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Asset Management
Tax Highlights –
Asia Pacific
January to March 2015
In this edition's asset management tax highlights for the
Asia Pacific region, we highlight industry developments
from Australia, China, Hong Kong, India, Korea, Malaysia,
and Singapore, which may impact your asset management
business. We hope you find these updates of interest, and will
be pleased to discuss these developments and issues with you
The Australian Treasury has released draft
legislation for the final element of the
Investment Manager Regime (IMR) on 12
March 2015. The IMR measures are aimed
at removing tax uncertainty that has been
a disincentive for foreign funds to invest in
Australia. The IMR is accessed under two
alternative measures, where a foreign
fund invests in certain Australian
1. Directly (Direct Concession); or
2. Indirectly via an "Independent
Australian Fund Manager" (Indirect
Where the concession applies, broadly,
returns, gains and losses from the disposal
of certain Australian assets (excluding
"land-rich" investments) are disregarded
(or treated as non-assessable non-exempt)
for tax purposes.
Direct concession
For a foreign fund to access the Direct
Concession, it must satisfy the following
• It is a foreign resident at all relevant
• It does not carry on a trading business or
control a trading business
• It satisfies the widely held test
• The asset (IMR financial arrangement)
must be a portfolio interest (i.e. less than
10% interest); and
• The returns, gains or losses must not be
attributable to an Australian permanent
establishment of the foreign fund.
Broadly, a foreign fund is widely held if:
• It has wide membership (i.e. no member
holds a participation interest of 20% or
more, or five or fewer members do not have
a combined participation interest of at least
50%). There is also a start-up concession
which allows foreign funds up to 18
months to satisfy the widely held rules;
• Or, it is a specified widely held entity (e.g.
foreign life company, Government pension
funds etc).
2 Asset Management Tax Highlights – Asia Pacific
Indirect Concession
For a foreign fund to access the Indirect Concession, it must
satisfy the following requirements:
• It is a foreign resident at all relevant times
• It does not carry on a trading business or control a trading
• The IMR financial arrangement is made on its behalf by an
independent Australian fund manager, and
• The direct participation interests held by the foreign fund or
associates in a resident issuer of, or counterparty to, the
financial arrangement are less than 10%.
An independent Australian fund manager is defined as an entity
which is:
• An Australian resident
• Carries on investment management activities in the ordinary
course of its business
• Receives arm's length remuneration for carrying out the
activities, and
• One of these:
–– The foreign fund receiving the services is widely held, or
–– 70% or less of the fund manager's income is income received
from the foreign fund (or connected entities); or
––Where the fund manager has been carrying out investment
management activities for 18 months or less, it is taking all
reasonable steps to ensure it meets the 70% threshold
described above.
If the Australian fund manager (or its connected entities) derive
profits from the foreign fund exceeding 20%, and the
requirements of the Direct Concession are not met, the concession
is reduced by that percentage. However, the foreign fund can
lodge an application to the Commissioner such that this outcome
does not arise in certain circumstances (i.e. it is intended that the
requirements will be met within five years with the intention that
the investment in the foreign fund is being actively marketed).
This final element of the IMR is proposed to apply from 1 July
2015 with certain transitional provisions for prior income years.
For further details, please refer to http://www.pwchk.com/
Draft legislation for the Managed Investment
Trust Regime
On 9 April 2015, the Australian Treasury released draft
legislation in respect of the new tax system for Managed
Investment Trusts (MITs). The new MIT Regime is designed to
provide greater tax certainty for MITs and their investors, and
enhance the competitiveness of Australia's funds management
industry. An MIT qualifies under the MIT Regime if it meets the
requirements to be an attribution MIT (AMIT), which is broadly a
MIT where members have clearly defined interests.
The key features of the MIT Regime include the following:
• Under the attribution model, the AMIT attributes trust
components to members.
• The treatment of "unders" and "overs" (i.e. differences between
distributed trust components and actual components per the
income tax return) has been codified. Generally, unders and
overs can be carried forward and offset against trust
components in the following year rather than requiring a
reissuing of investor tax statements. However, an "uplift"
(representing the time value of money) and penalties may arise
if certain safe harbour thresholds are exceeded, and depending
on the level of culpability of the trustee.
• AMITs are deemed to have a fixed trust status for income tax
• There may be upward cost base adjustments to members'
interests in the AMIT where attribution amounts exceed the
amount distributed in order to prevent double taxation.
• A multi-class AMIT has the option to recognise each class as if
it was a separate AMIT.
• There are detailed and complex withholding tax changes
aimed at ensuring withholding applies to "attributed" amounts
rather than the amount distributed.
• The treatment of tax deferred distributions in the hands of
members has been clarified.
• As an integrity measure, where the AMIT derives non-arm's
length income, the trustee is subject to tax at the highest
marginal tax rate (plus applicable levies) on the excess over an
arm's length amount less certain deductions (if any).
The draft legislation indicates a general start date of 1 July 2015,
however, it is understood that the Government intends to defer
the start date to 1 July 2016, with an optional start date of 1 July
The Australian Taxation Office provides
guidance on foreign currency hedging
The Australian Taxation Office released Taxation Ruling TR
2014/7 dealing with foreign currency (FX) hedging transactions
entered into as part of a FX currency overlay or portfolio hedge.
The Ruling sets out the Commissioner's views on:
1. Determining the source of foreign currency hedging gains; and
2. The allocation of foreign currency hedging losses against
foreign income for the purposes of the foreign income tax offset
(FITO) rules.
Whilst the Ruling applies to the calculation of the FITO limit (i.e.
cap on the amount of foreign tax credits that can be claimed), the
Ruling also has implications for Australian funds in determining
the ability to pass FITOs through to investors, and for
determining the components of trust distributions.
The latest draft legislation is a significant improvement from
previous versions, and more closely aligns the IMR with the
Government's policy objectives. However, foreign funds will
still need to closely consider whether they fall within the
rules, as not all funds will qualify.
MITs will need to assess the impact of becoming an AMIT and
whether early adoption is beneficial. In addition, the new
regime is expected to require changes to operations
(including systems, processes and governance), service
arrangements, investor reporting and product development.
Asset Management Tax Highlights – Asia Pacific 3
Source of hedging gains
For a FX hedging transaction undertaken in accordance with
normal commercial practice (i.e. under the terms of a standard
ISDA Agreement) the Commissioner's view is that the office
through which the counterparty acts determines the source of the
FX hedging gain. The office through which the counterparty acts
is as follows:
• for a single branch Master ISDA Agreement, the office specified
in the Master ISDA or if none, the counterparty's head office.
• for a multi-branch Master ISDA Agreement, the office identified
in the relevant confirmation. Where it is impractical to track
every confirmation, the Commissioner accepts a reasonable
basis for determining the percentage of confirmations which
are Australian sourced (e.g. a representative percentage over a
3 month period).
Allocation of FX Hedging losses against income
For the purposes of calculating the FITO limit, whether FX
hedging losses are "reasonably related to", and therefore offset
against relevant foreign income/gains, will need to be
The Ruling states that a FX hedging loss will be reasonably
related to a FX hedging gain where the FX hedging transactions
giving rise to the losses and gains are entered into under the
same foreign currency hedging strategy.
If the FX hedging gain is foreign sourced, then a FX hedging loss
under that same hedging strategy will need to be offset against
that foreign income. If the FX gain is Australian sourced, and
there is no foreign income to which it otherwise reasonably
relates, then a FX hedging loss under that same hedging strategy
is to be allocated to Australian sourced income.
In some circumstances, the Commissioner states that FX hedging
losses may need to be apportioned between both foreign and
domestic income. Examples include:
1. where there are both foreign and domestic sourced FX hedging
gains in relation to the same hedging strategy; or
2. where there are domestic sourced FX hedging gains and foreign
capital gains to which the hedge relates.
Reform of Australia's tax system –
Tax Discussion Paper
On 30 March 2015, the Australian Government released a tax
discussion paper "Re: think, Better tax system, better Australia"
(the Discussion Paper), which formally starts the process for
developing the White Paper for Reform of Australia's Tax System
(the White Paper).
The purpose of the Discussion Paper is to generate a dialogue
with the community as to how to create "a better tax system that
delivers taxes that are lower, simpler, fairer". It is part of the
broader process of tax reform to respond to globalisation,
Australia's decline in productivity and the ageing population
(which was a major theme in the recently released
Intergenerational Report).
The Discussion Paper is a comprehensive summary of the current
Australian tax system, and raises a number of questions for
consultation. The broad areas of consideration include: personal
tax, general business tax, small business, indirect taxes, local
taxes, State and Territory taxes, not-for profit sector, and
governance and administration.
The Discussion Paper identifies a number of key challenges that
the Government faces:
• Australia has a high reliance on income taxes (including
company taxes) than most other comparable countries.
• State and Territory governments rely considerably on taxes
which impose high economic costs (e.g. stamp duties) by
impeding Australia's productivity.
• The tax system is complex with significant resources spent on
tax compliance and tax management activities.
• The interaction between the tax system and the transfer system
can discourage workforce participation.
• Tax on savings is very complex and distorts savings choices. For
example, savings on bank accounts are taxed at full marginal
rates while superannuation may not be taxed at all.
• Tax changes need to be managed carefully as it may negatively
impact long term decisions based on previous arrangements.
In the context of the business tax system in an increasingly
digitised and globalised world, the Discussion Paper identifies a
number of key points:
• Tax is increasingly becoming important in competing for
foreign investment (and noting that Australia's corporate tax
rate is high compared with others in the Asia-Pacific region).
• A more competitive tax environment would encourage higher
levels of investment and increase employment and wages in the
long run.
• Dividend imputation ensures no double taxation but
contributes little to attracting foreign investment into
• Australia's corporate tax system is extremely complex. Certain
distinctions embedded in the tax system create investment
biases and distorts business decisions.
• The research and development incentive and concessional tax
treatment of employee share schemes are two ways that the tax
system supports innovation.
In releasing the Discussion Paper, the Government has taken the
first step in the tax reform process. Submission can be made until
1 June 2015, with a "Green Paper" to be released in the second
half of 2015 outlining tax reform options. The Government will
then release the White Paper outlining its tax reform proposals
which it will take to the next Federal election in late 2016.
As the Ruling applies from 1 July 2014, Australian funds will
need to assess the impact of the treatment of FX hedging gains
and losses prior to year end distributions. In particular, funds
will need to review their ISDA agreements to determine the
location of FX hedging counterparties and consider whether
system changes are required.
4 Asset Management Tax Highlights – Asia Pacific
Second round of consultation on the Asia Region
Funds Passport regime
The Asia Region Funds Passport (ARFP) Working Group
(Australia, Korea, New Zealand, the Philippines, Singapore and
Thailand) released a second Consultation Paper comprising of a
Feedback Statement and draft Memorandum of Understanding
(MOU). The Feedback Statement summarises the views
expressed in earlier submissions and the Working Group's
treatment of those views in developing the draft MOU.
The proposed timetable and milestones are as follows:
The consultation questions focus on specific operational aspects
such as investment restrictions, distribution, performance fees
and suspension of redemptions.
The Feedback Statement indicates broad support for the passport
but amongst other things, also acknowledges that a large number
of submissions urged the Working Group to consider domestic tax
implications and advocated for neutral tax treatment of passport
funds. In addition, each Working Group member agreed to share
to other members, information about their tax and capital control
settings in their respective country to identify potential issues
that could impede the use of the passport.
The Australian Government faces a number of challenges to
bring about substantive changes to the broader tax framework
in Australia given the politically sensitive matters up for
consideration and debate. If reform is managed well, there is
opportunity for significant positive impacts on economic
growth and livings standards, and international
competitiveness. The process has just started and we
anticipate plenty of community engagement during the
consultation period.
The regulatory framework is close to finalisation with certain
refinements being considered in the Consultation Paper.
There is an acknowledgement that tax issues are a critical
piece in ensuring that the ARFP will be successful, and we
expect further developments in this is area.
Timing Milestone
April 2015 Public consultations on Passport MOU annexes
conclude.Working Group continues to engage with
other economies to encourage their participation
May 2015 Working Group considers public submissions
August 2015 Working Group finalises MOU and annexes
September 2015 Willing and ready economies will become party to
the Passport MOU
+ 12 months
from economies
becoming party
to the passport
Economies which are party to the MOU (Passport
member economies) will endeavour to implement
changes to legislation and regulations where
necessary to give effect to the Passport
arrangements within 12 months after becoming
party to the MOU.When at least two economies
give effect to the Passport arrangements, eligible
Collective Investment Schemes in these economies
can access the Passport arrangements.
Asset Management Tax Highlights – Asia Pacific 5
A totally different tax landscape for offshore
indirect transfer upon the release of Public
Notice [2015] No. 7 – wider, clearer and more
In early February 2015, the China State Administration of
Taxation (SAT) released Public Notice [2015] No. 7 (Public
Notice 7) to supplement the current Chinese tax rules in
relation to offshore indirect equity transfer. Public Notice 7
introduces a new tax regime, which is significantly different
from that under Guoshuihan [2009] No. 698 (Circular 698)
issued by the SAT in 2009. Firstly, it widens the China tax net
to capture not only offshore indirect equity transfer
transactions addressed under Circular 698, but also
transactions involving transfer of immovable property in
China, and assets held under the establishment and place
(E&P) in China of a foreign company through the offshore
transfer of a foreign intermediate holding company. Public
Notice 7 also broadens the term 'transfer of the equity interest
in a foreign intermediate holding company' to cover any
changes in the shareholder of that foreign company being
transferred in the course of the group's overseas
restructurings. In addition, compared to Circular 698, Public
Notice 7 provides clearer criteria on how to assess 'reasonable
commercial purposes' and introduces 'safe harbour' scenarios.
However, it also brings challenges to both the foreign
transferor and transferee in the offshore indirect transfer
transaction as they have to make a self-assessment on whether
the transaction should be subject to China Corporate Income
Tax (CIT) and to file or withhold the CIT accordingly.
It is worth noting that Public Notice 7 clearly states that the
payer of the sales consideration (which is usually the
transferee) should withhold CIT in an offshore indirect equity
transfer if the transaction is subject to CIT. Failure to fulfil the
withholding obligation may trigger a penalty of 50% to 300%
(or three times) the amount of the CIT liability based on the
relevant provisions in Tax Collection and Administration Law
(TCAL). This penalty may be reduced or waived if the
withholding agent has reported the transaction to the Chinese
tax authorities within 30 days of signing the equity transfer
contract. This is the first time the SAT has explicitly stated that
the transferee, including a foreign one, would have such heavy
monetary consequence. Needless to say, this stipulation would
cause the transferee, especially an unrelated party, to be very
cautious about the foreign transferor's China tax position in an
offshore indirect transfer deal.
Public Notice 7 sets a new landscape for tax treatments of
offshore indirect transfer transactions. It imposes more
responsibilities on the transaction parties when assessing and
making their decisions. Both foreign transferors and
transferees should examine carefully the facts and merits of
each transaction and rethink their strategies accordingly.
Despite this, Public Notice 7 still leaves several uncertain but
important issues unanswered, such as how to allocate the
gains attributable to China Taxable Properties in the case of a
regional offshore indirect transfer; the cost base of China
Taxable Properties after a few transfers including direct and
indirect, etc. We are eager for the SAT to release further
clarification on these important issues. Public Notice 7 has
demonstrated the Chinese tax authority's determination to
combat erosion of China's tax base through offshore indirect
In view of Public Notice 7's release, private equity funds should
take the following into account when making investments and
• Consider reasonable commercial purpose when planning
investment structure and business arrangements
• Prepare sufficient documentation to support the reasonable
• Assess China tax implications and make appropriate decisions
on whether to perform the indirect tansfer reporting or not
• Both buying and selling parties of the transaction should
discuss how to handle the tax matters for the transaction and
reach a consensus as early as possible, and
• Communicate with the in-charge China tax authority
throughout the whole process of the transaction.
6 Asset Management Tax Highlights – Asia Pacific
Hong Kong
The Bill extending the profits tax exemption
for offshore funds to PE funds gazetted
The Hong Kong Government published the Inland Revenue
(Amendment) Bill (the Bill) 2015, which extends the current
profits tax exemption for offshore funds to private equity
funds in the Gazette on 20 March 2015. The Bill will be introduced
into the Legislative Council on 25 March 2015.
For further details, please refer to http://www.pwchk.com/
Amendments to the China-HK double tax
arrangement – what it means for the financial
services industry
On 1 April 2015, Hong Kong and Mainland China signed the
Fourth Protocol (the Protocol) to the comprehensive double
tax arrangement between China and Hong Kong (the CDTA).
The most important benefit to Hong Kong taxpayers from the
amendments set out in the Protocol is to provide a tax
exemption in China for gains derived by Hong Kong residents
and "Hong Kong resident funds" (as specifically defined in the
Protocol) from the disposal of shares listed on recognised
Chinese stock exchanges, provided certain conditions are met.
Additionally, the withholding tax rate for rentals from aircraft
leasing (as well as ship chartering) is reduced to 5% from the
current 7%. This News Flash explores these two amendments
in more detail, and its impact to Hong Kong taxpayers in the
financial services industry.
For further details, please refer to http://www.pwchk.com.
Regulatory updates
• On 5 February 2015, the Securities and Exchange Board of
India (SEBI) and the Reserve Bank of India (RBI) each
issued a circular permitting Foreign Portfolio Investors
(FPIs) to invest in coupons in Government securities
investments, or "G-Secs". The circular further stated that
such investments shall be kept outside the applicable limit
(currently USD30 billion) for investments made by FPIs in
government securities.
• On 6 February 2015, the RBI issued a circular in connection
with the policy changes for FPI investment in the debt
market. These are:
I. Investments in all debt instruments will need to comply
with a minimum residual maturity of 3 years. Any
further investment in Commercial Papers will not be
II. Investments in instruments having minimum initial /
residual maturity of 3 years with an exercisable option
within 3 years are not permitted.
III. Investments in amortised debt instruments are
permitted provided the duration of the instrument is 3
years and above.
• On 20 March 2015, the RBI issued guidelines to address
operational issues faced by FPIs by providing an extended
reporting time and T+2 settlement for outright secondary
market trades in G-Secs. In these guidelines, RBI permits
settlements on T+2 basis for outright secondary market
transactions in G-Secs undertaken by FPIs and reported on
the Negotiated Dealing System – Order Matching (NDS OM)
subject to fulfilling certain conditions. The guidelines were
effective from 6 April 2015.
• On 31 March 2015, the RBI issued a circular to increase the
limit for taking currency positions in INR-USD on the
exchange traded currency derivatives market without
underlying securities exposure to USD15 million per
exchange. In addition to this, the aggregate limit in INREURO,
INR -GBP and INR -YEN shall be an amount
equivalent to USD5 million per exchange. Prior to this
circular, FPIs were only able to take currency positions
across all currencies up to USD 10 million or equivalent per
Key decisions from SEBI's board meeting on
22 March 2015
• Approved the SEBI (International Financial Services
Centres) Guidelines, 2015, which had effect from 1 April
• Approved a proposal, prepared in consultation with RBI, to
relax the applicability of certain provisions of the SEBI
(Issue of Capital and Disclosure Requirements) Regulations,
2009 and the SEBI (Substantial Acquisition of Shares and
Takeovers) Regulations, 2011 in cases of conversion of debt
into equity of listed borrower companies in distress by the
lending institutions.
• Approved SEBI (Issue and Listing of Debt Securities by
Municipality) Regulations, 2015 thereby providing a
regulatory framework for issuance and listing of debt
Asset Management Tax Highlights – Asia Pacific 7
securities by Municipalities. These regulations are in line with
the Government of India's guidelines for the issue of tax-free
bonds by Municipalities. Although the regulations have not
been released yet, a concept paper was released by SEBI on 30
December 2014.Relaxed the 20,25 rule for local fund managers
– i.e. removed the rule of having 20 investors with no
individual investor holding more than 25% in the fund.
Instead, domestic fund managers are now allowed to manage
offshore funds belonging to Category I FPIs and appropriately
regulated broad based Category II FPIs. A circular amending
the present regulation will be issued in due course.
Union Budget 2015: Key Policy Announcements
• Doing away with the distinction between different types of
foreign investments in Indian companies, especially FPI and
• Setting up a Public Debt Management Agency in order to bring
it to the same level as the equity market
• Proposing to merge the Forwards Markets Commission with
• The intent to consider concealment of income or evasion of tax
in relation to a foreign asset considered to be a predicate
offence; suitable provisions to be introduced under the
Prevention of Money Laundering Act
Tax updates
• On 26 February 2015 the Central Board of Direct Taxes issued a
circular clarifying that the dividend declared by a foreign
company outside India does not have the effect of transfer of
any underlying assets located in India and the said dividends
would not be deemed to be income accruing or arising in India
by virtue of the provisions of Explanation 5 to section 9 (1) (i)
of the Act, even if the shares derive their value substantially
from assets situated in India.
• The Finance Minister specified in its Union Budget 2015 its
intent for the Budget to lay a roadmap for accelerating growth,
enhancing investment and passing on benefit of the growth
process to the common man, woman, youth and child those,
whose quality of life needs to be improved. Salient points are as
a. General Anti -Avoidance Rules provisions deferred by two
years and are now effective from 1 April 2017.
b. Minimum Alternate Tax provisions will not be applicable
to capital gains income of FPIs.
c. The term substantially clarified in context to indirect
transfer provisions.
d. Sunset clause for provisions relating to the applicability of
5% tax rate for FPIs on income from certain corporate
bonds and G-Secs, extended from 31 May 2015 to 30 June
e. Taxability of income of foreign funds whose fund manager
is located in India has been clarified. Fund management
activities carried out through an eligible fund manager
shall not constitute a business connection in India by the
eligible fund subject to certain conditions.
f. A foreign company to be regarded as a tax resident of
India if its place of effective management is in India at any
time during the year.
g. A person responsible for making payment to a nonresident
is now required to provide information about the
payment to Indian revenue authorities, even if the
payment is not chargeable to tax in India.
h. Increase in surcharge from 10% to 12% for foreign non
corporate tax payers where income exceeds INR10
i. Definition of Global Depository Receipts (GDRs) are
proposed to be amended to include GDRs issued against
shares of listed companies.
j. Interest payable by an Indian branch to its head office or
other offshore branches is taxable in India, and is deemed
to be a separate and an independent person from its head
office or offshore branches for taxation purposes.
k. Tax 'pass-through' status provided for all Category-I and
Category-II of AIFs (Investment funds) governed by SEBI
(AIF) Regulations, 2012. Tax 'pass-through' also extended
to LLPs and body corporates. However, business income is
not eligible for 'pass-through', and is taxable in the hands
of investment funds.
l. Gains arising from the transfer of units during initial
public offering or subsequently upon the listing of units
held in business trust shall be liable to Securities
Transaction Tax and the long-term capital gains shall be
exempt from tax. Short-term capital gains tax will be
taxable at 15% (plus surcharge and education cess). Also,
'pass-through' status for rental income received in relation
to assets directly held by the business trust.
m. Transfer of units (where held as a capital asset) under a
consolidation scheme of a mutual fund not to be regarded
as a taxable 'transfer'.
The budget proposals would be effective once they are passed
by both houses of Parliament and receive Presidential assent.
Please refer to the link for more details: http://www.pwc.in/
• Provisions relating to Advance Pricing Agreements were first
introduced in the Finance Act 2012, with effect from 1 July
2012. However, these provisions did not then include roll back
provisions, which were subsequent brought into the Finance
Act 2014, with effect from 1 October 2014. Please refer to the
link for more details: http://www.pwc.in/assets/pdfs/
• On 31 March 2015, the Central Government notified Income
Computation and Disclosure Standards (ICDS), which would
be applicable to all assessees, following the mercantile system
of accounting, for computing income chargeable to income-tax
under the head "Profit and gains of business or profession" or "
Income from other sources" As against 12 ICDS proposed, 10
are presently notified, covering Accounting Policies, Valuation
of Inventories, Construction Contracts, Revenue Recognition,
Tangible Fixed Assets, Effects of Changes in Foreign Exchange
Rates, Government Grants, Securities, Borrowing Costs,
Provisions Contingent Liabilities and Contingent Assets. The
ICDS will be applicable from FY 2015-16 (AY 2016-17).
8 Asset Management Tax Highlights – Asia Pacific
Additional surtax to facilitate the use of
corporate retained earnings in facility
investment and increases in payroll and
dividend payments
In order to motivate corporations to utilise corporate retained
earnings to fund facility investment, wage increases and dividend
payments, the recently amended Corporate Income Tax
Law (CITL) introduces a 10% additional levy on corporate income
if the use of such earnings falls short of a certain portion
of corporate net income for the concerned year. Major points of
the additional levy under the amended CITL are as follows:
• The additional levy shall apply to companies with net equity
in excess of KRW50 billion (excluding small and midsize
companies) and companies belonging to business groups
subject to restrictions on cross-shareholdings under the Act
on Monopoly Regulation and Fair Trade.
• Regarding the method of charging the additional levy,
companies may elect one of the following methods and
cannot revoke its election for three consecutive years:
1. (taxable income (*note 1) for the year x 80% – the total
amount of investment (*note 2), payroll increases and
dividend payments) x 10%; or
2. (taxable income for the year x 30% – the total amount of
payroll increases and dividend payments) x 10%
The taxable income in (*note 1) shall be adjusted for certain
items. Examples of add-backs to taxable income include
dividends received from subsidiaries, interest income
received on refunds of overpaid national taxes and the
amount of depreciation expenses incurred in facility
investments made in the current year. Examples of
deductions from taxable income include corporate taxes
(excluding this surtax), tax loss carried forwards, statutory
reserve transfers, disallowed donations, etc.
The scope of investment in (*note 2) will include tangible
and intangible fixed assets for business use. Investments
made to build new or additional business buildings ranging
from factories, sales shops, offices, warehouses and head
offices to laboratories and purchase the relevant building
site, machinery and equipment, vehicles, tools, patents,
trademarks, mining rights, and developments costs will be
included in the scope of investment. Where a certain part of
buildings are rented, only the proportion of the gross area
directly used for its own business to the total area of the
rented building shall be deemed as facility investment.
Scope of 'non-traditional' financial services
subject to VAT
Subsequent to the amendment of a series of tax laws on 2
December 2014, the government announced bills to amend
the relevant enforcement decrees of tax laws on 26 December
2014. The government's bills to amend enforcement decrees
were approved and legislated on 3 February 2015.
The VAT law has been amended to include the supply of 'nontraditional'
financial services to the scope of taxable supplies. The
amended Enforcement Decree of the VAT law includes five categories
of affected non-traditional financial services: (i) safe deposit
of securities certificate; (ii) investment advisory; (iii) insurance
actuary and pension actuary; (iv) money trust and discretionary
investment business investing in real estate and non-financial
assets; and (v) real estate trust business limited to management,
disposition and parcel-out administration.
This change will apply the supply contracts made on or after 1 July
Scope of related party to test a controlled
foreign corporation expanded
For the purpose of testing a controlled foreign corporation
(CFC), the scope of related party shall be expanded to related
parties as prescribed in the Law for Coordination of International
Tax Affairs. In other words, related parties where a Korean
national takes control by shareholding or in substance, shall be
added to the scope of related parties and their shareholdings will
be combined with the shareholdings held by the Korean national
in a CFC to test the 10% threshold. Under the Korean CFC rule,
when a Korea national and its related parties own directly or
indirectly at least 10% in a foreign corporation and the foreign
company's average effective income tax rate for the three most
recent consecutive years is 15% or less, the amount of retained
earnings as of the end of each business year of the CFC shall be
deemed to be paid as a dividend to the Korean national and subject
to tax in Korea unless certain exemptions apply.
Asset Management Tax Highlights – Asia Pacific 9
Overview of Malaysian Goods and Services Tax
Malaysian Goods and Services Tax (GST) is a multi-stage tax on
domestic consumption which was implemented on 1 April 2015
to replace the existing sales tax and service tax. GST is charged
on all taxable supplies of goods and services in Malaysia except
those specifically exempted. GST is also charged on importation of
goods and services into Malaysia.
Payment of tax is made in stages by the intermediaries in the production
and distribution process. Although the tax would be paid
throughout the production and distribution chain, only the value
added at each stage is taxed thus avoiding double taxation.
In Malaysia, a person who is registered under the Goods and Services
Tax Act 2014 is known as a "registered person". A registered
person is required to charge GST (output tax) on his taxable supply
of goods and services made to his customers. He is allowed to
claim back any GST incurred on his purchases (input tax) which
are inputs to his business. A person who makes taxable supplies in
excess of RM500,000 is required to register for GST.
Singapore Budget 2015 announcements
"Umbrella" approvals for Singapore fund structures
To encourage fund managers to set up operations in
Singapore, a tax exemption regime for offshore funds was put
in place since the early 1980s. In 2006, the fund tax
exemption regime was extended to approved Singapore
resident funds (the Singapore Resident Fund Scheme, also
referred to as the SRF Scheme) to enhance the appeal of
Singapore and attract more fund managers here. The
Government did not stop there and brought about the
Enhanced-Tier Fund Tax Incentive Scheme (ETF Scheme) in
2009, which was a great enhancement to the SRF Scheme.
Today both the SRF and the ETF schemes co-exist and are
being extensively used by fund managers. However, with the
increased use of Singapore domiciled funds, limitations t the
above schemes became apparent.
For example, a practical difficulty arises when a Singapore
fund acquires investments through the use of Singapore
special purpose vehicles (SPV). The need for such a SPV is
driven by legal and commercial reasons. The limitation of the
ETF and SRF schemes is that whilst the main fund might have
obtained tax exemption under the SRF or ETF scheme, its
wholly owned SPV will not be automatically exempted (it will
continue to be exposed to Singapore tax). In order for the SPV
to qualify for tax exemption, the SPV needs to independently
apply for tax exemption and satisfy an additional layer of
conditions to obtain the ETF or SRF status. This leads to
additional costs and compliance burden.
This budget seeks to address this difficulty. From the reading
of the budget, it seems that SPVs of funds approved under the
ETF scheme can automatically qualify for tax exemption. It is
expected that the conditions that are normally applicable to
ETF applicants may be increased for those funds looking to
avail themselves of the automatic exemption for the SPVs.
However, for the enhanced scheme to be attractive, it is
expected that the conditions will be lighter than having to
apply for tax exemption individually for the SPVs. This
announcement is generally welcomed by the industry.
This enhancement will take effect for applications made from
1 April 2015 and further details are expected to be released by
the Monetary Authority of Singapore (MAS) by May 2015.
Venture Capital Funds
Currently, venture capital funds approved under section 13H
(13H Scheme) of the Income Tax Act (13H Funds) can enjoy
exemption on income derived from approved investments.
Most tax incentive/tax exemption schemes have a review date
to give the policy makers an avenue to review the relevance of
a particular scheme after a period of time. A review date for
exemption under section 13H has now been set at 31 March
2020 to allow the review of this exemption scheme at that
The take up rate of this incentive is not as good as it used to
be. This is primarily due to the fact that many venture capital
funds prefer the SRF and ETF Schemes. All the three schemes
aim to provide tax exemption. However, the 13H Scheme is
more restrictive in terms of the type of income that is exempt,
lays down conditions on the location of the investments and
also comes with a limited life of 10 years.
10 Asset Management Tax Highlights – Asia Pacific
Venture Capital Fund Management Companies
Venture capital fund management companies (FMCs) managing
13H Funds have historically enjoyed tax exemption on
management fee and performance bonus received from 13H
Funds. This exemption was available under the Pioneer Service
incentive and was subject to certain conditions.
As managing venture capital funds is no longer considered a
pioneering activity in Singapore, the tax exemption will no longer
be available to new applicants with effect from 1 April 2015.
Instead, a 5% concessionary tax rate will be accorded to approved
venture capital FMCs managing 13H Funds. The approval period
will be from 1 April 2015 to 31 March 2020.
The allure of applying for the 13H Scheme was that, besides the
exemption of income at the fund level, the FMC could also enjoy
tax exemption on its fee income. The limitations of the 13H
Scheme were considered acceptable to some FMCs who were
keen to get their tax rate on fee income reduced to 0%. With the
increase in the tax rate to 5% on the fee income of the FMC, the
attractiveness of the 13H Scheme would perhaps be less now, but
is nonetheless still considered attractive relative to the normal
tax rate of 17%.
Other developments
Goods and Services tax
Any services provided to the fixed or business establishment of
the fund or an overseas fund manager (OFM) in Singapore is
supposed to attract Goods and Services Tax (GST) at the
standard rate of 7%. There has been some uncertainty on what
constitutes a fixed or business establishment such that GST
should be charged to an overseas fund or an OFM.
There have been recent developments aimed towards providing
certainty to this matter. The Inland Revenue Authority of
Singapore (IRAS) issued the e-tax guide "GST: Guide for the
Fund Management Industry (Second Edition)" on 18 March 2015
(IRAS E-tax guide). In addition, the MAS Circular (Circular No.:
FDD 02/2015) was issued on 24 March 2015 (MAS Circular
To summarise, an overseas fund (other than a trust fund) or an
OFM can be treated as having a business establishment in
Singapore if the fund or OFM wholly relies on a Singapore Fund
Manager to carry on its business. In addition, an overseas fund
will have a fixed establishment in Singapore if it conducts regular
board meetings in Singapore. In such cases, GST would be
applicable on the fees charged to an overseas fund or an OFM for
services provided to them.
Having said that, services to the overseas fund (that has a
business establishment in Singapore due to wholly relying on the
Singapore fund manager) can be treated as zero-rated supplies
a. the overseas fund meets the conditions of the Offshore
Fund Tax Exemption Scheme (section 13CA) or the ETF
Scheme (13X) of the Income Tax Act, as the case may be;
b. the overseas fund does not have any other fixed or
business establishment in Singapore.
In the case of an OFM that relies wholly on a qualifying Singapore
fund manager, the fees charged to the OFM would be zero-rated
provided the OFM des not have any other establishment in
The above rules would apply from 1 April 2015 onwards.
Transfer pricing
On 6 January 2015, the IRAS issued revised transfer
pricing guidelines that require taxpayers to prepare and
keep contemporaneous transfer pricing documentation
except in very limited circumstances. Contemporaneous
refers to documentation and information that taxpayers
have relied upon to determine the transfer price prior to
or at the time of undertaking the transactions. However,
for ease of compliance, the IRAS is willing to accept as
contemporaneous transfer pricing documentation any
documentation prepared no later than the time of filing
the tax return for the financial year in which the
transaction takes place.
The IRAS' position is that the transfer pricing
documentation requirement is effective since 2006 when
the first edition of the transfer pricing guidelines was
issued. Hence, there is no transitional period for
implementation and, at a minimum, the
contemporaneous transfer pricing documentation should
be completed for the financial year 2014 by the tax
return filing date or latest by 30 November 2015.
The date of creation or update of each document should
be stated in the document. The IRAS does not require
taxpayers to submit the transfer pricing documentation
with their tax return. However, taxpayers should keep
their transfer pricing documentation and submit it to the
IRAS within 30 days upon request.
The transfer pricing documentation should be organised
at group level and local entity level. Broadly, the transfer
pricing documentation should contain a description of
the business and the related party transactions, a
functional analysis and a transfer pricing analysis/
Asset Management Tax Highlights – Asia Pacific 11
For more information, please contact the following territory tax partners:
Country Partner Telephone Email address
Australia Ken Woo +61 (2) 8266 2948 firstname.lastname@example.com
China Jeremy Ngai +852 2289 5616 firstname.lastname@example.com
Hong Kong Florence Yip +852 2289 1833 firstname.lastname@example.com
India Gautam Mehra +91 (22) 6689 1155 email@example.com
Indonesia Margie Margaret +62 (21) 5289 0862 firstname.lastname@example.com
Japan Akemi Kitou +81 (3) 5251 2461 email@example.com
Stuart Porter +81 (3) 5251 2944 email@example.com
Korea Kwang-Soo Kim +82 (0) 10 3370 9319 firstname.lastname@example.com
Malaysia Jennifer Chang +60 (3) 2173 1828 firstname.lastname@example.com
New Zealand Darryl Eady +64 (9) 355 8215 email@example.com
Philippines Malou Lim +63 2 845 2728 firstname.lastname@example.com
Singapore Anuj Kagalwala +65 6236 3822 firstname.lastname@example.com
Taiwan Richard Watanabe +886 (0) 2 2729 6666 26704 firstname.lastname@example.com
Thailand Prapasiri Kositthanakorn +66 (2) 344 1228 email@example.com
Vietnam Van Dinh Thi Quynh +84 (4) 3946 2231 firstname.lastname@example.com
This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
© 2015 PricewaterhouseCoopers Limited. All rights reserved. PwC refers to the Hong Kong member firm, and may sometimes refer to the PwC network. Each member
firm is a separate legal entity. HK-20150427-4-C1


text:
It's your wedding day. All eyes are on you. All cameras are on you, including the expensive photographer you paid to follow you around all day.
Suck it in + breath out when the picture is taken + angle your body just right + put your hand on your hips + chin up = slimming picture position.
Come on ladies!!! The only way to look slimmer in a photo is to actually be slimmer! You're not fooling anyone or any camera lenses by following these silly tactics. Come up with your own fitness plan or find a location near you to help you get in shape. Be proactive about your bod by doing a little research and then make it happen. There are different programs around Chicago that give brides an intense program to shave off pounds before you have to slip into that white dress. Check out local gyms to see if they have a Bridal Boot Camp for you to join. Hiring a personal trainer is always an option, as long as you have the funds for it. Because these programs are a bit costly, perhaps you would rather make a couple appointments with a nutritionist and put together a workout program; that way you can always see what your workout has in store for you.
In the end, your family, friends, and most importantly your fiance, don't care if you lose those extra 5 pounds, but maybe you do. You are going to enjoy yourself more if you are happy with yourself. No one likes feeling self conscious in pictures and in front of crowd, which is all happening on your wedding day. You'll feel more energetic, confident, and camera ready if you just make that extra effort. So what are you waiting for?
Stay tuned for more from Big City Bride
Filed under: Weddings

subset: commoncrawl


text:
Cyril Lignac rushed to hospital after a scooter accident
In the night from Saturday to Sunday Cyril Lignac has been the victim of a road accident. The head had to be hospitalized.
Then he walked to the Eiffel Tower on a scooter after a party, Cyril Lignac has been the victim of a road accident , which occurred around 2:30 am in the night from Saturday to Sunday. At the intersection of the Quai d'Orsay and the Invalides bridge in the seventh arrondissement of Paris, the young chef of 39 years was denied priority by a car that failed to prevent .
The most famous leader of the PAF was taken care of immediately by firefighters from the nearest fire station that took him to the Bichat Hospital. Given the violence of the impact, he is doing relatively well since he suffered "only" a fracture of the tibia and left fibula, it should recover easily.
Under the Regulation, Cyril Lignac was submitted, as the motorist who knocked down, to a blood alcohol test. Neither of the two protagonists had exceeded the permissible limits. The investigation by the service of judicial treatment of accidents soon reveal the causes that led to this accident.


text:
Status: Closed
Know more about this business than we do? Cool! Please submit any corrections or missing details you may have.Help us make it right
Be the first MLive.com user to add photos or videos of Polce & Szuba Pllc
Sent a check on July 14, still not cashed and you usually do that right away...did you receive it? Alan Fisk 06-02377
Polce & Szuba Pllc is located at 40500 Ann Arbor Rd E, Plymouth, MI..
Polce & Szuba Pllc can be found at Ann Arbor Rd E 40500. The following is offered: Phonebook. The entry is present with us since Sep 7, 2010 and was last updated on Nov 12, 2013. In Plymouth there are 127 other Phonebook. An overview can be found here.


text:
Business Directory-ONLY for businesses in Castle Cary, or within a 5-10 mile radius, and at the discretion of the Webmaster/Promotion & Communication Committee. Please submit your listing with as much info as possible, especially email address & website/Facebook listing. Listings from outside the area will not be published.
The Manor House Inn 4 miles
Off road parking. Converted old Mews; five bedrooms, double and twin; double/twin room £90pn; family suite £120pn; single £65pn. B&B.
Send Message to listing owner
The Manor House Inn 4 miles


text:
It's nice to hear the regional films are able to make their content talk rather than just the figures. When two big projects from South have attracted the pan-Indian audiences, it is obvious that the makers want to make them bigger by planning grand audio launch or pre-release events.
The arrangements for the audio launch event of 'Baahubali-2′ are anyway under progress and it is learnt that the makers intend to make it grander. After this big event, Bollywood is going to witness one more audio launch event from South which attracted their attention by virtue of the actors and the technicians roped for the movie.
By now, you might have guessed it. Right? It's Rajinikanth-Shankar's '2.0' event which would take place in Chennai, probably in June. Going by the whopping budget of the movie, it is understood that the audio launch event is going to be a gala affair in Kollywood. Of course, separate audio launch events may happen for Telugu and Hindi versions. Let's see.


text:
Twenty-one prisoners deliberately cut themselves overnight on Monday in a protest at a prison camp in Russia's Chelyabinsk region in the Ural mountains, law enforcement officials said Tuesday.
"On December 6 and 7, 21 detainees slashed their arms in Camp No. 2 in the Chelyabinsk region. All of them received medical help," the regional prosecutors said in a statement.
The spokesman for the regional prison service, Alexander Bushuyev, told AFP that the prisoners' lives were not in danger.
He dismissed the protest as an anarchic rebellion against prison rules.
"The prisoners did not want to follow regulations," he said. "They did not put forward any demands."
The Foundation for the Defence of the Rights of Prisoners confirmed the incident to AFP, saying that it was apparently sparked by ill-treatment of prisoners.
"It's a protest against the behaviour of the prison administration," said Nadezhda Radnayeva of the foundation.
One prisoner died in May after being severely beaten in the camp and in the region as a whole, "at least three prisoners have been killed since the beginning of the year," Radnayeva said.
Despite penal reforms getting underway in Russia several months ago, "the complaints of mistreatment are growing more and more numerous," Radnayeva said.
To attract attention to their problems, prisoners have self-harmed, slashing their veins, sewing up their mouths, or even swallowing nails, she said.
Four prisoners were clubbed to death in camps in 2008 and NGOs at the time accused the prison authorities of blocking an independent inquiry into the causes.
Russian prisons are overcrowded and known for the brutality of their staff. In June 2005. several hundred prisoners self-harmed in a camp in the south-west town of Lgov to protest against abuses by guards.


text:
Flights from Faro to Alicante
4 Posts
Driving to Alicante would take 8 - 10 hours.
Driving to Seville and flying from there is certainly an option. By train, Seville - Alicante is currently 6 - 7 hours, via Madrid, so no quicker overall than driving.
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text:
Study of the EEqn.H in rhoPimpleDyMFoam.
I'm working with the solver "rhoPimpleDyMFoam" from the OpenFOAM 2-2-x version. In specific i was trying to replicate the polytropic process in an adiabatic compression.
The case i studied is a pistone-cylinder sistem where air is compressed by the pistone patch which is a moving wall. The pistone velocity is adjusted to 0,1(m/s) to aproximate a reversible process.
When i choose energy "he" as internal energy i could reproduce the polytropic process in an adiabatic compression.
However when i choose energy "he" as entalphy I couldn't achieve the theoretical expression for air. Instead the system looks as it would be non adiabatic or like the conversion between work and internal energy was not made properly.
Therefore i started to study the EEqn.H.
I compare the theoretical balance of total energy in terms of entalphy with what is written in the EEqn.H.
Balance of a tensorial property in an arbritary moving domain.
Balance of mechanical energy.
Balance of internal energy.
The balance of internal energy can be expressed in terms of entalphy.
Replacing in the balance of internal energy.
Balance of total energy.
The sum of the balances of mechanical and internal energy results in the balance of total energy.
If the terms of work of viscous forces and the gravity are neglected, the balance is:
rhoPimpleDyMFoam: EEqn.H
The balance of total energy in the EEqn.H file with considered as entalphy is:
fvm::ddt(rho, he) + fvm::div(phi, he) + fvc::ddt(rho, K) + fvc::div(phi, K)
If fvOptions(rho, he) are considered as zero, the term from the final balance is no considered in EEqn.H.
Then i try adding in the EEqn.H the therm .
fvm::ddt(rho, he) + fvm::div(phi, he) + fvc::ddt(rho, K) + fvc::div(phi, K)
The question is,
should the term be introduced in any way in fvOptions(rho, he) or it must be explicit in the EEqn.H?
Any clues?. It seems we have to upload the question to the bug tracker.
1 Attachment(s)
I'm trying to simulate exactly the same case, but I get very unphysical solutions even using the internal energy formulation. I also tried your proposal concerning the EEqn.H file without any success.
You said you were able to reproduce the adiabatic compression, so I would appreciate it if you had a look at my settings or if you shared me your case.
rhoPimpleDyMFoam: Adiabatic expansion
1 Attachment(s)
I tried your case without modifying it and i get bad results too.
I made the following modifications,
File: /0$ U
If you want to reproduce an expansion, you should set for the "top" velocity the same velocity of the "patch", in this case, 0.1 m/s for the third coordinate.
Remember that the type "fixedValue" indicates absolute velocities. If you want to set relative to domain velocities you can use type "movingWallVelocity".
File: /system$ fvSolution
I added in the subdictionary PIMPLE the flag "correctPhi" equal to "no".
The correctPhi equation makes the linear solver to diverge.
For compressible fluids, i think that this equation is no necessary as the non conservative effects due to the mesh change in the flux are absorbed by the density equation.
I run the case with a time step of 0.001s from time 0 to time 1s and the adiabatic expansion was obtained successfully.
I hope this can help you,
Hi Horacio Aguerre,
thank you very much for the correction of my case and the detailed explanation, this really helps a lot!
Hi ,Horacio Aguerre
could you see my problem and tell some thing?I think you can answer my question.I moves fireFoam of 2.0.1 to 2.2.1,then rewrite hEqn according to the EEqn.H in fireFoam of 2.2.1 and other necessary codes.But ,when I wmake my rewrited fireFoam,it gives me errors:undefine div(phi,h) in fvscheme.
The following is codes of EEqn.H:
volScalarField& he = thermo.he();
fvScalarMatrix EEqn
fvm::ddt(rho, he) + fvm::div(phi, he)
+ fvc::ddt(rho, K) + fvc::div(phi, K)
+ (
he.name() == "e"
? fvc::div
fvc::absolute(phi/fvc::interpolate(rho), U),
: -DpDt
- fvm::laplacian(turbulence->alphaEff(), he)
fvOptions(rho, he)
Info<< "T min/max = " << min(T).value() << ", " << max(T).value() << endl;
There is div(phi,he) insteading of div(phi,h),So It should be no need to define (phi,h) in fvshceme,but define div(phi,he).However,I see the fvsheme in smallpoolfire2D of 2.2.1,there indeed is div(phi,h).In fact,there is the term of "div(phi,he)" in EEqn.H,why define div(phi,h) in fvsheme?I think I have some thing not understand.!
http://www.cfd-online.com/Forums/ima...ser_online.gif http://www.cfd-online.com/Forums/ima...reputation.gif http://www.cfd-online.com/Forums/ima...ons/report.gif http://www.cfd-online.com/Forums/ima...c/progress.gif
Energy variables
The EEqn is able to solve the energy balance in terms of enthalpy ("h") or internal energy ("e"). Both balances have common expresions. For this expresions it is used the generic energy variable "he". However the expresions differ. Then appears the conditional statement that selects the appropiate source term for the respective form of energy.
he.name() == "e"
In fvSchemes and in fvSolution you must set for the energy parameters the name "he.name()"
If you choose enthalpy "he.name()=h" you must define "div(phi,h)" in fvSchemes.
If you choose internal energy "he.name()=e" you must define "div(phi,e)" in fvSchemes.
In the OpenFOAM official web site there is an explanation on how to set up the thermophysical properties.
HTML Code:
Thanks ,Horacio Aguerre!It is kind of you!
Dear Horacio Aguerre:
Thank you for your last reply!I have another problem I would like to consult you.In my thermophysicalPropertise,I want to define thermo type like this:
type hePsiThermo;
mixture reactingMixture;
transport sutherland;
thermo janaf;
energy absoluteEnthalpy;
equationOfState perfectGas;
specie specie;
}I want use "absoluteEnthalpy;",but when I run my case,it tells me have no this thermo combination.I found just "psiuReactionThermo" Class can use absoluteEnthalpy. "psiReactionThermo"and "rhoReactionThermo"can not use absoluteEnthalpy.They only have sensibleEnthalpy.My case have chemical reaction and I must use absoluteEnthalpy,can you give me advise how to change my thermo type?Thanks again!
Henry changed the code using the snippet suggested by Horacio, but in pEqn.H
|All times are GMT -4. The time now is 14:16.


text:
U-M Investment Group TAMID Introduces Students to Entrepreneurship, Israeli Startups
(Page 2 of 2)
companies, depending on whom you ask. And items like Intel's Pentium chip and ICQ—the technology that ultimately turned into AOL Instant Messenger—were originally developed in Israel.
According to Nathan Gilson, the vice president in charge of TAMID's fellowship program and a sophomore at U-M, the program gives students an introduction to the innovation-heavy environment that proliferates in the country, which is about the same size as New Jersey. Members are able to take what they learn from this intense environment and apply it to their studies and experience in the U.S. "There's such a startup culture in Israel, and going there and being involved in their business world, you can't help but feel it," Gilson says.
Gilson, who spent last summer in Jerusalem interning for a solar housing company called Real Housing, said he was able to connect with entrepreneurs and venture capitalists across the country during his time there. He even got the chance to showcase TAMID in a presentation to TechAviv, an organization of Israeli high-tech founders and investors.
"The response was astoundingly positive," Gilson says, adding that after the trip he was able to count many of TechAviv's members among TAMID's "network of both startup companies and investors in Israel."
In addition to hobnobbing with big players in the Israeli startup scene, Gilson says participating in TAMID gave him the chance to have an immediate impact on an Israeli startup. During the second phase of the program, Gilson did some consulting work for IceCure Medical, a Caesarea-based startup that makes a medical device for treating benign breast tumors through a non-invasive procedure. "As a small company without that many resources, they didn't know what it meant to sell in the American marketplace," Gilson says. "We kind of filled that void for them. They were so appreciative of our work."
Indeed, the startup companies not only learn from the students, but the group's members also learn about how to run an organization from their work with the companies, according to Allison Berman, the group's vice president for programming. What's more, it's relatively easy for the group's members to relate to Israeli startups because of the "dynamic" nature of TAMID, says Berman, a sophomore in Michigan's business school.
"It's such a new group that I can have a very formative role in how the group ends up running," she says. "It's kind of like beginning on a startup venture."


text:
She was a 25-year-old, single girl at the time. Sharon Osbourne dished on the season premiere of The Talk that decades ago, she had a "flingy wingy" with Jay Leno.
What started as a prank call turned into more for Leno and Osbourne because, well, "He liked my voice and I kept calling."
"I said I had the wrong number but I kept talking with my English accent," and eventually, "he actually came to my house and met me and we had a little fling."
"The fling was more fling for me," and not "fling enough for him," she told her show co-hosts.
"A couple of months later he brought around the real love of his life for me to meet," she said. "And she was lovely and they took me to Fatburger and showed me around town," added Osbourne.
The "real love" of Leno's life, of course, turned out to be Mavis Nicholson, whom the show host married in 1980. Sharon, meanwhile, wed Ozzy Osbourne in 1982.
Watch the video below.


text:
and get 2 track for free to try out the service
Styles: Country-Rock, Pop/Rock
Tagged as: Dancehall, Danseband, Hedmark, Norsk, Norwegian, Singer-songwriter
All tracks compatible with iPod, iTunes & Windows Media Player.
Burn your own compilation and listen to it in car!
Only three clicks required! It's so easy, your pet can do it!


text:
GraphicRiver 8.5x11 Poster with 3D objects rendered 306291
Photoshop \ Print Template \ Flyers \ Events \ Clubs & Parties
Poster \ Mirror \ Instructions \ Productid \ Findfonts \ Detail \ Portal \ Provided
Print Template - 8.5x11 Poster with 3D objects rendered 306291 by scarab13 @ GraphicRiver
Photoshop \ Print Template \ Flyers \ Events \ Clubs & Parties
You can use this one the way it already is, considering that I've rendered these evil girls, the stage and the portal (the mirror behind) in C4D, so no copyright issues here. You can even go inside my layers and remove her wings, trident, skulls from the mirror, etc and totally redesign the poster in no time. It's easy to replace the image (detailed instructions provided).
Fonts used.
Lucida Blackletter ( http://www.fonts.com/findfonts/detail.htm?productid=154875)
Trajan Pro Bold ( http://www.fonts.com/findfonts/detail.htm?productid=159644)
Or you can use any other similar fonts
- PSD file
- Instructions
- Readme file
Layered: Yes; Graphics Files Included: Photoshop PSD; Minimum Adobe CS Version: CS2; Print Dimensions: 8.5x11.
Original 70ЎЇs Style Punk Rock Poster; Nautical Flyer / Card; Grunge Card with 6 Backgrounds; Smashed Glass Event Poster; 14 Pro Photo Looks; Vintage Event Flyer; Nu-Metal Poster.
Keywords: 3d girls, 3d model, 3d rendering, black, club opening poster, curtain, demon, devil, evil, fire, gangsta, girls, grunge, hell, hio hop poster, hot chick, invitation, mirror, modern, party poster flyer, portal, purple, rap flyer, red, traditional, yellow.


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An Eddie Bauer Original—and the first down jacket patented in America—the Skyliner started a revolution in cold-weather outerwear. Classic bomber style with signature diamond quilting. 650 fill Premium Down insulation for exceptional warmth. Rib-knit collar, cuffs, and hem.
Every product we sell carries a lifetime warranty. If you are unhappy with it for any reason, you may return it for an exchange or refund.Learn more
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Comments about Men|Outerwear|Jackets Men's 1936 Skyliner Model Down Jacket:
At 6'5" 245 lbs, it's hard to find a good fitting jacket. The XLT fits perfectly both length and width. I can get a heavy weight hooded sweatshirt underneath. I'm surprised at how warm this jacket is, I was wearing just a T shirt underneath it when the weather was 40 degrees and windy the other day and I was sweating while wearing it. Great quality, great fit, it just attracts a lot of lint.
Comments about Men|Outerwear|Jackets Men's 1936 Skyliner Model Down Jacket:
I needed a jacket that was both warm, and lightweight for wear in winter in Toronto, Canada. With sweater as a mid layer, this jacket alone will keep you warm on your commute / running around town most of the winter. On extremely cold days, I wear the very thin, micro therm down field vest. Result: very warm - half the weight of most parkas.
Highly recommend for urban wear in cold weather. Breathes very well too, when you are inside, shopping etc, you aren't sweating in this. And weight is great!
Best Uses
Comments about Men|Outerwear|Jackets Men's 1936 Skyliner Model Down Jacket:
I ordered two of these jackets in different colors. They had to be back ordered so I waited quite long to receive them. The excitement ended when I finally did receive them.
I am 6'4" tall 245 lbs. slender build. Generally everything in shirts and jackets in size XL Tall fit me well in the Eddie Bauer lineup of clothing. Not so with this garment, felt more like a LT. The sleeve length was good and the body length was adequate. It felt very snug in the shoulder and chest area, too restrictive to be called comfortable. I can not see myself wearing a garment this uncomfortable so I had to return them. Nice garment but did not work for me.
Comments about Men|Outerwear|Jackets Men's 1936 Skyliner Model Down Jacket:
I am a new customer to Eddie Bauer, but I am very familiar with the brand. I was looking for a down filled bomber jacket for Fall/Winter and I found a winner with the 1936 Down Jacket . The jacket is lightweight and can easily be packed into a backpack of messenger bag. The Cotton/Poly fabric is what I desired instead of Nylon jacket, you can definitely wear for casual dress up days or hanging out on weekends. The fit is true to size , I am slim 5'11" /160 lbs / 30 waist , I work out so the jacket in a size small fits perfectly . The sleeve length is average and the muscle size is good ( room enough( for layering. I bought the jacket on sale at a discount which helps , but after receiving I would definitely buy at regular price for this style of jacket. The jacket is warm but light in weight. I live in NYC and this jacket will be perfect the chilly/cold weather. I bought the Cadet color which loos great and is denim friendly .Thanks you Eddie Bauer !!!
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The information society promises to dematerialise society and make it more sustainable, but modern office and knowledge work has itself become a large and rapidly growing consumer of energy and other resources.
Continue reading "The Curse of the Modern Office" »
Posted on November 22, 2016 at 02:17 PM in Architecture, Communications, Computers, Cover story, Energy, Energy consumption, Offices | Permalink
Comments (8)
The modern glass greenhouse requires massive inputs of energy to grow crops out of season. That's because each square metre of glass, even if it's triple glazed, loses ten times as much heat as a wall.
However, growing fruits and vegetables out of season can also happen in a sustainable way, using the energy from the sun. Contrary to its fully glazed counterpart, a passive solar greenhouse is designed to retain as much warmth as possible.
Research shows that it's possible to grow warmth-loving crops all year round with solar energy alone, even if it's freezing outside. The solar greenhouse is especially successful in China, where many thousands of these structures have been built during the last decades.
Continue reading "Reinventing the Greenhouse" »
Posted on December 24, 2015 at 03:04 PM in Agriculture, Architecture, Cover story, Energy consumption, History, Insulation, Low-tech solutions, Solar energy, Thermal energy, Tiles & masonry, Zero emissions | Permalink
Comments (19)
Combining the old local heating practices with modern radiant and conductive heating systems could lower energy consumption, improve health, and increase thermal comfort. This is especially true for uninsulated buildings, where air heating is particularly disadvantageous. Local heating sources can be applied on their own, but can also be used in combination with air heating. This may mean, however, that thermal comfort standards need to be redefined.
Continue reading "How to Keep Warm in a Cool House" »
Posted on March 11, 2015 at 04:16 PM in Architecture, Cover story, Energy consumption, Heating, Insulation, Low-tech solutions, Thermal energy | Permalink
Comments (6)
Most modern heating systems are primarily based on the heating of air. The old way of warming was based upon radiation and conduction, which have the potential to be more energy-efficient than convection.
While convection implies the warming of each cubic centimetre of air in a space in order to keep people comfortable, radiation and conduction can directly transfer heat to people, making energy use independent of the size of a room or building.
However, restoring the old way of warming would not make sense without new technology. Most heating systems from the old days were inefficient, polluting, dangerous and impractical. Today, we have better options available, which can be combined in interesting ways.
Continue reading "Radiant & Conductive Heating Systems" »
Posted on March 11, 2015 at 04:05 PM in Architecture, Cover story, Energy consumption, Heating, Thermal energy | Permalink
Comments (2)
The steadfast rotating fan has been employed to keep people cool since the eighteenth century, and it remains highly effective, requiring much less energy and providing more comfort than air-conditioning. Cooling people by increasing local airflow is at least ten times more energy efficient than refrigerating the air in a given space, and it also adds the benefit of a personally controlled thermal environment.
If used in combination with air-conditioning, fans could lower energy use by 30-70%, even in incredibly hot climates or during heat waves. Circulating fans, which have become very energy efficient in their design, can be readily and cheaply applied in both new and existing buildings. Recent changes in international comfort standards have paved the way for their comeback.
Continue reading "The Revenge of the Circulating Fan" »
Posted on September 10, 2014 at 02:00 PM in Architecture, Cooling, Cover story, Energy consumption, Low-tech solutions, Wind energy | Permalink
Comments (21)
1 / 2 / 3
Architects all over the world have demonstrated the usefulness of buildings which are heated and cooled by design rather than by fossil fuel energy. What has received much less attention, however, is the possibility of applying this approach to entire urban neighbourhoods and cities.
Designing a single, often free-standing, passive solar house is quite different from planning a densely populated city where each building is heated and cooled using only natural energy sources. And yet, if we want passive solar design to be more than just a curiosity, this is exactly what we need. Modern research, which combines ancient knowledge with fast computing techniques, shows that passive solar cities are a realistic option, allowing for surprisingly high population densities.
Illustration by Diego Marmolejo for Low-tech Magazine.
Continue reading "The solar envelope: how to heat and cool cities without fossil fuels" »
Posted on March 24, 2012 at 08:52 PM in Architecture, Cities, Cover story, Energy consumption, Heating, Low-tech solutions, Solar energy, Thermal energy, Zero emissions | Permalink
Comments (23)
You could fill a library with reports and books describing the importance of energy-efficient heating systems and home insulation. However, not a word has been said or written about the energy savings potential of clothing, even though there has been a lot of progress in this area too. Modern thermal underclothing offers the possibility to turn the thermostat much lower without sacrificing comfort or sex appeal. The potential energy savings are huge; the costs are almost nil.
This article explains through science and statistics how to maintain thermal comfort at any given indoor temperature using only clothes.
Continue reading "Insulation: first the body, then the home" »
Posted on February 27, 2011 at 01:05 AM in Architecture, Clothes, Clothing, Cover story, DIY, Energy, Energy consumption, Heating, Human energy, Insulation, Low-tech solutions, Thermal energy, Zero emissions | Permalink
Comments (45)
From the earliest civilisations right up to the start of the Industrial Revolution, humans used sheer muscle power, organisation skills and ingenious mechanics to lift weights that would be impossible to handle by most power cranes in operation today.
Continue reading "The sky is the limit: human powered cranes and lifting devices" »
Posted on March 25, 2010 at 04:13 PM in Architecture, Cargo, Cover story, Craftsmanship, Cranes & lifting devices, History, Human powered machines, Knots, Low-tech solutions, Obsolete technology, Ropes, Speed, Towers, Treadwheels, Wire ropes, Zero emissions | Permalink
Comments (25)
About a year ago we presented a medieval building technique that could save large amounts of brick and thus embodied energy in construction: timbrel vaulting. Turns out that there is also a 19th century brick and tile production technique that is surprisingly energy efficient: the Hoffmann kiln, a giant version of the medieval oven stove.
Continue reading "Rings of fire: Hoffmann kilns" »
Posted on October 19, 2009 at 12:03 AM in Architecture, Cover story, Factories, History, Obsolete technology, Thermal energy, Tiles & masonry | Permalink
Comments (8)
The craftsmanship associated with timbrel vaulting has long vanished, but the achievements are still with us today.
Brick, stone and concrete are materials strong in compression (you can pile them up almost indefinitely), but weak in tension (if the structural breadth increases, the material has to be supported by many columns or it collapses).
Nowadays, this problem is solved by steel structures or the use of steel reinforced concrete - the tensile strength of steel is significantly more than that of bricks, stone or plain concrete. Pre World War II, the weak tensile strength of brick was compensated for by superior craftsmanship.
The "timbrel vault" allowed for structures that today no architect would dare to build without steel reinforcements. The technique was cheap, fast, ecological and durable.
Continue reading "Tiles as a substitute for steel: the art of the timbrel vault" »
Posted on November 12, 2008 at 05:48 PM in Architecture, Cover story, Craftsmanship, History, Low-tech solutions, Obsolete technology, Tiles & masonry | Permalink
Comments (12)


text:
Fairmont Le Montreux Palace is situated on the shores of Lake Geneva, overlooking the Alps in the very heart of downtown Montreux. Fairmont le Montreux Palace luxury hotel provides all of the facilities and services one would expect of a world-class city. Built in 1906, this Jewel of Belle-Époque architecture offers a traditional and elegant atmosphere, personalized and attentive service in true Swiss style. In addition to being one of the most prestigious Switzerland hotels, Fairmont le Montreux Palace is one of the largest hotels in the Swiss Riviera region. The Montreux Hotel has 236 rooms and suites that are luxuriously furnished, designed with five star standards and amenities and equipped with the latest technology.
Fairmont Mountain View Rooms are the traditional guest rooms in elegant and comfortable décor. These rooms include air-conditioning, bathrobes and slippers, deluxe toiletries, hair dryer, coffee making facilities, mini-bar, an in-room safe, TV with national and international channels and Pay-Per-View Movies, and a working desk.
Deluxe Lake View Rooms are modern classic rooms with an elegant and luxurious design, a balcony and a large bathroom. These rooms include air-conditioning, bathrobes and slippers, deluxe toiletries, hair dryer, coffee making facilities, mini-bar, an in-room safe, TV with national and international channels and Pay-Per-View Movies, and a working desk.
Montreux Jazz Café features a laid back luxurious decor, inspired by the atmosphere of the legendary music festival, and decorated with a plethora of Claude Nobs memorabilia. Pulsing to the jazz rhythms, guests will discover generous cuisine, combined with a selection of the region's best wines and irresistibly-named aperitifs.
The premier grill in the region, MP's Bar & Grill features refined yet relaxed dining spaces, with an outdoor terrace and a cocktail bar. A perfect fusion of belle époque elegance and arresting contemporary aesthetics compliment the excellent service and menu of distinctive and memorable dishes, prepared with prime cuts of meat, the freshest fish, seafood, and the finest local produce.
La Terrasse du Petit Palais is a haven of peace with its unbelievable view over the lake and the Alps. Open for lunch and dinner in the summer. Discover the salads from their own bio garden, grilled fish, and succulent meat dishes. Ice-cream and refreshments are served during the afternoon.
This sophisticated cocktail bar is the meeting point for internationals and locals alike. A vast choice of cocktails are available and an à la carte menu is served until late in the evening. Live music every evening except on Sunday.
The Willow Stream Spa is a unique oasis. It represents deep-rooted authenticity, strong center, and flexibility while the Stream stands for our energizing journey through life - bending and changing peacefully as we find our way around obstacles. Here, you will find authentic spa experiences inspired by local traditions, plants, and herbs as well as expert attentive spa staff and Willow Stream signature treatments. Finding your energy can be the difference between just living and living well. Recharging your energy gives you the power to take control. That's why energy renewal is their mission at Willow Stream.


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On DVD
Blue Jasmine
Movie Review
Jasmine is indeed blue, and she has reason to be.
Her late husband, Hal, was a crooked businessman who killed himself in prison. The government took almost everything he bought with his swindled cash, and Jasmine has since pawned the rest. Her son left home in a huff. She had a nervous breakdown. She has no job and no prospects.
But she still has her pride. And boy, does she.
Taking with her just a few bags of designer luggage and buying a first-class ticket, Jasmine leaves her old life in New York City for a new one in San Francisco. Her sister, Ginger, has offered to let her stay at her cozy (read: cramped) flat until she gets back on her feet—pretty decent of ol' sis, considering Hal lost all her and her ex-husband's money in a financial scam.
And Jasmine tries to be appreciative. Really she does.
It's just that everything is so … different. Ginger's a grocery checker, for goodness' sake. Her boyfriend's a mechanic. Instead of going to dinner parties and attending polo matches, they drink beer and watch MMA on TV. They're not trying to improve their lot in life. Why, they seem to be perfectly satisfied with themselves just the way they are—no matter if they have designer labels on the throw pillows or not.
Jasmine would, of course, never judge her sister for her way of life or taste in men. Oh, perhaps she pushes Ginger to better herself and strive for more, and she repeatedly tries to help the woman see that she has a horrific habit of hooking up with the wrong guys. But that's the least a loving sister can do. It's encouragement, not judgment! Meanwhile, she herself must try to get back on her feet again and figure out what to do with the rest of her life. Perhaps she could get that college degree she never finished. Or take up something like interior design, perhaps. Yes, yes, that would be a fine way to make a living. Genteel. Clean. Stylish. Just like her.
Of course, that means she might have to take a more menial job to pay her way for a time. She'll just have to pull herself up by her own bootstraps—no easy feat when you've grown so used to Luis Vuitton heels.
Positive Elements
Director Woody Allen is not known for his heroic characters. They are quirky, often neurotic and sometimes sympathetic, but rarely heroic. One might find an exception, though, in Jasmine's long-suffering sister, Ginger. She's an exceptionally kind soul, opening her home to her proud and standoffish sibling, willing to forgive past injuries and think the best of Jasmine, even under some pretty trying circumstances. When people insist Jasmine should've had an inkling as to what her husband was up to, Ginger defends her. When Ginger's beau and friends weary of Jasmine, Ginger stands up to them. She takes and absorbs Jasmine's barbs and rarely barks back, conscious of Jasmine's pain and mental instability.
Granted, she probably suffers a little too much at her sister's hands: To be courteous and kind doesn't mean one must become a doormat. But her heart's in the right place (which is so much more than we can say for Jasmine).
Spiritual Content
Sexual Content
Jasmine tells a stranger at the airport how fantastic sex was with Hal. But Hal, we later learn, also carried on a string of affairs—a truth Jasmine could not or would not see. His conquests included lawyers, personal trainers and mutual friends. He calls them "casual flirtations" until he "falls in love" with a French au pair (a teen, according to Jasmine). With her he says he wants to start a new life—an admission that is as humiliating as it is hurtful to Jasmine.
In San Francisco, Jasmine is pursued by three men. The first, a friend of Ginger's beau, Chili, is brusquely shooed away. The second, a dentist for whom Jasmine works for a time, is not so easily put off. Dr. Flicker tells her that the way she dresses arouses him. He presses her, both physically and verbally, finally forcing a kiss and clearly wanting more. (Jasmine eventually succeeds in escaping.) The third is Dwight, a wannabe politician who kisses Jasmine (which we see), sleeps with her (which we don't) and takes her shopping for engagement rings before uncomfortable truths bring an end to the courtship.
Ginger and Chili talked about moving in together before Jasmine comes to stay. Ginger later meets Al, a guy she believes is a far better man, and the two enter into a torrid romance. We see them kiss and roll around on a bed, and from conversation we gather that they had sex the first night they saw each other. Ginger says it's the first time she's ever done that and asks Al if he thinks she's "easy." No, he says, "I think you're a fun-loving person."
Al also talks Ginger into having sex in a car right before she's supposed to get back from break. "Are you one of those sex addicts?" Ginger asks. "I am for you," he says. (She later discovers that he's married.)
It's clear that one woman isn't wearing a bra. There's talk about "hotness" and sex; a joke references casual prostitution. We see pinching and kissing.
Violent Content
Hal pins the arms of a struggling, out-of-control Jasmine when she learns about his affairs. He is said to have hanged himself in prison (with talk about whether he strangled or broke his neck). We see glimpses of mixed martial arts fighting on television.
Crude or Profane Language
Two f-words, two s-words and a number of other profanities, including "a‑‑," "d‑‑n" and "p‑‑‑." God's name is misused at least two-dozen times (once or twice with "d‑‑n"). Jesus' name is abused nearly 20.
Drug and Alcohol Content
Jasmine has some serious mental health issues, and she engages in a great deal of self-medication. She often pops pills (referencing Xanax) when feeling stressed or panicky, and she drinks almost constantly—sometimes pouring herself glass after glass of vodka. We also see her drinking wine, martinis and other alcoholic beverages.
Ginger, Chili and their associates prefer beer, and they're often all shown with bottles or cans in their hands. Someone jokingly suggests that Ginger's had one too many as she and others stagger back to her place. Folks smoke cigarettes as well. The dentist asks Jasmine whether she's ever gotten high on nitrous oxide. Jasmine's son says he's off drugs.
Other Negative Elements
There's a lame gag about a colonoscopy.
Blue Jasmine is predicated on deception and its brutal consequences for both the deceivers and the deceived. Hal is a world-class liar, rocketing through the world of business via duplicitous means and ripping through his marriage with the buzz saw of infidelity. Al lies to Ginger about his marital status. And, among other things, Jasmine lies to Dwight repeatedly, apparently hoping he'll never find out about her past until they're married, if even then. Honesty, it seems, is a rare trait, growing rarer and, in a way, less desirable the higher one climbs in society.
But it's telling that Jasmine's most persuasive lies are those she tells herself. In flashback, we hear her frequently admit how trusting she is—how she'll sign anything thrust in front of her. Ginger calls it a talent for looking the other way when she has to. And for years, Jasmine refused to see Hal's philandering and told herself she didn't know or care about his business dealings. Until, that is, the truths pushed into her life could no longer be ignored.
It could be said that Jasmine loses her mind when she loses the ability to lie to herself. She can still put on her beautiful face for others—the lie she learned the best. But when she begins to talk to herself (as she often does), the veracities spill out, cutting like glass.
Truthfully, then, Blue Jasmine is moving and illuminating and beautifully acted. It is also bitterly profane and tragically bleak. While some have called it a comedy, it is of the saddest sort I've ever seen. There is occasional levity, but little hope. It only mutters to itself its anguish and pain in the dark of the theater.
Pro-social Content
Objectionable Content
Summary Advisory
Plot Summary
Christian Beliefs
Other Belief Systems
Discussion Topics
Additional Comments/Notes
Episode Reviews
Content Caution
Readability Age Range
Cate Blanchett as Jasmine; Alec Baldwin as Hal; Sally Hawkins as Ginger; Andrew Dice Clay as Augie; Bobby Cannavale as Chili; Louis C.K. as Al; Peter Sarsgaard as Dwight; Michael Stuhlbarg as Dr. Flicker
Woody Allen ( )
Sony Pictures Classics
Record Label
In Theaters
July 26, 2013
On Video
January 21, 2014


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1906 North 6th Street, Wausau WI 54403 $49,900
Features of 1906 North 6th Street Wausau WI 54403
- Multi-Family
- Status: Active
- Total Number of Units: 0
- Garage Type: None
- Estimated Age: Not Available
- Est. Lot Size: 0
- School District: Wausau
- High School: Wausau
- County: Marathon
- Property Taxes: $1,400
- Property Tax Year: 2015
- Listing Company: Coldwell Banker Action
Property Description for 1906 North 6th Street Wausau WI 54403
1906 North 6th Street Wausau WI 54403 - East Side Upper/Lower Duplex On Bus Line. Separate Heat. Updated. Plenty Of Parking In Classic Cleaners. Commercial Potential.
Additional Features
Interior Features
- Heating/Cooling: Forced Air, Space Heater(s)
- Water Waste: Municipal Sewer, Municipal Water, No Meter
Building and Construction
- 2 Story, Duplex
- Roof: Shingle
- Exterior: Deck, Porch
- Construction Type: E
Land Features
- Waterfront/Access: N
- Lot Size: 0
Property History
|MLS Number
|New Status
|Previous Status
|Activity Date
|New List Price
|Previous List Price
|Sold Price
|Feb 15 2016 5:10PM
Estimated Monthly Payment
$3,287 per monthCalculate Payment
Make An Appointment
Contact Shorewest
Get More Info
Receive more detailed information on this propertyAsk a Question
Community Homes Near 1906 North 6th Street
Buyer understands that the information which is contained on Data pages is obtained from a number of different sources and which has not been independently verified or confirmed by the various real estate brokers and agents who have been and are involved in this transaction. If any particular measurement or data element is important or material to buyer, Buyer assumes all responsibility and liability to research, verify and confirm said data element and measurement. REALTOR *MLS* Equal Housing Opportunity


text: Ok, so I'm a complete newb at technology and everything, I don't know why. Anyways I did the is recording last winter. I was just ****************ing around because I really wanted to get something onto youtube for the first time. I looped the rhythm to Pearl Jam alive and just solo'd over that. It's my G&L Legacy going through my Kustom 36 Coupe and probably just running a MXR Phase 90. It was done through a Flip Video Recorder. Anyways, just a little taste.


text:
OnePulse. One Mission.
Unite charities and people through the power of biking. Together we will address the needs of communities and the environment around us.
Building A Global Community
If you are looking at the image above, you see the world as we do; as one. We started OnePulse in 2013 to bridge the gaps between charities and communities by hosting bicycle expeditions around the globe. During these bike expeditions, we learn about many of the world's pressing issues and what we can do to help through our partnered charities.
Pangea physically existed long ago, but now it is time for us to create Pangea in our hearts and minds so that we may allow our mental concepts of borders to fade away, and focus on what we can do as a species to create a sustainable future for all.
Earth is our home, and we plan to take care of it by creating global initiatives that unite people for causes that make a difference.


text:
Global Icon has just released their very first mini-album, "Tremendous".
The mini-album features a total of 7 tracks, including their pre-release track "Because of You", their title track "GI" (clever name), "Don't Lie" which features rapper DOK2, "Dilidium", their debut track "Beatles", as well as the instrumental versions of both "Gi" and "Don't Lie".
While "Because of You" was a nice ballad to warm up Global Icon's loyal fans, "Gi" is completely different.
"Gi" features a completely different sound, one that I'm sure many Global Icon fans and even regular K-pop fans can enjoy. It starts off with some oriental instrumentals, but then it completely dives into a encompassing beat. The entire song is very catchy and the girls' vocals are on-spot.
After listening to "Gi" once or twice, you'll be guaranteed to have the chorus stuck in your head. Congrats to Global Icon for reaching this milestone in their career. Best of luck to them on their comeback stages! You can check out Global Icon's "Gi" below.


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Website to mobile css
Προϋπολογισμός $10-30 USD
I need my site converted to mobile soon as possible. so it compatible to mobile :)
53 freelancers κάνουν προσφορές με μέσο όρο $46 γι' αυτή τη δουλειά
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can you please send me your site link so we will estimate it accordingly ....................................................
Hi! Please send me your website link to review and estimate the time and cost to complete the "mobile css" job, thank you.
HI, I can convert your website to mobile responsive. Please message me to further discuss any details.
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can you show me your website? I can convert it into mobile responsive, can we please have a chat about your project?


text:
Robbery (album)
|Studio album by Teena Marie
|September 18, 1983
|49:18 (Original release)
69:18 (Expanded edition)
|Teena Marie
|Teena Marie chronology
Robbery is the fifth album by Teena Marie, released in 1983. It is her first album for Epic Records, following her acrimonious departure from Motown the previous year. The album was written and produced by Marie herself and features contributions from Patrice Rushen, Paulinho da Costa, and Steve Ferrone among others. However, the album did not repeat the success of her last Motown release It Must Be Magic, stalling at #13 on the Black Albums chart and only reaching #119 on the Billboard Albums chart.
In 2012, the album was re-released in a remastered and expanded CD edition containing four additional tracks.
Cassanova Brown[edit]
Included on this album is the infamous song, "Cassanova Brown". After meeting Rick James in the 70's and being signed to the same label, James and Marie began a relationship, first professional, progressing (according to Marie) to a romantic one, and finally leading to an engagement. Although James himself denied ever having a romantic involvement with Marie, she said they were engaged for a few weeks. When James' alleged infidelities came to light, Marie realized that she herself was a mistress; James had a girlfriend, Alfie Davidson, who would later substantiate that James and Marie were once an item, while she was his girlfriend. After the breakup, their relationship waned to a tumultuous friendship. The lyrics are very thinly veiled in her contempt for the situation.
|Professional ratings
|Review scores
Track listing[edit]
All songs written by Teena Marie.
- "Robbery" - 5:23
- "Playboy" - 5:23
- "Shadow Boxing" - 6:49
- "Midnight Magnet" - 6:02
- "Fix It" - 4:44
- "Ask Your Momma" - 5:25
- "Dear Lover" - 5:18
- "Stop the World" - 4:16
- "Cassanova Brown" - 5:58
- "Playboy" (US 12" Remix) - 5:51 (Expanded edition)
- "Fix It" (US 12" Remix) - 6:30 (Expanded edition)
- "Fix It" (Instrumental)(US 12" Remix) - 8:16 (Expanded edition)
- "Midnight Magnet" (US 12" Instrumental) - 6:00 (Expanded edition)
Credits for Robbery adapted from Allmusic[1]


text:
Maybe Accepting Guests
- Last login over 5 years ago
Join Couchsurfing to see Penelope's full profile. It's free!
About Me
I like travelling, though I have a little free time. This autumn, I came to Paris for a short-term study and I would like to take this opportunity to wander in Europe, at meantime, having a look at the different scenery and feel the various cultures. I think travel is the best way to broad my horizon.
painting, reading, swimming...etc.
- reading
- traveling
- painting
- swimming
Countries I've Visited
France, Germany, Italy
Countries I've Lived In
China, France


text:
5 Ways to Beat the Back to Work Blues
Going back to work after a holiday break can be tough. Even for those of us who love our work. Here are five ways to beat back to work blues.
Get top stories and blog posts emailed to me each day. Newsletters may offer personalized content or advertisements. Learn more