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BudgetVoip - Cheapest Calls
by: Dellmont Sarl • 105
All Android applications categories
by: Dellmont Sarl • 105
BudgetVoip is a free application which enables you to save money on your international phone calls. Simply install the BudgetVoip application and start calling friends and family at the cheapest rates in the market, some examples:
Bangladesh Mobile 0.035 usd
Brazil Mobile 0.04 usd
India Mobile 0.008 usd
Pakistan Mobile 0.01 usd
And many more…
BudgetVoip operates over multiple internet connection options (3G, WiFi, GPRS, Edge, UMTS) directly from one integrated contact list. Install BudgetVoip now and start making cheap international 3g calls and WiFi calls today; no need for expensive calling plans anymore!
For more information, visit: www.budgetvoip.com
Using our app as a default dialer may interfere with dialing 911 emergency services.
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- Mighty Peaks Realty
- Looking to buy property in the Great Smoky Mountains? Mighty Peaks is the perfect site to find the perfect property for you.
- Top Cabin Rentals
- Whether you are looking for a cabin with a spectacular mountain view or a premier cabin on the Little Pigeon River, Top Cabin Rentals offers premium cabins to suit your family's needs and your vacation budget.
- Acorn Cabin Rentals
- Luxury cabins in premier Smoky Mountain locations can be yours with Acorn Cabin Renals.
- ABC Gatlinburg
- View our selection of Gatlinburg Cabins at www.abcgatlinburg.com.
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- Like the area of Pigeon Forge and Galinburg, but don't want to stay too close to it's busy streets? Eagle Springs Cabins is the place for you! Offering several Sevierville Cabins, located far enough away from Pigeon Forge and Galinburg to enjoy the peace of the Great Smoky Mountains, but close enough to enjoy the attractions Gatlinburg and Pigeon Forge have to offer.
- Above The Smokies
- Above The Smokies offers a broad selection of Gatlinburg cabins in the beautiful Smoky Mountains.
- Ober Gatlinburg ski resort and family amusement ice skating
- More Smoky Mountain links

subset: commoncrawl


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We stayed for 3 nights over the Thanksgiving weekend. It was a pleasant experience all around. We stayed in the hotel section, not the motel section. Our room was a good size and had a nice flatscreen tv in it. I immediately fired up my Kindle when we got the the room and connected to the wireless without any issues. The linens were fine, and I slept better here than at most hotels. The beds are not too hard or too soft, and they give you 4 pillows per bed. I love the toiletries, Bath and Body Works Coconut Lime.
We ate in the restaurant each morning for breakfast. The waitstaff is very pleasant and friendly. They have a big buffet, and if you order off the menu, they get the food off the buffet, so I would suggest just getting the buffet.
No complaints, just one small issue, the toilet in the bathroom is so close to the door, that you can barely sit on it. Its a very strange layout for a bathroom.
- Official Description (provided by the hotel):
- Welcome to the Holiday Inn Baton Rouge-South!The Holiday Inn Baton Rouge-South is the largest full-service hotel near the city, located less than 6 miles from downtown Baton Rouge, LA and 13 miles from Baton Rouge Metro (BTR). Our prime Baton Rouge location, near Louisiana plantation homes, puts you near Blue Bayou Water Park and Dixie Landin Theme Park as well as Baton Rouge Town Center shopping. Our hotel s recent renovation of 334 well-appointed guestrooms and suites includes a state-of-the-art fitness facility, indoor and outdoor pools, Business Center with complimentary High Speed Internet access and complimentary wireless Internet access in the atrium areas. On-site is the full-service Cafe Galvez Restaurant & Bar, and the Alamo Lounge for after dinner cordials. Room service is available from 6am until 11pm.Our location near downtown Baton Rouge puts us close to: LSU, Louisiana Arts & Sciences Museum/Planetarium, Southern University, the Louisiana State Capital, the Mall of Louisiana, the USS Kidd, the Greater Baton Rouge Zoo, and Casino Rouge.Holiday Inn South features more than 9,000 square feet of flexible meeting space with a special reception capacity for up to 500. Our experienced staff is more than happy to help with all arrangements for your conference, wedding, exhibit or special event we are your first choice in Baton Rouge! Relax, it s Holiday Inn! ... more less
- Reservation Options:
- TripAdvisor is proud to partner with Booking.com, IHG, Hotels.com, Expedia, Orbitz, TripOnline SA, Hotwire, Travelocity, Cancelon, HotelQuickly and getaroom.com so you can book your Holiday Inn Baton Rouge South Hotel reservations with confidence. We help millions of travelers each month to find the perfect hotel for both vacation and business trips, always with the best discounts and special offers.
- Also Known As:
- Holiday Inn Baton Rouge
- Baton Rouge Holiday Inn


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Sinus infections can be throbbing and for various they are a customary incidence. The learned profession cure for a sinus contamination is ofttimes to nutrition it next to antibiotics. However, these can have cynical squad effects and are not impelling once taken too habitually. For these reasons it is of assistance to try fetching a household remedy for passage infection. There are a few undemanding passageway household remedies that you can try. These don't have the sideways personal estate of pills medications and can be even more rough-and-ready in natural process a passageway health problem.
Sinus infections commonly set in after various days of having a cool or the flu. If you are prone to sinus infections try some preventative measures. As in two shakes of a lamb's tail as you instigation to get a frigid form convinced that you swill plentitude of hose. Fluids will impede mucous from proper gelatinous and save the passage cavities unambiguous. Increase the wetness even in your marital by mistreatment a movable humidifier or blister some hose down on the range.
Once you get a fistula infection enter a new phase fetching close bustle. Use a haze shelter various nowadays a day as needful. To breed a haze tent staphylococcal infection a pot of hose. Use a piece of material finished your manager and put up with or sit near your organizer done the vapor. The piece of cloth will activity keep hold of point-blank the steam into your muzzle and oral fissure. Be wise not to singe yourself. If your sinuses are effusive blocked, add an flavorer quotation to the water. Eucalyptus and application backing unfold up rhinal passages and brand exhaling easier.Post ads:
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Lemon Balm - A good-tasting herb, lemon balsam is a colloquial anti-virus, anti-bacteria active vascular plant. It is sedative and soothing, and normally untaken as tea. You can helping up to 4 cups of tea per day.
Sinus home remedies can be utilized unsocial or in dissimilar combinations as needed. You may status to try your hand beside a mixture of passage address remedies to insight one that complex good for you.


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Friday, Aug. 23, 2013 7:49 p.m. to 7:49 p.m.
Location: Woodie Wheaton Land Trust, 2 Grove Road, Forest City, Maine
For more information: Patty BuBar; 207-448-3250; woodiewheaton.org
In days gone by rural folks often wrote poems about their unusual experiences, particularly sporting adventures, and the long winters of eastern Maine lent themselves to armchair verse. This oral history preserved many curious tales that would otherwise have been lost. Join us for an evening of fun and hear how Uncle Percy slayed the dragon, as local people recite their favorite family poems. Bring yours along to share. Bud Brooks will sign copies of "The Hunter's Lament," a classic bear tale of the Maine woods.


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We have a nice Gerber deal over at Walgreens! Through 4/2, Walgreens has Gerber Graduates Puffs and Lil Crunchies on sale 2/$4. Even better, folks are reporting that there are TWO $2 Register Rewards popping out when you buy six. We also have a printable coupon to use for additional savings. Note that we are not sure if this deal is regional; it isn't advertised to pop out two $2 Register Rewards when you buy six. Here's the scenario:
At Walgreens:
BUY SIX GERBER GRADUATES PUFFS OR LIL CRUNCHIES, on sale 2/$4
Get two $2 Register Rewards ($4 total) when you buy six Gerber Graduates Puffs or Lil Crunchies (unadvertised; possibly regional)
Use two $1/3 Gerber Graduates Puffs, Lil Crunchies or Yogurt Melts printable coupons (preclipped)
Price at Register: $10, but get two $2 Register Rewards ($4 total)
NET PRICE FOR ALL: $6 (or $1 each!)
Thanks and photo credit Hip2Save.Extreme Couponing Tip: You can usually get two prints of most internet coupons. To find them in the easiest possible way, use our preclipped links that take you right to the coupon. Then come back and click the same link to get your 2nd print. This will save you the time spent searching for the coupon.
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After a long week, everyone deserves a relaxing Day Spa Lakeway Tx experience. However, most people searching for a day spa have no idea what to look for! Every Day Spa Lakeway Tx is different, some are smaller and offer a more intimate experience while others have large resort style amenities.
Finding the right Day Spa Lakeway Tx can be the difference between a relaxing spa experience or added stress. One salon customer had this to say about her experience,
Whether you are looking for a large or small Day Spa Lakeway Tx here are 3 tips for finding a great day spa that will carter to your needs.
|Available Services. Call the Day Spa Lakeway Tx and make sure that you ask about their services. A good Day Spa Lakeway Tx will include massage, skin care, body treatments and endless pampering. Additional services they might include are hair and nail care.
|Professional Staff. When you walk into any Day Spa Lakeway Tx, make sure that their certifications are displayed prominently. You will want to insure the spa is staffed with professionals.
|Make An Appointment. Many Day Spa Lakeway Tx say walk-ins welcome, however working a walk-in into an already busy schedule can take some time. To save your self the frustration of waiting around a Day Spa Lakeway call ahead and schedule an appointment a few days in advance.


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Opeth and Katatonia played an awesome show for an excited Guelph crowd
Tuesday, November 15, 20110 Comments
Photo Credit: Katie Maz
Photo Credit: Katie Maz
Photo Credit: Katie Maz
The sombre silence of downtown Guelph on the lazy, cold evening of Sunday October 30th was broken by a horde of Metalheads clad in their favourite band shirts, studs and long curls lining up on the side walk beside the Guelph Concert Theatre. Some restless, some anxious, and some a tad bit lazy, but none unhappy.
Opeth and Katatonia, two Swedish bands with careers spanning over two decades were at Guelph to put on a marvellous show that saw fans chant, mosh, crowd surf, and have a good time. The doors to the venue opened shortly after 6:35PM and the lines started moving. Everyone rushed in to get closest to the stage and to get the best view of their heroes who tour this part of the globe less frequently than most other bands of their calibre.
Katatonia, the opening act for the night, launched into "Leaders" after teasing the crowd with a mock performance. The crowd embraced the performance well though only a few got worked up enough to break into a mosh. "Liberation", "Day and Then the Shade" and "Soil's Song" saw the fans breaking into a mosh pit which expanded when the band played "My Twin", a crowd favourite. Jonas Renske hiding behind his long black curls delivered a beautiful vocal performance with backing vocals by Anders Nystrom. Per Eriksson , the most recent addition to the Katatonia line up delivered the tunes , riffs, and solos with perfection and an onstage persona of a true metal legend. Katatonia's set covered a multitude of albums giving their fans a taste of both old and new, a glimpse of their 20 year career. The set list included "Ghost of the Sun"," The Longest Year", "Forsaker", and a song from the band's debut 'Dance of the December Souls'. The vocal duties for the two songs off of 'Dance of the December Souls' (1993) and 'Brave Murder Day' (1997) were handled by Nystrom with Jonas taking up the guitar. Nystrom's vocal delivery was intense and had the crowd go wild to the screams and growls backed by heavy guitar riffs and aggressive drumming reminiscent of the band's roots with death metal at the very beginning of their career. Katatonia was nothing short of spectacular and the crowd was pleased. Their charged delivery of music almost made Opeth look pale in comparison.
As the Katatonia gear was cleared off the stage the chanting started once again. This time more intense with fans becoming more anxious to see the headlining band Opeth. Mikeal Akerfeldt's name was chanted like a mantra and the crowd was told by none other than Akerfeldt himself that Akerfeldt meant "field" in Swedish. "The Devil's Orchard" was unleashed upon the fans to their delight and the tone was set for the rest of the night with the dual guitars and the added layers of keyboard. With only a few heavy songs, the Opeth set list was, for the most part, more progressive than metal oriented- an approach that disappointed some of the fans who were expecting some of the heavier anthems from the band. "I Feel the Dark", "Face of Melinda" and "Porcelain Heart" were to follow with a drum solo thrown in much to the bemusement of the fans. "Nepenthe", then followed which led to an acoustic set; "The Throat of Winter", "Credence" and finally "Closure". The acoustic segment dragged on a little too long and a grain of disappointment was visible in the faces of the die-hard fans. Akerfeldt and the band made up for it by a heavier segment with a few fan favourites and a song dedicated to the memory of Ronnie James Dio of Dio/Black Sabbath who succumbed to his death last year after battling cancer for months. The Dio tribute was full of intense emotion and heavier segments saw the fans in motion once again.
The Swedish masters then played an "encore-game" with the fans and played their final song for the night, "Folklore". The night was warm and stuffy inside the Guelph Concert Theatre after a night of heavy music, screaming and a nice workout for the fans who paraded the streets after the gig. Happy faces and lots of buzz in the air signalled that it was a night to remember.
Chanditha Priyanatha is a student at the University of Guelph and a dedicated volunteer at thecannon.ca


text: 2. As of noon trading, Shire ( SHPG) is up $5.55 (5.4%) to $108.07 on heavy volume. Thus far, 712,897 shares of Shire exchanged hands as compared to its average daily volume of 547,000 shares. The stock has ranged in price between $105.37-$109.06 after having opened the day at $105.80 as compared to the previous trading day's close of $102.52. Shire plc, a specialty biopharmaceutical company, engages in the research and development, manufacture, sale, and distribution of pharmaceutical products. It operates in three segments: Specialty Pharmaceuticals (SP), Human Genetic Therapies (HGT), and Regenerative Medicine (RM). Shire has a market cap of $18.9 billion and is part of the drugs industry. Shares are up 11.2% year to date as of the close of trading on Wednesday. Currently there are 9 analysts that rate Shire a buy, no analysts rate it a sell, and 4 rate it a hold. TheStreet Ratings rates Shire as a buy. The company's strengths can be seen in multiple areas, such as its largely solid financial position with reasonable debt levels by most measures, expanding profit margins and increase in stock price during the past year. We feel these strengths outweigh the fact that the company has had sub par growth in net income. Get the full Shire Ratings Report now. 3x UPSIDE POTENTIAL: TheStreet Quant Ratings has identified a handful of stocks that can potentially TRIPLE in the next 12-months. Learn more.


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Alright, so this is either my second to last or last bog before Moon comes out. This one is on the various types of zombies.
I ranked this on a couple things:
Design- How interesting the creature looks and any evolution the design may have seen
Challenge- How much or how little of a challenge the zombie is
Ability- The "Special Ability" each type has, and how special it is.
Frustration- How easily I get frustrated with the zombie.
As always, this will be updated after Moon is released, and is just my opinion. This list does not inclued Dead Ops Arcade zombies.
From worst to best:
9. George A. Romero: I think we can all admit that George is incredibly awful. His appearance is boring and uninteresting unless he's angry. His ridiculously high health and capability of getting angry with the player after one shot just make him a truly annoying enemy to face. Though he makes the game more interesting by eliminating camping to an extent, he truly is the worst zombies enemy,
8. Pentagon Thief: He is interesting to look at, and I would love to know about his backstory. Too bad every time you see him he steals your weapon. You are then forced to chase him through a confusing teleporter system that seems to change up every time you use it. The only pro to his appearance s a chance at a bonfire sale.
7. Space Monkeys: These guys just feel unpolished. Their attacks are confusing at first, but later easy to avoid. Their attacks on perk machines seem to have varying levels of effectiveness and difficulty, and their appearance alone is simply boring.
6. Crawler Zombie: You have to aim low and they obscure your vision. Their tedious to fight, but at least aren't as strong or fast as zombies, balancing them out a little. They are interesting to look at however, in a gross out kind of way.
5. Zombie Monkey: They offer an interesting new dynamic to power-up collecting. YOu can no longer wait out a nuke or insta kill to try and milk more points before you use it. But you can try and trade a carpenter for a max ammo, or even a max ammo for a perk bottle! They also look much cooler than the space monkeys look, more disgusting and zombie like.
4. Shrieker Zombie: These things are scary and fast, and blurring your vision is even worse. They enter the battlefield in a tornado and then run and try to kill you with sound and fists. Too bad they are just too weak to justify their badassery.
3. Hellhounds: Bloody, flaming dogs of hell that spawn from lighting bolts hitting the ground and then charge at you, barking demonic barks? I may have just shit my paints a little. Only problem, their too weak, both in attack and defense.
2. Napalm Zombie: The way they lumber toward you, burning the ground with every step you take, is creepy enough. But the fact that they then explode, and leave a large zombie killing fire, is awesome. And that death sprint they do sometimes is the single most imposing thing in the world.
1. Zombies- Lets admit it, when you first played Nacht der Untoten and saw these things lumbering around in the mist, your heart started racing. These things get creepier and creepier looking with every installment, and they've probably killed more players than all the other enemies combined.


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These Dennis Moreland spur straps are cut from the back of the skirting leather side to give you a very durable strap. They are basket stamped by hand and have a hand braided rawhide loop keeper. The leather beneath the stainless steel buckles is sewn together to keep the buckles in place. These basket stamped spur straps look very classy in the show pen as well as on the ranch.
Copyright © 2017 NRS World


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Safe Shopping Pledge
ADVANCE is committed to providing you with a worry-free shopping experience. Our proprietary ADVANCE Pass technology was designed to securely authenticate you when visiting our sites, keeping your information safe and secure. Our web servers and databases are located behind a firewall that inspects all incoming internet traffic to further protect your information from theft. Personal information transmitted over the internet between your computer and our web servers is encrypted using 128 bit SSL encryption. SSL is an industry standard technology for secure online transactions. All credit card data and passwords are stored in encrypted format to prevent anyone except authorized employees from seeing your credit card number or password.
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Oak Hill News
Local news for Oak Hill, WV continually updated from thousands of sources on the web.
Expected Traffic Delays During National Boy Scout Jamboree
Monday Jul 17 | WOAY | Comment?
Oak Hill man dies after shots exchanged in Fayette County
Tuesday Jun 27 | West Virginia Metro | 20
Oak Hill news is powered by NewsRank ®
Updated: Mon Jul 17, 2017 05:33 pm
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Puzzle Genie - Walkthrough
Puzzle Genie
By: NARCIS GHEORGHE
Welcome to the walkthrough for the iOS game Puzzle Genie, if you are looking for ways to make it to the next level, you've come to the right place!
The walkthrough contains the solution and will guide you through each of the levels with tips, tricks and cheats, to enjoy Puzzle Genie on your iPhone, iPad and Android devices.
Here you will find guides, answers, tutorials, helpful tips, as well as a discussion section for each level. It will help you if you're stuck!
We provide a community for gamers to discuss, learn and share anything about Puzzle Genie. Anyone can join in, share their experience and tips with others. If you have any questions, request or need extra help; feel free to ask by making a comment.
Puzzle Genie Game Overview
Puzzle Genie is available on iOS. For more details on the app, check out our review.
- Publisher: NARCIS GHEORGHE
- Developer: NARCIS GHEORGHE
- Genre: Puzzle
- Release Date: February 26, 2016
Gameplay & Videos: See it in Action
Want to get a high score in Puzzle Genie? Don't miss any of the new videos of Puzzle Genie gameplays played by pro gamers - Updates July 9, 2017.
Walkthrough Sections
Work in progress...
Note: Some of the levels still need walkthroughs. If you know how to beat a level, then please submit your level guide here and share your skills.Hit like if this helped you!
Stuck need help? Join the community
Ask questions about Puzzle Genie and get help from other gamers.


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Duane Brown Hoping For O-Line Improvement in 2017Texans left tackle Duane Brown is now the longest tenured Texan on the roster. 2017 will be his 10th season in Houston and the anchor of an offensive line in need of tweaking and re-tooling.
Texans - Buccaneers: In A NutshellPaul Gallant recaps the Texans' 19 - 9 victory over the Bucs.
Better/Worse: Houston Texans Offensive LineMad Radio looks at every position for the Houston Texans and discusses who is better and who is worse in each particular unit heading into the 2015 season.
Duane Brown: "I Can Be Better"
Texans - Giants: In A NutshellPaul Gallant breaks down the Texans' 30-17 loss to the Giants.
Offensive Line Meshing, Ready for Giants
Texans - Raiders: In A NutshellPaul Gallant's takeaways from the Texans' 30-14 victory over the Raiders
Game Prep Monday: O-Line Grinding It OutThe Texans' offensive line played a critical role in Houston's 30-14 win over the Raiders.
Charles Spencer Is Concerned About New CoachesFormer Texan, Charles Spencer, joined MaD Radio to discuss the Texans new offensive line coach and how it may impact Duane Brown.
Point Of Emphasis To Solidify Offensive Line
O-Line Coach John Benton on Brennon Williams
John Madden Selects Texans As Best O-Line For Week 13Led by more stellar play from their offensive line, the HOUSTON TEXANS clinched their second consecutive playoff berth with a 24-10 victory over the TENNESSEE TITANS.


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Metabolism is simply the way your natural object comic calories. Some factors can power your organic process plus sex, age, and article sized. But can you do thing to magnify your metabolism?
To answer some of those questions, here is a few investigating for authorities on weight loss and weight guidance to tender you the full-strength facts on metamorphosis.Post ads:
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Question: Do thin populace have a sophisticated metabolism piece bigger populace have a slower metabolism?
Answer: No. According to the Mayo Clinic, organic process is not strong-willed by your weight. Metabolism is the engine that comic the calories and regulates your body's dash wishes. Your weight is resolute by the calories you down smaller quantity the calories you char. So a banging somebody that consumes a rangy magnitude of calories can immobile have a soaring metamorphosis that is compliance them from getting hold of more weight.
Question: Do stout general public e'er have a lower metabolism?
Answer: No. It is exceedingly atypical for inordinate weight to be caused by a inferior biological process. However, if someone thinks that is the case, they should be evaluated by a dr. for conditions specified as thyrotoxicosis.Post ads:
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Question: Will workout mushroom your metabolism?
Answer: Yes. Adding in games to your daily government will advance your metamorphosis. As you grow your contractor from exercises resembling guts taming and aerobiotic exercise, you will physique muscle. Muscle burns much calories that fat, thereby accretive your organic process. Don't be on trips to the gym or laps about the vicinity. Find other distance to have bonus action for the period of your day: pace the way alternatively of winning the elevator, garden, rinse you car, and sponge down the building. That will escalate the magnitude of calories you smoulder and enhance the musculus you build.
Question: Should I skip a nutrition to extension my metabolism?
Answer: No. By skipping a meal, your article feels approaching it is in hungriness way and will use your contractile organ for oil and slows your biological process. Since contractile organ helps to amass your metabolism, losing any contractile organ is not the reply. You should try to eat 6 unimportant meals per day so your article does not consciousness like you are starving, causation it to electric switch directions and use musculus for substance and remiss downstairs biological process to fashion sure it stores the calories before in that. Make sure to eat healthy, supermolecule based meals. Eating by the USDA's supplies polyhedron is unmoving a respectable way to win what you eat respectively day. They have altered the old craze epitome beside 12 divergent models for you to plump for from victimization distraction even and sustenance ingestion as guides. You can see the new suggestions at online at the USDA's website.
Question: Can liquid mount my metabolism?
Answer: Yes. Water is the body's furthermost exalted nutritive. Without water, the internal organ will hold binary compound as an alternative of blister fat. A search by German researchers demonstrated that family that drank fitting finished 16 ounces of dampen had a 30 percentage complex work unit flame charge than their resting organic process charge per unit. They concluded that imbibing 8 8-ounce eyeglasses of hose a day-the largely recommended amount-can cremate off most 35,000 calories a year, or astir 10 pounds (source Prevention public press online).
To reply the initial questions:
o What is it astir metamorphosis that helps us miss weight? Metabolism is simply the body's act of baking the calories consumed.
o Does it truly facilitate us put in the wrong place weight faster? Yes, a higher metamorphosis does assistance you shine more calories.
o Can you genuinely expand your metabolism? Yes, you can increase your metabolism by maximising your every day exert and profit-maximizing the amount of binary compound you brew.
Do not be fooled to construe you cannot lose weight because of a long-playing metamorphosis. With elemental steps, you can extension your body's competence to reduce to ashes calories and put in the wrong place the weight!


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"The Archbishop of Canterbury is bending over backwards to placate the rabid homophobes of the born again charismatic wing of the church in the belief that cohesion is more important than conscience. He knows what we all know, that gayness is not a sin, it's not even a faux pas. It is the way some people are, but to placate a sordid, spiritually bereft prejudice he will go halfway round the world to search out mendacious phrases to keep the church one big, unhappy, sniggerable communion.
"What he should be doing is laying about him with an axe. He should welcome schism. He should tell them to take their massive thermometers and smudgy imaginations and sod off." —A.A. Gill


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A new kid in town is taken under the wing of a young baseball prodigy and his team in this coming of age movie set in the summer of 1962. Together, they get themselves into many adventures involving rival teams, lifeguards, and a vicious dog.
Scotty Smalls moves to a new neighborhood with his mom and stepdad, and wants to learn to play baseball. The neighborhood baseball guru Rodriquez takes Smalls under his wing, and soon he's part of the local baseball buddies. They fall into adventures involving baseball, treehouse sleep-ins, the desirous lifeguard at the local pool, the snooty rival ball team, and the travelling fair. Beyond the fence at the back of the sandlot menaces a legendary ball-eating dog called The Beast, and the kids inevitably must deal with him. Written by Ed Sutton <[email protected]>
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REIT Foreign Currency Gains
For certain REIT test failures, it may be able to simply pay a monetary penalty and bring itself into compliance. Read more in this article.
October 25, 2007
Sponsored by LexisNexis
Learn more about LexisNexis Tax Center
REITs (Real Estate Investment Trusts) are subject to a number of rules to ensure that their primary focus is commercial real estate activity. REITs must meet two gross income tests. First, at least 95 percent of a REIT's annual gross income must be from specified sources, such as dividends, interest, rents, and other enumerated qualifying passive income sources [IRC § 856(c)(2)]. In addition, at least 75 percent of a REIT's annual gross income must consist of real property rents, mortgage interest, gain from the sale of real estate assets, and certain other real estate-related sources, with a number of qualifying income items enumerated [IRC § 856(c)(3)].
REITs must also meet several asset diversification tests. At the end of each quarter of the taxable year, a REIT must have at least 75 percent of the value of its total assets represented by real estate assets, cash and cash items, and government securities [IRC § 856(c)(4)(A)]. Other asset diversification requirements restrict the securities that may be included in a REIT's asset composition [IRC § 856(c)(4)(B)].
Failure to meet the above tests can result in loss of REIT status. For some failures, however, if a REIT can show reasonable cause, it may be able to simply pay a monetary penalty and bring itself into compliance [IRC § 856(c)(6), (7)].
How Foreign Currency Gains Fit Into the REIT Picture
If a foreign currency depreciates against the U.S. dollar (i.e. the U.S. dollar strengthens in relation to that currency), the value of a REIT's investment in securities and other assets denominated in that currency will decline. With the plummeting of the value of the U.S. dollar against the euro, the Canadian dollar, and other currencies in the past several years, the converse has occurred. The weakening of the U.S. dollar, particularly against the euro, has caused the value of many REIT investments in assets denominated in other currencies to increase significantly. This can result in significant foreign currency gains that can skew a REIT's income.
The IRS Clarifies the Issue for Foreign Currency Gains
Until recently, it wasn't clear how the currency conversion gain should be treated under the REIT income and asset tests.
In May 2007, the IRS released Revenue Ruling 2007-33 [2007-21 IRB 1281] and Notice 2007-42 2007-21 IRB 1288]. These releases clarify that in the vast majority of cases, a REIT's foreign currency gains earned in the operations of a foreign real estate business will be qualifying income under the REIT rules.
In Revenue Ruling 2007-33, the IRS ruled that foreign currency gain that is recognized by a REIT will be qualifying income under the REIT gross income tests to the extent that the underlying income so qualifies.
Notice 2007-42 [2007-21 IRB 1288] — issued at the same time as Revenue Ruling 2007-33 — provides guidance regarding the proper treatment of IRC Section 987 gains. The Notice states that the IRS intends to amend the proposed regulations under IRC Section 987 to include guidance concerning the proper characterization under the REIT income tests of the foreign currency gains recognized by a REIT on a remittance from a QBU (Qualified Business Unit) of the REIT.
Impacts of Revenue Ruling 2007-33 and Notice 2007-42
The most immediate impact of the IRS guidance is that REITs will no longer have to obtain a private letter ruling to determine how most of their foreign currency gains will be treated under the REIT income tests. An even more favorable longer–term impact is that absence of uncertainty regarding the treatment of foreign currency gains is likely to accelerate further international investment and overseas expansion by REITs.
Legislation on the Horizon
At least two bills have been introduced in Congress [see S. 2002, H.R. 1147] to codify the position of the IRS in Revenue Ruling 2007-33. Each bill would specify by statute that qualified REIT income under the REIT gross income tests includes any foreign currency gains derived by a REIT with respect to its business of investing in foreign real estate assets [new IRC § 856(c)(2)(I), (c)(3)(J) (proposed)].
The bills also address related REIT foreign currency problems that were not resolved by Revenue Ruling 2007-33 or Notice 2007-42. Although Revenue Ruling 2007-33 in particular was welcome, it took the IRS nearly four years to issue it because of questions about the extent of the government's regulatory authority in the area.
For further discussion on IRC § 856 and additional IRC sections related to REIT, see LexisNexis Tax Advisor — Federal Code on LexisNexis Tax Center.For a topical discussion on REIT, see Tax Advisor — Federal Topical.
Request your free copy of the Matthew Bender treatise, Federal Taxes Affecting Real Estate.


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Tribune Opinion: Numbers show a lot to applaud
December 10, 2012
Two recent reports gave us some reason to feel pretty good about the future of Weld County, and pointed out an area of concern.
A report from a Connecticut-based data analytics firm predicts that Weld will see modest and steady population growth in the next five years.
The firm, Pitney Bowes Sotfware, projects that the Greeley Metropolitan Statistical Area — the fancy term statisticians use for Weld — will grow by 1.7 percent a year through 2017. That number is similar to what city of Greeley officials expect.
That growth rate is lower than Weld has experienced in recent years. At one point in the early 2000s, it was near the top of the nation in population growth, according to the U.S. Census Bureau. The Pitney Bowes report showed that Weld grew at 4.1 percent a year for the decade that ended in 2010. That was good enough for fourth in the nation.
While the new growth projections come in at a more modest rate, we think that's a good thing.
Weld, as much as any other county in the country, has experienced the upside of super-heated growth, and the challenges that come with it. More moderate growth will be good for the county because it will be easier to manage. However, it's possible some other scenario will develop that will see the county grow faster. Either way, growth will happen, and as a community we need to plan for it and embrace it.
The other report, from the U.S. Bureau of Economic Analysis, showed that per capita income grew 5.4 percent in the Greeley MSA in 2011 when compared with 2010. Weld's per capita income — total wages divided by total population — grew to $29,986, the fastest in the state. That's the good news.
The challenge for the county, however, is that wages remain the lowest in the state among seven major regional areas in the report. For comparison, the Fort Collins-Loveland area reported per capita income of $39,767, growing 4.4 percent. While the Boulder MSA reported the highest per capita income in the state with $51,893.
Weld's per capita income also sits near the bottom in the nation.
That's a tough challenge to overcome.
Once an area develops a reputation as a low-wage region, it can be tough to change. However, we think there's lots of reason to feel optimistic about continued income growth in Weld. While the boom in oil and gas extraction brings its own challenges, it also brings plenty of high paying jobs. We've also seen growth recently in high-tech and innovative manufacturing in the county. This, too, should help lift wages.
While the county does face challenges, Weld has a lot going for it. There's plenty of space and water resources. With support from the University of Northern Colorado and Aims Community College, the county can offer a well-educated workforce in just about any field, and the county's agricultural tradition means residents are no strangers to hard work.
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Predicting NBA Finals success off the numbers
MIAMI – In a complex game of screens and rolls and defensive switches and offensive maneuvers and precision passes and accurate shooting, the winner and loser can be determined by simple statistics.
Who had more rebounds? Who had more points in the paint? Who had more fastbreak points?
In Game 1 of the NBA Finals, the Oklahoma City Thunder outrebounded the Miami Heat 43-35, outscored them 56-40 in the paint and 24-4 in fastbreak points — and the Thunder won 105-94.
In Game 2, the Heat outrebounded (40-36) and had more points in the paint (48-32) than the Thunder, who outscored Miami 11-10 in fastbreak points. But the Thunder had no fastbreak points through 2½ quarters — and Miami won 100-96.
"In big-muscle areas and attack areas, both teams are similar," Heat coach Erik Spoelstra said Sunday morning. "Both teams know each other's strengths. It's probably a simplification for both teams, but the hard part is doing it. Who can impose their identity more consistently than the other team. And that's been the tale of the two games."
One of Miami's biggest adjustments from Game 1 to Game 2 was slowing Oklahoma City's transition game. Both teams love to run when given the opportunity — Oklahoma City even more than Miami. The Thunder finished fifth in fast-break points (16.1 per game), and the Heat were 11th (13.7) in the regular season.
"You have to execute and get good, quality shots," Spoelstra said. "For us, it's quality shots near the basket. In Game 1, we were launching long ones, not getting guys back, bang, it's a layup.
"Sometimes you've got to adjust your offensive rebounding rules. We made a bigger commitment in Game 2 to get another guy back and sometimes that's not even enough with the speed that they have. You try to create as many people back in the paint waiting for them as possible. They change ends probably similarly to us. It's impressive."
The Heat were eighth in points in the paint per game (42.5) and the Thunder were tied for ninth (41.9 per game).
Thunder coach Scott Brooks wants better screens and passes from his team, which should impact points in the paint.
"One may think it's just about the defensive end, but I always look at it as offensive, also," Brooks said. "We have to do a better job of setting screens. That's one of the strengths of our offense. We set screens, and we shoot a good percentage and score in the paint and we get to the free throw line. But we have to have better screens, we have to be able to come off our screens harder and we have to make the passes on time.
"They do a great job. They're a good defensive team, just like we are. They make you make the extra pass, and we have to do a better job with that."
Miami was also the best in the league at scoring points off of opponents' turnovers (19.7 points per game, tied with the Memphis Grizzlies), and Oklahoma City was tied for 16th (16.1).
"The way we prepare for them is how teams have had to prepare against us," Spoelstra said. "One, you have to take care of the ball. Flat-out, you have to keep your turnovers down. In the first game, every time we turned it over — (Spoelstra snaps his fingers) — it was a run-out for something easy."
While Miami wants to get back quickly on defense, forward Chris Bosh has leeway to chase offensive rebounds. Of his 15 rebounds in Game 2, seven were on the offensive end.
"We know getting back is more important than offensive rebounds," Bosh said. "I'm going to be in my same spots, and I have the power to pick and choose when to crash. If I can get my hands on the ball down there, I'm going to do that and try to get us some second chances."
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- Muriel Barrett
- 1 years ago
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1 SETTLEMENT AREAS Introduction Urban Serviced DRAFT POLICIES These urban areas have either full or partial primary urban services, mainly water, sewage and roads. Functionally, they tend to service larger areas and are the main location of residential, industrial and commercial and institutional uses. Rural Settlement There are numerous small villages and hamlets throughout the County that rely on private water and sewage systems, but are serviced by public roads. They function as limited residential and local commercial places, often they support local tourist operations. Settlement Areas are defined in the Provincial Policy Statement (PPS) as urban areas and rural areas within municipalities (cities, towns, villages and hamlets) that are: a. built up areas where development is concentrated and which have a mix of land uses; and b. lands which have been designated in an Official Plan for development over the long-term planning horizon. In the County of Haliburton, the following municipally serviced and unserviced settlement areas are identified on Schedule A to this plan: (to be reviewed with Planning Committee) Minden Haliburton Carnarvon Dorset Oxtongue Lake Hall s Lake Cardiff Village Wilberforce Highland Grove Gooderham Tory Hill Eagle Lake Harcourt West Guilford Lutterworth The County of Haliburton promotes the concentration of growth within Settlement Areas and away from significant or sensitive resources and areas which may pose a risk to public health and safety. Local official plans shall designate the listed Settlement Areas to ensure that sufficient lands are available at the municipal level to accommodate current needs and expected population growth, all while encouraging intensification in existing built-up areas. Efficient development patterns will be encouraged in Settlement Areas to optimize the use of land, resources, infrastructure and public service facilities. A mix of housing, employment, parks, open spaces, and transportation options will be promoted. These land use patterns ultimately provide for the long-term financial well-being of the Province and
2 municipalities and minimize the undesirable effects of development, including impacts on air, water and other resources. Moderate growth is anticipated over the next 20 years. Most of this growth will occur within Urban Serviced Areas and Rural Settlement Areas. The County has undertaken studies to determine the impact of expected growth on the existing municipal structure. Section XXX provides further detail in this regard. According to the 2011 census, the largest single age bracket for the population in the County of Haliburton is 55 years of age and older. The median age in the County is 54 years (compared to 40.4 years in Ontario). Seniors 65 years of age and older represent 27.8% of the population (approximately double the percentage of seniors in Ontario). This trend is anticipated to continue and potentially increase over the planning period. This aging demographic will have an impact on settlement patterns and services. Intensification Targets Insert growth management policies - Planning Committee Direction needed and add/update as required Community Directions The community recognizes the function and importance of all settlement patterns. The objective is to allow their development in a manner that continues to provide and improve the range of community services, while at the same time respecting the natural environment. The County of Haliburton Official Plan should function as an overall guide with local official plans and bylaws regulating the specifics of development and redevelopment. New development and redevelopment decisions shall consider all members of the County of Haliburton community and identify and remove land use barriers which may restrict full participation in the community. Policies and Actions All development within each settlement pattern type will be provided with appropriate services to sustain permanent occupancy in accordance with its function. Local municipalities will work with the County to coordinate infrastructure and public service facilities and will ensure that such facilities are strategically located to support the effective and efficient delivery of emergency services. Both the County and local municipalities will monitor new technologies, such as broadband, that would be beneficial to residents and businesses and which would best be coordinated across municipal boundaries and will work together to develop strategies to ensure that the County provides optimal services in a timely and efficient manner. Infrastructure and public service facilities should be provided in an efficient and cost-effective manner to accommodate existing and projected needs. Optimization of existing infrastructure and public service facilities should be given consideration first, wherever possible, rather than the provision of new infrastructure and public service facilities. The County of Haliburton and the local municipalities will include in their planning review of applications for development consideration of the needs, programs and services required to meet the needs of the
3 growing and changing senior population of the County. Accessibility and transportations systems as part of development and site alteration will include consideration for the senior population. Land use patterns and development should promote energy efficiency, improved air quality, and allow for compact development that is designed in such a way to support and encourage active transportation as well as the establishment of future transit. Development will allow for a mix of employment and residential to provide the opportunity for shortened commute times. The County supports the use of alternative or renewable energy systems to meet current and future energy needs. Alternative and renewable energy systems will be permitted in each settlement pattern type in accordance with provincial and federal requirements. The range of uses allowed in each type of settlement pattern will be determined in the local official plan and zoning bylaw. Serviced urban areas shall be provided a full range of uses. Other settlement types shall be permitted a range of uses based on their function and historical service area. Local official plans will define boundaries for all settlement types. The expansion of a settlement area boundary, as identified within the local official plans, is permitted only at the time of a comprehensive review. Extensions to urban areas will only be permitted if existing municipal services are extended, prior to or in conjunction with new development. Full municipal sewage and water services are the preferred form of servicing for urban settlement areas. Communal services are the preferred means of servicing multiple lots/units in areas where full municipal sewage and water services are not or cannot be provided. Lot/unit creation may be serviced by individual on-site systems where the use of communal systems is not feasible and where site conditions are suitable over the long term. Partial services will be discouraged except where necessary to address failed services in existing development, or because of physical constraints. Within settlement areas, partial services may be permitted to allow for infilling and rounding out of existing development provided that the development is within the reserve sewage system capacity and reserve water system capacity; and that site conditions are suitable for the longterm provision of such services. Development expansion will be permitted based on private services in urban unserviced areas, lakefront communities and dispersed development areas. All development will be either infilling or contiguous extension to the settlement pattern fabric. Prior to any expansion, or further development, the development boundaries of these areas, the permitted range of uses and service levels must be established in the local official plan and/or zoning bylaw. The County and local municipalities will develop and implement a quality assurance program to progressively upgrade existing septic tank systems and other private services to current permanent occupancy levels and the requirements of the District Health Unit. Home occupations, home industries shall be permitted subject to environmental, functional and visual compatibility with surrounding uses and municipal requirements. Second units
4 The Strong Communities through Affordable Housing Act, 2011 requires municipalities to permit second units. The County recognizes there may be inherent constraints within portions of the County which would make those areas inappropriate for second units (such as flood-prone areas or those with inadequate servicing). Local official plans shall consider constraints to the development of second units and identify any in their second unit policies. Alternatively local official plans may specifically identify the locations or designation where second units are permitted. The County supports second units being permitted by the local municipalities. Local official plans shall contain policies on second units in both existing and newly developed residential areas. Municipalities and development proponents are encouraged to incorporate second units in the planning of new neighbourhoods. The Act requires municipalities to permit second units in detached, semi-detached, row housing, and in ancillary structures. The provisions permit one additional unit (i.e., a second unit) either in a house (e.g., basement) or in an ancillary structure (e.g., above laneway garage) on the same lot. Local official plans shall identify in policy where second unit development is appropriate to meet the needs of their communities while protecting public health and safety. Local official plans that currently permit second units will need to be reviewed to assess whether they are permitted in the range of housing types listed in the Act and make any updates required. Municipalities through their local official plans are responsible for determining what standards or zoning provisions should apply to second units in relation to matters such as minimum unit size or parking requirements. Standards should support the creation of second units. Second units must comply with any applicable laws, which could include the Building Code, the Fire Code and property standards by-laws. The changes do not grandfather any existing second units that do not meet applicable laws. A building permit may be required to establish a second unit depending on whether alterations to the house are needed. As such, homeowners considering establishing a second unit should contact their municipality prior to doing so. The preferred method of dividing land is through plans of subdivision. However, it is recognized that the issuance of severances may be appropriate under certain circumstances. The local official plans shall include criteria for the review of severances and a provision that no more than four cumulative new lots may be created through the severance process on any conveyable lot. The criteria for the review of severance applications to ensure the orderly development of the County and local municipalities shall include policies related to servicing, natural heritage features, adequate road access, water quality, drainage, size of parcel, traffic hazards, and natural hazards. In determining the necessity of lot creation for potential growth, within areas identified as rural in the local official plans, the County shall take into consideration the volume of development ready lots of record within the local municipality.
5 Settlement area vacant lot supply (2014) Settlement Area Total potential area of vacant land Total Area minus constraint and infratructure Number of potential lots West Guilford Eagle Lake Harcourt Haliburton Wilberforce Highland Grove Cardiff Tory Hill Gooderham Otongue Lake Dorset Halls Lake Carnarvon (AH) Carnarvon (MH) Lutterworth Minden TOTAL Municipality Rural area vacant lot supply # of vacant parcels # of vacant parcel within 30 m of a municipal road # of vacant parcels with no constraints within 30 m of a municipal road Algonquin Highlands Dysart et al Highlands East Minden Hills Total The County shall encourage the local official plans to address seasonal residential conversion to year-round residences and shall provide provisions accordingly. Local official plans shall address provisions for group homes for those who are unable, whether temporarily or long term, to provide fully for their own wellbeing. Group homes shall be licensed and/or approved under Provincial statutes and shall exist in compliance with local bylaws. Group homes shall be permitted in local official plans within land use designations which ensure that adequate servicing is available. Any local official plan, which was approved prior to
6 the final approval of the County Plan, shall be revised, prior to, or at the time of, the next comprehensive review to include provisions for group homes. The County and local municipalities shall plan for a range of densities and forms of housing affordable to all community households, including low and moderate income, enabling all residents of the County to remain living and working in their communities. Council shall encourage the preparation of Community Improvement Plans and associated policies and programs at the local level to encourage redevelopment, and will direct municipalities to maintain the well-being of urban downtown areas and main streets and plan to meet the needs of pedestrians. Community improvement initiatives include construction, energy efficiency, accessibility, affordable housing and the cleanup of brownfield lands and/or buildings. Local official plans should designate, as part of an appendix or map, Community Improvement Project Areas to identify areas to which Community Improvement Plan policies apply. Opportunities for intensification and redevelopment will be promoted in these areas. Local official plans shall contain policies related to parkland or cash-in-lieu of parkland, the use of alternative requirements to the provision of lands for park or other public recreational purposes and may include, where the land is proposed for redevelopment, policies permitting a reduction to payments required for cash-in-lieu.
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