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No Cheating! :P
Most Helpful Guy
😂😂😂 the letter 'E' I presume11|00|0
However according to element physics.. The answer can be 'Higgs-Boson partical too..
I an beginning of end.. = we exist In a state of matter. And end to our elemental existence will mean us converting into energy...
If you decide to convert matter into energy.. The last state in which matter will exist.. Will be Higgs-Boson...
... And the end of space and time... = well space means anywhere where energy and matter exist.. End of space yeah.. If Higgs-Boson doesn't exist they won't define energy or matter. Hence it will be end of space.. Such portion in universe are known as dark matter regions..
Time is defined and measured by the speed of light.. Remove the Higgs-Boson and fucking light won't travel.. If light stopped traveling there is no fucking time.. We have an eternity if pause.
- Show AllShow Less
Nope curious about personal info.. Last time I chatted with you someone was shouting you are a celebrity..
Lol what 😂 I wish ahah


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This post is also available in: French
The R&D team is working on a new version of centreon DSM module. This new version of Centreon "Dynamic Service Management" module will be provided with a new daemon which will be able to enhance the load handling generated by a big alarms flow. This daemon allows you to better manage asynchronous returns. Exit the cron tasks, this daemon can better reprocess alarms in waiting status stored into the cache system of DSM.
As a reminder, Centreon DSM manages SNMP trap in time-stamped way. Initially, it is an event box which manages alerts from schedulers ($Univers, ControlM, VTOM), applications, logs or network equipments. You can redirect alerts sent by SNMP traps in slots (in Nagios meaning, passive services) and thus you can display them into the Centreon monitoring dashboard. Unlike the basic operating of Centreon trap system, services status are never overwritten by other alerts. Alerts are auto-fulfilled when DSM receives a callback trap in order to free the slot used by the alarm.
If the slot gets freed by the callback trap or monitoring operator, the alert stays visible in the monitoring dashboard. You never miss an alert with this operating.
The official documentation of Centreon DSM will be available soon on the documentation website and a beta version will be available on the Centreon forge for all those who want to test this new version.

subset: commoncrawl


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Author | Jagadeesh Krishnamurthy | Wednesday, Dec 06,2006 8:34 AM
Diageo, the group behind brands like Johnnie Walker and Smirnoff, has tied up with the Royal Western India Turf Club (RWITC) for the Johnnie Walker Race Day on December 24. With this event, the brand is trying to create more awareness among its target group.
Elaborating on the brand's marketing strategy, Asif Adil, MD, Diageo India, said, "Johnnie Walker is a well-recognised brand all over the world and people identify with it. We are promoting this brand through various associations with events like the One Tree Jazz Festival, Johnnie Walker Golf Classic and we are also looking at sponsoring the Cricket World Cup next year."
Adil further said that the prevalent restrictions on liquor promotion were appropriate to some extent.
Speaking on the Johnnie Walker Race Day, Adil said, "The marriage of Johnnie Walker and racing is ideal as both are thorough-bred. The event will be promoted across various mediums like billboards, radio, direct mail as well as print."
The brand is also inviting consumers from select bars in the city to attend the event where they will get an opportunity to participate in a contest run by the brand. The winner of this contest will get to take home a Bayliner Speed Boat.
The company is also showcasing the Mclaren MP4 21 Racing Car at the event, after which it will travel to Delhi as part of the brand's promotional strategy.
Programming HeadRadio Mango


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Question: According to Money the average amount of money that a
According to Money, the average amount of money that a typical person in the United States would need to make him or her feel rich is $1.5 million. A researcher wants to test this claim. A random sample of 100 people in the United States reveals that their mean "amount to feel rich" is $2.3 million and the standard deviation is $0.5 million. Conduct the test.
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View Solution:
Answer to relevant QuestionsThe U.S. Department of Commerce estimates that 17% of all automobiles on the road in the United States at a certain time are made in Japan. An organization that wants to limit imports believes that the proportion of Japanese ...Certain eggs are stated to have reduced cholesterol content, with an average of only 2.5% cholesterol. A concerned health group wants to test whether the claim is true. The group believes that more cholesterol may be found, ...According to the New York Times, the Martha Stewart Living Omni media Company concentrates mostly on food. An analyst wants to disprove a claim that 60% of the company's public statements have been related to food products ...Before a beach is declared safe for swimming, a test of the bacteria count in the water is conducted with the null and alternative hypotheses formulated as H0: Bacteria count is less than or equal to the specified upper ...According to an article in the New York Times, new Internet dating Web sites use sex to advertise their services. One such site, True.com, reportedly received an average of 3.8 million visitors per month. Suppose that you ...
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Rehoming a dog – or giving your pet away – is incredibly intense and sad. You'll find no judgment here, only understanding and compassion. I know how you feel; I had to rehome my dog a few years ago, and the decision was agonizing. Here's how to deal with the guilt and grief you feel now and that you may always feel.
First, want some good news? Your dog is a survivor! Your dog is lovable and adaptable, and will adjust to his new home so quickly that you'll feel insulted. Here's how I know: several months after we rehomed our big black Lab German Shepherd cross, we adopted a little white toy Poodle Bichon cross. Her name is Tiffy and she was three years old when we adopted her. Her previous owner was devastated that she had to give her beloved little dog away, and I was happy/sad to tell her that Tiffy happily made our home her home within three days. Dogs are survivors, they live in the moment, and they adjust so quickly it makes your head spin. So, while you're reading through my tips on how to deal with the guilt and grief of rehoming a dog, remember that your dog is probably curled up in front of the fireplace or happily playing with other dogs in the dog park at this very moment.
One of my most popular articles about dogs is How to Decide if You Should Give Your Dog Away. I wrote it because I had to rehome a dog called Jazz – she was a 77 pound black Lab German Shepherd cross. Since then, I adopted two new dogs: Tiffy (the wee white one in the picture) and Georgie (a the black and white terrier you'll meet later).
So, I already gave you the good news: rehomed and adopted dogs adjust quickly to their new environments. Dogs adapt because they live in the moment, and they're survivors. Rehoming a dog is more painful for dog owners than the dogs themselves – though I have no doubt that our dogs miss us! I just don't think they dwell on their loss, and they definitely don't have to learn how to deal with their adoption.
The bad news is that the pain, guilt, and grief you feel about rehoming your dog won't easily go away. The truth is that even though I may sound like I had no problem giving my dog Jazz away, I still feel terrible whenever I think about that day. We took our dog back to the SPCA, and both my husband and I wept like our hearts were breaking. Because our hearts were breaking.
The other bit of bad news is that the grief and guilt of giving a dog away doesn't just disappear – even after you read my tips on how to deal with this type of pet loss.
5 Ways to Deal With Rehoming a Dog
If you're overwhelmed with guilt, you may find How to Deal With Guilt After the Loss of Your Beloved Dog helpful. Pay particular attention to the readers' comments, because you'll see that you are not alone. Our dogs are so important to us and we love them so much…and causing them any pain is incredibly difficult for us to resolve. Rehoming a dog is traumatic, and I want you to be gentle with yourself.
1. Write a letter to the dog you gave away
Take time to say goodbye to your dog. Allow yourself to grieve your loss and work through the guilt you feel about adopting your dog to a new home. Face those ugly feelings of shame and guilt – don't push them down, or they will overwhelm you in the future. You need to process the pain of giving a dog away, or it will eat you alive.
One of the best tips on how to deal with rehoming a dog is to write him a letter. Tell him how much you love him, how sorry you are, and why you did it. Weep. Put your head on the paper and bawl like a little kid. Tell your dog exactly how you feel.
Read through the comments below – you'll find several letters written by dog guardians who had to give their dogs away. You can write your letter here in the comments section, or in your own journal.
Wherever you write it and however long it is, be honest with your dog. Just let yourself be a kid talking to his dog.
2. Read the letter my adopted dog Tiffy wrote to her previous owner
Below, I share a letter my newly-adopted dog Tiffy wrote to her previous owner. Learning how quickly and solidly she adapted to my home might help you see that rehoming a dog can have a very happy ending. You might also begin to understand how incredibly adaptable and resilient our dogs are.
Dear Old Ma,
I miss you, but I am very happy and glad to be in my new home! I get lots of love and attention here. My new Mama and Papa don't have human kids to take care of, so I get all their attention. I have a Big Sister called Georgie, who is a dog like me. She's bigger, but not nearly as smart as me. But she is showing me how to run and jump and play.
You should see me now – I'm so fast, racing through the forest like a speeding bullet! I run and sniff and get to follow all sorts of exciting new paths that take me on fun adventures. I chase squirrels and raccoons and birds – but they're too fast for me. I don't care, I just am so happy to run around after them. I feel big and brave in my new home, and when I bark I am even bigger and braver!
I've met all my Big Sister's friends – she has so many friends, and they all fell in love with me as soon as they saw me. They're called Nico, Shore, Benji, Hunter, Ivy, Bumpy, Senna, Kyla, Ruff, Diablo, and Smokey. See how many new friends I have? They think I'm cute, and the big ones finally stopped stepping on me (it took them awhile to remember how itty bitty I am).
My Big Sister Georgie taught me how to work the thing called "Kong" that gives us yummy treats. Did you know I get homemade chicken soup every day, for breakfast and dinner? And most nights I watch Papa Bear cook steaks or chicken or pork chops on the bbq. Sometimes he drops pieces of meat, and they are more delicious than anything I ever tasted.
Mama Bear always makes sure I have real chicken and crunchy bits to eat with my chicken soup meals. I love it so much, I lick the bowl clean every meal! Sometimes I chew on soup bones, because Mama and Papa say it's good for my teeth. I don't know anything about that – I just love the way the bones taste!
Even though I am very happy dog in my new home, I remember you in my dreams. I have a special place in my heart for you, and when I dream of where I was before I came here, I remember how good it felt to be held and hugged and kissed by you. You will always be in my heart and soul, and I will always love you.
3. Know that your decision to rehome a dog has brought happiness to another family
Last night, the person who gave my dog Tiffy to me emailed to say thank you for adopting her. She had to rehome Tiffy because she just couldn't take care of her anymore. I am so grateful she gave her dog away! And she is so grateful that I was able to adopt her dog and love her fully and completely.
If you feel like you can't deal with rehoming your dog, take heart. Know that your dog will adapt – and perhaps even be happier with his or her new family. After giving your dog away, you have to believe that the next home will be the right place for him or her. Otherwise, you'll just keep spinning your wheels in the thick muck of guilt. Believe that your dog and his new guardians are very happy together.
Are you dealing with overwhelming sadness or depression? It's possible that you haven't dealt with past grief and trauma. Read How to Recover From Loss and Survive Grief.
4. Be gentle with yourself as you deal with the grief of pet loss
Are you beating yourself up for giving your dog away? I sure did, for the longest time. I regretted our decision, and wished I hadn't rehomed our dog Jazz.
But regret and guilt got me nowhere. If I kept ruminating on my pain and condeming myself for taking our dog back to the SPCA, I wouldn't have found the strength to write this article. Maybe I had to experience the pain of rehoming a dog so I could help you learn how to deal with pet loss. Maybe we really are all just walking each other home, through the dark shadowy wintery late afternoons of our lives.
You made the right decision. You had to give your dog away for reasons that make sense to you.
5. Learn how others dealt with the pain and grief of pet loss
I wrote How to Heal Your Heart After Losing a Pet: 75 Ways to Cope With Grief and Guilt When Your Dog or Cat Dies to help pet lovers deal with death.
Yes, you are coping with grief after losing a pet – even though you made the painful decision to rehome oyur dog. Dealing with the guilt and grief after rehoming a dog is perhaps even more intense than coping with heartache after a losing a pet to death. Why? Because we had more choice in the matter. Most of our pets' deaths are natural and caused by old age or ill health. The feelings of loss, shame, and guilt caused by rehoming a dog can be traumatic.
Give yourself time and permission to grieve. Rehoming a dog is a painful experience, and you need to allow yourself to process your emotions in healthy ways.
I hope this article has helped you think differently about giving away your dog, and maybe even eased the pain a little bit. Your thoughts are welcome below, but I can't offer you advice on rehoming a dog. I do understand how you feel, though, and I send you warmth, compassion, and loving kindness.
My prayer is that you heal from the pain and grief of giving your dog away. May you find freedom and self-forgiveness, and peace knowing that you made the right decision. Woof.
One last tip on how to cope with rehoming a dog, from a surprising source (who wasn't talking about how to deal with pet loss, but it fits so well):
"You can't connect the dots looking forward; you can only connect them looking backwards. So you have to trust that the dots will somehow connect in your future. You have to trust in something – your gut, destiny, life, karma, whatever. This approach has never let me down, and it has made all the difference in my life." – Steve Jobs.
Trust that giving your dog away was the right thing to do. Have faith that your dog is being well taken care of, and that your souls will meet again one day.
Need your spirits lifted?
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Posts Tagged 'kawasaki ninja price in india'
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Cuisinart SmartPower 15 Piece Compact Portable Blending/Chopping System CPB 300W / CPB 300 / CPB 300PK Reviews
- Other Blenders:
- Average: 4.4
- High: 5.0
- Type:
- Countertop Blenders
- Brand:
- Cuisinart
- Models:
Meet the Cuisinart SmartPower Compact Portable Blender - the compact powerhouse that does it all! Use the streamline blending cup to make smoothies in a flash! Mince herbs in the chopper cup and whip up custom drinks right in the "To-Go" cups - we've included four of them so everyone can have their favorite! Designed of fit anywhere, the Compact Portable Blender delivers big blender performance with a 350 watt motor and the ease of a single hand operation with the user friendly electronic key pad! Stainless steel accents create an attractive, fashionable addition to any kitchen. New BPA free Tritan from Eastman co-polyestor is used for all the vessels - blender, chopper and your "To-Go" cups. They are all shatter resistant and dishwasher safe. A real timer saver, clean up and maintenance become simple chores.


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Two are dead after a murder-suicide Thursday afternoon involving a husband and wife at FPL Food, 1301 New Savannah Road.
According to Richmond County sheriff's Sgt. Dan Carrier, an FPL Foods employee, identified as Emanuel Jordan, 21, fired several shots outside the security gates at the business about 1:15 p.m.
Jordan, who worked at the facility, killed his wife, Tia Jordan, 40, then turned the gun on himself, according to Chief Deputy Coroner Mark Bowen.
Tia Jordan was not employed atFPL, according to a FPL Foodstatement.
"We are shocked and horrified by this terrible tragedy. We have provided and will continue to provide grief counseling to our employees. Our thoughts, prayers and deepest sympathies go out to the families of the victims," the statement said.
FPL Food is working with law enforcement, the statement said.
Authorities continue to investigate the deaths and have not released information on a possible motive. An autopsy is scheduled Friday.
Jordan has previous Richmond County charges of family violence, simple battery and theft by receiving stolen property from 2008 and a charge of possession of cocaine from 2009, according to law enforcement.
Tia Jordan's death was the first homicide of 2012 in Richmond County.
According to its Web site, FPL Food "is the largest privately held beef provider in the Southeast."


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Notary Services
DFW MOBILE NOTARY (DFW) Hello, I am a State of Texas Licensed Notary Public and Member of the National Notary Association. Insured, Bonded and Commissioned Please visit the website at dfwmobilenotary.net Notary ID Number-12927225-9 We notarize all types of legal documents / Notarizamos todos documentos legals We're open from Monday thru Sunday Even on Sunday & Holidays: I can meet you in a safe, public place or come to you for an additional small mileage fee. Cash Only -$40 Flat Fee-Doesn't Matter How Much Paper Work An extra travel fee will be added to cities/places outside of the DFW area.


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Find schools that offer these popular programs
- Computer Engineering Technologies, General
- Computer Hardware
- Computer Systems
- Software Engineering
School Overviews
Three top schools that offer programs in computer engineering include the renowned Massachusetts Institute of Technology (MIT), Carnegie Mellon University and the University of California in Berkeley. All three schools have consistently received high rankings from U.S. News & World Report for the quality of their computer science and engineering programs.
1. Massachusetts Institute of Technology (MIT) in Cambridge, MA
|School Highlight: According to U.S. News & World Report, MIT placed 1st among computer science and engineering schools in 2015.
The Department of Electrical Engineering and Computer Science offers both undergraduate and graduate programs in computer science and engineering, including an interdisciplinary Bachelor of Science (B.S.) in Computer Science and Molecular Biology. Graduate programs offered include, Master of Science (SM), Master of Engineering (MEng), Electrical Engineer (EE)/Engineer in Computer Science (ECS) and Doctor of Philosophy (PhD)/Doctor of Science (ScD). MIT reserves the MEng program for graduates of their Electrical Engineering and Computer Science school. Most programs emphasize experimentation and analysis through laboratories and research.
2. Carnegie Mellon University in Pittsburgh, PA
|School Highlight: Carnegie Mellon University is a private research institution that U.S. News & World Report ranked 3rd among computer engineering schools in 2015.
The Department of Electrical and Computer Engineering offers programs at both the undergraduate and graduate levels. The undergraduate program offers 8 options for minor study including robotics, machine learning, language technologies, computational biology, software engineering, human-computer interaction, neural computation and computer science. Undergraduate students may also choose to accelerate their studies by choosing the 5th year masters program. Computer engineering majors can also take advantage of Carnegie Mellon's research institutes and centers, such as the Center for Advanced Process Decision-Making and the Data Storage Systems Center.
3. University of California - Berkeley
|School Highlight: The University of California in Berkeley (UC - Berkeley) offers computer engineering programs ranked 4th in the country by U.S. News & World Report.
Undergraduates can earn a Bachelor of Electrical and Computer Engineering (ECE) or a Bachelor of Computer Science and Engineering (CSE). The focus of the ECE degree is electrical engineering in upper level coursework, while CSE degree coursework focuses on computer science in higher courses. Either program may be offered as either a Bachelor of Science or a Bachelor of Art depending on the coursework the student chooses to take. At the graduate level students may choose from the professional Master of Engineering (M.Eng.) in Electrical Engineering & Computer Sciences degree, the online Master of Advanced Study in Integrated Circuits (MAS-IC) or the Master of Science (M.S.) which prepares students to pursue a doctoral degree. Students who choose to pursue a doctoral degree may choose a Ph.D. in Engineering - EECC or a Ph.D. in Computer Science.
Top Schools with Computer Engineering Programs
|School Name
|University of Texas at Austin
|Ongoing research on software engineering and systems
|Austin, TX
|Purdue University - West Lafayette
|One of the largest computer engineering departments in the nation
|West Lafayette, IN
|University of Southern California
|Areas of ongoing research include artificial intelligence, information management and computational neuroscience
|Los Angeles, CA
|Cornell University
|Students can take courses from the Johnson Graduate School of Management
|Ithaca, NY
|Georgia Institute of Technology
|Faculty includes 40 Institute of Electrical and Electronic Engineers (IEEE) fellows
|Atlanta, GA
|Stanford University
|Ranked number 2 for computer engineering programs by U.S. News & World Report in 2015
|Stanford, CA
|California Institute of Technology
|Closely collaborates with numerous research centers to examine various areas of computer science and engineering
|Pasadena, CA


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A book review by Dr. John Psarouthakis, Executive Editor of www.BusinessThinker.com
I wish I had read this excellent book, "The LEAN CEO" by Jacob Stoller, when I was looking for and acquired over 20 medium size manufacturing companies, it would have made our efforts easier.
Way back in the 1970's and 1980's I was involved in acquiring manufacturing companies. I observed that many, well over 50% of the, companies we looked at were poorly performing. On further look we concluded that it was due to bad management. Never mind about the concept of Lean management, it did not exist, the mentality and approach was totally to the contrary. It reminded me of what we say about an augmented government and related costs.
In 1978 I decided to step out and start a corporation that would acquire underperforming manufacturing companies and make them profitable by streamlining (Lean) management and systems, bring on board relevant technology, train our employees in the plants and /or the near by community colleges, and so on.


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This Science On a Sphere (SOS) module is designed to help the public better understand the story of water on Mars and how we're learning more about it. It portrays the mystery of what happened to the water on Mars in the context of a detective... (View More) story. NASA's MAVEN mission (Mars Atmosphere and Volatile EvolutoN) will help solve this mystery by studying the Martian atmosphere, how it has changed over time, and how it interacts with the Sun and the solar wind. The module also delves into Mars exploration, featuring past, present, and future Mars missions, and includes an activity comparing images of water-related features on Earth and Mars. It will help people understand that a planet's climate can change over time and how learning more about Mars helps us learn more about Earth and other planets as well. Resources included are: script, SOS playlist and datasets, background and tips for the docent or facilitator, and image comparisons of water-related features on Earth and Mars. (View Less)
This lithograph shows an image of Mars on the front, with informational text on the back about how the Hubble Space Telescope (HST) has been used to study Mars weather. HST took this image on March 30, 1997, just as it was making a close pass to... (View More) Earth some 60 million miles (100 million km) away. It shows Mars during the transition between spring and summer in the northern hemisphere (summer solstice). The north polar carbon dioxide (dry ice) frost cap is rapidly evaporating from solid to gas, revealing a much smaller permanent water ice cap. Bright water ice clouds are visible across the center and along the bottom of the image. (View Less)
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From Mad World News
After a little girl had escaped being repeatedly raped by a group of Muslims, she thought she had finally gained relief from the horrific abuse. However, when she awoke to the sound of her rapists approaching, she knew there was only one way to make them stop forever.
As the Islamic State (ISIS/Daesh) ravages its way through the Middle East, thousands of women and children are taken as sex slaves, as instructed by verses in the Quran and the Islamic Prophet Muhammad's own behavior. Many are forced to endure the most heinous sexual abuse and physical torture, but for the few who manage to escape, that nightmare still remains.
According to NDTV, Jan Ilhan Kizilhan, a German doctor attending to refugees from Iraq, relayed horror stories of some of the escaped ISIS slaves he's assisted. As young as 8, the girls have suffered deep physical and psychological trauma, sometimes so severe that they feel there's no way out but to end it themselves.
Kizilhan spoke of a Yezidi girl who had only recently escaped her ISIS rapists. The girl was repeatedly sold, raped, and tortured by her jihadist owners. It wasn't until she was safe in a refugee camp that she realized there was only one way to make sure she'd never be a sex slave again.
One night, while she was sleeping in her tent, she thought she heard ISIS insurgents outside. Fearing that they were coming to recapture her, she poured gasoline all over her body and lit a match. She had hoped to mutilate herself so horrendously that no ISIS fighter would ever want to rape her again.
Christian Post reports that girl suffered horrific burns over 80 percent of her body in an effort to make herself unattractive to Muslim fighters.
"She had no nose, no ears left," the doctor said. "Over the last year, I have documented more than 20 cases of suicide, but this is surely just the tip of the iceberg," he said, adding the actual number was likely closer to 150.
Kizilhan revealed that most of the girls are between 16 and 20, but some as young as 8 and as old as 40 are taken as sex slaves.
"They have been through hell," Kizilhan explained, according to Gulf News. "It is really an urgent situation."
Unlike the women and children Kizilhan has helped, many ISIS sex slaves are not as fortunate. Mad World News previously reported that a girl attempted to escape her captor, only to be caught and brought before the rest of the slaves as an example of what would happen if they did the same.
"Another girl who tried to escaped had her legs cut off," an escaped Yezidi named Suzan said. "I do not understand why I escaped. I have nothing left. I wish they had killed me instead. What do I have to live for? I try to forget everything, but when I close my eyes, I see them before me and I want to kill myself."
Another captive was only 7 when she found out her kidnapper's purpose for her. After being separated from her family, the Yezidi child was to be groomed and educated for one year in preparation for the Muslim man who would take her as his bride.
"The families who give up their children to ISIL [ISIS] are enticed with money – $1400 per month per child. It's a considerable sum for those families; the people have been starving ever since ISIL seized control of the two cities. On the other hand, if the parents refuse to hand over their child, they could be executed," a source said.


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The election for married couples to elect portability of the Federal Estate Tax Exemption was introduced in late 2010 when the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act ("TRUIRJCA") was signed...more
Starting July 1, 2017, taxpayers that request an "Offer in Compromise with respect to doubtful collectability under Sec. 58.1-15, a Ruling Letter from the Commissioner under Sec. 58.1-203, a local tax advisory opinion under...more
The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its "no-rule" list since 2013. In a...more
The Internal Revenue Service (IRS) issued regulations last October (the 2016 Regulations) that significantly alter the landscape of allocations of partnership liabilities and the disguised sale rules. The 2016 Regulations...more
On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the "Ruling"), which helpfully clarifies that the separate steps of a typical "north-south" spinoff transaction will be respected, and announced...more
The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation's transfer of stock or securities of a controlled corporation (or "Spinco") in...more
Editor's Note -
In This Issue. The Senate confirmed Jay Clayton as the new chairman of the U.S. Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC) released its final handbook for...more
In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more
Not only is strict adherence to the structure set out in prior favorable rulings best, it is essential when it comes to obtaining a favorable ING ruling. The provisions in the trust document need to carve a very fine line...more
At a recent Federal Bar Association Tax Law Conference, an IRS Chief Counsel branch chief advised that due to budget cuts:
a. The IRS has temporarily suspended issuing private letter rulings regarding modifications to...more
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February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts -
The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
In Private Letter Rulings 201702005 and 201702006, the IRS favorably ruled on federal tax consequences of a proposed trust division. But for a minor change in facts, the two rulings are identical, so we will focus only on...more
With the holidays upon us, we all can relate to how easy it is to mistakenly overlook important things amidst the cheery holiday hustle and bustle: leaving the Christmas ham in the oven a few hours too long, forgetting to...more
A new private ruling may be of great interest to clients with substantial real estate interests who wish to contribute one or more properties to a family foundation. The ruling suggests that payment by the foundation to a...more
The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the "Proposed Regulations"), and a Revenue Procedure that address the treatment to regulated investment companies ("RICs")...more
Generally, an amount distributed from a qualified retirement plan (including an employer-sponsored plan and an IRA) is excluded from income if it is transferred to another plan within 60 days following receipt. In the past,...more
October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts -
The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more
On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more
Editor's Note -
Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more
The Internal Revenue Service (the "IRS") has announced plans to update Revenue Ruling 67-390, which requires an organization to "re-apply" for tax-exemption if it changes its corporate structure, including in situations...more
The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more
On August 31, 2016, the Treasury Department published final regulations (the "Final Regulations") clarifying the definition of "real property" under the real estate investment trust ("REIT") rules. The Final Regulations...more
Generally, distributions from a qualified retirement plan that are eligible for rollover must be rolled over within 60 days of the date on which the distribution occurs. If a taxpayer did not complete the rollover within 60...more
Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules.
On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more
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JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.
JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.
The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.
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Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.
In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.
This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.
We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.
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