text:
Woman charged with ID theft
BROOKINGS (AP) — A former secretary at South Dakota State University is accused of getting three credit cards in a co-worker's name and charging about $36,000 in purchases and cash advances.
According to court documents, 38-year-old Kari Lynn Fuks was arrested Dec. 5 on the Brookings campus and charged with three felony counts of identity theft and two felony counts of grand theft.
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Ellsworth Village Board not pleased with warehouse at old junior high
Members of the Ellsworth Village Board expressed their displeasure and exasperation Monday with the current owner of what was once the old junior high school building.
The building is currently being used as a warehouse to store supplies used in dollar stores. The owner, Mark Reisdorf of Mid-States Closeouts based in the Twin Cities, had planned on opening a dollar store branch in the building and renovating it to provide living quarters for his family as well.

subset: commoncrawl


text:
Visit create.airbnb.com »
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an Italian husband, American wife and two children with dual nationality
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Una Famiglia davvero simpatica e molto a modo! Spero abbiano apprezzato la "gym" nonostante la musica ....
Ann was a wonderful guest. Communication with her was easy and efficient, both before and during her stay. She was very respectful of the apartment and left the place very tidy when she left. Would love to have her again.
nice guests, would host them again


text:
Solar Lull Could Cause Colder Winters In Europe 320
from the i-blame-the-schools dept.
We've improved Slashdot's video section; now you can view our video interviews, product close-ups and site visits with all the usual Slashdot options to comment, share, etc. No more walled garden! It's a work in progress -- we hope you'll check it out (Learn more about the recent updates).
The Sun does not effect climate. Only carbon.
Only carbon.
Your wife's vagina smokes in bed, after she has sex with me. But then climate change occurs and the bitch gets cold when you're close to coming home from work.
-- Ty Rone
The Maunder Minimum is the degree of deviation from the white line allowed before the trooper cites you for being drunk. Even without exceeding the Maunder Minimum, poor performance here combined with "blowing an
* Scale normalized 0.0~~1.0 as per International Standards Req. 4:20, para 69, lines for two.
No no no. Only denialists are fools. Global warming proponents are superior intelligent beings who are never wrong and always have the answers if only all the illiterate peons would listen to them everything would be okay.
panic: kernel trap (ignored)


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Feelathome Marquet Beach Apartments, Barcelona
Within easy reach of the beach, Feelathome Marquet Beach Apartments is in Barcelona (Sant Marti), close to Bogatell Beach, Mar Bella Beach, and Nova Icaria Beach. Also nearby are Sagrada Familia and Palau de la Musica Catalana.
Property Features.
Wireless Internet access is complimentary in public areas. Additional amenities include multilingual staff, tour/ticket assistance, and laundry facilities. This is a smoke-free property.
The 4 air-conditioned guestrooms at Feelathome Marquet Beach Apartments include washers/dryers and coffee/tea makers. Guests can use the in-room complimentary wireless high-speed Internet access. Televisions are equipped with DVD players. Bathrooms offer showers and hair dryers. All units at this 4-star apartment have kitchens with stovetops, full-sized refrigerators/freezers, microwaves, and dishwashers.
Enter dates to check prices
Hotel Info: 020 3027 9803from £132
- Standard Apartment, 1 Bedroom
- Standard Apartment, 2 Bedrooms
- Standard Apartment, 2 Bedrooms
- Apartment, 2 Bedrooms
- Apartment, 1 Bedroom, Terrace
- Apartment, 2 Bedrooms (for 4 people)
- Apartment, 1 Bedroom
- Apartment, 1 Bedroom
Recommended hotels
At a glance
Key facts
Hotel size
- This hotel has 4 rooms
- This hotel is arranged over 3 floors
- Check-in time 2:00 PM-2:00 AM
- Check-out time is noon
- Express check-out
Required at check in
- Credit card or cash deposit required
- Government-issued photo ID required
Travelling with others
- No pets or service animals allowed
- Free WiFi in public areas
- Free WiFi in rooms
Other information
- Smoke-free property
Nearby Four Star Barcelona hotels
In the hotel
- Front desk (limited hours)
- Tours/ticket assistance
- Laundry facilities
- Number of buildings/towers - 1
- Elevator/lift
In the room
- Air conditioning
- Coffee/tea maker
- Iron/ironing board
- Washer/dryer
- Separate dining area
- Separate sitting area
- Private bathroom
- Shower only
- Hair dryer
- DVD player
- Free WiFi
- Full-sized refrigerator/freezer
- Microwave
- Kitchen
- Stovetop
- Cookware, dishware, and utensils
- Dishwasher
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Recently reviewed hotels in Barcelona
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"Good stay. The room is clean and the staff are very helpful. Only issue is the isolation between room is not very good."Mar 8, 2015
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"Great location! The hotel provides water kettle on demand. The only problem is that if you have a noisy neighbor, you might have some problem."Mar 7, 2015
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Feelathome Marquet Beach Apartments, Barcelona's small print
Cash transactions at this property cannot exceed EUR 2500, due to national regulations. For further details, please contact the property using information in the booking confirmation.
Mandatory fees
You'll be asked to pay the following charges at check in or check out:
A tourist tax will be collected at the property upon arrival. The tax applies up to a maximum of 7 nights per person per stay. Children under 17 years of age are exempt from this tax.
- A tax is imposed by the city: EUR 0.72 per person, per night, up to 7 nights. This tax does not apply to children under 17 years of age.
Optional extras
Late check-in between 9 PM and 2 AM can be arranged for an extra charge of EUR 30
Parking is available nearby and costs EUR 15 per night
We have included all charges provided to us by this hotel. However, charges can vary, for example, based on length of stay or the room you book.


text:
Free swag for Paradox Interactive forum members
Free games are pretty great, especially if, like me, you are always finding yourselves flat broke. To celebrate having over 500,000 forum subscribers, Paradox Interactive is offering everyone on its forums a free copy of the wonderful Europa Universalis III. Specifically, it's the Chronicles edition, which comes with the title's four expansion packs.
Five forum subscribers are also being selected at random to receive the entirety of the publisher's rather large library, including my personal favourite, Crusader Kings II, and the amusing co-op wizard adventure, Magicka.
If you're a forum member, check the email you registered with and you can get a key that allows you to redeem EUIII: Chronicles on Steam. Not too shabby for just signing up on the forums in the past.
Comments not appearing? Anti-virus apps like Avast or some browser extensions can cause this.
Easy fix: Add
[*].disqus.com to your software's white list. Tada! Happy comments time again.
Did you know? You can now get daily or weekly email notifications when humans reply to your comments.
34 free apps on Amazon including Five Nights at Freddy's 2 and Kingdom Rush Origins
4:30 PM on 03.20.2015


text:
What is the difference between lisinopril and HCTZ?
- Posted:
- 21 Jan 2010 by Raven 4
- Topics:
- high blood pressure, lisinopril
|Question is Closed
|Report Mark as Favorite
Answers (1)
30 Jan 2010
Lisinopril is in a group of drugs called ACE inhibitors. ACE stands for angiotensin converting enzyme.
Lisinopril is used to treat high blood pressure (hypertension), congestive heart failure, and to improve survival after a heart attack.
Hydrochlorothiazide is a thiazide diuretic (water pill) that helps prevent your body from absorbing too much salt, which can cause fluid retention.
Hydrochlorothiazide treats fluid retention (edema) in people with congestive heart failure, cirrhosis of the liver, or kidney disorders, or edema caused by taking steroids or estrogen. This medication is also used to treat high blood pressure (hypertension).
Further Information
- Lisinopril Information for Consumers
- Lisinopril Information for Healthcare Professionals (includes dosage details)
- Side Effects of Lisinopril (detailed)
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Hydrochlorothiazide - I was taking 1-Lisinopril-HCTZ 10/12.5mg. Because It was not controlling my?
... blood pressure, the dr. increased it to 2 tablets daily. I noticed my husband takes 1-Lisinopril - HCTZ 20/12.5mg. What would be the difference ...
1 answer • 11 Jan 2010
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... 116 over 83 .Should he still continue taking his meds even though it's not high?
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I have been given hydrochlorot 12.5 mg is this a fluid pill?
I also take lisinopril 10mg. the hydrochlorto with the lisinopril has dropped my blood pressure to 93 over 53. Why? I was given the hyd at an urgent ...
2 answers • 1 Apr 2013
Hydrochlorothiazide - I have been on HCTz for 25 years. Also take Lisinopril and Bistolic. My?
... doctor has told me to discontinue the HCTz because it is hard on my kidney function, but 10 days in to stopping my edema is really bad ...
1 answer • 25 Jan 2015


text: |At 31, Ellen Barrett has already won a Pulitzer Prize. But sadly, her journalistic skills far surpass her ability to resolve a troubled family history. So she's less than eager to return home to Little Traverse Bay in Michigan for her father's funeral. Before long, Ellen realizes she must reopen old wounds for healing to begin. Type: Paperback () Category: Books > Fiction ISBN / UPC: 9781576732854/1576732851 Publish Date: 7/1/1998 Item No: 111646 Vendor: Multnomah Publishers


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Conference Tables on Sale
Check out these great offers on conference tables for your organization's conference rooms and meeting rooms. Conferencing requires unique tables to allow group interaction and also promote your organization's sense of style. Whether you need a classic boat-shaped wood conference table or a contemporary modern looking table in a round or octagon shape, we have the table you need.
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Freeski Videos
One Of Those Days 2: Candide Thovex
Candide Thovex having another one of those days in his home resort.
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Thursday Jan 15, 2015
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A Way of Life - Extreme Sports Channel
The Extreme Sports Channel is for anyone who makes action sports a way of life. We've got you covered...
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Carpet Sledding in Azerbaijan Mountains
20 brave and creative teams took to the snowy mountains of Azerbaijan with a carpet in hand and the...
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Brigham City's best Hispanic online dating and relationship service. PerfectMatch offers what other Hispanic dating sites can't - our Hispanic dating service offers highly compatible matches based on your personality, values, faith, lifestyle AND we provide you with powerful search tools; working with you to find the right person for you. Sign up today to browse Brigham City Hispanic singles and pics FREE. Start dating Brigham City Hispanic singles today!
Be good and everything will go well


text:
Recent Posts
Twitter Updates
- @NeilanFranklin thanks for following my dad. I think he was a genius, too! 2 days ago
- There are various ways of moving in and taking over attractive land a person doesn't want to sell. There are tricks to making it valueless. 2 days ago
- Many LDS employers are notoriously stingy & demeaning to their help. Some of my kids have worked for them. You may also have found that out. 2 days ago
- We have just one measure by which we measure success, progress, and what is desirable under our version of capitalism. What is it? More! 2 days ago
- Secret templars degenerated into schlerafian, fraternities & things like that. Some of them have been quite a militant and full of mischief 5 days ago
Hugh Nibley [off the record]
We got featured
Tag Archives: Bob Bennett
Nibley Goes Multimedia – Beyond Politics Available on the iBookstore
Hugh Nibley & Associates, a company owned by the family of the late Hugh Nibley, has released a multimedia eBook edition of his classic essay Beyond Politics with multimedia supplemental materials. Continue reading
Posted in Philosophy, Politics Tagged Bob Bennett, E-book, Hugh Nibley, iBook, IPad, LDS politics, mormon politics, mormonism, Politics, Sen. Robert Bennett, Sen. Robert F. Bennett, Senator Bennett 2 Comments
Bob Bennett Video on Nibley and Politics: Part 2
The [Mormon] Church does not say, "Well let's purge Harry Reid." They say, "Let's call him up and ask him for something else we need." And he delivers. Continue reading
Posted in Philosophy, Politics Tagged Bennett, Bob Bennett, Book of Mormon, democrat, Harry Reid, Hugh Nibley, Latter-day Saints, LDS Church, LDS politics, Mormon, Mormon Democrat, mormon politics, Mormon Republican, Mormon voters, mormonism, Politics, republican, Sen. Bennett, Sen. Bob Bennett, Sen. Robert Bennett, Sen. Robert F. Bennett, Senator Bennett, Senator Reid, Senator Robert Bennett, Senator Robert F. Bennett 2 Comments
Bob Bennett Video on Nibley and Politics
If you want a political career as the only way you can earn your living, it's very dangerous if you win. Because if you win, and this is the only way you can earn your living…that becomes an enormous incentive to do the wrong thing. Continue reading


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Dead, Dead, Dead
Today I dug up the four Ghosts that I tried to overwinter in a hoop-house, and they wuz DEAD!
No unusual root pathology, just dead. We probably had some periods in the '20s that lasted 36 hours or so, and low 30's longer than that, so now I know that they won't overwinter here.
Tilled up the bed and got it ready for just two this year. Four is too many. I'm gonna encourage a better root system on the others by using a drip emitter that gives a larger radius under the plant than the point irrigation does.
Are you sure that was dead? It could have just gone dormant and not woke up yet. Those roots look pretty good in the photo. If the plant was exposed to the 20's for extended periods of time, then it likely is dead. But a lot of times, if the soil stays warm enough, the top will die off but come warmer weather, they stub will throw out new growth even though the plant looks deader than a nail.
Good luck with the plants this year.
No, I dissected one complete plant, and there was no green within any of the structure. Even the deepest roots were completely dead.
This species exhibits a very shallow root system, unlike native Tepins and Pequins. The Numex Suaves even have a more robust system also.
Think I'm gonna piddle around with grafting some Ghost onto Tepin rootstock and see what happens...
> "This species exhibits a very shallow root system"
Not that I've observed. Perhaps yours are finding enough in the top inches that they don't need to go deep.
The alternative is that the soil in the tilled layer is holding a water table above the sub-layer that is causing root death to anything that deep.
Interesting, but I don't think so. Sandy loam down to about 30", then alluvial cobbles of varying caliper, then hard-pan clay. Used to have 'maters in that bed before I had the nematode problem, and they all drove roots to at least 2'. I'm thinking that with the 4" of mulch that the root mat found sufficient nutrition and moisture to 1', and limited it's growth. They were grown in morning sun and afternoon shade. Now a plant in full sun with no mulch may exhibit a different root depth, and I'll find that out next winter when I dig some others up planted in a different micro-clime.


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Every time I've ordered from MJM Magic they have delivered the product in good condition and on time! Jeff goes the extra mile for his customers!...Read More ->
Let me start off by saying that I have dealt with many online Magic Supply companies, some good, some absolutely terrible. Jeff, Brandi, and everyone...Read More ->


text:
How do you send info. to the powers that be
carla17(Z7 NC)October 24, 2007
And where is the suggestion forum. I hate this since Spike left. It's like we're running our own ship.
At the bottom of this page, there's a horizontal green stripe.
At the far right side of that stripe it says "Contact Us".
Click on that.
When the message screen appears, be sure to select the nature of your message from the menu before you send it off.
The default subject is "Gardening-Related Question", & they'll always send an automated email that says they don't answer garden-related questions.


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£550 pcm
2 bedroom terraced house to rent OLD ROAD, Mottram, SK14Delightful Two Bedroomed Mid Terraced property situated in one of the sought after areas of Mottram. This beautiful property is well presented throughout and is conveniently located close to local amenities and major transport links. Briefly comprising of two reception rooms, two bedrooms, enclose.. More details ›
£595 pcm
3 bedroom semi-detached house to rent **OFF RD PARKING** Pearl Way, Mottram, Hyde, SK14 6PYsimple lettings offer this SPACIOUS home with GARDENS to THREE SIDES.Recently refurbished with modern DÉCOR throughout.SPACIOUS lounge,MODERN KITCHEN with oven & hob. TWO DOUBLE BEDROOMS,third single & BATHROOM with ELECTRIC SHOWER over bath.Boasting PRIVATE enclosed GARDENS & OFF ROAD PARKING More details ›
Added on 02/03/2015 by Simple Lettings and Sales, Hyde. Call: 0161 468 0780 Local call rate
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text:
Dutch Marquetry 19th c. Satinwood Inlaid Corner Cabinet
- Sold for: Start FREE Trial! or Sign In to see what it's worth.
- Item Category:
- Source: Fontaine's Auction Gallery
- Sold Date: Feb 23,2008
- Channel: Auction House
Door features inlaid bird and floral design, floral inlay on entire cabinet Good condition, minor veneer loss to edge of base, edge of door, minor inlay loss.
Items in the Worthopedia are obtained exclusively from licensors and partners solely for our members' research needs.
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- Sizes XL-3XL lace V-neck floral chiffon dress I9689


text: IECC stands for International Education Counselling Centre which is one of the leading international education consultancy firms based in the UK and Bangladesh. Since 2004, we have been supported more than 3000 students to get admission to the Top Ranked British, American, Canadian and Australian Universities and Colleges. Students from Bangladesh, India, Pakistan, China, Middle East, Africa, South America and Europe have highly benefited from our world class services. IECC is based in the UK with it's office in Sheffield. It benefits students beyond the realms of ordinary agents working from abroad. We try to make the whole application process very easy and flexible.


text:
Joe Nemechek gets the nod in the No 34 Ford this weekend.
The revised format will be tested with the XFINITY and CWTS teams.
Technical alliance between Venturini Motorsports and Kyle Busch Motorsports provides an invaluable opportunity.
Canadian standout to pilot No. 13 ThorSport Racing Tundra.
Sauter will drive the No. 83 Dustless Blasting Toyota during Speedweeks.
Kyle Busch Motorsports will sport the BitPay livery on the No. 54 Tundra at Daytona.
Elton Sawyer named managing director for truck series, Chad Little moves to Inspections and Officiating.
Jerry Gappens facing charges of lewdness.
Long is looking for a second chance with Mike Affrano Motorsports.
'I learned a lot in my rookie season,' he says.
Tyler Reddick to run full season, while Keselowski shares second seat with all-star cast.
JRM adds No. 00 Haas Automation Camping World Truck team to its roster
The Nemecheks will campaign trucks with ECR power.
Second time for truck series crewman.
Kennedy to campaign in the No. 11 Toyota Tundra in the Camping World Truck Series.
Four-time truck champion joins forces with Diamond Chassis.
Jerry Baxter moves to the 51 team.
Justin Boston is stepping up from the ARCA ranks at the conclusion of this season.
Major power outage in Phoenix' West Valley delays start of Lucas Oil 150.
Fresh rubber let Kyle Busch find the checkers in Texas.
Short-track specialist to drive Win-Tron Toyota Tundra.
Looking for an MRN radio station near you? Look no further.
Upholds penalty against number 20 truck of Austin Dillon.
Roo Motorsports plans to enter a truck in the 2015 NASCAR Camping World Truck Series season.


text:
"Well done passionate story"
Marshall is over the top sometimes but it in a good way..his story is compelling and the feelings he has for the subject are strong. I dont believe he is any more biased than the academics who write 'proper' history books. I believe that the account is accurate and a valid perspective. It is a good book and I encourage a listen
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|ESPN.com: Big Ten
|[Print without images]
Posted by ESPN.com's Adam Rittenberg
Thursday marks the official start to the Big Ten football season, as players and coaches from all 11 teams meet the media at the Hyatt Regency Chicago. Unlike some of the other conferences, which sprinkle several teams into media sessions that span two or three days, the Big Ten throws everybody at us at once. Having covered Big Ten media days for the last six years, the format can be a little overwhelming, but not too awful.
Here's how things will work. The two-day event begins Thursday at 10:15 a.m. Central time with a short video showing key points for college football officials in the 2008 season. After the video, the 11 coaches will conduct 15-minute question-and-answer sessions on the dais. Each coach then leaves the ballroom and usually spends a few more minutes taking questions in the hallway before their sports information director whisks them away to do TV interviews. Big Ten commissioner Jim Delany follows the coaches and does a one-hour question-and-answer session from 2-3 p.m.
Since 11 coaches appear in a fairly short time span (10:30 a.m.-1:45 p.m.) with only one 30-minute break, the first day doesn't have a ton of value. Every coach says how excited he is for the season, talks about his returning starters, takes a few questions and leaves. There are exceptions, though, and this year should produce some first-day intrigue. Here's a look:
The second day of media meetings brings better stories and more excitement, as the players join their coaches for a two-hour session with reporters. Big Ten Network president Mark Silverman and Big Ten coordinator of officials Dave Parry also will be available. Things begin at 8 a.m. Friday. Getting to all 46 interview tables in 120 minutes is impossible, but I'll do my best to bring you a solid sampling.
The biggest crowds are usually around Joe Paterno and Jim Tressel, but Rodriguez, Ferentz and Illinois coach Ron Zook will get their share of visitors. Ohio State's star threesome of James Laurinaitis, Malcolm Jenkins and Todd Boeckman won't be lonely. By the way, I forgot to complain about having no Beanie Wells at media days. I get the bringing-the-seniors thing, but he's a legit Heisman Trophy contender. Other players sure to be mobbed include Wisconsin tight end Travis Beckum, Michigan State running back Javon Ringer, Illinois quarterback Juice Williams and all three Penn State invitees (Josh Gaines, A.Q. Shipley and Derrick Williams).
Possible highlights of Day 2 include:
So there you have it, more than you ever wanted to know about Big Ten media days. Unlike my colleagues, I'm not staying at the Ritz or heading to Vegas. I'll be saving the company money and making the short trip down Lake Shore Drive from my home on the city's North Side. The blog should be buzzing the next two days, so check it out. And e-mail me any questions or comments as the event goes along.


text:
Check out the new, mobile-friendly WineSpectator.com!
The Emeril Lagasse Foundation's ninth annual Carnivale du Vin boasted an intimate venue, inspiring video footage of beneficiaries and a bevy of celebrity chefs. But it was the winemakers on hand who truly drove the auction's competitive energy, said foundation executive director Kristin Shannon. Their efforts paid off. Wine Spectator's Esther Mobley reports.
For the full article, check out the new issue of Wine Spectator, on newsstands January 28, 2014.
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text:
- Details
This midsize humidifier offers good looks, compact design and maximum humidification for up to 1100 sq. ft. The digital control panel provides precise humidity monitoring and control. The easy pour-in design makes refilling worry-free.
Product Features:
- 5 Gallon output per day
- Auto humidistat
- 4-speed motor with quiet nighttime setting
- Built-in hygrometer
- Easy pour-in fill method
- 3 Gallon total water capacity
- Uses two patented Super Wicks (part # 1040)
- Accomodates 2-Stage AirCare Filter (part # 1050)
- Dimensions: 17-3/4" L x 9-1/4" D x 13-3/4" H
- Specs
SKU 050240768 Model 5D6 700 Weight 12.0000 Color No Size No Width No In Store Only No Price $59.99
- Warranty
Rural King provides a defect or damage warranty within 30 days of receipt. All Manufacturing Return Policies Supersede Rural King's Return Policy.
- Reviews
Customer Reviews
- good Review by linda
Price Value Quality
Works good, but is very loud if turned to speed 3 or 4. Would recommend to a friend.
(Posted on 12/26/2014)
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text:
Technology Review, July/August 2010
Suntech CEO Zhengrong Shi made China a powerhouse in photovoltaic technology--and became a billionaire in the process. His next ambition: to make solar power as cheap as conventional electricity.
Brisbane Times, 25 February 2015
A Queensland researcher has taken home a huge gong at the Australian International Airshow and Aerospace and Defence Exposition in Victoria with a compound that detects potentially catastrophic paint deterioration.
Crikey, 24 February 2015
One of the most careful dissenting voices in the MH370 mystery is US science writer Jeff Wise, who has today published a study of tractor work on a patch of earth in Kazakhstan that matches the dimensions of the missing ...
National Geographic, March 2015
We live in an age when all manner of scientific knowledge—from climate change to vaccinations—faces furious opposition.
Some even have doubts about the moon landing.


text:
WOODBURY, New York – Hitachiâs popular SK Series of HDTV studio and field production cameras now significantly lowers the costs of fiber cable installation and camera equipment management. With the use of Multidyneâs advanced EOS-4000 series optical routing system, Hitachi camera customers now have complete flexibility in assigning camera heads to CCUs. This is a natural progression from Hitachiâs TCP/IP data network compliant control system, where any control panel can control any camera wherever thereâs access to a LAN, WAN, MAN or internet.
The HDTV camera optical routing system will be exhibited at the Hitachi Kokusai Booth (C4309) at this yearâs National Association of Broadcasters held at the Las Vegas Convention Center in Las Vegas Nevada next month.
âTodayâs modern stadiums, arenas, TV stations, production studios, universities, large churches and other HDTV camera installations all use digital fiber cable due to its superior ROI. Its low cost, ease of installation, seemingly limitless bandwidth, and ability to transport audio, data and video beyond 3Gbps make SM fiber the logical choice when deciding the cable infrastructure of a facility,â? explained Emilio Aleman, product manager for Broadcast and Professional products at Hitachi Kokusai America. âPreviously, assigning camera heads to different CCUs was done manually by connecting and disconnecting fiber patch cables.â?
Hitachiâs unique camera and CCU signal transport design utilizes the SMPTE-311M standard. With this design, camera power and digital optical transmission can be isolated without losing any function, operational benefit or picture quality. The total fiber optic distance that can be used with any camera and CCU through the Multidyne optical router is 10Km.
With the optical routing switcher, Hitachi can maximize CCU usage and offer the ability to connect studio and portable cameras moved around a facility for different production purposes and venues.
âItâs very exciting to see the use of the EOS-4000 optical router continue to expand within the traditional broadcast market,â? said Fred Scott, Vice President of Sales & Business Development for MultiDyne.
Existing and new fiber infrastructures can be utilized to increase flexibility, offering multiple camera locations all linked via fiber back to the optical routing switcher. The optical router switches the two fibers from each camera and ensures that the SMPTE signal formats are maintained and assigns each camera to the desired CCU.
Any number of cameras and CCU units can be configured with the optical router. The router is easily controlled via a standard PC, Crestron or AMX control system. Installations involving multiple studios and groups of cameras in each studio can share a common set of CCUs and control panels at the control room, saving the user substantial costs in equipment (CCUâs + control panels).
About Hitachi
Hitachi, Ltd., (NYSE: HIT / TSE: 6501), headquartered in Tokyo, Japan, is a leading global electronics company with approximately 400,000 employees worldwide. Fiscal 2009 (ended March 31, 2009) consolidated revenues totaled 10,000 billion yen ($102.0 billion). The company offers a wide range of systems, products and services in market sectors including information systems, electronic devices, power and industrial systems, consumer products, materials, logistics and financial services. For more information on Hitachi, please visit the companyâs website at www.hitachi.com.
Hitachi Kokusai Electric America, Ltd. designs, manufacturers and markets video cameras, digital transmission, processing and recording devices for the broadcast television, cable, video production, and industrial vision markets. For more information, please call (516) 921-7200 or visit Hitachiâs web site at http://www.hitachikokusai.us . Hitachi Kokusai Electric, Inc. (TSE, OSE: 6756), is a Hitachi, Ltd. (NYSE: HIT) group company.
Full versions of all press releases and product images are posted on the web site in the pressroom section: www.hitachikokusai.us
About Multidyne
For more than 30 years, MultiDyne has been a leading provider of innovative video and fiber optic-based transport and routing systems for the broadcast, cable, pro A/V, corporate, government, military, and transportation markets. MultiDyneâs fiber optic transport and routing systems include: HD-SDI, VGA, DVI, HDMI, audio, intercom, Ethernet, control data, L-Band, KVM interfaces and optical routers. These solutions are used worldwide by such industry leaders as ABC, CBS, NBC, CNN, RAI, BBC and the Department of Transportation.
MultiDyne, 191 Forest Avenue, Locust Valley, NY 11560
Tel: (516) 671-7278; Fax (516) 671-3362; website: www.multidyne.com
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Bio Of An Original Rock Band (www.shiftseven.com)
(The story so far)
Shift Seven is an unsigned original rock band from Central PA that write and perform in the 'Classic Rock' style.
The three guys that make up the band 'Shift Seven' are Terry Gayhart, Keith Myers and Rick Boltz, all from the Lebanon, Pa area. The guys have been together for over 20 years with this 'project' just to write and perform music that they are proud of and to produce albums, videos and a local reputation as a testament to their efforts over the years. In this endeavor, they have been very successful. The whole project is one of self production and creation. All of this work was paid for with sweat equity and hard to book gigs. Hard to book because not many venues locally are looking for original music. But they have garnered a reputation that attracts other great local musicians that want to sit in with them from time to time. They love the chance to add to their three piece power trio… icing on the cake.
Shift Seven has been chosen 5 years in a row to play the Millennium Music Conference in Harrisburg, PA. Twice (including this year) a Shift Seven song was chosen for the compilation CD out of the other 300 band submissions from around the country. Their music has sold and been on the radio in Europe. In the small venues they usually play, a common statement is heard over and over…"What are you guys doing in this place? You should be touring big places."
All of this was accomplished without a manager or booking agent and on a shoestring budget but with the goal of a quality end product. They pride themselves in being able to sound like their recording when playing live. Other unique things about the band; All three members write songs. Keith and Terry switch between bass, guitar and lead vocal duties according to the needs of each song, usually multiple times during a set. Probably why the albums are a bit eclectic.


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StartUpHire is the place to find CREATIVE WRITER jobs. Review the list of CREATIVE WRITER career opportunities to the left. These CREATIVE WRITER jobs represent some of the most rewarding careers available.
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The Senior Technical Writer produces accurate, efficient, and crystal-clear documentation for end users and developers on the AppNexus platform. Deliverables may include feature and process overviews, functional how-tos, use case-driven tutorials, concept2/14/2015 New York, NY Save This Job
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Job Tracking ID: 512449-480232Job Location: Santa Clara, CAJob Level: Mid Career (2+ years)Level of Education: BA/BSJob Type: Full-Time/RegularDate Updated: November 12, 2014Years of Experience: 5 - 7 YearsStarting Date: ASAP ---«Back to job search Invite a friend:2/15/2015 Santa Clara, CA Save This Job
Our focus on customer success makes high-quality technical publications at ExtraHop a top priority. If you are a Senior Technical Writer who is passionate about sharing technical knowledge with internal and external users, we would like to hear from you! Ideal for a candidate1/3/2015 Seattle, WA Save This Job
The Technical Writer produces accurate, efficient, and crystal-clear documentation for end users and developers on the AppNexus platform. Deliverables may include feature and process overviews, functional how-tos, use case-driven tutorials, conceptual deep-dives, screen text, and3/7/2015 New York, NY Save This Job
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Big Data, the cloud, elastic computing, SaaS, AWS, BYOD, HPC, SDN?we do it all. The solutions we build at ExtraHop are transforming the IT industry. From retail websites and point-of-sale systems to financial services and the healthcare industry, ExtraHop helps modern businesses1/3/2015 Seattle, WA Save This Job
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The instruction set extension capability of RISPs (reconfigurable instruction set processors) provides an attractive means to meet the flexibility, performance, and cost demands of ubiquitous computing devices. Run-time reconfiguration can further increase the cost efficiency and hardware specialization of these processors by dynamically changing the configuration of the reconfigurable logic to the required functionality. In this paper, we propose the use of a heuristic that leads to the selection of large custom instructions for increased performance gain. Result analysis of six applications from the MiBench embedded benchmark suite show that efficient data-path merging can be applied to the custom instructions to reduce the average number of configurations to less than 8 in a run-time RISP. In addition, there is only a small difference in the average number of configurations when compared to a custom instruction selection strategy that results in lower performance
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The 2012 Offshore Voluntary Disclosure Program: Analysis, Insight and Intrigue by William M. Sharp, Sr., Larry R. Kemm, and William T. Harrison, III William M. Sharp, Sr., Larry R. Kemm, and William T. Harrison, III are with the tax law firm Sharp Kemm P.A. with offices in Tampa, Florida, Zurich, Switzerland and San Francisco, California The authors gratefully acknowledge the review comments of their colleague David S. Barnhill. Introduction On January 9, 2012, the IRS announced yet another offshore tax compliance program as a follow up to the predecessor compliance programs released in 2009 and 2011.1 When Commissioner Douglas Shulman announced in February 2011 the release of the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI), he warned that the 2011 program was the "last, best chance" for U.S. taxpayers to become compliant.2 Given the release of the 2012 Offshore Voluntary Disclosure Program (2012 OVDP), the earlier program may have been the "best" chance to seek compliance given the new program's penalty increases, but certainly was not the "last … chance" to become compliant in light of the new program. Commissioner Shulman also recently announced that the two predecessor initiatives resulted in the collection of more than $5 billion in taxes, interest and penalties.3 This collection tally will most certainly increase given that the 2011 program is still processing many cases, with 95 percent of the cases from the 2009 program closed.4 And clearly the 2012 program will add more to this treasure trove. Contrary to its predecessor compliance programs, the new initiative has no "last chance" deadline, although the IRS ominously warned that the new program could be terminated at any time or in lieu of termination the program's terms could be modified, presumably to the detriment of the noncompliant taxpayer seeking relief. The 2012 OVDP represents a substantial improvement over its prior two predecessor initiatives by eliminating the overly aggressive time frames imposed by the IRS under those programs. The good news here is that the IRS apparently recognized that unreasonable and unattainable deadlines in the context of technically intricate offshore compliance programs are not productive administrative compliance tools.5 1 IR-2012-5, available at http://www.irs.gov/newsroom/article/0,,id=252162,00.html. See also IR-2011-14, available at http://www.irs.gov/newsroom/article/0,,id=235695,00.html; and "Memorandum for Commissioner, Large and Mid-Size Business Division, Commissioner, Small Business/Self-Employed Division," Doc 2009-6775 or 2009 WTD 57-32. The above-mentioned voluntary disclosure programs were preceded by the 2003 Offshore Voluntary Compliance Initiative, Rev. Proc. 2003-14, 2003-11 C.B. 311, and the Last Chance Compliance Initiative, IRS Letter 3549 (rev. 6-2003). 2 IR-2011-14. 3 IR-2012-64, available at http://www.irs.gov/newsroom/article/0,,id=258430,00.html. 4 IR-2012-5, supra note 1. 5 See William M. Sharp Sr., Larry R. Kemm & Andrea D. de Cortes, "The 2011 Voluntary Disclosure Initiative: Truly the 'Last, Best Chance'?," Tax Notes Int'l, Mar. 14, 2011, p. 865, at 869, Doc 2011-3931, or Despite this "no deadline" improvement, the 2012 OVDP's penalty framework continues the inherently defective and inflexible penalty mandates of both the 2009 and 2011 initiatives. Not surprisingly, the new overall offshore penalty is ratcheted up to 27.5 percent in comparison to 25 percent in the 2011 initiative and before that 20 percent in the 2009 program. The authors previously have voiced concern over this inflexible and inappropriate "one size fits all" penalty framework.6 Although the IRS has made some progress in moderating the penalty framework in its recently released Frequently Asked Questions (FAQs)7 for certain classes of taxpayers, these limited exceptions fall woefully short of an equitable and due process-driven approach for penalty determination.8 The fall-out of this "one size fits all" penalty framework necessitates in appropriate cases an "opt-out" of the 2012 program where a better result should be achieved in the follow-up IRS examination, or if not resolved, then in IRS Appeals and if necessary U.S. Tax Court or other federal court litigation. In addition to eliminating the "last chance" deadline and continuing the inflexible penalty framework, the new program institutes a series of new guidelines designed to enhance efforts of the IRS and Justice Department to pursue criminal prosecution of international tax evasion as well as supporting the government's continuing efforts to combat offshore tax noncompliance by bringing American taxpayers back into the U.S. tax system. As discussed below, the 2012 program requires a more significant level of disclosure to arm the IRS and the Justice Department with a fresh arsenal of information to combat offshore tax evasion and avoidance. The FAQs and the new version of the offshore voluntary disclosures letter enable the IRS to gather and develop from applying noncompliant taxpayers more information and documentation regarding offshore compliance of not only the applicants themselves but also those playing an advisory role, such as bankers, fiduciaries, attorneys, accountants, return preparers, trust or corporate service providers and others, both within and outside of the United States. 2011 WTD 49-11. The 2009 OVDP was announced on March 23, 2009, and taxpayers participating in that program were required to submit the required notification to the IRS initially by the September 23, 2009 deadline, which was extended by the IRS to October 15, 2009 only two days before the original deadline. The terms of the 2011 OVDI announced on February 8, 2011 initially required taxpayers to submit a completed voluntary disclosure package to IRS Civil by August 31, 2011 (extended to September 9, 2011 due to Hurricane Irene), however, taxpayers were eventually allowed to apply for a 90-day extension in which to submit the completed voluntary disclosure so long as their initial disclosure to IRS Criminal Investigation and extension request were received by the September 9, 2011 deadline. The deadlines imposed under the 2009 OVDP and the 2011 OVDI were designed to prod noncompliant taxpayers into compliance, but in reality these short sighted deadlines did not seem to achieve this objective in light of what appears to be a substantial community of noncompliant taxpayers. If anything, these unwarranted deadlines forced applying taxpayers' legal counsel to unduly rush intricate and technical analysis of client cases with the resulting hastily submitted case files to the detriment of both the IRS and the applying taxpayers. For a discussion of the 2009 program, see "IRS Guidance on Offshore Voluntary Disclosures: Further Refinements," Tax Notes Int'l, May 18, 2009, p. 595. 6 Sharp, et al., supra note 4, at 868. 7 The IRS released the 2012 OVDP FAQs on June 26, 2012. Offshore Voluntary Disclosure Program Frequently Asked Questions and Answers, available at http://www.irs.gov/businesses/small/ international/article/0,,id=256774,00.html. 8 See Sharp et al., supra note 4, at 867-8. 2 Separate but related to the 2012 OVDP and the new FAQs, on June 26, 2012 the IRS announced a new program intended to assist U.S. citizens residing overseas, including dual citizens, to catch up with respect to U.S. tax filing obligations (the Overseas Americans Program).9 Although the details of this program will not be released until sometime prior to the stated September 1, 2012 effective date, Commissioner Shulman recognized that a special protocol is required for Americans living overseas to provide for "a series of common-sense steps to help U.S. citizens abroad get current with their tax obligations and resolve pension issues."10 The Overseas Americans Program will be separate and apart from the 2012 OVDP and will generally apply to Americans living overseas who are "low compliance risks" and who generally will have simple tax returns with $1,500 or less in tax for any of the covered years. Eligible taxpayers would be required to file tax returns along with appropriate related information returns for the past three years as well as to file delinquent FBARs for the past six years. The IRS notes that these submissions will be more significantly scrutinized than submissions made under the 2012 OVDP but the good news is that most penalties should be waived, as discussed below.11 Of key importance, the new program will be in lieu of participation in the 2012 OVDP, and this point raises several issues as to how pending as well as closed voluntary disclosure cases relate to this new program. This article discusses the most significant aspects of the 2012 OVDP and the FAQs, focusing on variations from the predecessor compliance programs. This article also provides constructive criticisms regarding the new program and the FAQs with the hope that the IRS will modify the 2012 program to provide a more legally sound and equitable program. Finally, this article discusses the Overseas Americans Program and how it should be crafted to maximize U.S. tax compliance and fairness to participants. Overview of Key Differences The FAQs explain the differences between the 2012 OVDP in comparison to the earlier compliance initiatives as well as the relationship to the traditional and long standing voluntary disclosure practice of the IRS Criminal Investigation group. As noted above, one of the primary differences between the new initiative and the prior programs is the absence of a set deadline for taxpayers to apply for relief under the 2012 OVDP. As further noted above, the IRS warns that the penalty framework may be increased and eligibility may be narrowed for certain classes of taxpayers and in the end the IRS may decide to end the program entirely.12 Furthermore the IRS clarifies that the current program is a "counter-part" to the traditional voluntary disclosure practice of IRS Criminal Investigation. 9 IR-2012-65, available at http://www.irs.gov/newsroom/article/0,,id=258431,00.html. 10 Id. 11 Id. 12 FAQ 3. 3 Although the FAQ guidance is somewhat ambiguous on the application under the traditional voluntary disclosure practice versus the application under the 2012 OVDP, the guidance suggests that if a taxpayer with undisclosed offshore accounts or assets is otherwise eligible to apply under the IRM 22.214.171.124 voluntary disclosure practice, such taxpayers also may apply for relief under the 2012 OVDP penalty regime.13 However the FAQs fail to address the issue of what happens when a taxpayer previously sought relief under the traditional voluntary disclosure practice before January 9, 2012 and then later seeks relief under the new program. FAQ 19 raises this very question but in lieu of providing a meaningful answer the answer portion of the FAQ erroneously repeats the question. This needs to be fixed. Similar to the earlier FAQ guidance in the 2009 and 2011 compliance programs, the new FAQs include the laundry list of the relevant civil penalties that could arise in the event a noncompliant taxpayer does not seek relief under the 2012 OVDP and is subsequently examined by the IRS. FAQ updates this list to include penalty exposure for failure to file Form 8938 beginning with the 2011 tax year as required by Section 6038D.14 Both the 2009 and 2011 compliance initiatives required participating taxpayers to supply an extensive list of tax return, information return and related data and information, including copies of previously filed tax returns as well as amended tax returns along with information reporting forms. The new program continues this mandate with some additional items to be included in the new package, including an agreement to cooperate with IRS offshore enforcement efforts by providing information and documentation pertaining to offshore financial institutions, offshore service providers and other facilitators upon request by the IRS.15 Given the pre-closing agreement and post-closing agreement interviews conducted by the IRS as well as the Justice Department over the past year-plus, this new provision seems to put taxpayers on notice that the government will continue to seek cooperation even after the closing agreements are long completed. Based on past experience, the focus of such interviews is to develop additional information and documentation regarding the foreign and domestic bankers, fiduciaries, lawyers and other advisors. One of the key issues is whether and to what extent the government has the legal authority to compel such a taxpayer interview. The preferred course of conducting the interview is for counsel to provide an attorney proffer to the government interviewers after receipt of confirmation that the interviewee is merely a witness (and not a target or subject). In some cases the government will press for an in-person interview, but in 13 FAQ 12. 14 The penalty for failure to file each one of these information returns is $10,000 with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency with a maximum of $50,000 per return. Form 8938 requires taxpayers to report their interest in certain foreign financial assets, including foreign financial accounts containing certain foreign securities as well as ownership interests in foreign entities and other foreign-related assets. 15 FAQ 7. 4 general these should not be compelled given that the spirit of cooperation is voluntary by the inherent nature of the voluntary disclosure program. Related Domestic Tax Compliance Issues In some voluntary disclosure cases the noncompliant taxpayer not only has offshore-related noncompliance through the use of undisclosed foreign financial accounts or other foreign financial assets but also related or even unrelated domestic tax issues. For example, the noncompliant taxpayer with an undisclosed foreign financial account might also have claimed false tax deductions on Schedule A or mischaracterized long term capital gains instead of short term capital gains on Schedule D. The new IRS guidance clarifies that even if the domestic-related elements are unrelated to the offshore aspects of the case, the relevant taxpayer should still disclose both the offshore and domestic issues as a part of the 2012 OVDP.16 Although the new guidance states this was the case in the 2009 OVDP and the 2011 OVDI, the guidance relevant to those programs did not include this specific reference. Consistent with FAQ 7.1, taxpayers making both offshore voluntary disclosure and domestic voluntary disclosure submissions should follow the 2012 OVDP process.17 Voluntary Disclosure Period The new guidance clarifies that the eight year disclosure period covers the most recent tax years for which the due date has already passed, and this eight year time frame does not include current years for which there has been no non-compliance.18 For example, for taxpayers who disclose after the due date or the extended due date for 2011, i.e., after April 15, 2012 or October 15, 2012, then the disclosure time frame must include the 2004 through 2011 tax years. The FAQs establish in effect a rolling eight year time frame depending upon the timing of the disclosure relevant to the due date or extended due date. The new guidance clarifies that the eight-year time frame will not include any compliant years in which the taxpayers timely filed original compliant returns that fully reported previously undisclosed offshore accounts or assets before making the voluntary disclosure. Accordingly, if a taxpayer files compliant returns for 2009 and 2010, but noncompliant returns for earlier years, then the voluntary disclosure period will be 2003 through 2008. Narrowing OVDP Eligibility The 2012 OVDP imposes heightened restrictions to eligibility for noncompliant taxpayers to participate in the new program. In general, taxpayers with undisclosed 16 FAQ 7.1. 17 FAQ 24. 18 FAQ 9. 5 offshore accounts or assets who otherwise meet the requirements of IRM 18.104.22.168 are eligible to apply for the IRS Criminal Investigation's voluntary disclosure practice and the 2012 OVDP penalty regime, subject to certain restrictions on eligibility and certain limitations, as discussed below. Consistent with the 2009 and 2011 guidance, the new FAQs allow entities such as corporations, partnerships and trusts to participate in the OVDP.19 Not surprisingly, and also consistent with the 2009 and 2011 guidance, any taxpayer already under IRS examination is ineligible to participate in the new program, and any taxpayer under criminal investigation is similarly ineligible.20 Also consistent with the predecessor compliance programs, the penalty framework of the 2012 initiative is not available to taxpayers who have filed "quiet" disclosures by filing amended returns and paying any related tax and interest for the previously unreported offshore income but without otherwise notifying the IRS.21 The FAQs state that "quiet" taxpayers may, however, cure previously made "quiet" disclosures by submitting an application under the 2012 OVDP along with all required elements thereof. The FAQs again encourage taxpayers who submitted "quiet" filings to come forward to avoid the risk of being examined and potentially being criminally prosecuted for all applicable years.22 Eligibility Hazards - Overview The 2009 and 2011 compliance programs addressed in their FAQs the relationship of a John Doe summons and program eligibility but did not address the issue of what happens when the U.S. government makes a request for administrative assistance under a bilateral income tax treaty or a tax information exchange agreement. Consistent with the John Doe summons guidance in the predecessor programs, the 2012 OVDP guidance specifies that the mere fact that the IRS initiates a treaty request or takes similar action does not make every member of the class or group identified in the treaty request ineligible to participate in the voluntary disclosure program.23 However, once the requested information is obtained and this information includes evidence of a specific taxpayer's noncompliance with not only Title 26 but also Title 31 reporting requirements, then such a taxpayer will become ineligible under both the 2012 OVDP as well as the IRS Criminal Investigation's traditional voluntary disclosure practice.24 The above warning regarding treaty requests and similar undertakings comes as no surprise given the ongoing efforts of the IRS and Justice Department to seek information from various Swiss, Liechtenstein, Israeli and other foreign jurisdictions' banks regarding U.S. taxpayer/customer relationships. For example, on May 11, 2012, 19 FAQ 13. 20 FAQ 14. 21 FAQ 15. 22 Id. 23 FAQ 21. 24 Id. 6 the Justice Department served a Request for Administrative Assistance under the U.S.- Liechtenstein Tax Information Exchange Agreement to the Liechtenstein Government in connection with undeclared accounts at Liechtensteinische Landesbank AG.25 The purpose of this new guidance is to provide a warning to U.S. taxpayers with undisclosed financial account relationships with such banks. Once the administrative assistance is granted and the turnover of information occurs to the U.S. government, impacted taxpayers will no longer be in a position to meet the "timeliness" requirement set forth in the Voluntary Disclosure Program.26 The new guidance further expands the grounds to render a taxpayer ineligible based on two separate scenarios, as discussed below. Eligibility Hazards -- Foreign Turnover Proceedings The first scenario involves a U.S. taxpayer appeal of a foreign tax administration's decision to authorize the handover of offshore account information to the IRS assuming the taxpayer fails to serve notice as required under 18 U.S.C. § 3506 of such appeal on the U.S. attorney general. This notice must be given at the time of the appeal, and if this notice is not given the taxpayer is ineligible to participate in the 2012 OVDP.27 It is interesting to note that the language used in this FAQ also states that the taxpayer will be ineligible if the taxpayer "fails to serve the notice of account information to the IRS …," however, the legal basis for this requirement to serve a notice of account information on the IRS is questionable and requires further IRS clarification. Alternatively, this could be simply a scrivener's error in how this FAQ was drafted. Eligibility Hazards -- Targeted Offshore Financial Institutions The second scenario that can render a taxpayer ineligible is somewhat more generalized but certainly ominous. Under this scenario the IRS has the latitude to announce that certain "taxpayer groups" that have previously maintained accounts at specific targeted financial institutions will be ineligible due to U.S. government actions (not just IRS) directed to the specific targeted financial institution. The only saving grace of this specific ground for ineligibility is that the IRS announcements will provide notice of the "prospective date" upon which eligibility for the targeted taxpayer groups will be in danger.28 As noted above, the U.S. government reportedly is aggressively investigating several Swiss, Israeli, Liechtenstein and other foreign jurisdictions' banks regarding 25 See Larry R. Kemm, William M. Sharp, Sr. & William T. Harrison, III, "Liechtenstein Paves the Way for Disclosure of LLB Account Records to U.S. Authorities," Tax Notes Int'l, July 23, 2012, p. ____, Doc. 2012-___or 2012 WTD ____. 26 See id. 27 Id. Furthermore, the notice must include all relevant documents relating to the appeal. 28 Id. 7 their activities involving the tax noncompliance of U.S. taxpayers. Accordingly, it would come as no surprise if specific targeted financial institutions were deemed to taint a particular taxpayer's eligibility for voluntary disclosure if the submission is not made before an announced warning date. As noted above, the Justice Department served a Request for Administrative Assistance upon the Liechtenstein government in May 2012 under the U.S.-Liechtenstein Tax Information Exchange Agreement. Notwithstanding that this treaty request has been served and is being actively processed by the Liechtenstein government, the IRS has not listed (as of press time) this financial institution as a "targeted" bank under this particular FAQ. Pre-Clearance and OVD "Letter" Changes In general, the 2012 OVDP continues the pre-clearance and then full voluntary disclosure submissions steps that were applicable in the 2011 OVDI. The new guidance clarifies that in the case of jointly filed returns, each spouse should request pre-clearance if the intent is to include both spouses.29 In addition, the new guidance also allows spouses to either pursue the case jointly or separately.30 The new guidance also clarifies the submission procedure of the Offshore Voluntary Disclosure Letter, as discussed below. Deadlines From a timing perspective, the new guidance explains that IRS Criminal Investigation intends to complete its review within 45 days of receipt of the offshore voluntary disclosure letter. Accordingly, the criminal phase will generally consume about 90 days of effort, given that the offshore voluntary disclosure letter must be submitted within 45 days of the pre-clearance notice being issued, plus the follow-on 45 days of review of the offshore voluntary disclosure letter by the IRS. Also from a timing perspective, the complete IRS Civil package must be submitted to the Austin, Texas IRS campus within 90 days of the date of the preliminary acceptance letter issued by IRS Criminal Investigation.31 Fortunately, the new guidance provides that an extension may be requested for an additional 90 days within which to submit the civil package for the case. The extension request must be submitted before the 90th day set forth in the IRS Criminal Investigation clearance letter.32 This will be of particular importance in complex noncompliant offshore structures with foreign financial holdings in which the federal tax reconstruction and related legal analysis requires additional time and effort. Bifurcation of Domestic versus Offshore 29 FAQ 23. 30 FAQ 24.1. 31 FAQ 25. 32 FAQ 25.1. 8 Under the new program the IRS requires taxpayers to submit all domestic noncompliance issues as a part of the offshore noncompliance case even if the domestic element is not directly related to the offshore case. The offshore portion of the voluntary disclosure will not ordinarily be subject to a full IRS examination; instead, the voluntary disclosure will be subject to a certification review, and according to the new guidance, this review is less formal than an examination and thus does not implicate the rights and legal consequences of an IRS examination.33 Similar to the prior guidance, the "certifying" examiner will be allowed to ask any relevant questions, request any relevant documents and if necessary even make third party contacts in order to "certify the accuracy" of these submissions without treating this process as an examination.34 The FAQs also provide new guidance indicating that if a domestic voluntary disclosure is included as a part of the offshore case, the domestic disclosure will be treated as a disclosure under the IRS long standing voluntary disclosure practice rather than the 2012 OVDP and an examination may be opened for the domestic part of the disclosure.35 This represents a major hazard because the IRS could expand the number of years under review and increase the penalty base well beyond the OVDP's "package terms" although such an expansion would seem contrary to the IRS's long standing voluntary practice to review only the past six years and also to take all relevant factors into account, such as "reasonable cause" to mitigate penalties. Absence of Beneficial Ownership in Accounts Similar to the predecessor programs, the 2012 OVDP includes guidance regarding a foreign financial account in which a taxpayer has mere signature authority and does not have any financial interest in such account. Assuming the taxpayer has other noncompliance, the guidance allows the taxpayer to cure the FBAR delinquency for such account by filing the FBAR with an explanatory statement, provided however, this action must be completed before any contact is made by the IRS or other governmental agency regarding an income tax examination or a request for delinquent returns.36 This timing aspect is a new qualification in the 2012 FAQs. Continuation of "No Discretion" Unfortunately, the 2012 OVDP guidance continues the harsh limitation of the 2011 program and the post-FAQ 35 reversal of the 2009 program by flatly stating that offshore voluntary disclosure examiners "do not have discretion to settle cases for amounts less than what is properly due and owing."37 The IRS then explains that because the 27.5 percent offshore penalty is a "proxy" for the FBAR penalty and other 33 FAQ 27. 34 Id. 35 Id. 36 FAQ 38. If there is no tax noncompliance, FAQ 17 provides a similar procedure. 37 FAQ 50. 9 penalties imposed under Title 26, there may be cases where a taxpayer making a voluntary disclosure would owe less if the 2012 OVDP penalty framework did not exist. Along these lines, the IRS indicates that under no circumstances will taxpayers be required to pay a penalty greater than the amount they would otherwise be liable to pay under the maximum penalties imposed under existing statutes.38 This statement is a continuation of the old program guidance and the IRS provides helpful updated examples to illustrate this application. This is a key area that practitioners need to closely review because the "maximum penalties" could be significantly less under existing statutes versus the program. Back on the 27.5 percent offshore penalty, this inflexible "one-size fits all" IRS penalty framework for all offshore voluntary disclosure cases simply defies logic. The IRS once again has failed to take advantage of an opportunity to institute a legally appropriate and factually fair system by which the 27.5 percent penalty is administered on a graduated basis depending upon the level of willfulness, as determined by a combination of objective and even certain subjective factors. Disabling the voluntary disclosure examiners from having any discretion is simply poor tax administration. Furthermore, this denial of any examiner discretion means that a more substantial pool of voluntary disclosure participants will be forced to "opt-out" and argue their positions through an IRS examination, IRS Appeals and eventually Tax Court or Federal District Court litigation. Voluntary disclosure cases that clearly involve at most mere negligence and not willfulness will likely clog IRS examination resources, as well as IRS appeals and judiciary for many years to come. The IRS should immediately reconsider an alternative to FAQ 50 based upon a legally appropriate and factually fair framework. To this end, the IRS has allowed reduced 5 percent and 12.5 percent penalty amounts under certain circumstances and recently announced the upcoming Overseas Americans Program to be effective by September 1, 2012 (which can result in reduced penalties). However, the IRS has not gone far enough, and further consideration of facts surrounding willfulness should be allowed and discretionary authority vested in examiners. When to Opt Out? The new program offers guidance by way of additional examples of circumstances under which a taxpayer might consider opting out of the civil settlement structure. Similar to the 2011 program, the guidance reinforces that opting out of the civil settlement structure does not affect the status of a taxpayer's submission under the traditional voluntary disclosure practice and thus IRS criminal protection should still apply. The new examples assume that the voluntary disclosure started in January 2012 and thus affects the 2003 through 2010 tax years, with the implication being that 2011 is being filed in a compliant manner.39 38 Id. 39 FAQ 51.1. 10 Dual Citizen Examples One of the FAQ's new "scenarios" to the "opt out" portion of the 2012 OVDP provides additional guidance for the so-called dual citizen of the United States and a foreign country and offers insight as to the likelihood that the IRS would assert accuracy related and FBAR penalties. This example references IRS Fact Sheet 2011-1340 and also references the New Filing Compliance Procedures for Non-Resident U.S. Taxpayers (defined above as the Overseas Americans Program) to determine whether such dual citizen taxpayers qualify for the new procedure, as discussed below. In one of the new examples, the taxpayer is a dual citizen of the U.S. and a foreign jurisdiction and lived and worked in the non-U.S. jurisdiction for ten years.41 The taxpayer had no income from U.S. sources during the ten years of working abroad and maintained a checking and savings account in the foreign jurisdiction with an aggregate balance of approximately $50,000 each year. Most importantly, the taxpayer complied with the foreign jurisdiction tax laws and fully reported his salary as well as foreign financial account interest income. The example indicates that the taxpayer earned income in excess of the applicable exemption amount (presumably referring to not only the standard exemption but perhaps also the Section 911(a) foreign earned income exclusion) but did not timely file U.S. income tax returns or FBARs for the ten years he lived abroad. The taxpayer "learned of his U.S. filing obligations," although the example doesn't say exactly when this revelation occurred, and thereafter immediately consulted with counsel who appropriately determined that the taxpayer would not qualify for the expedited procedure under FAQ 17 because of the omission from gross income of the foreign source salary and passive income associated with the foreign financial account. Presumably based upon the advice of counsel, the taxpayer applied for voluntary disclosure treatment under the 2012 OVDP and reported tax for each year and he also filed delinquent FBARs. The IRS concludes that the taxpayer qualifies for a reduced penalty of 5 percent pursuant to FAQ 52, and therefore the offshore penalty will be 5 percent of $50,000 or $2,500. Pursuant to the "package terms" of the 2012 OVDP the taxpayer also would be required to pay the tax deficiency for each year, together with a 20 percent accuracy- related penalty. The example goes on to state that if the taxpayer elects to opt out, the taxpayer would still be required to pay the tax deficiency and interest thereon with respect to the unreported income but "upon examination, IRS is not likely to assert accuracy related or FBAR penalties."42 This example illustrates possible penalty abatement by the IRS upon opting out of the 2012 OVDP, and this lenient treatment presumably would be based upon a 40 IRS Fact Sheet, Information for U.S. Citizens or Dual Citizens Residing Outside the U.S., FS-2011-13 (Dec. 2011). 41 FAQ 51.1, Example 4. 42 FAQ 51.1, Example 4. This example erroneously states the accuracy-related penalty. Because this involves a non-filer, the correct penalty is the delinquency penalty. 11 factual finding that the taxpayer did not intentionally and voluntarily disregard a known legal duty to file U.S. income tax returns as well as FBARs, and that if anything, the taxpayer's conduct was negligent. The discussion of the degree to which a taxpayer is deemed to be willfully in violation of U.S. tax law versus mere negligence is beyond the scope of this article. However, it is worth noting that the sophistication of the taxpayer would need to be examined, including his or her education, experience, expertise in tax and accounting matters, and general background, as well as analyzing the particular facts and circumstances of each element of the specific case. For example, in the above example the taxpayer worked abroad for at least ten years, and had no U.S. source income during this ten-year time period. This suggests that the U.S. taxpayer had "cut ties" with the U.S. Compliance with the applicable foreign jurisdiction's tax laws is also a crucial factor. It is not clear from the example when the taxpayer learned of his required U.S. filing obligations, but the way the example is drafted one can infer that the taxpayer was unaware of these obligations during the ten years while living abroad (the reference to "[a]fter learning of his U.S. filing obligations…" suggests that the taxpayer may have been unaware of the requirement to continue to file U.S. tax returns and FBARs). Many times Americans who live abroad and file foreign tax returns genuinely believe such filings are in lieu of a U.S. filing obligation. In contrast, another new example is based upon the same facts as mentioned above except that the taxpayer also owned interests in offshore entities for which Forms 5471 or 3520 should have been filed, and the value of such unreported offshore entities was approximately $200,000 each year. The fact pattern also notes that the taxpayer acquired his interest in the unreported offshore entities with tax-compliant funds and the entities' assets did not produce any income. Because relief under FAQ 18 would not be available due to the presence of unreported foreign source income, the taxpayer was forced to pursue a voluntary disclosure. The example walks through the applicable offshore penalty of $2,500 (i.e., 5 percent of $50,000) and the likely application of the "package terms" to pay the tax deficiency, along with a 20 percent accuracy-related penalty (which as noted should be the delinquency penalty due to the non-filers status) on the tax deficiency. Finally, in the event the taxpayer elected to opt out, the taxpayer will still be subject to tax and interest on unreported income but the IRS is "not likely to assert" the accuracy-related penalty, FBAR or other information reporting penalties upon examination. Because this example is premised on the same facts as the earlier example above, it is likely that the taxpayer initially learned of his U.S. filing obligations just prior to retaining counsel and entering the voluntary disclosure program. Query, what if the taxpayer knew this all along? At what point does mere negligence cross over into willfulness, i.e., an intentional violation of a known legal duty? This is the reason substantial due diligence must be undertaken in each case to recognize that if the taxpayer pursues this course of voluntary disclosure that upon "opting out" the taxpayer will be subject to severe examination testing. The examples provided in FAQs 52 and 53 pertaining to qualification for the reduced 5 and 12.5 percent offshore penalties remain essentially unchanged from the 12 2011 OVDI, with the exception that the IRS has now specifically stated that a taxpayer who would otherwise qualify for reduced offshore penalty treatment will not be guaranteed such treatment if the taxpayer elects to opt out of the 2012 OVDP. Canadian Registered Retirement Savings Plan Update The 2012 OVDP guidance also addresses the issue of how to treat Canadian Registered Retirement Savings Plans under which a timely election pursuant to Article XVIII(7) of the U.S. – Canada income tax treaty was not made to defer the income earned on the retirement account.43 For those taxpayers participating in the 2012 OVDP, the taxpayer must submit a statement requesting an extension of time to make the election to defer income tax and also provide Forms 8891 for each of the tax years and the type of plan covered under the voluntary disclosure. Furthermore, the taxpayer must submit a dated statement signed under penalties of perjury to explain what events occurred that led to the failure to make the election, what events occurred that led to the discovery of the failure, the nature and extent to which the taxpayer relied on a professional adviser, including a discussion of the nature of the adviser's engagement and responsibilities, and presumably any other information that is requested by the IRS. Upon receipt of this requested information, the case will be assigned to an IRS examiner and this examiner will be the reviewing person and will provide the taxpayer further instructions on making the election if warranted. It should be noted that the new guidance indicates that making this election does not preclude a taxpayer from opting out of the civil settlement structure of the program.44 Furthermore, if the election is granted, the Canadian retirement plan or similar retirement arrangement will not be included in the offshore penalty base.45 The new guidance also provides for direction for those taxpayers who are participating in the 2011 OVDI as well as for those who participated in the 2009 OVDP and whose cases have not yet been closed and resolved. In the latter case, if the taxpayer now wishes to make an election the taxpayer should provide the statement as described above plus all other information, including the name of the examiner assigned to the case and a copy of the closing agreement, with the package to be sent to the IRS Service Center in Austin with the attention "2009 OVDP Determination." For those taxpayers who maintain retirement or pension plans in a foreign country other than Canada who believe that the foreign retirement or pension plan should be not included in the new program's offshore penalty base are directed to contact the OVDI hotline.46 43 FAQ 54. 44 Id. 45 FAQ 54.1. 46 FAQ 55. 13 New Compliance Procedures for Non-Resident U.S. Taxpayers The IRS first indicated in December 2011 that it would provide guidance and new procedures for U.S. taxpayers living abroad who have failed to file U.S. tax returns for one or more years.47 Recently, the IRS issued such guidance in IR-2012-65, which describes new procedures for filing delinquent U.S. federal income tax returns and FBARs by non-resident U.S. taxpayers, including dual citizens. The newly announced procedures, however, are not effective until September 1, 2012, apply only to the very smallest of income earners, and lack critical details concerning how the new procedures will be applied. Thus, although arguably a step in the right direction, these procedures as announced are nothing to cheer about assuming the IRS fails to implement flexible, broad and inclusive conditions for participation in this new initiative. Under the basic terms of the new compliance procedures, a U.S. taxpayer currently living abroad may file delinquent U.S. federal income tax returns for the past three years and file delinquent FBARs for the past six years. If the taxpayer presents a "low compliance risk," the IRS will process such returns with an expedited review and will neither assert penalties nor pursue follow-up actions against the taxpayer. For this purpose, a taxpayer is deemed to be "low risk" if the tax returns submitted under the program show less than $1,500 of tax due in each year. However, notwithstanding that the tax due in each year may be less than $1,500, the taxpayer will not be considered "low risk" as the income and assets of the taxpayer rise, if the taxpayer has implemented sophisticated tax planning, or if there is material economic activity in the U.S. Moreover, a history of prior U.S. tax noncompliance as well as the type and amount of U.S. source income might affect the taxpayer's risk profile, thereby rendering the taxpayer ineligible to use the new procedures. If a taxpayer is not determined by the IRS to be "low risk," the IRS will assess tax, interest and penalties in accordance with applicable U.S. tax law. Curiously, the announced procedures require taxpayers to submit a dated signed statement under penalties of perjury to explain any reasonable cause for previous failures to file tax returns, information returns and FBARs.48 Since the procedures only are available to taxpayers with "low risk," it is not clear whether the relief from penalties for taxpayers with less than $1,500 of tax due in each year is subject to the IRS' scrutiny of any reasonable cause explanations. If the government's objective is to entice non-resident U.S. taxpayers to come forward and become compliant, these new procedures will likely be a failure. First, the threshold at which taxpayers become ineligible for the new procedures is simply too low. At current tax rates, a U.S. taxpayer could reach the $1,500 tax threshold with as 47 See IRS Fact Sheet, supra note 40. 48 Additional requirements are imposed for taxpayers seeking relief under the new procedures for failure to timely elect deferral of income from certain retirement or savings plans where deferral is permitted by treaty. 14 little as $5,000 of previously untaxed income (i.e., income for which U.S. tax is not offset by foreign tax credits). Second, a U.S. taxpayer with less than $1,500 in tax due is still not assured that he or she is eligible to file under the new filing compliance procedures. Specifically, as noted above, a taxpayer may not be treated as "low risk" if other high risk factors exist. Notably, such high risk factors include a substantial amount of income or assets. Thus, a successful individual who regularly pays enough taxes in another country to substantially cover his or her U.S. tax liability through foreign tax credits may nevertheless be ineligible for the new procedures even though the residual U.S. tax liability is less than $1,500. Third, the newly announced procedures expressly do not provide protection from criminal prosecution. The IRS release indicates that, notwithstanding the filing of returns under the new procedures, a person nonetheless may be prosecuted if the IRS and Justice Department determine that prosecution is warranted under the circumstances. Moreover, once a taxpayer submits returns under the new procedure, the taxpayer is no longer eligible to participate in the 2012 OVDP (but no reference is made to the IRS voluntary disclosure practice). This puts a significant premium on determining whether a taxpayer has circumstances that warrant prosecution. Tax practitioners would be well advised to steer their clients away from the new compliance procedures if there is even a hint that the circumstances might warrant prosecution. Unfortunately, in today's environment it is difficult to predict what the IRS or Justice Department might consider circumstances warranting prosecution relative to tax non- compliance associated with offshore assets and income. Many of these non-resident U.S. taxpayers are not even on the IRS radar screen. For example, consider an individual born in the U.S. who moves abroad as a young child. Although that individual may have spent the better part of their life paying taxes in another country, through neglect or lack of knowledge he or she may not have filed U.S. tax returns and paid U.S. tax. The same reasoning extends to an American taxpayer who moved abroad many years or even decades ago, and lost all connectivity with the U.S. but at the same time followed all applicable local country tax and other legal requirements. The new procedures provide little incentive for such individuals to come forward, particularly when the IRS states that there will be no protection from criminal prosecution. Moreover, even if the U.S. government randomly discovers the existence of such a person, there are hurdles to effectively enforce U.S. criminal tax statutes from abroad. Thus, the new procedures do little to incentivize such individuals. Finally, the IRS states, "additional information regarding the specific factors the IRS will use to assess the level of compliance risk, and how information regarding those factors should be presented in the submission, will be released prior to the effective date of the new procedure."49 As a result, there are substantial unknowns at this point as to 49 IR-2012-65, supra note 9. 15 how the new procedures will be administered. Accordingly, the U.S. taxpayers living abroad are left wondering what to do as the IRS dribbles out the guidance over time. As an additional thought, query whether taxpayers who either completed a voluntary disclosure under the 2009 and 2011 programs or are currently pursuing a voluntary disclosure may seek relief under these new compliance procedures in appropriate circumstances. Under both the 2009 and 2011 programs, the IRS maintained that a taxpayer could not avoid the miscellaneous offshore account penalty if there was any unreported income for the years at issue. It seems unjust that taxpayers who came forward under the prior voluntary disclosure programs should be subject to arguably excessive penalties when they may have avoided them entirely by holding out until these new more favorable procedures became available. Despite the laudable goal of providing relief to non-filers living abroad and procedures for coming into compliance, these newly announced procedures are not likely to draw a large response. To the extent U.S. taxpayers do take advantage of such procedures, they may achieve higher compliance objectives but will have little impact on government fiscal management due to the low tax threshold at stake. Conclusion The 2012 OVDP's refinement of the penalty framework as applied to certain classes of taxpayers together with the newly introduced Overseas Americans Program demonstrate progress on the part of the IRS in developing an equitable and due process-driven approach for penalty determination under the voluntary disclosure program. However, the new program's continued use of an inflexible penalty framework for most OVDP applicants is ill advised. Further, this "one-size-fits-all" penalty protocol likely will clog the exam, appeals and judicial systems with unnecessary "opt out" cases where taxpayer "willfulness" does not exist. On a more favorable note, the IRS appears to be providing noncompliant offshore taxpayers with an ongoing as opposed to a deadline-based "last chance" remedial program. Tax practitioners should closely review the 2012 OVDP FAQs and the terms of the Overseas Americans Program once they are announced because despite the increased financial exposure associated with returning to compliance for noncompliant taxpayers, the escalating efforts of the IRS and Justice Department in the area of offshore tax noncompliance are clearly increasing the both the criminal as well as the civil tax risks for noncompliant taxpayers with offshore holdings. The days of bank secrecy are over. 16
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text:
Those were the words of Jeff Bezos while speaking to German paper Berliner-Zeitung.
So it came as a surprise when it was announced Monday that Amazon.com's
That's all well and good. And I want to take the press release at face value. But who are we kidding here?
There are many theories as to why Bezos would risk what amounts to only a small fraction of his wealth to buy the Post. The most popular opinion is that Bezos, by the kindness of his heart, somehow "wants to save journalism." Well, "journalism" doesn't necessarily reside exclusively in newspapers. If that were the case, Bezos could have founded a journalism school for much less, or he could have simply made a sizable donation to one.
Buying the Washington Post, as shrewd of a move as I have ever seen, is about power and influence. Let's not forget that for his $250 million, Bezos also gets other assets such as Southern Maryland newspaper groups, Fairfax County Times and El Tiempo Latino. He's also buying the Express newspaper, the Gazette and Greater Washington Publishing. Bezos, a brilliant mind by many standards, also understands the political pressures Amazon has been under.
Bezos sees how rivals like Wal-Mart
Do you suppose that Bezos feels bad about crushing family-owned bookstores? Does anyone care about the fates of former rivals like Borders, Dalton's, Media Play and several others that were killed off by Amazon's online/e-books concept? Even Best Buy
In the interest of full disclosure: I'm a frequent shopper at Amazon and I love it. I want to make this clear. But I also understand that one of Amazon's advantages is that Amazon pays minimal property tax and no sales tax. I don't believe that Amazon could save its customers so much money without this benefit. While it's great that we get awesome deals and free shipping, where's the outcry for the fact that our states are cheated out of much-needed revenue? Yet, we complain when our local taxes go up. Do you suppose that perhaps Amazon should be on the hook for some of that? Where's the media?
Along those lines, it was only Apple's
Nor do I believe that the media's love affair with this company is Bezos' fault. But let's not pretend that Amazon is a saint and everyone else is evil. I don't believe for a second that there is any "humanitarian cause" to Bezos buying the Washington Post. Rather, this move has everything to do with preserving Amazon's retail and media empire.
There's no denying that Bezos' vision of what Amazon would become has been realized. But now, he's about to own a portion of the press. Let's recall, in his other vision last November, he told the German paper that "newspapers would be dead in 20 years." I expect that he'll be right about that as well.
But until then, he's going to use it to save Amazon, which clearly didn't need "saving" in the first place. But I don't expect that we'll see many "Amazon should pay taxes" articles from the Post any time soon.
At the time of publication, the author was long AAPL.
This article was written by an independent contributor, separate from TheStreet's regular news coverage.
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