allow or encourage multinational enterprises to reduce overall taxes paid by artificially shifting profits to low-tax jurisdictions."
There are big lacunae to be addressed in the Dutch plans, however. The FT article describes an official Dutch report presented last week, which seeks to insert new anti-fraud provisions in their tax treaties with the 23 countries; will pass on information to tax authorities in developing countries; and will 'crack down' on letterbox companies. In a brief email to TJN, Lee Sheppard of Tax Analysts spoke of the Dutch
"promises to put more 'substance' in shell companies MNCs [Multinational Corporations] use. Turns out the "substance" ain't gonna be much."
Despite the disappointments in the detail (as is so often the case with shiny-looking tax justice-styled reforms, or world leaders' statements on these kinds of issues) the broad new public statement by the Dutch authorities is greatly welcome. The headline announcement is of great political significance, and an official admission that the tax justice movement, in the Netherlands and elsewhere, has had a point all along.
Today's blogger remembers a tax justice meeting in Amsterdam a few years ago when a top Dutch tax official gave a horribly patronising presentation, seeking to pooh-pooh a seminal report by our excellent Dutch NGO colleagues at SOMO. Times, they are a-changin'.
"Over the past 10 years the trend has been for the number of letterbox companies in the Netherlands to keep growing. I want to turn that trend around," Mr Weekers said. "I see the Netherlands being portrayed in a bad light. I don't want to be portrayed in a bad light.
The Dutch move stems from a government-commissioned report over the summer which, for the first time, agreed with tax-justice groups that developing countries miss out on substantial tax revenues because of their treaties with the Netherlands."
Here is a clear and public admission by the Netherlands government that this tax haven activity is causing great harm around the world. Or, to put it more succinctly, Tax Havens Cause Poverty.
Which, of course, immediately raises the next question: why stop at 23 countries? And why stop at these limited measures?
The logic points inexorably in one direction: the Netherlands should work towards rolling up this whole sordid industry and starting to compete on the basis of genuine business activity.
We urge other nations engaged in this shameful trade – such as Ireland, Luxembourg, Switzerland, Belgium, the United Kingdom and others – to take note. We applaud the Netherlands for making what must have been -at least as far as it goes – a politically difficult move.
For those with a Financial Times subscription, there is a whole lot more in the FT story.
Press Release: response to OECD Action Plan on corporate tax avoidance
Posted by Nicholas Shaxson in EU on July 19, 2013
From the Tax Justice Network blog, a response to the OECD's Action Plan on corporate tax avoidance. Now updated, with full commentary below.
The OECD has now published its long-awaited Action Plan on how to deal with corporate tax avoidance. Our response is below. It is broadly in line with a briefing yesterday as a curtain-raiser to this report.
Taxing multinational corporations: OECD chooses a path strewn with obstacles, headed in the wrong direction.
TJN's Response to the OECD's Action Plan on "Base Erosion and Profit Shifting"
July 19th, 2013
The OECD this morning published its long-awaited Action Plan to tackle corporate tax avoidance, which has seen the likes of Starbucks, Google, General Electric, Vodafone, Apple, Amazon and many others avoid billions in taxes.
Having carefully examined the Plan, which the OECD sent us under embargo on Wednesday, we have not changed our overall assessment we published on July 17th.
- The Action Plan proposes the design of a series of piecemeal patches. These patches are generally to be welcomed, as immediate remedies to the gaping holes in the broken international tax system.
- After a year's work, the OECD has only identified the issues on which work is needed; developing actual proposals will be a far more arduous task, and the timetables of up to two years are likely to prove optimistic.
- This approach is fraught with political obstacles. Although many of the envisaged measures are welcome, the overall approach would ultimately entrench the current broken system.
- The OECD's recommendations are not binding, and would require many governments to reverse their policies, in the face of determined opposition from business, and from the influential armies of accountants and lawyers who greatly benefit from designing tax avoidance schemes.
- If governments did adopt the recommendations, this would intensify tax conflicts as each nation seeks to 'grab' as much cross-border income as possible for tax purposes. An already highly complex system will also become still more convoluted. Coordination will be extremely difficult, and the OECD's ambitious idea for a multilateral convention is more likely to take twenty years than two.
- The OECD should open the door to an approach that many tax experts agree is superior: unitary taxation, where multinationals are taxed not according to the tax haven-friendly, inefficient and distorted economic forms that their accountants and lawyers contort them into – but instead according to the genuine economic substance of what they do and where they do it.
- The OECD experts have for years stubbornly clung to the outdated principles of a system devised 80 years ago, and have sought to close down any debate on this alternative, which would effectively cut tax havens out of the international tax system and restore countries' abilities to tax multinational corporations. They claim that unitary taxation is not politically feasible.
- We demonstrate below why unitary taxation is more politically feasible than the OECD's approach, if governments are serious about taxing multinational corporations. It can be introduced gradually, starting with a transparency requirement, then expanded, building on years of accepted practice.
Professor Sol Picciotto, a Senior Adviser to the Tax Justice Network, said:
"The Action Plan contains some ambitious measures, which would produce some benefits if implemented. But its approach is like trying to plug holes in a sieve. The OECD has chosen a road that is strewn with obstacles, and leads in the wrong direction.
The OECD has missed this big opportunity to crack open the door to the big reform that the world's citizens need. It is still open to countries to adopt their own versions of worldwide taxation of multinationals, and for other organizations such as the United Nations to take a lead in developing an effective worldwide system."
Part 2: detailed commentary
The section below explores the OECD report in more detail. The OECD Action Plan: the positives.
The Tax Justice Network supports the OECD's efforts to strengthen international tax rules. The Action Plan is uneven, but in many respects ambitious. Some of its proposals would mean ending tax breaks that we have fought hard against, or introducing measures that we have supported. For example:
- Strengthening so-called Controlled Foreign Corporation (CFC) rules. These have been eviscerated notably by the U.S.' so-called "check-the-box" and pass-through rules, and by the UK's move to a 'territorial' system in 2012, as a result of lobbying by multinational corporations and their advisers;
- Limiting corporations' ability to deduct interest and other payments made from affiliates in high-tax jurisdictions to related affiliates in low-tax or no-tax jurisdictions;
- Ending arrangements that facilitate so-called treaty-shopping, such as the 'Dutch Sandwich', and other abuses of provisions in tax treaties;
- Reforming the concept of "Permanent Establishment" and of attribution of profits, which are easily avoided by separating related functions.
A path strewn with obstacles, and leading ultimately in the wrong direction
Despite these positive recommendations, which if implemented would provide some relief for citizens who bear the economic brunt of corporate tax avoidance, the OECD report is build on a fatally flawed approach.
The OECD experts could have taken this unique political opportunity – on the back of widespread citizen protests and pressures from cash-strapped governments to tackle corporate tax avoidance – to set the world on the road towards a new and far better system. It does not do this, but instead aims to strengthen existing rules.
The fundamental flaw in the current system is that it tries to tax transnational corporations (TNCs) as if they were loose collections of separate entities operating independently in each country. This is a system built on a fiction: the OECD knows as well as anyone that these firms are not bunches of separate entities – but unified firms under central direction.
A tax system fit for the 21st Century would recognise this economic reality, and seek to tax them using a unitary approach. Most tax experts, even some at the OECD, recognise the clear superiority of the unitary approach.
Their main objection has been that such an approach would require a degree of political cooperation which would not be politically feasible. However, a gradual transition towards such a system is both possible and necessary, as we explained in our previous Briefing, and in a more detailed earlier report.
In our view, on the contrary, the OECD's piecemeal approach is itself fraught with political obstacles, and is far less politically feasible as an approach, if we are serious about taxing TNCs effectively.
Recommendations are not binding; lobbyists will fight hard
Many of the measures that the OECD proposes to formulate would require states to reverse their international tax strategies, in the face of determined opposition not just from business, but also from the powerful firms of accountants and lawyers who find the current porous and complex system allows them to design highly lucrative tax avoidance schemes.
There will be many who will hope that while the OECD tries to flesh out these ideas into detailed provisions, the economic and political climate might change, fiscal pressures will abate, and press and public will lose interest in tax justice. We think this is unlikely.
More plausibly, cash-strapped governments will want to try to plug some of the holes in the leaky sieve of international taxation. Each will prioritise the measures that they think would least upset their own business lobbies. It will prove hard to persuade governments to repeal tax provisions that they believe attract business, even if these provisions harm other nations' economies.
A recipe for conflict
To the extent that the OECD does succeed in persuading governments to follow its new recommendations, it faces an enormous task of coordination. If each state prioritises measures that give it a bigger slice of the tax pie, that is a recipe for international tax conflicts between nations. Some issues raised by countries have been ruled to fall outside BEPs project. These would add to the numerous conflicts that already bedevil the system. For example, India and other developing countries remain concerned about the limits current tax rules place on source taxation of foreign-based service providers.
Internet-based services: a growing headache
Many governments would like a quick solution to the problem to taxing internet-based companies. Google, for instance, has avoided large amounts of tax by selling its advertising through its affiliate in the tax haven of Ireland. The OECD is unlikely to deliver a good solution to this. One of the fifteen points in the Action Plan concerns the Digital Economy: it expects to deliver only an analysis in a year's time, and even this deadline is unlikely to be met.
There are good reasons for this: the digital economy is not a distinct sector, but an important element in all business today, to a greater or lesser extent. Specific ways may be devised to tax some particular activities such as internet sales, but such partial and unilateral methods would produce imbalances and conflicts. In fact, the issues identified by the examples of Google, Apple and Amazon point to the more fundamental systemic flaws of the "separate entity" approach described above, which as we have pointed out the OECD does not propose to tackle head-on.
The OECD's powers of persuasion
In its very tough task of coordination, the OECD's only weapons are technical expertise and peer-pressure persuasion.
It proposes to use three methods.
First, at the most voluntaristic level, it will `revamp' its Forum on `harmful tax practices'. This essentially entails using peer-pressure to persuade countries to remove tax breaks and preferential regimes.
Second, it will draw up revisions mainly of the Commentary to the Model Tax Treaty, and if necessary also to the actual model treaty articles. The treaty articles are legally binding, and the Commentary has significant legal effect in interpreting those provisions. But this effect only works if and when states actually renegotiate their existing bilateral tax treaties. With the best will in the world, this would take years.
Third, the Plan also proposes to formulate a multilateral treaty, which it hopes would override existing treaties. This poses complex legal problems, and a special group of international legal experts will be recruited for this delicate task. But such a multilateral treaty also would only come into force once ratified by individual states, and only among the states which do ratify it. We recall that in 1988 the OECD drew up, in conjunction with the Council of Europe, a multilateral convention on tax co-operation. This took over twenty years to gain more than a handful of ratifications.
Transfer pricing: a deeper and deeper hole
In our view, the OECD has chosen a road that is not only strewn with obstacles, but leads in the wrong direction. This can be seen most clearly, perhaps, with respect to the transfer pricing problem. Here, the OECD has dug itself progressively into a deeper and deeper hole by doggedly pursuing the fiction of "separate entity" and the "arm's length method', described above.
The Action Plan suggests that there is the beginning of a realisation of the need for a new approach, in mentioning that `special measures, either within or beyond the arm's length principle, may be required'. This could potentially be construed as a possible tiny opening. However, it falls well short of the fundamental reorientation of approach that is required.
The OECD experts can be said to have done what could realistically be expected of them, given the political constraints. We had hoped for more, at least as regards transparency.
A road map to true reform
As we have pointed out, moving towards unitary taxation would not entail the sudden shock of a 'big bang.' It can be introduced gradually, building on existing practice. It involves three components, each of which can build on elements already existing in the current system.
A first, immediate step towards a unitary approach would be a transparency requirement, to require TNCs to submit to each relevant tax authority a Combined and Country-by-Country Report. This would outline the genuine economic substance of what the TNCs do and where they do it, and build on and enhance the already fast-emerging standard of Country by Country reporting.
This report should include global consolidated accounts, for which the OECD could and should develop a template. Action 13 of the Plan does seem to open up this possibility, and for this we must be grateful.
Second, tax authorities could use this information to apportion the global profits multinationals using appropriate allocation factors reflecting the economic substance of their activities around the world.
This can build on existing practice, in particular the so-called "profit-split" method already accepted by the OECD Transfer Pricing Guidelines, which aggregates the profits of related entities then apportions them according to so-called "allocation keys." This is a narrower, transaction-level version of apportioning profits by formula.
This approach, as currently used, aggregates profits only at the level of bilateral transacting entities – whereas in reality TNCs use more complex cross-linkages among multiple affiliates. It would not be such a great stretch to extend this practice from the level of transacting entities to the combined whole. Indeed, there is already considerable experience in some sectors in applying formulaic profit apportionment, especially in the finance sector, e.g. where a trading book is transferred between offices in different time-zones over 24 hours. Formula apportionment of such profits has been done for 20 years through Advance Price Agreement (APAs) with banks. If firms such as Apple, Amazon, Google and Starbucks really do want to pay a fair level of taxes wherever they do business, they too could enter into APAs and agree an appropriate apportionment.
The experience of using profit split and APAs could be combined with proper research to determine appropriate apportionment formulae. Some degree of divergence of formulae is likely, but this is acceptable.
Some argue that states would simply aim to weight the factor which produces the biggest 'tax grab' for themselves – and that therefore it will be impossible for there ever to be full global agreement on a formula: and so, they argue, the whole approach is politically impossible.
But this is quite wrong, for several reasons.
First, full convergence is not necessary. Differing formulae could certainly lead to some overlaps between different countries' tax systems – but as explained above this already happens under the current system, and the problem is likely to be less under unitary taxation.
Second, states won't just go for the biggest possible tax grab – because they need also to consider the effects that this would have on inward investment. This is likely to lead to a more balanced approach towards designing a formula, and to encourage convergence. A balance between production and consumption factors seems best. In the US, the trend among states using unitary taxation has been for convergence (towards emphasising the sales factor.)
Some also argue that firms could still reorganise themselves to minimise their taxes.
This is true but it would happen to a dramatically lesser degree, and in a very different way. It is far harder for a firm to relocate physical assets, workers and sales to other countries than it is for them to shift artificial profits under the current system. And if they chose to divest some operations to truly independent third parties, they would lose the profits of synergy and scale. It is hard to imagine a company like Apple being willing to transfer to a truly independent wholesaler in a low-tax country a significant slice of its profits. Relocation of real activities may well occur, but this is very different from the artificial shifting of profits to largely paper affiliates that happens under current rules.
States would remain free to choose their own marginal tax rates. So countries could compete to attract genuine investment rather than formation of paper entities aimed at subverting the taxes of other countries.
Unitary Tax would therefore eliminate harmful tax competition, while allowing countries to make genuine choices between attracting investment in production and generating revenues from corporate taxation. Such a system would of course not be perfect, but aligning tax rules more closely to the economic reality of integrated firms operating in liberalized world markets would make it simpler and more effective.
The third important element of reform would involve a procedure for resolving disagreements and conflicts between states. Such a system already exists in the OECD's Mutual Agreement Procedure (MAP) but it could be improved, as explained above, and extended to include negotiation of APAs.
Currently, the MAP is very secretive, and decisions often involving hundreds of millions or even billions of dollars are not published. The secrecy of both MAP processes and APAs greatly increases the power of frequent actors in these processes, i.e. the international tax and accounting firms – to the great detriment of the system as a whole.
Publication of both would be a great step towards a system which could both provide and more importantly be seen to deliver a fair international allocation of tax.
Not just the OECD.
A new approach to international tax in any case should not come from the OECD alone.
Although they propose to include at least seven of the eight non-OECD members of the G20, this still excludes the vast majority especially of developing countries. A more inclusive forum is needed. The United Nations Tax Committee should be the appropriate body – but it is hampered by lack of resources and bureaucratic problems. Nevertheless, if sympathetic governments could supply it with special funding, it could initiate a special project, following up its rewrite of the Transfer Pricing Manual which was published this year.
The IMF's Tax Policy Department could also play a role, given its expertise. Indeed, the IMF last month recognised that there is considerable interest in a unitary taxation approach:
"such schemes—including their impact on developing countries—deserve a more thorough and realistic assessment."
We hope that the OECD would also contribute to such a broader initiative to study and develop a new approach, even while it pursues its task of repairing the leaky sieve. The Tax Justice Network will continue its own work, and would be be happy to contribute to any initiatives aimed at restoring the integrity and efficacy of the international tax system.
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Lamoine Village
Following the guidelines and recommendations set forth in the UHDS Master Plan, Lamoine Village Apartments are scheduled to close May 31, 2012. Availability for apartments in Graduate & Family Housing will be affected by this closure. Contact UHDS at 309-298-3331 for more information.
Opened in 1970, Lamoine Village has a total of two buildings. Building 2 contains 88 one-bedroom apartments, and Building 3 contains 48 two-bedroom apartments, for a total of 136 apartments. (building 1 was taken offline May 31, 2011) Lamoine Village is located at the northwest end of campus off Wigwam Hollow Road.
Unfurnished Apartments
Unfurnished apartments are available for rent in Lamoine Village.
Furnished Apartments
Furnished one-bedroom apartments have a loveseat, lounge chair, end table, dinette set with table and four chairs, bedroom set with two twin beds and chest of drawers or dresser with mirror and a night stand.
Furnished two-bedroom apartments have a loveseat, lounge chair, end table, dinette set with table and four chairs, bedroom set with double bed and chest of drawers or dresser and a night stand. The second bedroom includes (an) additional twin bed(s) and chest of drawers.
Floor Plans
One Bedroom Furnished Two Bedroom Furnished
Village Contact Information
Building 2 Resident Manager:
Gao Niu
Building 3 Resident Manager:
Sheila Galvez
Sara Featherlin
Graduate & Family Housing
Chief Clerk
(309) 298-3331
Bridget McCormick
Graduate & Family Housing
Complex Director
(309) 298-3328


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Beyonce Knowles, wife of a famous rapper, mother to a cute baby and winner of more than a dozen Grammys, as well as a dubious celebrity magazine title, has added another honor to her figurative trophy case. One you may not have expected.
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Jay-Z expects his wife Beyonce Knowles to win music awards – because she's so "magnificent". It wasn't a shock when Beyonce took home 6 Grammys this Sunday for the rapper because he believes she has true talent. It's almost got to a... Read Post
As if there wasn't already enough excitement surrounding the 56th Grammy Awards, Beyoncé Knowles and Jay Z have just added another healthy buzz boost. According to Billboard, the "Picasso Baby" rapper and his "Run the World (Girls)"... Read Post
He kicked off the evening with a thrilling duet with his wife Beyonce Knowles and Jay-Z just scored the title for Best Rap/Sung Collaboration at tonight's (January 26) Grammy Awards. The "99 Problems" rapper shared the accolade with... Read Post


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By Jeremy Houghtaling
Not even 24 hours after notching his first shutout in a Syracuse Crunch sweater, Cedrick Desjardins was back at it.
The netminder kept his streak going, stopping all 29 shots and leading the Crunch to a 4-0 win over the Connecticut Whale at the Onondaga County War Memorial Sunday afternoon.
"You never expect that," Desjardins said of his back-to-back whitewashes. "Those were two big games for us and teams we don't see a lot. We need to step up against those teams."
Most first impressions take all of a few seconds.
For the first 13-plus minutes in front of his new home crowd at the Onondaga County War Memorial, Syracuse Crunch goalie Cedrick Desjardins waited for his opportunity.
When the shots finally came - 26 in total - the New Brunswick native had an answer, notching his first shutout in a Crunch uniform and third of the season in a 3-0 win over the Springfield Falcons Saturday night.
"You want a good first impression at home," Desjardins said. "I don't think it gets better than that."
Beasts of the East.
Cedrick Desjardin (pictured) raised shields for a 26 save shutout.
First Period NO SCORING
Second Period NO SCORING
Third Period SYR Barberio, (8) (Labrie, Connolly), 4:37 SYR Labrie, (10) (Cote, Wyman), 12:35 SYR Brown, (7) (Tyrell, Cote), 19:33 (EN)
Desjardins, Mark Barberio, and Pierre-Cedric Labrie were the game's three stars. J.T. Brown returned from injury and had an empty net goal in his first game back.
Syracuse came into this game 1 point ahead of Springfield for the top spot in the Eastern Conference. This was a battle of titans with a lot on the line, and ultimately Syracuse smoked the Falcons like a fine cigar. Mind you, Springfield netminder Allen York made it interesting, but Syracuse outshot Springfield 46-26 in this game, including 17-8 in the decisive final frame. That was a 1 versus 2 game. Think on that. Then think on the fact that the Crunch have won 6 in a row.
Uh oh, rest of the AHL. Jon Cooper sorted out the post-lockout madness. Jon Cooper has started to tune up the machine again. We've seen this movie before, folks, and we all remember how it ends.
Syracuse draws Connecticut next tomorrow afternoon.
Box score from TheAHL.com.
Dana Tyrell believes it was a bit of hockey karma.
His team trailing 3-2 with less than two minutes remaining in regulation, the Syracuse Crunch forward caught a break. The puck bounced behind the net, and despite many of the Toronto Marlies looking for the puck in the corner, Tyrell found it on his stick.
"I think it went up my pants. To be honest, I'm not really sure what happened," Tyrell said. "I was forechecking the puck down - hunting it down - and it bounced up somewhere. I think it got caught up in my gear somewhere. As I was coming around the net, it dropped down in front of me and I had an open net.
"If we work hard as a team, we're going to get bounces like that," he added.
Tyrell's goal sent the game to overtime and the Crunch completed the comeback in the shootout, topping the Marlies 4-3 at the Onondaga County War Memorial Wednesday night. Syracuse has shrugged its slump that lasted from late January into early February, winning its last five games.
5 in a row.
Riku Helenius allowed 3 goals on 31 shots before stopping 3 of 5 in the penalty shot session for the win. Riku is now on a personal 4 game winning streak.
First Period TOR Colborne, (8) (Zigomanis, Hamilton), 19:59 (PP)
Second Period SYR Angelidis, (9) (Palat, Hutchings), 2:46 TOR Colborne, (9) (Abbott, Mottau), 5:43 SYR Palat, (7) (Barberio, Helenius), 6:51 (PP)
Third Period TOR Hamilton, (21) (Yeo, Colborne), 6:50 SYR Tyrell, (4) (Korobov), 18:26
Overtime NO SCORING
Shootout TOR- Colborne, Connolly SYR- Palat, Connolly, Gudas
Dana Tyrell and Ondrej Palat were named the game's first and third stars. Palat has 1 goal and 6 points in his last 3 games, all multi-point efforts.
The return of The Entertainer.
Cedrick "The Entertainer" Desjardins made his Crunch debut stopping 23 of 26 for the win. Riku Helenius, who was named the AHL Player of the Week, got the night off.
First Period SYR Tyrell, (3) (Hutchings, Angelidis), 9:40 SYR Johnson, (24) (Palat, Cote), 10:14 ALB Sislo, (3) (Zalewski, Urbom), 14:32 (PP)
Third Period SYR Johnson, (25) (Wyman), 3:45 ALB Zalewski, (9) (DeSimone, Urbom), 7:26 SYR Johnson, (26) (Palat, Korobov), 14:27 (PP) ALB Josefson, (9) (Gelinas, Anderson), 18:28 SYR Connolly, (22) , 19:57 (EN)
Tyler Johnson and Ondrej Palat (pictured) were the game's first and third stars. Palat's 29 assists are tied for 6th most in the league while Johnson is now tied for the lead in goals.
So, after a month of struggling to regain their equilibrium, lookee at the standings and Syracuse is right back on top of the Eastern Conference standings, moving 1 point ahead of Bingo and Springfield. Jon Cooper = Jedi. Syracuse draws the Toronto Marlies on Wednesday.
Riku is hulking up.
Riku Helenius (pictured) stopped all 23 shots he faced for his 2nd shutout in the past 3 games and his 4th shutout of the season. He's allowed just 1 goal over the span of those 3 games. We've seen this before with Helenius, when he had a string of shutouts early in the season for JYP en route to backstopping them to a SM-liiga title. His save percentage is still just .891 for the season, and the Lightning just acquired Cedrick Desjardins for a reason, but when Riku starts getting on a roll like this, he can be unbelievable.
Third Period SYR Wilson, (2) (Labrie), 2:02 SYR Connolly, (21) (Palat, Johnson), 3:25 SYR Wilson, (3) (Johnson, Palat), 11:44
Helenius, Kyle Wilson, and Brett Connolly were the game's three stars.
Syracuse draws Albany tomorrow night as they try to run down Springfield and Binghamton for the conference lead.
Jon Cooper must be a Jedi.
Riku Helenius (pictured) allowed 1 goal on 34 shots for the victory. His season save percentage is still languishing at .885, but he's only allowed 1 goal over his last 2 starts and has stopped 56 of 57 shots in that span. There's not a huge opening for Helenius, but with Tokarski gone, if he can take the #1 job in Syracuse and run with it for a great second half and a deep playoff run, he could set himself up to the NHL.
First Period SYR Connolly, (20) (Tyrell), 3:51 (PP) SYR Wyman, (7) (Gudas), 5:36 SYR Hutchings, (1) (Angelidis, Cote), 8:12 SYR Wyman, (8) , 11:03 (SH)
Second Period SYR Labrie, (9) , 12:55 BNG Prince, (10) (Cannone, Lebda), 16:18 (PP)
Third Period SYR Wyman, (9) (Connolly, Barberio), 4:40 SYR Tyrell, (2) (Wyman, Gudas), 19:23 (PP)
J.T. Wyman, Brett Connolly, and Helenius were the game's three stars.
Connolly becomes the third Crunch player to hit 20 goals this season (Johnson and Panik). Dana Tyrell has 3 points in 3 games since being sent down to the AHL. After posting two straight multi-point games, Radko Gudas is just 3 points shy of his pro high in points. He's also 6 PIMs shy of his pro high in penalty minutes, too, for that matter.
Entering the night, Binghamton was tied for the top spot in the Eastern Conference, and Syracuse just smashed them after destroying Albany 6-0 on Wednesday night. Whatever voodoo potion Jon Cooper employed to not only weather all the call ups, the trade of his #1 goaltender, and the lineup shuffling, but to start annihilating teams in the midst of it all, he needs to Fedex a supply to Guy Boucher.
Syracuse draws Wilkes-Barre/Scranton on Sunday.
No Panik? No Killorn? No problem.
Riku Helenius stopped all 24 shots he faced for the shutout victory.
First Period SYR Barberio, (7) (Johnson, Connolly), 0:45 (PP)
Second Period SYR Korobov, (3) (Devos, Gudas), 4:30 (PP) SYR Gudas, (4) (Korobov, Namestnikov), 5:07 (PP) SYR Tyrell, (1) , 12:21 (SH) SYR Wyman, (6) (Devos, Barberio), 16:49 (PP) SYR Angelidis, (8) , 19:44 (SH)
Third Period NO SCORING
Helenius, Radko Gudas, and Dmitry Korobov were the game's three stars.
Dana Tyrell chipped in a shorthanded goal in the victory.
Last night's collapse continues into today's match.
Riku Helenius allowed 4 goals on 14 shots for the loss before giving way to Dustin Tokarski, who allowed 2 on 12 shots the rest of the way. At some point you'd like one of your two championship pedigree goaltenders to step up and act like it and steal you a game rather than getting lit up like Roman candles.
First Period ADK Gustafsson, (4) , 7:02
Second Period ADK Mangene, (2) (Sim), 0:37 ADK Dimmen, (3) (Mangene, Sim), 10:56 ADK Laliberte, (2) (Syvret, Akeson), 12:34 (PP)
Third Period ADK Eddy, (2) (Wellwood, Lauridsen), 1:30 ADK Laliberte, (3) (Akeson, Noebels), 13:21 SYR Johnson, (23) (Connolly, Neilson), 18:38 (PP)
This is the kind of embarassing loss where you'd expect Julien BriseBois to start looking to make some moves, now. The Crunch let some valuable veteran components like Segal, Smith, and Jackson walk over the offseason with the thought there was enough good youth to handle it. And, yes, there is a lot of good youth. But, in my mind, a piece needs to be added to, at the very least, try to fill some of what was lost between Conacher and now, possibly, Alex Killorn, to Tampa Bay.
Ranking date: 7/21/2014


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Staff Reviews
Daniel Goleman is the bestselling author of Emotional Intelligence and former science journalist for the New York Times. In this groundbreaking work he presents cutting-edge research, case studies from diverse fields and practical lessons regarding our ability to focus and pay attention. One of the most relevant non-fiction books for current times. (Praveen)
The author of the international bestseller Emotional Intelligence returns with a groundbreaking look at today's scarcest resource and the secret to high performance and fulfillment: attention.
For more than two decades, psychologist and journalist Daniel Goleman has been scouting the leading edge of the human sciences for what's new, surprising, and important. In Focus, he delves into the science of attention in all its varieties, presenting a long-overdue discussion of this little-noticed and underrated mental asset that matters enormously for how we navigate life. Attention works much like a muscle: use it poorly and it can wither; work it well and it grows. In an era of unstoppable distractions, Goleman persuasively argues that now more than ever we must learn to sharpen focus if we are to contend with, let alone thrive in, a complex world.
Goleman analyzes attention research as a threesome: inner, other, and outer focus. A well-lived life demands that we be nimble at each. Goleman shows why high-performers need all three kinds of focus, as demonstrated by rich case studies from fields as diverse as competitive sports, education, the arts, and business. Those who excel rely on what Goleman calls smart practice--such as mindfulness meditation, focused preparation and recovery from setbacks, continued attention to the learning curve, and positive emotions and connections--that help them improve habits, add new skills, and sustain excellence. Combining cutting-edge research with practical findings, Focus reveals what distinguishes experts from amateurs and stars from average performers. Ultimately, Focus calls upon readers not only to pay attention to what matters most to them personally, but also to turn their attention to the pressing problems of the wider world, to the powerless and the poor, and to the future, not just to the seductively simple demands of the here and now.
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Prince Charming takes his Princesses to Disney World~Updated 6/7 with ADR's
Hi everyone!!
This is my first foray into a pre-trip report...heck any type of trip report for that matter! I hope I do this justice and don't sound like a goober Anyway, let me introduce the family. There is me, DW extraordinaire and Head Princess, Margaret. My favorite character is Belle and DH would say it is more of an obsession... ok, maybe it is. I have been married to DH, Rod , for almost 14 years and he is my Prince Charming. His favorite Disney character is Mulan. Which is good b/c I like her. Our little Princess is Paige. She is 4 and is the light of our lives, sometimes she turns that light off and it gets dark, but then she turns it right back on. Her favorite character is Ariel. Also a good choice as I like her also. This will be the second family trip. We took DD for her 2nd b-day and brought my parents along for that one. This one will just be the 3 of us and I am extremely excited. Here is how it all came to be: At the end of January we decided to do a good behavior calendar, stickers for good days, x's for not so good days. Paige decided that after getting 12 stickers we would take her bowling. At the end of February, DH decided that if she got "lots" of stickers we would go to Disney World!!!!! Of course all I heard was "go to Disney World" That same weekend I decided to check out the price of flights to Florida. We had already decided to go over Labor Day since it required the fewest days off work. Guess what??? I found 3 round trip, direct flights for less than $500 total!!! I couldn't believe it!! So, DH says, book it. Guess who is going to Disney World??? So far, we have plane tickets. That's it, nothing more, just plane tickets. But that is okay, I have a countdown going...at work. I am trying to keep this a secret from DD so it will be a surprise, not sure if I can keep up with it though. Since I am the planner of the house, I have already bought a book to help me remember all those things I need to do before going....like book a room. No, seriously, I know I need to book a room but it is nice to have something to keep me sane until we fly out. I have some ideas of where I want to stay, yep it is all about where I want to stay b/c if Momma's not happy, ain't nobody happy! I would love to stay at POFQ but the economy may decide on All Star Sports. Either one works for me as long as I get to go. I am trying to hold out a little longer to see what deals Disney drums up but am also checking out what kind a deal I get thru AAA. I have the best AAA TA and I know if I book thru her and Disney comes out with a better deal she will work her magic to get that for me. I am soo lucky to have her. That is all I have for today, I hope you enjoy this journey as much as I do. Once I figure out how to insert pics, I will add some. Sometimes technology can be so difficult. Thank you for reading...
I lost my name when I became Paige's mommy
Me DD Last edited by princesspaige; 06-07-2009 at 09:16 AM. |
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6 (Non-3D) Movie Gimmicks from The Warped Mind of William Castle
Cinematic Listology By Ashe Cantrell on July 28, 2011 | Comments (4)Most cynical internet denizens will tell you that the resurgence of 3D is a mere gimmick, meant to drag more people to theaters and jack up ticket prices. (I am one of those cynical people.) Average movie-goers seem to be agreeing, with a resounding "I paid five bucks extra for this crap? I could have had nachos!" 3D has come and gone throughout film history, and each time we come to the same general conclusion: We kinda don't like it. Until we have some kind of full immersion films (and would they even be films at that point?) we'll probably never be satisfied. When 3D movies fell apart the first time, Hollywood just went back to doing what they had been doing before the 3D boom: Trying to make good movies. One man was not satisfied, though. William Castle, director and producer of ridiculous B-movies, had a vision. He wanted to make every single one of his films into a spectacle event (much to the annoyance of theaters that booked his movies) that drew the masses to the cinema for the experience. Here are six of his most notorious gimmicks.
Will J.J. Abrams Become to D-Box What James Cameron is to 3D?
Movie News By Nathan Adams on April 27, 2011 | Comments (5)The first question you must be asking yourself, if you aren't in the know, is what the heck D-Box is. Turns out it's a ridiculous version of a standard theater seat that jerks around and vibrates while you're watching a movie. Anyone with spinal issues or hemorrhoids might want to avoid this new breakthrough technology, but for the rest of us it sounds like an exciting new development in movie watching. Right? Okay, maybe not. But it's an idea that could be poised to grow. It doesn't take a gypsy fortune teller to predict that J.J. Abrams's upcoming Amblin Entertainment love letter Super 8 is going to be a huge, gigantic success at the box office this summer. Even from the first trailer alone I can tell that people are going to be seeing this movie multiple times, talking about it all summer, and maybe even drinking out of Burger King cups with its logo on them. The good news for D-Box is that Super 8 is going to be using their shaky chair technology on 50 select screens. If you're lucky enough to live somewhere near the 50 D-Box enabled theaters that can be found on a map here, then you might be the perfect guinea pig to try this growing craze out.
Neil Miller
Scott Beggs
Rob Hunter
Kate Erbland
Christopher Campbell


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OPINION: Neuroheroism? The word's made up but we'll claim it as a fair description of what southerners can achieve when they put their minds to it.
Our communities have shown themselves prepared to strive collectively, inventively and with stamina to save, enhance and future-proof neurosurgery services.
Even in its initial form this was a sensational thing: an uprising from Otago and Southland to defend a key Dunedin-based service in the face of what seemed the implacable judgment of the medical bureaucracy that Christchurch alone could attract and sustain the expertise and resourcing necessary.
Stripping the service from Dunedin would have put it out of timely reach for too many southerners. The result - a 40,000-signature petition, a march of 10,000, and a campaign that stood strong in terms of medical, financial and social imperatives. There may even have been an element of political heat applied too; we can't quite recall.
But when the Government in 2010 accepted an independent expert inquiry and determined that not only would the Dunedin service be retained, it would be better resourced, the activists were not done.
If the job was worth doing, it was worth doing properly. People bestirred themselves afresh. So began, in January this year, a campaign to raise $3 million to set up an endowment fund for a chair in neurosurgery at Otago University, protecting the position against the vagaries of medical funding. And now it's mission accomplished, just 10 months later. The south has put its money where its mouth is. A feat all the more impressive because, let's face it, we'd been mouthing off all over the place.
It is not simply the amount raised that should be remembered. The breadth and depth of the fundraising campaign was remarkable. Right at the very end, we were reporting substantial donations like $100,000 from RD Petroleum - but alongside it income from the sale of used car batteries in Owaka, a winter feed competition in Tokanui and a quilt fundraiser in Middlemarch.
Plenty of events were, shall we say, coherently purposeful, such at the Brain Week Walk on the Milford Track, whereas others were the result of more elliptical thought processes. Over at Dorothy Browns theatre in Arrowtown they had a Brains and Brawn fundraiser combining a performance by pianist Mark Wilson, who had undergone neurosurgery in 2009, with screen footage of the Bledisloe Cup game between the All Blacks and Wallabies. Well, we say combined. It was first the piano, then the footy, which was arguably a shame. Combining the two in the manner of old-fashioned silent movie screenings would have further enhanced the appeal for some of us.
Many a worthwhile cause has advocates and champions who struggle ardently without being able to obtain anything remotely approaching the level of support that the neurology campaigns have. In no small part these two successes were due to the people prepared to step forward and say plainly and with passion what they owed to the Dunedin neurosurgery team's expertise and speedy accessibility.
While expert voices were able to mount their case for supporting the chair of neurosurgery campaign, it was those powerful testimonies that helped ensure people didn't just understand the benefits; they cared.
- The Southland Times
Sponsored links
Editorial: Unforgettable? Never count on it.
Long-eared rabbit interlopers, begone
Southland's dog problem: Stupidity behind the savagery
Editorial: Going not-so-boldly backwards
Editorial: Bigger issues at risk in film debate
Editorial: The sane response to atrocity
Editorial: Want a pollie cracker?
Dead puppy found in suitcase at cemetery
Bones examined for link to missing girl
Scuffle breaks out between three women
Mouse eradication programme delayed by a year
Future legal high sales restricted to Invercargill CBD
Sleepout destroyed by fire in Otago
Missing Balclutha man found safe
Mallards falling prey to predators
Chimney fire damages Wanaka house
Mataura fire brigade to host challenge
Exercise boosts teens' brains - study
Police warn against removing drivers' keys
Young widow Stephanie Davidson thanks community for support


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A few gardening events have already been announced for this year, and there's a few I just happen to already know about. A list with dates, times, and locations can be found on the East Tennessee Plant Swap site: www.EastTnPlantSwap.com (click the 'Events' button) Here's the list as of today (note that the Ijams seed swap is coming up pretty soon): Ijams Nature Center Annual Seed Swap Racheff House and Gardens Spring Plant Sale UT Gardens Spring Spectacular Plant Sale 49th Annual Talahi Plant Sale Franklin Square Spring Garden Festival Ijams Nature Center Spring Plant Sale UT Gardens Blooms Days Spring 2014 East Tennessee Plant Swap |
This post was edited by brandon7 on Thu, Mar 13, 14 at 0:04
Follow-Up Postings:
The Ijams Nature Center Annual Seed Swap is this weekend! If you're going, call for reservations (they get your name and expected number of people attending). |
Updates: Ijams Nature Center Spring Plant Sale The Garden Conservancy's Open Day Program |
Addition to the list: East Tennessee Daffodil Society Daffodil Show |
This post was edited by brandon7 on Thu, Mar 13, 14 at 0:09
Update: Franklin Square Spring Garden Festival Also, don't forget the 49th Annual Talahi Plant Sale is tomorrow. |
Figured I'd bump this back to the top so people would notice the Talahi Plant Sale announcement. |
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U.S. District Judge John Shabaz, a conservative Republican lawmaker named to the federal bench by President Ronald Reagan in 1981, died Friday. He was 81.
Shabaz served eight terms in the Wisconsin Assembly - earning the nickname "Dr. No," along with then-Rep. Tommy Thompson, for their efforts to thwart Democratic legislation - before taking the bench in the Western District of Wisconsin.
Shabaz served as chief judge from 1996 to 2001. He moved to senior status, a form of semiretirement, in 2009.
"John Shabaz was a person of principle, of integrity, who never let his philosophy get in the way of a good friendship," said former Democratic Gov. Tony Earl, who served with Shabaz in the Assembly in the late '60s and early '70s.
"Though we were on opposite sides of the political aisle, on a personal level, we were always the best of friends," he said. "I admired him very much."
Shabaz was born in Milwaukee and graduated from the University of Wisconsin-Madison before earning his law degree from Marquette University.
He represented the New Berlin area in the Assembly, first elected in 1964, and governed with the majority until Democrats took control of the Legislature in 1970.
A fiscal conservative, Shabaz fought the growth of social programs and government, and was once picketed by Father James Groppi for his proposed cuts to state welfare programs.
"He had a reputation in the Legislature for telling the hard truths and living his principles," said his wife of 26 years, Patty Doughty Shabaz.
Shabaz was known as a quick study - he knew the content and nuances of every bill, colleagues said - and a firebrand who grew disillusioned by the moderate leanings of his party near the end of his legislative career.
"John had the finest grasp of legislative knowledge of anyone I'd worked with," said former Rep. Sheehan Donoghue, who served with Shabaz in the 1970s and '80s.
Thompson said Shabaz had memorized the legislative rule book and was able to use his knowledge to thwart Democratic legislation he believed was wrong or would increase regulation or taxation.
"He was an extremely intelligent, hard-working, highly ethical and wonderful person," said the former governor, now campaigning for the U.S. Senate. "He cared deeply about our country, our state and the law."
As a jurist, Shabaz presided over an efficient and fast-moving court - it became known as the "rocket docket" - where he expected attorneys to arrive on time and be prepared.
"He was a firm, tough judge who treated the prosecution and defense the same," said John Vaudreuil, U.S. Attorney for the Western District of Wisconsin, who argued hundreds of cases before Shabaz.
"He worked very hard, he listened to what you said, he always read what you wrote, and he was decisive."
Shabaz was known to admonish attorneys he didn't think knew what they were doing, or, worse, those seeking extensions - though some of his rebukes were more funny than biting.
When Vaudreuil asked for a delay in 1984 so he could go on his honeymoon, Shabaz told him, "I thought I gave you a continuance for that last year."
Shabaz's death prompted statements of condolences from around the state.
"The entire court family is saddened by the news of Judge Shabaz's passing," Chief Judge William M. Conley said on the U.S. District Court's website Friday. "He left an indelible mark on this Court," Conley said. "No one worked harder than Judge Shabaz."
In addition to his wife, Shabaz is survived by four adult children, Scott, Jeff, Emily and John.
Funeral arrangements are pending.
Tom Tolan of the Journal Sentinel staff contributed to this report.


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Fairy Meditation
11 Aspects of Woman
David Uhl "Clothing Optional"
Daddy's Little Minions
Four Elemental Goddesses
Good vs Evil by Sugargrl14
Rose Faerie
Silver Dream
Draco Faerie
Faery & Wolf by ElvenRavenWolf
Sassy II
Fantasy Gyrls
Dr. River Song, Valley of the Gods, UT
Hell in High Heels
Rose Fairy by Anne Stokes
Cathie plus One
I am the Bad Wolf. I create myself.
Old Bat Cheer Squad
FAE - Cristina Ocejo


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Adam Lambert in Details (November 2009)
8 of 8
Great. Awesome. They already love to go shopping and now they're making out with naked women. I was on your side, gay people! Carrie Prejean warned me about you in her retarded, hypocritical fake-breasted way that, in hindsight, nobody ever should've listened to. But still.
NOTE: Pics links to NSF...


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Des Moines rescue crews were called to an overnight house fire early Friday morning.
Police said a newspaper carrier saw the flames at 503 Southeast 8th Street at 2:30 a.m. and called 911.
Fire crews said the homeowner was not at the home at the time of the fire, but a dog was inside and died.
Firefighters said it looked like the fire started on the second floor of the home.
Investigators were at the scene Friday morning.
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Must I confess my sins? |
Bishop's Message | |||
By Bishop Dr Wee Boon Hup Most would answer the question saying, Of course you must! However, there are some who would say, There is no need, since Christ died once and for all. The question here is about our confession to God. When we sin against another person, James settles the question for us by saying: Confess your sins to one another, and pray for one another, that you may be healed. (James 5:16a, ESV) Such acts are salubrious to our soul and body. But do we need to confess our sins to God, since there are scriptures that seem to suggest otherwise? There is therefore now no condemnation for those who are in Christ Jesus. (Romans 8:1) For the death he died he died to sin, once for all, but the life he lives he lives to God. (Romans 6:10, ESV) He entered once for all into the holy places, not by means of the blood of goats and calves but by means of his own blood, thus securing an eternal redemption. (Hebrews 9:12, ESV) Yet 1 John 1:9 (ESV) states If we confess our sins, He is faithful and just to forgive us our sins and to cleanse us from all unrighteousness. I have come across the views of those who debunk the need for believers to confess our sins. They interpret this verse as referring to unbelievers. Personally, I think it is confusing for believers reading a letter addressed to them to find that the we in that line refers to unbelievers. A more convincing perspective is given by John MacArthur in his book The Freedom of Power and Forgiveness. MacArthur makes a critical distinction between what he calls judicial forgiveness and parental forgiveness. Judicial forgiveness was bought by Christ when He died for us, justifying us, freeing us from condemnation so that we do not need to seek it again. Parental forgiveness, on the other hand, is what 1 John 1:9 refers to. Our Father is displeased over His childrens recurring sin, about which He will chasten us for our good because He loves us. Sin which remains unconfessed to God can exact a toll on our physical body, not to mention the spiritual consequences. David shared this experience in Psalm 32:35 (ESV). For when I kept silent, my bones wasted away God chastens us, knowing how much going our own way will end up destroying us. When we do confess our sin to God, we are agreeing with Him regarding what is not right. It is the first step to align ourselves with His way again. Confessing our sin thus makes the chastening unnecessary. God does not need to discipline the obedient. But when we stubbornly resist His way and He disciplines us, Hebrews 12:10 says that His motivation is that we may share in His holiness, i.e. so that we might be like God. So here is the end game when we do not confess our sin: our physical body suffers (along with other aspects of our lives), and we are not aligned with Gods will (and do not see it). These are the consequences of sin (reaping what we sow; Galatians 6:7) and not Gods judgment that was settled with judicial forgiveness. Because of His great love for us, unwilling to allow us to stray too far and too long, God will exercise His fatherly discipline to draw us back into fellowship with Him. When we do confess, our fellowship with the Father is restored. He extends His parental forgiveness. He cleanses us of all unrighteousness, thus removing the consequences of the previously unconfessed sin. We are back on track to realise the best plan that He has for our lives. [Updated 6 September 2013]
Last Updated on Friday, 06 September 2013 10:06 |


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Watson a beauty
Emma Watson will play Belle in Disney's live-action remake of "Beauty of the Beast."
Emma Watson will play Belle in Disney's live-action remake of "Beauty of the Beast."
McCain gives thumbs up to 'American Sniper' movie.
Everywhere you look there are signs of the big game.
Church of England ordains first female bishop.
A Florida woman is suspected of drowning a 2-week-old puppy in a Nebraska airport bathroom so she could board a plane.
Defense lawyers say they're negotiating with prosecutors for a plea deal in the case of a Utah woman accused of killing six of her newborn b…
Tom Petty has earned a writing credit on Sam Smith's megahit "Stay With Me" for its similarities to his song "I Won't Back Down."
A Garden City landmark has been leaking millions of gallons of water and a lot of taxpayer dollars.
After a high profile athlete is arrested on suspicion of DUI, one group hopes the allegation will help curb drinking and driving.
Joseph Andrew DeRusse, 24, Austin, Texas, was charged in a criminal complaint filed in U.S. District Court in Wichita.
Young Seattle Seahawks fan meets his hero after receiving prosthetic leg bearing Richard Sherman's image.
The Navy SEAL marksman drama starring Bradley Cooper stayed in first place in its second weekend in wide release, earning $64.6 million.
Law enforcement is concerned that the popular Waze mobile traffic app by Google Inc.
A Southern California woman who killed a 2-year-old girl by giving her chili powder has been sentenced to 15 years to life in state prison.
Kansas geologists say they need more funding to investigate an unprecedented spike in earthquakes in the state.


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Seth Meyers Shoots Down Reports That He Will Replace Regis
Rumors went white hot last week that "Saturday Night Live" head writer and Weekend Update anchor Seth Meyers was at the front of the line to replace Regis Philbin as… More
Rumors went white hot last week that "Saturday Night Live" head writer and Weekend Update anchor Seth Meyers was at the front of the line to replace Regis Philbin as… More
Seth Meyers of "Saturday Night Live" is being named as a frontrunner to be hired as Kelly Ripa's permanent co-host. Our take on that …
Actors and writers react to the death of writer-director Nora Ephron on Tuesday at age 71: – "So sad to hear that the brilliant Nora Ephron passed away. Her films… More
First-time winners and upsets dominated the 39th annual Daytime Emmy Awards. Full coverage from columnist Sara Bibel …
LOS ANGELES (TheWrap.com) – For those of you who think you're up to filling Regis Philbin's big, big shoes as co-host of "Live!" you may soon have your chance to… More
On Thursday's show, Nick Lachey pulled a stunt proving he really, really wants the job.
Kelly Ripa and Anderson Cooper were the guests on Monday's "Watch What Happens Live," where Ripa, who hails from New Jersey, gabbed about the "Real Housewives."
We can now scratch one potential replacement for Regis Philbin off the list of likely co-hosts for "Live! With Kelly." While a plethora of names have graced the co-host chair… More
To celebrate the 100th episode of Anderson Cooper's daytime talk show in an hour that airs Monday, a giant cup of frozen hot chocolate topped with whipped cream was wheeled onto the set after its star interviewed a svelte Janet Jackson.
If it seems like the search for a permanent co-host to join Kelly Ripa on "Live! With Kelly" has been dragging on forever, then you probably have a short memory… More
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Reviewed The Best Chili You Will Ever Taste
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"Made this chili for a superbowl party. It was bar far the best chili I have had. The guests at the party also ...""


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The snow outside my window this morning.
Snowman in Belfast,VA
The snow was beautiful today. It was 7 inches. It kept falling. This photo was taken today at 11:24 a.m.
Building our first snowman
It's a Luau!!!
The snow was beautiful today. It kept falling. I measured the snow. It was 7 inches.
Chickens are trying to figure out what this white stuff is.
This was made with the foot of snow we received on Hutton Branch in Marion.
This is the snowman that my son Jacob Webb built!!
Moon rising over the mountain,
Our 10 foot 8 inch snowman was created by Johnny, Jessica, Tyler, Dustin, and Kayla!
Enjoying the snow
Quick break in the clouds to allow the evening sun to peek through. It only lasted a few minutes, but it was BREATHTAKING!
Snow Feb 2014
Kolton plays in his first big snow
Ellie & Lacy playing in the snow
enjoy the picture
Picture of The Snowy Streets of Big Stone Gap
Snowy creek
Handstand competition... and the snowman wins!
Caterpillar made of snow by Chad and Dana Hurley of Hurley, Va.
Hootin' Owl Holler
My driveway
Big Ole Snow Man
loving the snow
The kids had a great time sledding and building a snowman this afternoon.
My sweetheart, Brian and I made a snowlady named Val. She is a day early for Valentines day!
Yes sir,we had enough snow to build a whole family.
Loving the snow!
Oriole Frosty
Even the snowlady is ready for Summer!!
Blake and his dad build their biggest snowman .
Made a Dino for my kids
Jabba The Hut - made today along with friends!
Hurley Va
Thanks wcyb for warning us about this awesome and massive snow storm
2 year old Brayden helping Grandma shovel the driveway today.
6 - 10 inches of snow
Mason and the 7' snowman getting ready to sleigh ride!
my dogs loving the snow
My grandson Brady Counts showing the amount of snow in Haysi, Va,
my dogs loving playing in the snow
He found snow mountain
My car drifted in snow first thing this morning.
Snow Day Fun 2/13/14
Snow 2014
Snowfall of 2/12-13-2014
Snowman in Clintwood. 2-13-14
Braden throwing snowballs.
Zach threw a snowball at Willow
This is what happens when Big kids make Big snowmen!
Hayden Huffman and Ally Gilly built a snowman in tribute to their aunt Ella!! She has been in the hospital for several months...they wanted to cheer her up.
Border Collies Bailey and Keegan love the snow!
Zachary just fell down..
7" In Midway , 2/13/14
Snowmen relaxing by the snow
my babies and their snowman
having fun in the snow
Dallas Cowboys Snowman by: Chad and Becky Poore & Christopher and Carrington Hobbs Abingdon Virginia
7+ inches of snow in Ridgefields
IndianCreek Rd, Wise
Time: 3:45 Place: Backbone Ridge A Snow-Woman
9.5 inches of snow
Our son, Landon Stiltner, enjoying a day of fun in the snow.
Colourful Snowman
My daughter and her snowman!
Building snowmen on a cold winter day
taken the morning of 2-13-14
Neighbors joining together enjoying their snow day
My poor hubby has to walk out about 3/10 ths of a mile in and out -Road is too slick to try it out and too steep
Winter wonder land.
Poor bird I forgot to buy more food before I got stuck
Frosty the Country Duke Man
Snow buddies surviving the storm,
Our Snowman
Trevor's Snowman :)
Our First Snowman of 2014.. Erwin Tennessee
my brother and my sister playing the snow having a good time
Even a snow Lady need s her hair done.
Just Laying Around In Erwin Tennessee
Enough hay for the winter feed days.
This is my 5 year old son after being in the snow no more then five minute! He was not happy about it being cold and wet!
Snow Day in Erwin Tennessee
two headed snowman waiting for summer
My Grandbabies Snowman.. Erwin Tennessee
This is what happens when BIG kids make snowmen!
Two buddies having a hay snack.
I made my dog a chair
Austin, Abby, and Hannah at their new igloo
The snowman built by my son Clay
eat your heart out
We had 12'" of snow today, February 13, 2014...Look What My Snowman Can Do!!
snowman with frozen fake blood heart
Grand kids having fun in the snow.
Newest member of the Ruiz-Estrada family :]
Loving the snow
my kids having a snow day no school
The view atop Flinchum-Montgomery Mountain in SE Pulaski County, VA.
Playing in the snow today Trinity and I made a new friend!
7ft snowman made from this storm's snow.
Built this in my front yard in 10 inches of snow.
We had fun on our day off!
Ava and Amelia Hendrix playing in the snow.
Giant snowman 7 ft tall 5 ft round
Adults can have fun too!
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