text:
Friday, September 26, 2014
Reuters: Muslim Scholars Present Rebuttal to Islamic State
Reuters is reporting that over 120 Islamic scholars from around the world have issued an open letter denouncing Islamic State militants and refuting their religious arguments. Many of these scholars are themselves leading Muslim voices in their own countries.
The 22-page letter, written in Arabic and heavy with quotes from the Koran and other Islamic sources, strongly condemns the torture, murder and destruction Islamic State militants have committed in areas they control.
The Reuters report states in part:
"You have misinterpreted Islam into a religion of harshness, brutality, torture and murder," the letter said. "This is a great wrong and an offense to Islam, to Muslims and to the entire world."
[The letter's] originality lies in its use of Islamic theological arguments to refute statements made by self-declared Caliph Abu Bakr al-Baghdadi and his spokesman Abu Muhammad al-Adnani to justify their actions and attract more recruits to their cause.
The letter is addressed to al-Baghdadi and "the fighters and followers of the self-declared 'Islamic State'", but is also aimed at potential recruits and imams or others trying to dissuade young Muslims from going to join the fight.
Nihad Awad of the Council on American Islamic Relations (CAIR), which presented the letter in Washington on Wednesday, said he hoped potential fighters would read the document and see through the arguments of Islamic State recruiters.
"They have a twisted theology," he said in a video explaining the letter. "They have relied many times, to mobilize and recruit young people, on classic religious texts that have been misinterpreted and misunderstood."
Reuters describes the 126 signatories as "prominent" Sunni men from across the Muslim world -- from Indonesia to Morocco, and from other countries such as the United States, Britain, France and Belgium.
Among those who signed are "the current and former grand muftis of Egypt, Shawqi Allam and Ali Gomaa, former Bosnian grand mufti Mustafa Ceric, the Nigerian Sultan of Sokoto Muhammad Sa'ad Abubakar and Din Syamsuddin, head of the large Muhammadiyah organization in Indonesia. Eight scholars from Cairo's Al-Azhar University, the highest seat of Sunni learning, also put their names to the document."
September 26, 2014 in Church and State, Current Affairs, In the News, International | Permalink | Comments (0) | TrackBack (0)
American Association of Librarians Accepting Applifcations for Innovative Reading Grant Program
The Philanthropy News Digest is reporting that the American Association of School Librarians, a division of the American Library Association, is accepting applications from school librarians for its AASL Innovative Reading Grant program.
One grant in the amount of $2,500 will be awarded in support of the planning and implementation of a unique and innovative program for children that motivates and encourages reading, especially among struggling readers.
Projects should promote the importance of reading and facilitate literacy development by supporting current reading research, practice, and policy. In addition, projects must be specifically designed for children (grades K-9) in the school library setting, encourage innovative ways to motivate and involve children in reading, and should demonstrate potential to improve student learning.
To be eligible, applicants must be a member of AASL. Grant recipients may be invited to write an article that delineates their reading incentive project and demonstrates their successes, trials, and recommendations so others may replicate the project.
September 26, 2014 in Current Affairs, In the News, Other | Permalink | Comments (0) | TrackBack (0)
Thursday, September 25, 2014
NFL Tax Exempt Status in Jeopardy
The NFL has garnered a great deal of unwanted attention lately. However, as of last week, things seem to have taken a turn for the worse. On September 18, a group of Democratic Senators introduced a bill that would ultimately revoke the NFL's tax-exempt status under 501(c)(6) if the league continues to support the Washington Redskins name and logo.
Recently, the Redskins franchise has been under fire for its racially insensitive depiction of Native Americans, prompting the U. S. Patent Office to cancel the Redskins' trademark protection. While this hasn't been the first time the patent office has revoked the Redskin's trademark, the serious prospect of Congress revoking the NFL's tax-exempt status may be a first, and it raises some interesting questions about the league's protection under 501(c)(6). Should the NFL—a powerful, high revenue generating American institution—continue to enjoy tax-exempt status? If not, what are some of the potential implications for taxpayers and other tax-exempt organizations? For the full article click the link below.
Senators introduce bill to revoke NFL's tax-exempt status if Redskins name stands
September 25, 2014 in Current Affairs | Permalink | Comments (0) | TrackBack (0)
Wednesday, September 24, 2014
Clinton Global Initiative Ends Today -- Millions of Dollars Pledged
The Clinton Global Initiative, former President Bill Clinton's annual philanthrophy summit held in New York ends today. The summit opened on Sunday and has thus far heard from speakers include actor Matt Damon, representing the charity he co-founded, Water.org; Laurent Lamothe, Prime Minister of Haiti; and Judith Rodin, president of the Rockefeller Foundation.
Ever since it was established in 2005, the Clinton Global Initiative has drawn more than 180 world leaders and more than 2,900 commitments worth an estimated $103-billion. This year's announced pledges include:
- $280-million from BRAC International to help more than 2.7 million girls across eight countries to finish school and go on to careers;
- $100-million from Camfed to help girls in Sub-Saharan Africa complete secondary school;
- $50-million from Grameen America to support 7,000 female entrepreneurs in Harlem;
- $19-million from Discovery Communications and the United Kingdom's Department for Internaitonal Development to improve learning for girls in Ghana, Kenya, and Nigeria;
- $16-million from Plan International to prevent and respond to gender-based violence at schools in Asia;
- $12-million from Room to Read to help an additional 15,000 girls in nine countries to finish secondary school and go on to college and careers;
- $6-million noncash support from Direct Relief, Last Mile Health, Wellbody Alliance, and Africare to airlift 100 tons of medical supplies to West Africa to combat the Ebola outbreak;
- $4-million from the FHI Foundation and FHI 360 to study how to improve international-development projects across different fields;
- $3.2-million from the Lumina Foundation and $3-million challenge grant from Cisco to the National Service Alliance for its Service Year program, which encourages young adults ages 18 to 28 to embark on community service for a year;
- $3-million from Comcast and NBCUniversal, Airbnb, Jonathan and Jeanne Lavine, and Josh and Anita Bekenstein to Be the Change for its ServiceNation campaign to encourage people to volunteer for a year.
September 24, 2014 in Conferences, Current Affairs, In the News | Permalink | Comments (0) | TrackBack (0)
March of the Benefit Corporation: So Why Bother? Isn't the Business Judgment Rule Alive and Well? (Part III)
(Note: This is a cross-posted multiple part series from WVU Law Prof. Josh Fershee from the Business Law Prof Blog and Prof. Elaine Waterhouse Wilson from the Nonprofit Law Prof Blog, who combined forces to evaluate benefit corporations from both the nonprofit and the for-profit sides. The previous installments can be found here and here (NLPB) and here and here (BLPB).)
In prior posts we talked about what a benefit corporation is and is not. In this post, we'll cover whether the benefit corporation is really necessary at all.
Under the Delaware General Corporation Code § 101(b), "[a] corporation may be incorporated or organized under this chapter to conduct or promote any lawful business or purposes . . . ." Certainly there is nothing there that indicates a company must maximize profits or take risks or "monetize" anything. (Delaware law warrants inclusion in any discussion of corporate law because the state's law is so influential, even where it is not binding.)
Back in 2010, Josh Fershee wrote a post questioning the need for such legislation shortly after Maryland passed the first benefit corporation legislation:
I am not sure what think about this benefit corporation legislation. I can understand how expressly stating such public benefits goals might have value and provide both guidance and cover for a board of directors. However, I am skeptical it was necessary.
Not to overstate its binding effects today, but we learned from Dodge v. Ford that if you have a traditional corporation, formed under a traditional certificate of incorporation and bylaws, you are restricted in your ability to "share the wealth" with the general public for purposes of "philanthropic and altruistic" goals. But that doesn't mean current law doesn't permit such actions in any situation, does it?
The idea that a corporation could choose to adopt any of a wide range of corporate philosophies is supported by multiple concepts, such as director primacy in carrying out shareholder wealth maximization, the business judgment rule, and the mandate that directors be the ones to lead the entity. Is it not reasonable for a group of directors to determine that the best way to create a long-term and profitable business is to build customer loyalty to the company via reasonable prices, high wages to employees, generous giving to charity, and thoughtful environmental stewardship? Suppose that directors even stated in their certificate that the board of directors, in carrying out their duties, must consider the corporate purpose as part of exercising their business judgment.
Please click below to read more.
September 24, 2014 in Current Affairs, In the News, State – Judicial, State – Legislative | Permalink | Comments (0) | TrackBack (0)
Wednesday, September 3, 2014
The March of the Benefit Corporation: Next Up, West Virginia (PART II)
(Note: This is a cross-posted multiple part series from WVU Law Prof. Josh Fershee from the Business Law Prof Blog and Prof. Elaine Waterhouse Wilson from the Nonprofit Law Prof Blog, who combined forces to evaluate benefit corporations from both the nonprofit and the for-profit sides. The previous installment can be found here (NLPB) and here (BLPB).)
What It Is: So now that we've told you (in Part I) what the benefit corporation isn't, we should probably tell you what it is. The West Virginia statute is based on Model Benefit Corporation Legislation, which (according to B Lab's website) was drafted originally by Bill Clark from Drinker, Biddle, & Reath LLP. The statute, a copy of which can be found, not surprisingly, at B Lab's website, "has evolved based on comments from corporate attorneys in the states in which the legislation has been passed or introduced." B Lab specifically states that part of its mission is to pass legislation, such as benefit corporation statutes.
As stated by the drafter's "White Paper, The Need and Rationale for the Benefit Corporation: Why It is the Legal Form that Best Addresses the Needs of Social Entrepreneurs, Investors, and, Ultimately, the Public" (PDF here), the benefit corporation was designed to be "a new type of corporate legal entity." Despite this claim, it's likely that the entity should be looked at as a modified version of traditional corporation rather than at a new entity.
This is because the Benefit Corporation Act appears to leave a lot of room for the traditional business corporations act to serve as a gap-filler. West Virginia Code § 31F-1-103(c), for example, explains, "The specific provisions of this chapter control over the general provisions of other chapters of this code." Thus, the benefit corporation provisions supplant the traditional business corporation act where stated specifically, such as with regard to fiduciary duties, but general provisions of the business corporations act apply where the benefit corporation act is silent, such as with regard to dissolution.
In contrast, the West Virginia Nonprofit Corporation Act is a broader act that discusses dissolution, mergers, and other items specifically in a way that more clearly indicates the nonprofit is a distinct, rather than modified, entity form. Furthermore, a benefit corporation is actually formed under the Business Corporations Act: "A benefit corporation shall be formed in accordance with article two, chapter thirty-one-d of this code, and its articles as initially filed with the Secretary of State or as amended, shall state that it is a benefit corporation." W. Va. Code § 31F-2-201.
So what makes a benefit corporation unique?
1. Corporate purpose - The traditional West Virginia business corporation is created for the purpose "of engaging in any lawful business unless a more limited purpose is set forth in the articles of incorporation." W. Va. Code § 31D-3-301. Under the Benefit Corporation Act, "A benefit corporation shall have as one of its purposes the purpose of creating a general public benefit." Id. § 31F-3-301. A specific benefit may be stated as an option, but is not required. Note similarly that a part of the corporation's purpose must be for general public benefit, but that benefit need not be a primary, substantial, significant or other part of the corporation's purpose.
For purpose of comparison, the low-profit limited liability company (or L3C) typically has a much more onerous purpose requirement. For example, the Illinois L3C law requires
(a) A low-profit limited liability company shall at all times significantly further the accomplishment of one or more charitable or educational purposes within the meaning of Section 170(c)(2)(B) of the Internal Revenue Code of 1986, 26 U.S.C. 170(c)(2)(B), or its successor, and would not have been formed but for the relationship to the accomplishment of such charitable or educational purposes.
2. Standard of conduct – The statute requires, in § 31F-4-401, that the directors and others related to the entity:
(1) Shall consider the effects of any corporate action upon:
(A) The shareholders of the benefit corporation;
(B) The employees and workforce of the benefit corporation, its subsidiaries, and suppliers;
(C) The interests of customers as beneficiaries of the general or specific public benefit purposes of the benefit corporation;
(D) Community and societal considerations, including those of each community in which offices or facilities of the benefit corporation, its subsidiaries, or suppliers are located;
(E) The local and global environment;
(F) The short-term and long-term interests of the benefit corporation, including benefits that may accrue to the benefit corporation from its long-term plans and the possibility that these interests and the general and specific public benefit purposes of the benefit corporation may be best served by the continued independence of the benefit corporation; and
(G) The ability of the benefit corporation to accomplish its general and any specific public benefit purpose;
(emphasis added). While these are significant mandatory considerations, they are nothing more than considerations. Directors and others "[n]eed not give priority to the interests of a particular person referred to in subdivisions (1) and (2) of this section over the interests of any other person unless the benefit corporation has stated its intention to give priority to interests related to a specific public benefit purpose identified in its articles." § 31F-4-401(a)(3).
As such, while directors must consider the general public benefit of their decisions (and any specific benefits if so chosen), it is not clear the ultimate decision making of a benefit corporation director would necessarily be any different than a traditional corporation. That is, a director of a benefit corporation could, for example, consider the impacts on a town of closing a plant (and determine it would be hard on the town and the workforce), but ultimately decide to close the plant anyway.
Furthermore, many corporations seek to serve communities and benefit the public. McDonald's, Coca-Cola, and many others already have programs to benefit the public, so it appears that many traditional corporations have already volunteered to meet and exceed the standards of the West Virginia benefit corporations act.
3. Formation – An entity becomes a benefit corporation by saying so when filing initial articles of incorporation with the Secretary of State, § 31F-2-201, or by amending the articles of an already created corporation, § 31F-2-202. Presumably, this serves a notice function, informing the benefit corporation's current and potential constituents that there is the possibility that profit maximization will not be (or may not be) the corporation's primary goal. The notice function does not work in reverse, however, as benefit corporation status does guarantee that public benefits have any primacy at all, merely that such benefits will be considered.
4. Termination - Termination of the benefit corporation status is allowed and is achieved by changing the articles of incorporation in the same manner in which traditional corporations modify their articles. § 31D-10-1003. As a result, it doesn't appear that there is anything in the statute from preventing a benefit corporation from reaping the public relations or capital raising upside of being a benefit corporation, and thereafter abandoning the status should it become inconvenient. Query whether to the extent a transfer to a benefit corporation could be deemed a gift for a public purpose, the Attorney General might have oversight over the contribution in the same manner as it has oversight in cy pres and similar proceedings.
5. Enforcement – Third parties have no right of action to enforce the benefit goals unless they are allowed to use derivatively as "specified in the articles of incorporation or bylaws of the benefit corporation." Id. § 31F-4-403. Otherwise, a direct action of the corporation or derivative actions from a director or shareholder are the only ways to commence a "benefit enforcement proceeding." Again, the statute does not give the Attorney General specific statutory authorization to proceed on the basis that a member of the public may have transferred funds to the benefit corporation in reliance upon its benefit corporation status.
So, the statute provides the option for stating and pursuing general and specific benefits, but there are not a lot of structural assurances to anyone—investor, lender, public—that a benefit corporation will actually benefit anyone other than its equity holders. But benefit corporations are required to consider doing so. This is not to say there isn't some value. As Haskell Murray has noted,
Directors would benefit from having a primary master and a clear objective. . . . [But,] [t]he mandate that a benefit corporation pursue a "general public benefit purpose" is too vague because it does not provide a practical way for directors to make decisions.
As such, an entity may create a clear set of priorities and guidelines that could provide useful and lead to benefits, but the benefit corporation act most certainly does not mandate that.
Finally, although most of the above is focused on the West Virginia benefit corporation law, much of it applies to the other versions of such laws in other states. Cass Brewer notes
Effective July 1, 2014, West Virginia's benefit corporation statute generally follows the B-Lab model legislation, but among other things relaxes the "independence" tests for adopting third-party standards and does not require the annual benefit report to disclose director compensation.
As an additional resource, Haskell Murray provides a detailed chart of the state-by-state differences, here.
Next up: Part III - So Why Bother? Isn't the Business Judgment Rule Alive and Well?
September 3, 2014 in Current Affairs, In the News, State – Legislative | Permalink | Comments (0) | TrackBack (0)
Tuesday, August 26, 2014
The March of the Benefit Corporation: Next Up, West Virginia (Cross Post)
West Virginia is the latest jurisdiction to adopt benefit corporations – the text of our legislation can be found here. As with all benefit corporation legislation, the thrust of West Virginia's statute is to provide a different standard of conduct for the directors of an otherwise for-profit corporation that holds itself out as being formed, at least in part, for a public benefit. (Current and pending state legislation for benefit corporations can be found here.)
As WVU Law has two members of the ProfBlog family in its ranks (Prof. Josh Fershee (on the Business Law Prof Blog) and Prof. Elaine Waterhouse Wilson (on the Nonprofit Law Prof Blog)), we combined forces to evaluate benefit corporations from both the nonprofit and the for-profit sides. For those of you on the Business Prof blog, some of the information to come on the Business Judgment Rule may be old hat; similarly, the tax discussion for those on the Nonprofit Blog will probably not be earth-shaking. Hopefully, this series will address something you didn't know from the other side of the discussion!
Part I: The Benefit Corporation: What It's Not: Before going into the details of West Virginia's legislation (which is similar to statutes in other jurisdictions), however, a little background and clarification is in order for those new to the social enterprise world. A benefit corporation is different than a B Corporation (or B Corp). B Lab, which states that it is a "501(c)(3) nonprofit" on its website, essentially evaluates business entities in order to brand them as "Certified B Corps."
It wants to be the Good Housekeeping seal of approval for social enterprise organizations. In order to be a Certified B Corp, organizations must pass performance and legal requirements that demonstrate that it meets certain standards regarding "social and environmental performance, accountability, and transparency." Thus, a business organized as a benefit corporation could seek certification by B Lab as a B Corp, but a business is not automatically a B Corp because it's a state-sanctioned benefit corporation – nor is it necessary to be a benefit corporation to be certified by B Labs.
In fact, it's not even necessary to be a corporation to be one of the 1000+ Certified B Corps by B Lab. As Haskell Murray has explained,
I have told a number of folks at B Lab that "certified B corporation" is an inappropriate name, given that they certify limited liability companies, among other entity types, but they do not seem bothered by that technicality. I am guessing my fellow blogger Professor Josh Fershee would share my concern. [He was right.]
A benefit corporation is similar to, although different from, the low-profit limited liability company (or L3C), which West Virginia has not yet adopted. (An interesting side note: North Carolina abolished its 2010 L3C law as of January 1, 2014.) The primary difference, of course, is that a benefit corporation is a corporation and an L3C is a limited liability company. As both the benefit corporation and the L3C are generally not going to be tax-exempt for federal income tax purposes, the state law distinction makes a pretty big difference to the IRS. The benefit corporation is presumably going to be taxed as a C Corporation, unless it qualifies and makes the election to be an S Corp (and there's nothing in the legislation that leads us to believe that it couldn't qualify as an S Corp as a matter of law). By contrast, the L3C, by default will be taxed as a partnership, although again we see nothing that would prevent it from checking the box to be treated as a C Corp (and even then making an S election). The choice of entity determination presumably would be made, in part, based upon the planning needs of the individual equity holders and the potential for venture capital or an IPO in the future (both very for-profit type considerations, by the way). The benefit corporation and the L3C also approach the issue of social enterprise in a very different way, which raises serious operational issues – but more on that later.
Finally, let's be clear – a benefit corporation is not a nonprofit corporation. A benefit corporation is organized at least, in some part, to profit to its owners. The "nondistribution constraint" famously identified by Prof. Henry Hansmann (The Role of Nonprofit Enterprise, 89 Yale Law Journal 5 (1980), p. 835, 838 – JSTOR link here) as the hallmark of a nonprofit entity does not apply to the benefit corporation. Rather, the shareholders of a benefit corporation intend to get something out of the entity other than warm and fuzzy do-gooder feelings – and that something usually involves cash.
In the next installments:
Part II – The Benefit Corporation: What It Is.
Part III – So Why Bother? Isn't the Business Judgment Rule Alive and Well?
Part IV – So Why Bother, Redux? Maybe It's a Tax Thing?
Part V - Random Thoughts and Conclusions
EWW and JPF
August 26, 2014 in Current Affairs, In the News, State – Legislative | Permalink | Comments (1) | TrackBack (0)
Thursday, August 21, 2014
Samaritan's Purse as Illustrative of the Benefits and Challenges of Government-Nonprofit Collaboration
The Washington Post has published a piece featuring Samaritan's Purse – the charitable nonprofit making headline news for its role in helping save the lives of two front-line medical missionaries who contracted Ebola while serving in Liberia. The story describes the world-wide humanitarian relief provided by Samaritan's Purse, its role in partnering with governmental and nonprofit agencies to address international public health crises, and the occasional controversies that have arisen from its faith-based mission or some of the opinions that its president, Franklin Graham, has expressed on contemporary issues.
As to its important role in promoting international public health, the story states the following:
… Smart Money magazine has named Samaritan's Purse the most efficient religious charity numerous times, and the group maintains a reputation of being among the first to combat the worst public health crises around the world.
Given the remote and hard-to-reach areas they work in, there's been many instances in the past where we've first heard of specific suspected clusters of illnesses through them," Rima Khabbaz, the CDC's deputy director for infectious diseases, said of NGOs such as Samaritan's Purse. "They are no doubt very important partners in our global public health work. Not infrequently, [the] first unconfirmed reports reach the public health community through them."
Michael Osterholm, director of the Center for Infectious Disease Research and Policy at the University of Minnesota, said in many parts of the world, groups such as Samaritan's Purse and Doctors Without Borders "are the safety net for global health." He added: "They are the ones in the areas of war and civil unrest."
As to the "controversies" involving the organization itself, the story first cites criticism by the New York Times when SP communicated a religious message while assisting victims of an earthquake in El Salvador. Apparently the Times objected to such communications because SP had received $200,000 from USAID – though SP was later found not to have violated governmental guidelines. Another alleged controversy involved an effort by SP to distribute Arabic-language Bibles during the 1990-1991 gulf war through U.S. troops (presumably volunteers, although the story never says so) – a plan that reportedly "drew a sharp rebuke" from General Norman Schwarzkopf because it would have violated a US-Saudi agreement that there would be no proselytizing.
In my judgment, the story illustrates inevitable differences between the public and nonprofit sector. What SP does effectively by way of humanitarian relief depends on its faith – at numerous levels. SP assists the suffering because of theological commitments to meet both spiritual and physical needs. Indeed, a tenet of SP's Statement of Faith reads as follows:
We believe that human life is sacred from conception to its natural end; and that we must have concern for the physical and spiritual needs of our fellowmen. Psalm 139:13; Isaiah 49:1; Jeremiah 1:5; Matthew 22:37-39; Romans 12:20-21; Galatians 6:10.
SP's faith-based mission takes it to isolated places many governmental agencies would otherwise overlook – places where not just spiritual needs, but also pressing medical and other physical needs, surface. SP's vast network of volunteers and staff likely works with unusual dedication because of their commitment not just to a "cause," but to a "Cause."
Yet care must be taken when government partners with nonprofits – by both partners. A religious nonprofit must be careful not to use government resources in a manner inconsistent with valid secular objectives. And government must be careful not to try to transform the religious nonprofit into a neutral, nonsectarian agency. The public is right to demand that both hold up their obligations in such a partnership. On the whole, the story suggests that SP and public bodies that have worked with them generally follow the rules of the partnership.
August 21, 2014 in Current Affairs | Permalink | Comments (0) | TrackBack (0)
Tuesday, August 19, 2014
Update on ProPublica's Request for Information on Post-Sandy Expenditures
We previously blogged about the efforts of ProPublica to obtain from the American Red Cross (ARC) information about how the ARC has spent its $300 million-plus in donations that it received for humanitarian aid following Hurricane Sandy. The blog entry opines as follows:
Soliciting and expending funds in connection with major disasters can present some thorny legal issues (as several of us tax and nonprofit law scholars have discussed in our scholarship). In general, analyzing whether these issues pose a problem in any given case does require assessment of the type of information that ProPublica seeks. While privacy laws protecting individuals should certainly be observed, I would think the public interest better served by erring on the side of full disclosure.
Perhaps the ARC has come to appreciate this viewpoint. The Chronicle of Philanthropy reports that the ARC has sent a 108-page document disclosing that it "has used roughly three-quarters of the $312-million raised, with just under $130-million going to 'financial assistance' and $46-million dedicated to the deployment of staff and volunteers." Additional details are available on ProPublica's website.
August 19, 2014 in Current Affairs | Permalink | Comments (0) | TrackBack (0)
Monday, August 18, 2014
Hospital Charity Care after the Affordable Care Act
In Hospitals Reassess Charity as Obamacare Options Become Available, the Washington Post reports that "hospitals are rethinking their charity programs, with some scaling back help for those who could have signed up for coverage but didn't." The story cites concern "that offering free or discounted care to low-income, uninsured patients might dissuade them from getting government-subsidized coverage," and notes the obvious financial interest that hospitals have in treating "more patients covered by insurance as the federal government makes big cuts in funding for uncompensated care."
The story reveals the calculus facing hospital decision-makers:
Hospital executives say they are weighing many questions in evaluating whether to change their policies. Did people choose not to enroll, or were they unable to get through the new health insurance marketplaces during the open enrollment in the fall and spring? Did they know subsidized coverage is available? Could they afford insurance?
"That's something hospitals have struggled with for decades: Is the patient unwilling to pay or unable to pay?" says Katherine Arbuckle, senior vice president and chief financial officer at Ascension Health based in St. Louis.
The story further reports that some hospitals, including those managed by two major chains, plan no major changes to their charity care policies under Obamacare.
August 18, 2014 in Current Affairs | Permalink | Comments (0) | TrackBack (0)
Sununu's Boston Globe Op Ed on the Tax-Exempt Status of Colleges after O'Bannon
In a recent opinion editorial in the Boston Globe, John E. Sununu, former Republican senator from New Hampshire, argues that the recent decision of O'Bannon v. NCAA sounds the death knell for the federal income tax exemption of universities with major athletics programs. In the O'Bannon case, a federal district judge ruled that the NCAA's rules prohibiting student-athletes from receiving payments of a share of licensing fees for the use of their names and likenesses violates federal antitrust laws. Sununu opines that the "ultimate destination" of the O'Bannon case is "a date with the Internal Revenue Service."
His argument appears to be simple initially: "If universities are going to compensate athletes for supporting multi-million dollar sports programs, the idea that these organizations are tax-exempt nonprofits becomes absurd."
But then Sununu cites many other factors to support his conclusion that the "far bigger lie is that these major sports schools are nonprofit institutions." He continues:
Today, at least a dozen schools generate $100 million per year from sports programs -- a figure that approaches 10 percent of the operating budget for powerhouses like Auburn and Louisville. Paying athletes strips away whatever pretense remains of that educational mission, at least for a significant portion of their student body and revenue base. As payments flow and revenues grow, the school administrators, NCAA officials, and IRS bureaucrats who have colluded to maintain that pretense will have little left to argue.
It's especially hard to hide behind the educational mission when the highest paid employee at your school is a coach. Last year, 25 college football coaches took home more than $2.5 million each. At Alabama, Coach Nick Saban's salary topped $5 million. The issue here is not whether they are worth it, or whether the schools are justified in paying that freight, but whether the business entity paying such rich contracts should operate tax-free.
The eye-popping numbers on ESPN's recent deal for a Southeast Conference Sports Network lay bare the economics at stake. With $800 million in profits, each of the 14 schools can expect yearly distributions of roughly $50 million tax-free. … Paying coaches and athletes, selling tickets and television rights, licensing merchandise and fight-song ringtones. Sounds like a business to me.
Yes, in a non-technical, intuitive sense, it "sounds like a business." But I am not nearly as quick as Sununu to jump to the conclusion that O'Bannon means that all universities with major sports programs are now doomed to lose federal income tax exemption.
First, it is doubtful that the payment of athletes for the use of their likenesses – which the O'Bannon court decision permits to be done, subject to an NCAA-imposed cap – is the decisive factor that should transform an institution from "educational" under the law to one that is not. An educational institution compensates those who perform services in the pursuit of the institution's mission – including students. The bigger question is whether what athletic programs do is really properly characterized as educational or otherwise charitable. A modest payment for the use of a student-athlete's likeness is probably not sufficient to tip the scales in one direction or another with respect to that larger question.
And although I, too, tend to be shocked at the amount of money some head coaches are paid and feel a sense of disbelief at what such compensation says about the priority that we, as a society, place upon sports, it is also true that large, tax-exempt charitable institutions of many types pay their top executives very well. My point is not that such compensation is normatively justifiable (although in many cases, it probably is). My point is simply that under current law, a very large salary is not necessarily inconsistent with a charitable institution's income tax exemption. (And of course, if the athletics department were treated as a distinct, taxable entity, the payment of the coaches' salaries would generally be fully deductible in computing the payor's taxable income.)
Moreover, even if a school's athletics program were properly viewed as an unrelated trade or business – a question that I do not intend to answer in this post – it does not follow that the university itself should lose federal income tax exemption because of its athletics program. The dollar value of these programs is indeed high. But the significance of these programs does not necessarily surpass that of the clearly educational operations of major universities. I am far from convinced that a major teaching and research institution fails the organizational and operational tests of the Treasury regulations just because it also operates a prominent national athletics program.
Thus, while I share many of the concerns of Mr. Sununu, I think that the O'Bannon case alone is unlikely to prompt a wave of revocations of university tax exemptions.
August 18, 2014 in Current Affairs | Permalink | Comments (1) | TrackBack (0)
Monday, July 28, 2014
Private Foundation investments have almost erased the impact of 2008
The 2013 Common Fund/Council on Foundation study of private foundation investments is available here, and it's generally pretty good news.
According to a summary article at Chronicle of Philanthropy, private foundation investments grew on average 15.6% in 2013. The five year annual return, including 2013, is now at 12%; compare that to last year's five year annual return, which was only 1.7%. The article notes that the disasterous retuns of 2008 have now rolled out of the 5 year running average. In additional good news, foundation debt is down and spending is up.
The bad news - nonprofit grant recipientss are still in a rough state, which is part of the reason why foundation giving is up. In addition, the report warns of increasing volatility and, therefore, likely lower returns in the coming year.
July 28, 2014 in Current Affairs, In the News | Permalink | Comments (0) | TrackBack (0)
Friday, July 25, 2014
$650 Million Gift to Study Genetics of Psychiatric Disorders
The Chronicle of Philanthropy is commenting on billionaire businessman Ted Stanley's recent $650-million pledge to the Broad Institute to study the genetics of psychiatric disorders. The pledge is one of the largest individual donations ever to medical research.
The pledge comes at a very opportune moment. According to the Chronicle,
About one in four adults suffers from a mental disorder, and one in 17 people live with a serious mental illness like major depression, bipolar disorder, or schizophrenia, according to the National Institute on Mental Health. The World Health Organization estimates 450 million people worldwide suffer from such diseases.
One would think that such staggering statistics would lead state and national leaders to allocate more funds to addressing the needs of the mentally ill. Not so, says the Chronicle. Instead,
. . . from 2009 to 2011, states cut more than $1.8-billion from their budgets for services helping children and adults who have mental illnesses, states the National Alliance on Mental Illness. Support for scientific research has dwindled, and what remains is difficult to obtain because of increased competition for scarce dollars.
This is a sad situation. Like the Chronicle, I hope Mr. Stanley's gift will "spark a flurry of additional donations to mental-health causes."
July 25, 2014 in Current Affairs, In the News | Permalink | Comments (1) | TrackBack (0)
Wednesday, July 23, 2014
Eisenberg: Start Campaign to Curtail Excessive Trustee Fees
Writing in yesterday's Chronicle of Philanthropy, Pablo Eisenberg, a senior fellow at the Center for Public and Nonprofit Leadership at the Georgetown Public Policy Institute, calls on nonprofits to start a campaign to ask Congress and the IRS to curtail excessive trustee fees paid by nonprofit foundations.
According to Eisenberg, "[t]he tens of millions of dollars that foundations pay to trustees every year is a total waste of money that could be used to finance needy nonprofit organizations. He contends that:
Fresh concerns about those fees were raised when the news become public that the Otto Bremer Foundation, which last year gave $38-million in grants, had paid its three board trustees more than $1.2-million in 2013. So egregious was the payment that Aaron Dorfman, executive director of the National Committee for Responsive Philanthropy, requested an immediate investigation by the Minnesota attorney general.
The Bremer trustees had fired the foundation's executive director, leaving them totally in charge without any accountability mechanisms in place.
Eisenberg continues:
Data about the total amount trustees are paid are hard to come by, but a Chronicle of Philanthropy survey in 2011 found that 38 of the nation's 50 largest foundations paid a fee to their trustees amounting to a total of $11-million.
He also reports that
[a] 2006 Urban Institute report about the compensation practices of 10,000 of the largest foundations based on 2001 tax returns found that 3,400 of the foundations had paid a total of almost $200-million in trustee fees.
Finally, he reveals that an earlier study of 238 foundations he conducted with two of his graduate students at Georgetown University in 2003 revealed that the foundations "had paid more than $44-million in trustee fees. About two-thirds of the 176 largest foundations compensated their board members, while 79 percent of the 62 smaller foundations surveyed paid their board members."
On the basis of this sample, Eisenberg and his students estimated that foundations throughout the country had paid more than $300-million in trustee fees.
That is a lot of money. Moreover, says Eisenberg, it is infuriating:
What has infuriated foundation critics and many nonprofits is that foundation trustees are among the wealthiest and highest-paid individuals in the country. As Aaron Dorfman has noted, most foundation trustees would take on their duties even if they weren't paid. Most other nonprofits don't pay their trustees, after all.
But habits die hard. Many foundations maintain that it is important to offer fees as an incentive to busy corporate and wealthy individuals who might otherwise not give their time. And, they add, it is difficult enough to recruit topnotch board members; fees just make the process easier. The corporate culture that believes "time is money" is a tradition that lingers on.
Eisenberg admits, though, that annoyance at the practice of trustee fees has not yet morphed into sufficient energy and public pressure that could produce some changes. Neither philanthropic trade associations, philanthropy roundtables, nor regulators and legislators appear ready to do something about the excessive fees. Hence, Eisenberg has a solution: nonprofits should stasrt a campaign to have Congress and the IRS curtail these excessive trustee fees. Eisenberg concludes:
Nonprofits should start a campaign to ask Congress and the IRS to curtail excessive fees. Almost all nonprofit groups hungry for new dollars should be willing to support the idea, and how could politicians be opposed to the idea that more money goes to communities than affluent trustees? Now we just need some leadership to get the movement going.
Will the nonprofits respond? Time will tell.
July 23, 2014 in Current Affairs, In the News, Other | Permalink | Comments (0) | TrackBack (0)
School of Philanthropy Dean Search Down to Two
The Nonprofit Times is reporting that the search for someone to fill the shoes of retiring founding dean Eugene R. Tempel at the Indiana University Lilly Family School of Philanthropy has been narrowed down to two candidates.
The Times reports that while the university will only confirm that the search is ongoing and the intention is to have a new dean by January 1, 2015, the Times has information that only two candidates -- neither of whom is from Indiana University -- remain.
The Times continues:
Multiple sources have told The NonProfit Times that the process has not been as smooth as was expected. In fact, there has been some consideration as to under what terms Tempel might stay on for up to one more year if the new dean is not selected soon, according to multiple sources within the university and search process.
The search committee presented candidates to Charles R. Bantz, Ph.D., chancellor of the Indianapolis campus, known as IPUI since it is shared with Purdue University. There were three finalists but one of them, from a university in California, has withdrawn his application, according to sources.
Andrew R. Klein, J.D., chair of the IU Lilly Family School of Philanthropy selection committee and dean of the IU Robert H. McKinney School of Law, disputed the idea that the search has not gone as smoothly as hoped. He said the plan was to present a pool of candidates to the administration by mid-summer and that has happened. He said eight candidates were reduced to "those who came back to campus."
He declined to confirm the number of candidates who made campus visits and the number of candidates still in the running for the coveted position in nonprofit academia. He cited a confidentiality pledge to the candidates who are still employed. "Chancellor Bantz is in consultation with President (Michael A.) McRobbie about the search," he said. "The appointment of any dean is ultimately made by the Board of Trustees of Indiana University," Klein said. "I am not involved in the conversations at this point, but I am certain that Chancellor Bantz is consulting with President McRobbie to make sure the administration presents a candidate to the board in which they both have confidence."
The Lilly Family School evolved from the internationally known Center on Philanthropy of the IU-Purdue University campus in Indianapolis, Indiana. The school encompasses and expands all of the previous academic degree, research and training programs at Indiana University, including The Fund Raising School, the Lake Institute on Faith & Giving, the Women's Philanthropy Institute and International Programs.
July 23, 2014 in Current Affairs, In the News, Other | Permalink | Comments (0) | TrackBack (0)
Monday, July 21, 2014
Charities that Support People with Mental Illness Win Hilton Prize
This morning I came across this touching story published in Friday's Chronicle of Philanthropy. The story begins by stating that the biggest danger for people living with severe mental illnesses is not navigating the health-care system or finding a good therapist, but living in isolation. Because people with mental illnesses no longer spend much time in hospitals, they end up living alone. According to Kenneth Dudek, president of Fountain House, a New York charity that helps mentally ill people live independently, living in isolation makes the illness worse and the patients do not get the help they need.
For its efforts to provide a sense of community to the mentally ill, Fountain House and its sister organization, Clubhouse International, have won the Conrad N. Hilton Humnanitarian Prize, a $1.5 million award that recognizes an organization that works to alleviate human suffering.
This is the first time the prize has been awarded to a mental-health organization. According to Hawley Hilton McAuliffe, a member of the prize's jury and granddaughter of Conrad Hilton, the organizations were chosen because mental health has not received much attention despite the prevalence of the problem. Said McAuliffe: "It's a humanitarian crisis at this point, especially here in the United States. It's one area that has not been addressed by many organizations."
McAuliffe revealed that as the prize jury deliberated about this year's award, it considered Fountain House's success at giving mentally ill people opportunities to find fellowship. It also considered the recent spate of mass shootings by mentally ill individuals, in particular the spree committed by 22-year-old Elliott Rodger, who killed six people and injured 13 others near the campus of the University of California at Santa Barbara in May. The Chornicle quotes McAuliffe as saying, "Here was this isolated individual who had no sense of community. Wouldn't Fountain House have been a good resource for him?"
The truth is, many mentally ill people are in need of similar resources. The Chronicle states it well:
In the United States alone, 13.6 million people live with a serious mental illness like major depression, bipolar disorder, or schizophrenia, according to the National Alliance on Mental Illness. And the World Health Organization estimates 450 million people worldwide suffer from such illnesses. Three-quarters of chronic mental illnesses begin by the age of 24, but people sometimes wait decades to seek treatment. Most alarming, nearly half of all homeless adults in America has a severe mental illness.
That is a sobering statistic. I applaud Fountain House and Clubhouse International for the assistance they give to some of the suffering people.
July 21, 2014 in Current Affairs, In the News | Permalink | Comments (0) | TrackBack (0)
Saturday, July 19, 2014
Assessment of the "America Gives More Act"
Unsurprisingly, the U.S. House passed charitable giving legislation, the "America Gives More Act," on July 17 by a vote of 277-130. (For a summary of the bill's contents, see prior blog post.) Broadly, the bill would encourage food donations, transfers from IRAs, conservation easement donations, extend the time to claim charitable deductions to April 15, and reduce the tax on private foundation investment income. According to the Joint Committee on Taxation, the legislation would cost taxpayers $16.2 billion over ten years.
Supporters of the bill (mostly Republicans) emphasized familiar themes. Charitable giving legislation is good because giving helps those in need (see, e.g., Chairman Camp's floor statement, Majority Whip McCarthy's statement) and because giving itself should be encouraged. The bill was also praised as a simplification (Statement of Representative Griffin) (though only one of the five provisions simplifies the Code).
Opponents of the bill (all Democrats, but one), though praiseworthy of charitable giving in general, cited in particular the failure to pay for the tax benefits and the resulting increase in the deficit. (Floor statement of Representative Levin, the White House.) The White House also objected that the giving incentives would benefit high-income taxpayers. One Democrat, Representative Lloyd Doggett, objected on substantive grounds, saying that the incentives for donations of food inventory encouraged donations of items with "no nutritional value, like Twinkies, candy, stale potato chips, and expired foods." "We do not need a permanent tax break for Twinkies" he said. (Video of Mr. Doggett's commentary on the food proposal here.)
How to assess the legislation? Helping "the needy" certainly is a familiar rationale cited in support of charitable giving legislation. But it bears repeating that "the needy" is but one segment of the 501(c)(3) sector. (Additional commentary on who benefits from the charitable deduction here). Broad-based charitable giving incentives such as extending the filing deadline and encouraging more IRA transfers are not directed toward helping the needy. Thus, if this really is a goal of lawmakers, much more targeted legislation to benefit social safety net organizations would be more appropriate.
Further, it is hard to ignore the absence of offsets. When tax benefits like these are not paid for, the question should be whether the America Gives More Act is the best use of $16.2 billion dollars. It is ironic that about 64 percent of the Act's cost comes from extending two provisions (the special rule for food donations and the exclusion for IRA distributions) that were allowed to expire in the Tax Reform Act, which undermines the argument that this legislation is an optimal use of tax dollars.
Other provisions have some merit, depending on the goal. Extending the time to claim donations to April 15 may be a cost effective way to get more dollars to 501(c)(3) organizations, assuming the IRS can administer the provision to protect against double deductions.
Streamlining the excise tax on private foundations will likely result in diverting dollars from the U.S. Treasury to foundation grantees – sort of an inter-501(c)(3) sector transfer. This may be desirable, depending on one's judgment about whether foundations or the government spends money more in the public interest. But the provision does not result in new charitable dollars and so is not a giving incentive.
The permanent extension and expansion of the special rules for deductions of conservation easements without any associated reforms is harder to understand, given the many administrative difficulties and abuses associated with this provision of the tax Code. (For commentary, see Halperin, McLaughlin, Colinvaux).
So although there may be merit in the margins to some provisions, as a whole, the case for the legislation without offsets is rather underwhelming. If there were offsets, then at least the trade-offs could be more directly assessed.
In short, although it is obvious that the America Gives More Act is not intended as a tax reform measure but rather reflects legislative business as usual, nonetheless it is disappointing to see more give-aways without much if any consideration of who should pay, and whether the give-aways are really worth it. But without an offset, there is little electoral cost to voting in favor of legislation, especially charitable giving legislation, which is always easy to frame, without much analysis, as helping those in need.
Roger Colinvaux
July 19, 2014 in Current Affairs, Federal – Legislative | Permalink | Comments (0) | TrackBack (0)
Wednesday, July 16, 2014
Notes on the CPI Report on the IRS Targeting Scandal
The Center for Public Integrity has released an investigative report about the IRS Tea Party targeting scandal, in which the CPI reviewed thousands of pages of documents and interviewed dozens of insiders. The report provides a good high-level overview of the scandal, and makes a few useful findings about the Exempt Organization function within the IRS. To many, the findings may come as no surprise, but bear repeating: over time the IRS has fewer employees to regulate a rapidly growing sector, the already low rate at which the IRS investigates exempt organizations is shrinking, the social welfare category (i.e., the one at the heart of the targeting scandal) is growing, and the IRS is increasingly timid – backing down to political pressure. Unfortunately, none of this makes for an effective overseer of a vital part of civil society.
Although the report is useful, some peripheral statements should be more closely considered if only because a number of misconceptions about the IRS targeting scandal continue inadvertently to be spread. One statement in the report is that "It wasn't until the Supreme Court's Citizens United v. Federal Election Commission decision in 2010, however, that politically active nonprofits — social welfare groups as well as 501(c)(5) labor unions and 501(c)(6) trade groups — became a major force in political elections, all while receiving a de facto tax subsidy." The implication from the "de facto tax subsidy" language is that political activity, when conducted after Citizens United by a noncharitable tax-exempt like a 501(c)(4), (5), or (6), gets an unwarranted subsidy and is abusive. But this is not really right. Political activity by a noncharitable exempt generally is not tax-advantaged relative to the same activity by a political organization (aka a "527"). Rather, political activity by a noncharitable exempt actually triggers a tax that is intended to make the tax treatment of political activity consistent across sections of the tax code. There is no abusive subsidy for political activity here.
Later, the report notes that "Social welfare and other nonprofit groups galloped into the post-Citizens United era with an inherent advantage over overtly political groups: They could hide the source of their funding, regardless of whether those sources were corporations, individuals or other special interests. And they're only required tell the FEC the names of donors who give money to help produce specific ads — something that rarely happens." This point bears more than passing emphasis. The anonymity offered to donors by noncharitable exempt status, and not a tax subsidy, is the underlying legal issue at the heart of the targeting scandal post-Citizens United. In other words, the targeting scandal is not really about taxes at all, it is about donor disclosure or the lack thereof.
The report says that: "The tea party affair has directed attention away from what many IRS workers say is the much larger problem — regulating the activities of politically charged nonprofits." and also that the IRS is "supposed to ensure 501(c) nonprofit organizations don't become more political than the law allows." The broad meaning here is right: the targeting scandal has diverted attention from some real problems with the legal architecture. Also, the IRS does have a legitimate role to play when it comes to political activity and tax exemption. But these statements unintentionally play into another misconception about the IRS's role when it comes to the political activity of noncharitable exempts and political organizations. In this context, the IRS does not really "regulate" political activity in the sense of deciding whether or not the activity is permitted. Rather, the IRS's function is to classify organizations based on their purpose as measured by the quantum of their activities. This is an important distinction. The IRS does not regulate speech or activity as such; rather, the IRS, as charged by Congress, assesses organization purposes and activities and applies a tax label ((c)(4), 527, etc.). So political activity is relevant to tax classification, but it is not a question of permitting or prohibiting political activity.
The report also states that "Political '527 groups' are tax exempt like 501(c)(4) groups, but unlike them, they must disclose their donors." It should be noted that the point about disclosure is correct, but not the point about tax-exemption. Broadly, 527 groups are taxed on their investment income whereas 501(c)(4)s and other noncharitable exempts are not. So the tax treatment is not equivalent. But as noted earlier, if a noncharitable exempt engages in political activity, then a tax is triggered, which is intended to make the organizational tax treatment of political activity broadly uniform across exemption categories.
But none of this undermines the key thrust of the report's message -- that the regulatory environment of the IRS exempt organization function is in crisis and in need of constructive solutions.
Roger Colinvaux
July 16, 2014 in Current Affairs, Federal – Executive, Federal – Legislative, Studies and Reports | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 15, 2014
U.S. House to Consider Charitable Giving Legislation
The House of Representatives this week is likely to take up charitable giving legislation. Last week, the Rules Committee reported out H.R. 4619, which modifies and expands on a charitable giving bill of the same number marked up by the Ways and Means Committee on May 29. Committee Report here.
Renamed the "America Gives More Act of 2014," H.R. 4619 combines several separate charitable giving measures. The charitable giving incentives of H.R. 4619 now are:
- Food Donations. Make the special enhanced deduction for charitable contributions of food inventory permanent and modify this enhanced deduction to: increase the percentage limitation from ten to fifteen percent for business taxpayers, provide for a special deemed basis rule for certain taxpayers, and permit fair market value of donated food to be determined disregarding the fact that there may not be a market for the food, among other special valuation rules. (This provision applies retroactively to restore this expired deduction.)
- IRA Distributions to Charity. Make permanent the exclusion for distributions from individual retirement arrangements to certain public charities. (This provision applies retroactively to restore this expired exclusion.)
- Conservation Easements. Make permanent the special percentage limitations and carryforwards for charitable donations of conservation easements, and extend such favorable treatment to contributions by certain Native Corporations, as defined under the Alaska Native Claims Settlement Act. (This provision applies retroactively to restore this expired deduction.)
- Extend Time to Claim. Generally allow taxpayers until the tax-filing deadline (April 15) to claim charitable deductions for the tax year.
- Reduce Foundation Excise Tax on Investment Income. Replace the two rates of tax on the investment income of private foundations with a single flat rate of one percent.
These provisions are broadly consistent with provisions in the "Tax Reform Act of 2014," a discussion draft released by Ways and Means Committee Chairman Dave Camp in February, with some notable exceptions. For instance, the Tax Reform Act:
- Eliminates the special enhanced deduction for food inventory rather than retaining and expanding it.
- Does not include the IRA distribution exclusion, i.e., allows it to expire.
- Does not expand the special rules for donations of conservation easements to new donor categories, and provides for a modest reform that no deduction is allowed for easements relating to golf courses, a proposal also advocated by the Treasury Department (page 95).
Whether the differences between H.R. 4619 and the Tax Reform Act reflect a change in position (and a move away from reform) or reflect the fact that H.R. 4619 is not primarily a tax reform measure remain to be seen.
Roger Colinvaux
July 15, 2014 in Current Affairs, Federal – Legislative | Permalink | Comments (1) | TrackBack (0)
Thursday, June 26, 2014
Charges of Royal Charity Fraud in Spain
The Los Angeles Times reports that Spain's Princess Cristina was indicted Wednesday on charges of tax fraud and money laundering. She and her husband, Iñaki Urdangarin, are said to "have been under investigation for years on allegations of the embezzlement of about $8 million in public money through charitable sports foundations they ran." The story continues:
On Wednesday, the judge found sufficient evidence to proceed with charges of money laundering and tax fraud against the princess and nine other counts against her husband, and recommended that they go on trial. Fourteen other people, including Urdangarin's former business partner, were also charged.
"There are many indications that Cristina profited from illegal funds on her own behalf, and also helped her husband to do so, through silent cooperation and a 50% stake in his business," Judge Jose Castro wrote in his 167-page indictment.
Additional coverage of interest appears in the New York Times, BBC News and Reuters.
June 26, 2014 in Current Affairs | Permalink | Comments (0) | TrackBack (0)


text:
Israel is seeking more partners for trade after the shekel's surge against the U.S. dollar this year sent exports plunging in the third quarter.
The shekel has climbed 8.7 percent over the past year, the most among 31 major currencies tracked by Bloomberg, undeterred by three interest-rate cuts and $4.7 billion of foreign-currency purchases. Shipments abroad, which account for about a third of the $273 billion economy, tumbled more than 16 percent last quarter.
Economy Minister Naftali Bennett appealed to the Muslim world to ease trade barriers and open markets at last week's World Trade Organization in Bali, Indonesia. He also pressed the idea of striking trade accords in talks with envoys from Russia, Vietnam, Thailand, Australia and others, according to an Israeli government official, who asked not to be identified because he wasn't authorized to speak on the record.
"With the strong shekel and the weaker economies in its traditional trade markets such as Europe and the U.S., Israel is looking to push exports in other regions, especially the growing economies in Asia," said Ofer Klein, head of economics and research at Harel Insurance & Financial Services.
The shekel weakened for a second day, depreciating less than 0.1 percent to 3.4951 by 8:32 a.m. in Tel Aviv, after an association of exporters yesterday urged the central bank to cut the benchmark lending rate, which at 1 percent is already the lowest since 2009.
'Mortal Blow'
The strong shekel "is a mortal blow to Israeli exports, especially in a period which the Israeli economy is slowing," Ramzi Gabbay, chairman of the Israel Export & International Cooperation Institute, said yesterday in an e-mailed statement.
Israel Manufacturers Association, a separate group whose members produce 95 percent of the country's industrial output, in October urged the government to target an exchange rate of 3.8 shekels to the dollar, and to promote exports from small and medium-sized businesses.
"I invite you to work together with me and my country to remove barriers standing in the way of achieving a flowering of global prosperity," Bennett said in Indonesia, the first Israeli minister in 13 years to visit the world's most populous Muslim nation, which has no diplomatic ties with his country. "I look forward to the day when I can sign free trade agreements with all our neighbors, including the surrounding Arab and Muslim countries."
Russia Accord
Israel and Russia agreed this week to set up a research group to draft a free trade agreement, during a visit by Israeli Foreign Minister Avigdor Liberman to Moscow. Liberman said Israel would push to conclude a trade deal next year, according to the Itar-Tass Russian state news agency.
Another focus of Israel's export push is China, its second-biggest trading partner after the U.S., with annual imports and exports totaling more than $8 billion. Prime Minister Benjamin Netanyahu set a goal of boosting trade to $10 billion within three years during his trip there in June.
"We must make the national effort to enter Chinese markets and to create partnerships," Netanyahu, who was accompanied on the trip by a high-level delegation of Israeli businesspeople, told a group of Shanghai business leaders.
This month, the Economy Ministry announced it would earmark more funds to promote exports to China, India and Africa through activities including trade delegations and national pavilions at expositions.
Top Exporters
Israel's top exporters include Teva Pharmaceutical Industries Ltd. (TEVA), Elbit Systems Ltd. (ESLT) and the Israeli branch of Intel Corp. (INTC), according to the export institute. Israel's trade deficit narrowed to $1.2 billion in October from $1.5 billion the previous month. Trade figures for November will be published tomorrow.
Bank of Israel Governor Karnit Flug sounded a pessimistic note about the country's exports last month, predicting they would remain sluggish because of a falloff in global demand and a strong shekel.
The central bank has said it would buy $5.6 billion this year and next just to offset the effect of new natural gas revenue on the currency. Finance Minister Yair Lapid has promised to work with Flug to try to tame the shekel.
The export institute's Gabbay called on the government to cancel tax exemptions for foreigners on interest income from medium- and long-term bonds, in order to prevent shekel appreciation.
Threatened Sanctions
The campaign to expand trade to new markets comes at a time when exports to Europe may be hurt by threatened sanctions protesting Israel's settlement of captured lands Palestinians claim for a state. The European Union imposed funding restrictions on research programs run by entities operating in captured territories, and Lapid expressed concern this week that sanctions could widen if peace talks collapse.
"Exports are central to Israel's success and our exports are dependent on our relations with the rest of the world," Lapid said on Dec. 8. "I won't elaborate here on the types of sanctions Israel could possibly face, as I do not want to give our enemies any ideas. Suffice it to say that the results would likely be extremely destructive to the economic welfare of each and every Israeli citizen."
To contact the reporter on this story: Calev Ben-David in Jerusalem at firstname.lastname@example.com
To contact the editor responsible for this story: Andrew J. Barden at email@example.com

subset: commoncrawl


text:
Andy Paley
Andy Paley | |
Origin | Albany, New York |
Genres | Power pop, film score |
Associated acts | The Beach Boys, Brian Wilson, Catfish Black, the Paley Brothers Jonathan Richman, the Sidewinders |
Andy Paley is an American record producer and musician, who has been active since the late 1960s. His work includes stints as a producer for Madonna, the Ramones, Jonathan Richman, Debbie Harry and Brian Wilson.
Early career[edit]
Paley began performing in his early teens as a drummer and singer for local Albany NY area bands. He was a founding member of and the drummer for the Boston, Massachusetts band, Catfish Black, which also included future Modern Lovers members Jerry Harrison and Ernie Brooks. The band was renamed the Sidewinders and was later joined by Billy Squier. The band performed around Boston and in NYC at venues like Max's Kansas City. They released an album, produced by Lenny Kaye, which featured songs written and sung by Paley. The Sidewinders broke up in the mid-1970s. Paley then played on Elliott Murphy's album Night Lights, and performed with Jonathan Richman after the break-up of the original Modern Lovers.[1]
The Paley Brothers[edit]
Andy went on to form The Paley Brothers[2] with his brother Jonathan - a guitar player and singer who also was part of the early Boston punk scene, and had played with Boston and NYC bands like The Nervous Eaters and Mong. The Paley Brothers toured extensively and released a self-titled album in 1978, produced by Sire Records founder, Seymour Stein. One track on the album: "Baby, Let's Stick Together" was produced by Phil Spector. The album is referred to as power pop by some,[who?] with the punk and straight rock roots of the brothers mixed in. The Paley Brothers also recorded a single with the Ramones (another of Stein's Sire groups): "Come On Let's Go" that was included on the Ramones' Rock and Roll High School soundtrack. After signing with Sire Records, The Paley Brothers opened for Shaun Cassidy at arenas including Madison Square Garden. They also achieved an underground cult following prior to disbanding in the early 1980s, when Andy focused on songwriting, session work and record production and worked with Madonna, k.d. lang, Brian Wilson, Mandy Barnett, Jerry Lee Lewis, Elton John, Brenda Lee, Little Richard and many others.
Paley and his brother Jonathan released a compilation album:The Paley Brothers: The Complete Recordings in late 2013. The album is a compilation that includes 11 tracks of previously unreleased songs, along with all of the tracks from the 1978 Paley Brothers album.
Collaborative work[edit]
In 1979, Paley played guitar on Jonathan Richman's album Back in Your Life, and continued to perform on and off with Richman and later incarnations of the Modern Lovers, and produce many of their recordings, through the 1980s. He produced Richman's 1985 album Rockin' and Romance. Paley has worked extensively and co-written with Brian Wilson. In 1988 he also produced and co-wrote songs on Wilson's comeback solo album, and continued to work with Wilson on unreleased material in the 1990s. He also co-wrote numerous tracks on Brian's 2004 Album "Gettin' In Over My Head".
Film and television work[edit]
He produced the soundtracks for Dick Tracy (1990) and A Walk on the Moon (1999) and wrote the original music for Traveller (1997, starring Bill Paxton). In 2009 he contributed to the soundtrack of World's Greatest Dad, directed by Bobcat Goldthwait and starring Robin Williams. He also wrote the musical score for Season One of Showtime's The L Word.
Paley writes and produces the music for Nickelodeon's SpongeBob SquarePants. He leads the Andy Paley Orchestra, which provides the music for The Thrilling Adventure & Supernatural Suspense Hour, a theater group in Los Angeles which performs original stage productions in the style of old radio melodramas.
- ^ Tim Mitchell, There's Something About Jonathan, 1999, ISBN 0-7206-1076-1
- ^ Tim Sendra. "Paley Brothers | Biography". AllMusic. Retrieved 2013-11-01.


text:
by PowerReviewsReviewed by 1 customer
Displaying review 1
(1 of 1 customers found this review helpful)
tabs too small
Best Uses
Comments about Pendaflex® Ready-Tab® Extra-Capacity Standard Green Hanging File Folders; Letter Size:
very thin
Bottom Line No, I would not recommend this to a friend
(1 of 1 customers found this review helpful)
Was this review helpful? Yes / No
- You may also flag this review
Displaying review 1
Can't find what you need? Contact Us
©Quill Lincolnshire, Inc. 2015, All Rights Reserved.
This Web site is intended only for use by U.S. residents.


text:
So I have a 3 gallon glass carboy, and thinking of picking up a 3 gallon Better Bottle to use as my secondary. (I brew 2.5 gallon batches) I have heard that it might not be good to use the better bottle as a secondary since it is plastic. Is this true? I probably would not keep the beer in the BB longer than 4 weeks. Or should I use the BB as my primary and the glass as my secondary?
I don't see why it would matter either way. But why use a secondary at all? Rick
Primary - Big Pale Citra Ale (AG)(1.063) Secondary - Bitter (AG) Bottled - Best Bitter, Bitter, SNPA clone On deck - Tank #7 clone.
A better bottle is FINE to use as a secondary, it's FINE to use as a primary (even for an extended one)....It's FINE TO USE, PERIOD. All that other stuff you heard is just opinions, mostly spread from the glass carboy industry when the CHEAPER better bottles hit the market.....
Like my snazzy new avatar? Get Sons of Zymurgy swag, here, and brew with the best.Revvy's one of the cool reverends. He has a Harley and a t-shirt that says on the back "If you can read this, the bitch was Raptured. - Madman I gotta tell ya, just between us girls, that Revvy is HOT. Very tall, gorgeous grey hair and a terrific smile. He's very good looking in person, with a charismatic personality... he drives like a ****ing maniac! - YooperBrew
I have a couple glass carboys and a better bottle carboy. I actually do the opposite: primary in the better bottle, and move to the glass for secondary. While it should be fine, I prefer to use the glass anytime I need to secondary, which I tend to do for longer period. Also, if you want to play with sours like I do, the better bottle is probably not the best choice for sours. Don't want it to pick up the "infection" from the sours and pass it along, which is easier if you don't take good care of it (can be rougher with glass). But Revvy is right, no reason you can't use them. I like mine.


text:
Introducing another fresh idea, Osthoff In Bloom – our new in-house floral department, offers the general public and resort guests a variety of beautiful wedding arrangements, banquet accents, table centerpieces and an array of bouquets perfect for any special occasion!
Designer Victoria Vonier, long time owner of Private Gardener in Milwaukee, will be the "hands on" resource for this addition to The Osthoff Resort. Ms. Vonier may be contacted directly at firstname.lastname@example.com or by phone at (414) 254-7867. View pictures of The Osthoff In Bloom Testimonials: Thank you so much for your expertise in the floral arrangements for our wedding. The day was unforgettable and the flowers were an amazing part of that. Our bouquets and boutonnieres were perfect and the centerpieces were better than I would have ever imagined. Our receptions would not have been complete without you and I truly enjoyed working with you during the past year. Thank you, again! - Katie THANK YOU - they were beautiful! Matched nicely with the room and the season! - Nancy |


text:
Man In Santa Suit Hits Dane Co. Deputy, Arrested
A 69-year-old man in a Santa suit was arrested for drunken driving after authorities say he struck a Dane County Sheriff's deputy who was directing traffic.
Man, 54, Dies After Stabbing In Duluth Duplex
Duluth police say a 54-year-old man has died from severe stab wounds, and investigators are following several leads.
1 Arrested After Man Shot In Anoka
A man is in the hospital after a shooting in an apartment in Anoka, Minn, according to police.
Man Accused Of Killing Teens Could Be Charged Monday
A Morrison County man accused of shooting and killing two teens will likely be charged on Monday.
Body Found In Mpls. Alley, Homicide Unit Investigates
The Minneapolis Police Department is investigating a homicide after a man was found dead in an alley.
Police: Wis. Bar Patron Spits On Cop, Charged With Felony
A Wisconsin man is facing felony charges after police say he spit in an officer's face after being ejected from a Minneapolis bar.
Police Need Help Locating Missing Northfield Man
Police need residents help after a Northfield man with recent mental health issues went missing last week.
Man, Woman Found Dead In Swift County
Authorities in Swift County are investigating the deaths of a man and a woman at a home north of Benson.
27 Fall With Collapsing Deck, No Major Injuries
A man broke both of his ankles Saturday after a deck collapsed, holding at least 20 people who were posing for a family photo.
Wis. Man Drowns Near Virgin Timbers Resort In Moose Lake
A 68-year-old man drowned Sunday after attempting to swim to shore on Moose Lake.
Cops: Man, Woman Shot To Death In Apple Valley
A man and a woman were found shot to death in an Apple Valley parking lot Saturday morning, police say. Two children are now orphaned as it appears to be a murder-suicide.
Heart Attack Kills Man On Lake Independence
A man was pulled from Lake Independence in Baker Park Saturday afternoon.
Police: 1 Injured After Hit-And-Run In Minneapolis
A man is in the hospital after a driver hit him and took off from the scene.
Man Still Missing From Lake Pepin Identified
The 55-year-old man still missing in Lake Pepin has been identified.
Crews Search For Man Who Fell Overboard On Lake Pepin
A 38-year-old man is missing after police say he fell overboard on Lake Pepin Saturday evening.


text:
New King James Version (NKJV) | New International Version (NIV) |
17 No weapon formed against you shall prosper, And every tongue which rises against you in judgment You shall condemn. This is the heritage of the servants of the Lord, And their righteousness is from Me," Says the Lord. | 17 no weapon forged against you will prevail, and you will refute every tongue that accuses you. This is the heritage of the servants of the LORD, and this is their vindication from me," declares the LORD. |
Scripture taken from the New King James Version. Copyright © 1982 by Thomas Nelson, Inc. Used by permission. All rights reserved. (New King James Version) | Scripture quoted by permission. Quotations designated (NIV) are from THE HOLY BIBLE: NEW INTERNATIONAL VERSION®. NIV®. Copyright © 1973, 1978, 1984 by Biblica. All rights reserved worldwide. (New International Version Bible Online) |


text:
Results 1 to 3 of 3
My kubuntu is great I just got it.But when I do a update and reboot the kubuntu logo will not come off the screen and I have to reformat.Can someone ...
Enjoy an ad free experience by logging in. Not a member yet? Register.
- 07-23-2006 #1
Kubuntu problem
- 07-24-2006 #2
Can you explain yourself better please?
- 07-24-2006 #3
Update and re-boot... then re-format and reinstall? What???
Two levels higher than a newb.
(I can search google)


text:
You arrived to this page because the domain name registration of the website you were trying to reach expired.
Most likely the owner of this domain name didn't pay his invoice.
If you are the owner of this domain, please log into your client area and pay your invoice as soon as possible to get your website reactivated.
Copyright © 2003 SKGOLD® Hosting Calgary, Alberta, Canada - Calgary Internet Marketing Company


text:
A free Test Your Well Water Fair will be held on Thursday, Sept. 25, from 4 to 6 p.m. at Carlisle High School Science Lab, 250 Jamaica Road in Carlisle.
Just a reminder, the eighth annual Greene County Test Your Well and Soil event is set for Tuesday, Sept. 16, from 4:30 to 6 p.m. at the Xenia High School cafeteria, 303 Kinsey Road in Xenia.
MCD has released its new report on water quality and quantity in Great Miami River Watershed.
The eighth annual Greene County Test Your Well and Soil event is set for Tuesday, Sept. 16, from 4:30 to 6 p.m. at the Xenia High School cafeteria, 303 Kinsey Road in Xenia.
Repaving that was scheduled to begin along the Great Miami River Recreation Trail in Moraine, West Carrollton and Miamisburg has been delayed but is still expected to be complete by the end of August.
Cyclists will soon have a smoother ride along parts of the Great Miami River Recreation Trail. Construction of four sections of the trail is set to begin July 28.
June brought an average of 5.95 inches of precipitation in the Great Miami River Watershed — 1.88 inches above normal for the month. The high station was Lockington Dam (9.15 inches), and the low station was Englewood Dam (3.41 inches). As of the end of June, the Great Miami River Watershed had received 22.99 inches of precipitation in 2014 which is 2.73 inches above normal for this point in the year.
Just a reminder, Montgomery County is replacing the Ridge Avenue Bridge so the Stillwater River Bikeway has a short detour through Triangle Park. Trail users are re-routed along the Great Miami River Bikeway between DeWeese Park and the southern tip of Triangle Park. Construction is expected to be completed by September of 2015.
Great story about the Great Miami River Trail.
MCD dams and levees prevented additional flooding during last night's intense rainfall, which closed parts of I-70 and I-75.
All five of The Miami Conservancy District (MCD) dams are storing floodwater this afternoon after snowmelt earlier this week, saturated ground from a long winter, and less than an inch of rain.


text:
Browsing articles in lifestyle
News: Guest Posts One of the challenges of a multi-pet household
A few days ago, a friend encouraged her six dogs to go outside after dinner then let them back in. She and her husband returned to watching TV in the living room. Fifteen minutes later, they heard a high-pitched bark that seemed to be coming from outside! Sure enough, one of their dogs had not followed the rest of the pack. After some more backyard fun, he had patiently waited at the back door...
News: JoAnna Lou NYC apartment building requires pets to be neutered
Many people are surprised to find that New York City, despite the miles of asphalt, is actually pretty dog friendly. Walk down any street and you're bound to see someone out with their pup. Trendy pet stores seem to be a prerequisite for every neighborhood and there are almost 30 fenced dog runs on the 23 square mile island of Manhattan. Someitmes it seems as if everyone in New York is an animal...
Dog's Life: DIY Do it yourself
Martingale collars are not just for sighthounds anymore—they're also a good choice for dogs who've learned they can back out of their collars and head for the nearest dog park on their own. Martingales are modified slip collars; the large loop goes around the dog's neck, while the leash is attached to the D-ring on the smaller loop. (Dogs should NOT wear this collar unsupervised, and it should...
Dog's Life: DIY Crafts
Immortalize your pup in yarn by following the patterns in Knit Your Own Dog by Sally Muir and Joanna Osbourne. Using just simple knit, purl and loopy stitches, capture a Bulldog's wrinkles, a Poodle's curls or an Afghan's flowing mane— 25 breeds in all. Download the pattern below to try your knitter's hand at the Jack Russell Terrier pattern.
Dog's Life: Lifestyle
It's easy to spend Superbowl Sunday glued to the couch, sucked in by the game, the million dollar commercials and all that food. Subaru reminds you to spend some quality time with your own MVP—your Most Valuable Pooch—this Superbowl Sunday. Take a time-out from the TV, grab a leash and join in on the Subaru Game Day Dog Walk. Kick off an annual tradition: just you, your dog and maybe a few fellow...
Dog's Life: Lifestyle Dog-friendly photographers, planners, wedding venues and accommodations
In our research for "Here Comes the Bride ... and Her Dog" (Bark, February 2011), we talked to many brides around the country about their big day. They had great stories to tell but also important advice. Among their discoveries were dog-friendly resources, which we list here with links to make your planning a little easier.
Accommodations and venues
Page and Barry Jenson were able to...
Dog's Life: Lifestyle An intimate wedding on a dog-friendly beach
Molly McNamara met Jeff McGlynn in obedience class when her Bearded Collie, Max, "dragged me across the room to meet him," she says. McGlynn attended with his laidback St. Bernard, Cujo. With the dogs as matchmakers there was no doubt they'd be present for the wedding four years later—along with a three-month-old Bearded Collie puppy named Stanley.
The couple lives in San Jose, where she's an...
Dog's Life: Lifestyle With sled dogs as attendants
Shortly before Gay Salisbury was expected at her nuptials in Sun Valley, Idaho, a cacophony of barking washed over the 50 or so waiting guests. "My dad thought they were wild dogs and guests were thinking, 'Poor Gay, that's going to be distracting,'" Salisbury says. "Then, I come flying up."
By flying up, she means arriving atop an all-terrain vehicle pulled by a team of fine Alaskan Huskies...
Dog's Life: Lifestyle Restaged classics to the rescue
Since the dawn of advertising, lovely ladies have been used to sell everything from soap to pickup trucks. But the women of Pinups for Pitbulls are more than simply beauties or burlesque queens. Founder Deirdre Franklin, whose stage name is Little Darling, describes a modern burlesque artist as "a strong woman who's expressing herself in an art form that's liberating." Part of a subculture that's...
Dog's Life: Lifestyle Safety first in the great outdoors.
Camping and hiking with your dog are two of life's great pleasures, provided your pooch is well suited to the particular excursion and you've sufficiently prepared for the trip. The most important factor to consider is whether you truly believe your dog will enjoy herself. Is she well socialized and confident in new situations? Is she controllable around other people and pets? Does she bark at or...
Pages |
Copyright © 1997-2015 The Bark, Inc. Dog Is My Co-Pilot® is a registered trademark of The Bark, Inc |


text:
Blog | Comments |
WoW | 6 Comments |
Recent Comments:
Caption This! {WoW}
Aug 8th 2007 4:46PM Cause I'm freeeeee as a birdddd
(Leonard Skynard song)
Breakfast Topic: You're the shaman now dog! {WoW}
Jun 23rd 2007 12:23PM oh sorry, at low levels yea, paladin and shamans are good. But at high levels you wont be dpsing in most PUGS. Windfury is never dropped because WoA is better
Breakfast Topic: You're the shaman now dog! {WoW}
Jun 23rd 2007 12:21PM @12, Haha you dont give a paladin windfury, you drop WoA because that paladin should be healing. WoA is better than Windfury totem. And good paladins shouldnt need mana spring. Paladins almost never have to drink
Anyway shamans rape in PVP. Nuff said
Azerothians vs. Earthlings: Oh the Humanity! {WoW}
Jun 21st 2007 12:26PM Aziraphale has too much time. How about men like looking at curvy women and vice versa for men. It's marketing
Let's get ready to rumb-- err, raid {WoW}
Jun 20th 2007 12:05PM Hahaha, a Ret paladin pulling top 3 DPS? Get better players. Hhahahaha
WoW Moviewatch: A Ballad of Fire {WoW}
Jun 16th 2007 12:22PM Normally I don't like RP, but I thought the intro was well done.
Anyone know the mods the player is using?


text:
(03-26-2012 02:59 PM)rgf17 Wrote: agreed. i did the heritage set from threads and saw these the other day and am gonna do this one now. this ones a little bigger with 64 cards rather than 14 in threads. usa - dont have much for trade bait but if you wanna work somethingon the nonprime heritage ones you have please lmk.
(03-26-2012 08:35 AM)sconnienation3 Wrote: Those do look pretty sharp--especially the Heritage Collection. Nice stuff!
(03-26-2012 05:42 PM)cybertrenz02 Wrote: Maybe could help ya out if ya need...
(03-27-2012 09:54 PM)usafshelland Wrote: You'll need to help him... I didn't see anything I would like.
(03-27-2012 05:12 PM)BauerNYJ Wrote: I want that Revis SO BAD
(03-26-2012 07:37 PM)younglover Wrote: I was gonna say the same thing. Might have to try and do the set. It's got what I like - shiny, great players, shiny.


text:
- Hotel Details
- Member Reviews
- Photos
Manilow Suites At One Superior Place
4 Stars1 West Superior Street Chicago IL 60654
Manilow Suites is conveniently located at 1W Superior Street and in the River North area bordering the Gold Coast. Guests can visit the city attractions such as Navy Pier and John Hancock Building.
Guests can relax at any of the accommodation units which feature modern amenities such as cable TV, DVD player, internet access, telephone, CD player and washing machine. Each unit has fully equipped kitchen where guests can prepare the meals.
Manilow Suites in One Superior Place does not have restaurant facility. Several restaurants are available in the surroundings where guests can relish a wide variety of local, regional and international cuisines.
Manilow Suites At One Superior Place features conference room and business centre where the guests can host their business meetings equipped with modern facilities. Friendly staff at the reception would be pleased to guide the guests while their stay at this property. Lincoln Park Zoo can be visited by guests at leisure.
Hotel Facilities
- Business Centre
- Gym / Fitness Facilities
- Lobby
- Reception
- Cafe
- Internet Access - High Speed
- Parking Facilities
- Room Service
- Conference Facilities
- Library
- Pets Allowed
- Swimming Pool - Outdoor
Room Facilities
- Alarm Clock
- CD Player
- DVD Player
- Telephone
- Bathroom Amenities
- Crockery / Cutlery
- Internet Access
- Washing Machine
- Cable / Satellite TV
- Dryer
- Kitchen


text: I don't know if anyone else is having Customer Appreciation Month this October, but mine is. I kept "stalling", & one of the girls at my center suggested I try control trim. It is on special at my center this month, you buy the caps, & they give you a container of powder for free. This morning for breakfast, I had 2 capsules before breakfast, then I had 2 eggs, a packet of instant grits with the powder mixed in, & some juice. The powder makes your food go a lot further, (it is a bulk extender), plus it is like you have had extra oatmeal. It is now 1:30pm & I am still stuffed. And it helps with you-know-what. And, as you guys know, oatmeal is recommended for anybody with high cholesteral, so you get an extra benefit. Plus, is anyone elses center playing bingo this month??? :carrot:


text:
Log Out
Call in to speak with the host
(805) 830-8355
Greg Hogben, author of The British Devil, comes to Stonewall Live! Thursday, August 9th, 9PM EST.
Greg Hogben was born and raised on the South Coast of England where he spent his school days learning how to get into trouble. But more importantly, he learned how to tell stories to get out of it. Greg is a huge fan of British humor and counts Stephen Fry and Jennifer Saunders among his comedy gods. You can contact Greg at
email@example.com or on Facebook.
Join me at 9PMEST Thursday, August 9th www.blogtalkradio.com/stonewalllive
Sorry we couldn't complete your registration. Please try again.
Please enter your email to finish creating your account.
old-style code for hosted blogs
Player Size 300 x 295 400 x 370 640 x 550


text:
The stupid question is the question not asked | |
PerlMonks |
Re^3: For want of a ++by Nkuvu (Priest) |
on Feb 26, 2004 at 16:04 UTC ( #332029=note: print w/ replies, xml ) | Need Help?? |
Oy, kids today, don't know nothin'... </lame humor> "Curse you Red Baron" was the catch phrase of one Snoopy (you've heard of Snoopy, right? From the Peanuts comic?) when he was in "World War I Flying Ace" persona, after being shot down again and again by the Red Baron. Snoopy was, by the way, a beagle.
In Section
Past Polls


text:
Malware Hash Checking Tool – Online & Offline Support
This program intends to detect a malicious file in two ways; online and offline. It calculates the md5 hash of a specified file and searches it in its current hash set (offline) or on VirusTotal site (online) and shows the result. It has http proxy support and update (for hash set) feature.
It's a simple python script so you can check out the source code, screenshots and a readme are included in the zip file. To add proxy support simply edit the .py script and add in the relevant proxy details.
1 2 3 4 5 6 |
proxy_info = { 'user' : 'username', # proxy username 'pass' : 'password', # proxy password 'host' : "proxy host", # proxy host 'port' : 8080 # proxy port } |
You can download the Malware Check Tool here:
Or read more here.
Recent in Countermeasures:
- isowall – Completely Isolate A Device From The Local Network
- ThreadFix – Vulnerability Aggregation & Management System
- StegExpose – Steganalysis Tool For Detecting Steganography In Images
Related Posts:
- HashTag – Password Hash Type Identification (Identify Hashes)
- CrowdRE – Crowdsourced Reverse Engineering Service From CrowdStrike
- Malware Analyser v3.0 – A Static & Dynamic Malware Analysis Tool
Most Read in Countermeasures:
- AJAX: Is your application secure enough? - 119,314 views
- Password Hasher Firefox Extension - 117,127 views
- NDR or Backscatter Spam – How Non Delivery Reports Become a Nuisance - 57,579 views


text:
Worldwide Availability of Monte Carlo Dose Calculation Software Announced
at European Radiation Oncology Meeting in Barcelona
BARCELONA, Spain, Sept. 10 /PRNewswire-FirstCall/ -- Accuray Incorporated (Nasdaq: ARAY), a global leader in the field of radiosurgery, announced today that its Monte Carlo Dose Calculation algorithm has received 510(k) clearance from the U.S. Food and Drug Administration and is now commercially available worldwide. This announcement was made as part of the product's launch at the 9th Biennial European Society for Therapeutic Radiology and Oncology (ESTRO) meeting on Physics and Radiation Technology for Clinical Radiotherapy in Barcelona, Spain.
Treatment with radiation therapy or radiosurgery requires a linear accelerator to deliver one or more x-ray beams to a target. Each beam is made up of trillions of photons, and each photon follows an individual path to the target. Traditional dose calculation methods assume all photons take a single path and therefore use a single calculation to represent the dose delivered by all photons.
Monte Carlo methods are considered the gold standard of probabilistic statistics. The Monte Carlo dose calculation method takes the probability and potential interactions for each individual photon into account when it calculates the dose being delivered by a single photon. It then considers the probabilities for each of millions of photons to generate a dose calculation for the target and surrounding structures.
Previously, because of the repetition of algorithms and the large
number of calculations involved, Monte Carlo dose calculations were time
consuming to compute and therefore were difficult to employ in clinical
settings. No
SOURCE Accuray Incorporated Copyright©2007 PR Newswire. All rights reserved |


text:
>> Might it be a good idea to have a central repo for it? I think it can't
I have actually been using Ingen for a while, two simple patches are
available with the source code of the plugins I ported from AMS into
LV2 especially for Ingen:
A while back I even did a started video tutorials on Youtube on my
experience of creating Modular Synths with Ingen (sadly, I created
only one, but I have some material for more):
Linux-audio-user mailing list
LINUX® is a registered trademark of Linus Torvalds in the USA and other countries.
Linuxaudio.org logo copyright Thorsten Wilms © 2006.
Hosting provided by the Virginia Tech Department of Music and DISIS.


text:
Latest News Update on pankaj kapur
Related News Results:
"pankaj kapur"
Shahid's work in 'Haider' impresses dad Pankaj Kapur
Mumbai, Aug 20 : "I am happy to see my son doing well," said acclaimed actor Pankaj Kapur referring to Shahid Kapoor's work in his forthcoming film "Haider", an Indian adaptation of Shakespeare's "Hamlet".
Dying to see dad in 'Finding Fanny': Shahid Kapoor
Mumbai, Aug 15 : Actor Shahid Kapoor, who is currently busy promoting his film "Haider", is extremely excited about "Finding Fanny" because the film shows him the other side of his father Pankaj Kapur's personality.
'Finding Fanny' like an acting class for Arjun Kapoor
Mumbai, July 11 : Actor Arjun Kapoor, who will next be seen sharing screen space with veterans like Naseeruddin Shah, Pankaj Kapur and Dimple Kapadia in "Finding Fanny", confesses he got to learn a lot on the sets.


text:
London, November 17 : US President Barack Obama has left his followers on Twitter facing disappointment after revealing he never used the popular microblogging website himself.
The president was portrayed as "connected" to the people through the website and his ever-present blackberry phone during his election campaign.
The leader recently confessed in front of students in Shanghai that he was not so gadget savvy.
"Let me say that I have never used Twitter," the Telegraph quoted him as saying.
"I noticed that young people are very busy with these electronics. My thumbs are too clumsy to type in things on the phone," he added.
Some fans said they were not surprised with the revelation considering the nature of his job.
@Inap asked: "Did anyone really think he was posting on his own?"
Others, however, were more disappointed, for example @bkuri, who wrote: "Unfollowing @BarackObama now. What a letdown!" (ANI)
Check out More news from Telecom Sector :: Pharmaceutical Sector :: Auto Sector :: Infrastructure :: Real Estate
Technology Sector
- Toshiba, United Technologies ink agreement for global growth in HVAC solutions
- Google offers artificial personal assistant for users ready to give up personal info
- Apple launches iPhone 6, iPhone 6 Plus in India
- Google profits plunges 5 percent YOY, in Q3
- HCL Technologies Q1 Net up 32.3% at Rs 1,873 crore