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The Application of FATCA to International
Withholding under the U.S. Foreign Account Tax Compliance Act
("FATCA") is scheduled to take effect starting July 1, 2014. This briefing
provides broad‑brush guidance for identifying FATCA withholding
concerns that may arise in certain international transactions. Its focus is
on identifying whether FATCA withholding is a concern in a transaction,
and how parties can get comfortable with knowing whether they have a
FATCA problem.
The briefing first provides a description of FATCA withholding and its
relationship to the long‑standing U.S. withholding regime. It then
describes in detail the methods that can be used to be comfortable that
FATCA withholding will not apply to various types of payments. Finally,
the briefing outlines certain relevant dates for FATCA implementation.
FATCA Withholding Overview
A. Background
The United States enacted FATCA to prevent banks and other entities from
helping U.S. taxpayers avoid U.S. federal income tax by hiding income in
offshore accounts. The United States has long had extensive reporting and
withholding tax obligations with respect to payments made from the
United States. However, a U.S. citizen could avoid detection by, for
example, opening a foreign bank account and not filing U.S. tax returns.
FATCA was enacted as an attempt to close this loophole. FATCA was
enacted in 2010, and was initially scheduled to take effect January 1, 2013,
but the effective date has been extended.
FATCA applies in some form to all non‑U.S. entities. There are two
principal categories of non‑U.S. entities, each with different rules. The first
category is a "foreign financial institution" ("FFI"). The definition of FFI
encompasses far more than what is commonly thought of as a "financial
institution," including for example most investment funds. In general, in
order to comply with FATCA, an FFI must enter into an "FFI agreement"
U.S: Tax
June 2014
Introduction 01
FATCA Withholding Overview 01
Determining Whether FATCA
Withholding is Required
FATCA Timeline 09
Contacts 10
02 U.S. TAX BRIEFING with the U.S. tax authorities, which generally requires the FFI to perform due diligence to
determine who among its account holders are U.S. persons, and to provide reports to the
U.S. Internal Revenue Service ("IRS") regarding its U.S. account holders.
A non‑U.S. entity that is not an FFI is a "non‑financial foreign entity" ("NFFE"). Although
the reporting and documentation requirements for an NFFE are often much simpler than
those of an FFI, FATCA withholding has the potential to apply to payments made to an
NFFE in the same manner as to an FFI.
In order to ease the burdens of FATCA compliance for foreign entities, the U.S. Treasury
has entered into "intergovernmental agreements" ("IGAs") with many country
counterparties. It is expected that eventually, most major participants in the world of
international finance and commerce will be covered by an IGA. There are two model
IGAs. The Model 1 IGA (which comprises the majority of currently effective IGAs) allows
FFIs to provide information and make reports to their home jurisdiction tax authorities,
rather than the IRS, and the home‑jurisdiction authorities pass the information along to
the IRS. The Model 2 IGA (which applies to a smaller number of jurisdictions), eases
FATCA compliance somewhat, but still requires foreign entities to make reports to the
IRS. The IRS has announced that certain IGAs that are agreed in substance but not yet
signed may be treated as if they were in effect.
B. FATCA Withholding and Standard U.S. Source Withholding
1. Two Withholding Regimes
If FATCA withholding applies to a payment, any person making the payment to a foreign
entity generally will be required to collect and pay over to the U.S. Treasury 30% of the
amount paid. (The obligation also extends to persons who have custody or control over
such a payment, such as an agent or middleman.) The 30% withholding tax is similar to
and builds on the standard 30% U.S. withholding tax ("U.S. Source Withholding"). Like
U.S. Source Withholding, there are many exceptions to FATCA, but the rules and
exceptions to FATCA are not the same as those for U.S. Source Withholding.
2. Exceptions to FATCA and U.S. Source Withholding
a. Treaty Exemptions
Many U.S. treaties exempt or reduce U.S. Source Withholding on payments to
residents of the treaty country. Those treaty exemptions or reductions do not,
however, eliminate FATCA withholding.
b. Non U.S. Source Payments
Neither FATCA withholding nor U.S. Source Withholding is required on income that
is not "income from sources within the United States" (often referred to as "U.S.
Source Income"). (FATCA withholding may also apply to "passthru payments" that
are not U.S. Source Income, as described briefly below.) The determination of
whether a payment represents U.S. Source Income can be complex, as discussed in
greater detail below.
c. Non‑Financial Payments
FATCA withholdable payments generally include financial payments, such as
interest, dividends and swap payments. On the other hand, most non‑financial
payments such as payments for services, payments for the use of property (i.e., lease
payments), and payments for freight and transportation are not subject to FATCA
withholding. These types of payments are nonetheless subject to U.S. Source
Withholding if they constitute U.S. Source Income (unless another exemption, such as
a treaty exemption, applies). Guidance on what constitutes a non‑financial payment
"... treaty
exemptions or
reductions do not,
however, eliminate
for this purpose is discussed below.
Great care must be exercised in using this exception. The characterization of a
payment for U.S. tax purposes may be very different from its characterization in the
transaction documents or under local law (or even U.S. law other than tax law)
because what type of payment is being made is determined under U.S. tax
principles. For example, a "lease" or "charter" with "financing" characteristics may
well be a debt instrument for U.S. tax purposes, and the payments under it may well
not be payments for use of property or services, but rather debt service.
d. Grandfathered Obligations
"Debt obligations" issued prior to July 1, 2014 are grandfathered from FATCA, and
therefore payments under these instruments are not subject to FATCA withholding
unless the instrument is amended in a fashion that ends the "grandfather"
protection. (The original cut‑off date was March 18, 2012, two years after FATCA
was enacted, but this has been extended many times.) These types of payments are
nonetheless subject to U.S. Source Withholding (although they may qualify for a
Treaty exemption or the exemption for "portfolio interest"). Guidance on what
transactions qualify for the FATCA grandfather exception is discussed below.
e. Offshore Payments
Until January 1, 2017, FATCA withholding is not required on certain payments made
from an offshore party to another offshore person. U.S. Source Withholding may
apply. A short description of the temporary "offshore payments" exception to
FATCA is given below.
f. Gross Proceeds Payments
Starting January 1, 2017, FATCA withholding will also apply to the gross proceeds
from the sale or other disposition of an asset (e.g., a loan or shares of stock) that can
produce U.S. source withholdable payments. This means, for example, that if a
lender makes a $100 loan to a U.S. borrower and then sells the loan for $100, the sale
will be subject to a $30 withholding tax unless the lender is FATCA‑compliant or
otherwise establishes an exemption. Generally, U.S. Source Withholding does not
apply to gross proceeds payments.
g. Pass‑Through Payments
Also starting in 2017, FATCA withholding is scheduled to be imposed on certain
"passthru payments," even if those payments are not from a U.S. source. Although
the meaning of "passthru payments" is not yet defined, this category is designed to
provide the U.S. tax authorities with a weapon to prevent abuse. U.S. Source
Withholding does not apply to passthru payments (with an exception for certain
"conduit" payments). Passthru payments will be grandfathered and not subject to
FATCA withholding for debt obligations executed six months or less after the date
that regulations defining "passthru payments" are finalized.
Determining Whether FATCA Withholding is Required
A. Overview
Starting July 1, 2014, any payor making a payment, and any payee receiving a payment,
needs to know whether FATCA withholding is required. Before an agreement is signed or
a payment is made, the payor and payee should confirm that no FATCA withholding is
required and arrange for the requisite documentation.
Watson, Farley & Williams June 2014
"Starting July 1,
2014, any payor
making a
payment, and any
payee receiving a
payment, needs to
know whether
withholding is
04 U.S. TAX BRIEFING The best way to do this is to collect U.S. tax forms establishing that FATCA withholding
does not apply at the time the transaction closes and to require updates of those forms
from time to time. If exemption forms are not available, other avenues for comfort are to
determine that no FATCA withholding is required because one of the following is true:
The payments are not of a type that makes them withholdable payments.
The payments are not "U.S. source."
The payments are grandfathered.
For payments made before January 1, 2017, the payments qualify as payments on
"offshore obligations".
Each of these rules involves a potential complex analysis of U.S. tax law. The following
sections describe, first, the documentation that can be relied upon to establish an
exemption, and then the relevant other exemptions.
B. Establish that the recipient is entitled to an exemption
To a large extent, FATCA piggybacks on the long‑standing U.S. Source Withholding tax
regime. The U.S. Source Withholding regime generally requires the recipient of a payment
to provide to the payor an IRS Form W‑8 or W‑9 in order to establish an exemption from
or reduction in the rate of U.S. withholding tax. The Form W‑9 is for a U.S. recipient. The
Form W‑8 is for a non‑U.S. recipient, and includes several subcategories of Forms W‑8. If
there is any possibility that FATCA withholding may apply to any payment, a payee
should be required to provide tax forms to the payor (and any other party to the
transaction who may have possession or control of the paid funds, such as a facility agent
in a credit facility) demonstrating that it is entitled to the exemption. Often the
requirement to deliver U.S. withholding tax forms is already present in the
documentation for transactions with U.S. Source Income. Typically, the payee will deliver
a Form W‑8BEN‑E (to indicate that it is the beneficial owner of the income represented by
the payment) which has been adapted to cover FATCA. The documentation that
demonstrates that the payee is exempt is described briefly in the sections below.
There may be instances in which collection of forms is impracticable (for example, where
the payee is a partnership or other intermediary entity with multiple beneficial owners
who are not fluent in the language of U.S. tax). In those cases, the other exceptions
described below should be explored.
1. Payee is a U.S. person and provides an IRS Form W‑9
FATCA withholding does not apply to payments to U.S. persons, namely:
U.S. citizens.
Other individuals resident in the United States.
Corporations and partnerships organized in the United States.
U.S. trusts and estates.
A payee who is entitled to this exemption should provide an IRS Form W‑9 to evidence its
status as a U.S. person.
An entity which is treated for U.S. tax purposes as a disregarded entity and which is
owned by a non‑U.S. person is not a U.S. person for this purpose. If the payee is merely
receiving the payment as an agent for some other principal, the principal should provide
its tax form to claim exemption from FATCA withholding. (Special rules apply to U.S.
financial institutions acting as agents for foreign persons.)
"Each of these
rules involves a
potential complex
analysis of U.S.
tax law."
2. Payee provides an IRS Form W‑8BEN‑E, W‑8BEN or W‑8IMY demonstrating FATCA
compliance or claiming an exemption
IRS Form W‑8BEN‑E (the "BEN" refers to beneficial ownership, and the "‑E" refers to
entities as opposed to individuals) is the primary form that non‑U.S. entities that receive
payments should submit to prevent FATCA withholding. A non‑U.S. individual payee
generally should submit Form W‑8BEN. A non‑U.S. payee that is an intermediary acting
on behalf of another beneficial owner should deliver a Form W‑8IMY (the "IMY" refers to
intermediary), and generally must also provide an applicable Form W‑8 or W‑9 from the
person or persons for whom it is acting as an agent. For this purpose, the U.S. tax rules
treat a partnership (or entity treated as a partnership for U.S. tax purposes) as merely an
agent of the partners (or owners), so a non‑U.S. partnership generally is required to
deliver a Form W‑8IMY for itself together with an applicable Form W‑8 or W‑9 for each
partner (or owner).
An entity filling out either form must select the appropriate one of roughly thirty possible
FATCA classifications. From the standpoint of a payor, these can broadly be classified
into five simplified categories:
1. "Participating FFI" (or "Reporting FFI")
This is a foreign financial institution (FFI) that either has entered into an FFI agreement
with the IRS, or is eligible to claim the benefits of a Model 1 intergovernmental agreement
(IGA) between the United States and the FFI's home jurisdiction or branch jurisdiction, as
applicable. The participating FFI must obtain from the IRS and include on the Form W‑
8BEN‑E a "global intermediary identification number" ("GIIN"), which is the principal
identifying number for FATCA.
A payor receiving a W‑8BEN‑E with a GIIN is responsible for verifying the GIIN
provided against the list of GIINs maintained and publicly available on the IRS
website. The first list of FFIs that have registered for FATCA (roughly 77,000 entities)
was released on June 2, 2014. The list can be searched either by entity name or by
A payor who receives a pre‑FATCA IRS Form W‑8BEN prior to January 1, 2017 can
accept it as the basis for exemption if it also obtains and confirms the FFI's GIIN and
satisfies certain other documentary requirements.
A payor to an FFI or FFI branch that is subject to a Model 1 IGA is not required to
verify the FFI's GIIN until January 1, 2015 (although an FFI subject to a Model 1 IGA
should nevertheless obtain its GIIN well in advance of January 1, 2015 to ensure that
it is included in the official GIIN list by that date).
2 . "Exempt FFI" (or "Non‑reporting FFI")
This is an FFI that is subject to one of several exemptions from FATCA (including certain
entities exempted by an IGA). These entities generally are not required to obtain a GIIN.
3. "Active NFFE"
A non‑financial foreign entity (NFFE) — a foreign entity that is not passive and is not an
FFI. An active NFFE does not need to enter into an FFI agreement or obtain a GIIN.
4. "Passive NFFE"
A passive NFFE is a passive foreign entity that is not an FFI. A passive NFFE does not need
to enter into an FFI agreement or obtain a GIIN, but it does need to provide certain
information as to its U.S. owners (if any) that beneficially own at least a 10% interest in
the NFFE.
Watson, Farley & Williams June 2014
"An entity filling
out either form
must select the
appropriate one of
roughly thirty
possible FATCA
06 U.S. TAX BRIEFING 5. "Non‑participating FFI"
This is an FFI that is not exempt, does not qualify for the benefits of an IGA and has not
entered into an FFI agreement. The payor must withhold a 30% tax on all payments to the
payee that are U.S. source withholdable payments.
3. Payee provides an IRS Form W‑8ECI claiming payments are effectively connected with
a U.S. trade or business
A non‑U.S. payee can also provide an IRS Form W‑8ECI (the "ECI" stands for "effectively
connected income"), which certifies that the payments received will be subject to
ordinary U.S. income tax because the payments are effectively connected with the payee's
U.S. trade or business. Such payments are exempt from FATCA withholding.
C. Payee establishes that the payments are not U.S. source
If the payor is certain that the payments are not "U.S. source" then it need not withhold.
The rules for whether a payment is U.S. or non‑U.S. source are complex. Moreover, there
are no clear guidelines regarding the evidence a payor needs to possess to establish that
the income is not U.S. source. It is rarely safe to rely on payments being non‑U.S. source to
avoid FATCA withholding. However, the following is a general summary of situations in
which a reasonable level of comfort is available that payments will not be U.S. source.
(Note that even non‑U.S. source payments can be subject to FATCA withholding if they
are "passthru payments"; however, because passthru payments will be subject to
grandfathering protection for some time, withholding on passthru payments is unlikely
to be relevant in the near future.)
1. Interest and guarantee payments
Whether interest is treated as U.S. source or non‑U.S. source depends on the identity
and/or activities of the payor.
1. Interest paid by a U.S. corporation (even if its business is conducted entirely outside
the United States) or a U.S. partnership (even if all its partners are non‑U.S. persons)
is U.S. source, by definition.
2. Interest paid by a non‑U.S. corporation or partnership will be U.S. source if
attributable to a U.S. trade or business. Whether interest is attributable to a U.S.
trade or business can be complex, so a non‑U.S. corporation or partnership generally
cannot be confident that none of the interest it pays will be U.S. source unless it is
engaged in no U.S. trade or business. In addition, if a non‑U.S. partnership is engaged
in a U.S. trade or business to a significant extent, all of the interest it pays may be
U.S. source.
3. Interest paid by an entity that is disregarded for U.S. tax purposes is characterized
based on the identity and activities of its non‑disregarded parent.
An entity's U.S. tax classification is determined by the "check‑the‑box" rules, which
means that the entity often has the ability to elect its U.S. tax classification. If no
owner of the entity has liability for the debts of the entity, the default U.S. tax
characterization of the entity is likely to be that of a corporation.
4. The source of payments on a guarantee of a debt obligation is the same as the source
of the payments on the underlying debt obligation. Therefore, payments by a
guarantor under a loan agreement are sourced based on the identity and/or activities
of the underlying borrower.
"It is rarely safe to
rely on payments
being non‑U.S.
source to avoid
In certain cases (e.g., where the borrower is very thinly capitalized), the guarantor
may be treated as the "true" borrower for U.S. tax purposes.
5. Under a special rule, foreign flag shipping companies generally do not have any
income that is effectively connected with a U.S. trade or business, so the interest paid
by these companies generally is not U.S. source. This rule may not apply to a
taxpayer that has a fixed place of business in the United States whose shipping
business consists almost wholly of operating liners or ferries or almost wholly of
bareboat charters. The rule also does not apply to shipping companies that earn nonshipping
income that is effectively connected with a U.S. trade or business.
2. Dividends
Dividends from a non‑U.S. corporation are non‑U.S. source, unless a substantial amount
of the non‑U.S. corporation's gross income is effectively connected with a U.S. trade or
3. Swaps
Swap payments received by a non‑U.S. person will usually be non‑U.S. source (even if the
payor is a U.S. person).
This rule applies only if the payments are treated as "notional principal contract"
income, and not as embedded interest or another type of payment.
This rule does not apply to payments attributable to the recipient's U.S. trade or
This rule does not apply to swaps with significant upfront or termination payments
which have an embedded interest component.
Payments on a swap that is identified as a hedge or part of an integrated transaction
with an underlying debt instrument generally have the same source as the
underlying debt instrument.
4. Lease Payments, Payments for Services, Rents, Freight Charges, etc.
All of these payments, if properly characterized for U.S. tax purposes in accordance with
their form, are not subject to FATCA withholding regardless of their source, as described
D. Establish that the payments are not financial payments
FATCA withholding applies only to financial payments (generally, interest, dividends
and most payments on swaps or other derivatives). No withholding is required on nonfinancial
payments, including lease/rent payments, payments for services and charter
payments for a bareboat, time or voyage charter. However, the U.S. tax characterization
of a payment determines whether this exemption applies. The U.S. tax characterization of
a payment can be very different from the legal form of the payment: the rules are based on
the "substance of the transaction" and on analysis of all related agreements and
understandings, not merely the individual contract giving rise to the payment in
1. Lease Payments
A lease may be characterized for U.S. tax purposes as a "true lease," a financing, or some
other type of transaction. All agreements and documents must be examined together to
determine a lease's characterization (so for example, a lease that appears to be a "true
lease" may be characterized as a financing or a current sale if the lessee or an affiliate also
has an option to purchase the leased property that is substantially certain to be
exercised). If the lease is intended by the parties as a financing or intended as the collateral
Watson, Farley & Williams June 2014
"The U.S. tax
characterization of
a payment can be
very different from
the legal form of
the payment."
08 U.S. TAX BRIEFING for a financing, it is likely that the lease will be treated as a financing for U.S. tax purposes.
2. Payments for Services
Payments for services are usually easier to characterize than lease payments. However,
there are circumstances where payments purportedly made in return for services will be
treated as financial payments. For example, a time charter normally is treated for U.S. tax
purposes as providing a service, but some agreements designated as time charters are
treated as financings.
3. Vessel Charters
Bareboat charters are generally subject to the same rules as leases. Time or voyage charter
income is generally characterized as income for services. (Note that if a charter is treated
for U.S. tax purposes as not a financing, U.S. Source Withholding does not apply. Instead,
U.S. source gross transportation income is subject to a 4% U.S. gross freight tax, unless an
exemption under a treaty or under Section 883 of the U.S. Tax Code applies.)
E. Establish that the payments are grandfathered
Payments that would otherwise be withholdable payments will not be subject to FATCA
withholding if they are "grandfathered" obligations. The cut‑off date for grandfathered
obligations is July 1, 2014.
Grandfathered obligations include:
Loans and other debt instruments issued prior to July 1, 2014.
Guarantees of loans granted prior to July 1, 2014.
Draws on credit facilities under an agreement that was signed and fixed as to
material terms (including amount and maturity date) prior to July 1, 2014.
Most swap and other derivative payments entered into pursuant to an ISDA master
agreement evidenced by a confirm prior to July 1, 2014, excluding payments on
instruments that are treated as equity for U.S. tax purposes.
Payments on collateral posted in respect of a grandfathered obligation.
A grandfathered obligation that is modified "materially" on or after July 1, 2014 loses its
grandfathered status. Whether a modification is "material" is often unclear. Certain
modifications are per se material, such as changing the interest rate of a loan by more than
a de minimis amount. Other changes are tested under a "facts and circumstances" test.
A payor other than the borrower or its agent is required to treat a modification as
material only if it has "actual knowledge" of the modification and that it was material. If
a modification of a grandfathered obligation is not per se material under the regulations,
and a payor has not received notice from the borrower stating that the modification was
material, the payor is permitted to assume conclusively that the obligation remains
grandfathered. The borrower and its agent are required to treat a modification as
material if they have "actual knowledge or reason to know" that the modification is
F. Establish that the payment falls within the temporary exception for offshore payments
The regulations include a temporary exception to withholding: until January 1, 2017, a
payment made with respect to an account maintained outside the United States generally
is not subject to FATCA withholding except for payments on debt or equity issued by a
U.S. person. Thus, an interest payment on a loan by a non‑U.S. borrower (even if the
borrower has substantial U.S. ties) paid to a non‑U.S. account is not subject to FATCA
"Payments that
would otherwise
be withholdable
payments will not
be subject to
withholding if
they are
withholding prior to 2017. However, the exception for offshore payments does not apply
to U.S. Source Withholding. In addition, if the relevant agreement extends past January 1,
2017, payments made in or after 2017 will be subject to FATCA withholding. Accordingly,
this exception should be viewed as a "last resort", to be relied upon only when there is no
other exemption from FATCA withholding (and even then, a payor must confirm that the
payment is not subject to ordinary U.S. Source Withholding).
FATCA Timeline
The following is a timeline of relevant dates to be aware of in the implementation of
FATCA. In the case of an intergovernmental agreement, some of these dates may be
modified. Also, these dates have been extended before, and may be subject to future
First half of
FFIs are eligible to enter into FFI agreements and obtain GIINs (special
FATCA identification numbers)
June 2, 2014
First list of registered FFIs and corresponding GIINs released, to be
updated monthly
July 1, 2014
FATCA withholding in effect; new debt obligations cease to be
grandfathered; all FFIs not subject to a Model 1 IGA should have
registered and obtained a GIIN well before this date
January 1,
First date FFIs in Model 1 IGA countries need a GIIN (FFIs should
obtain GIINs well before January 1 to ensure that they are included in
the official GIIN list)
March 31,
First FATCA reports due by FFIs (other than FFIs in Model 1 IGA
countries); reports due annually thereafter
30, 2015
First FATCA reports due by FFIs in Model 1 IGA countries; reports
due annually thereafter
January 1,
FATCA withholding on gross proceeds and passthru payments in
effect (later if "passthru payments" is still undefined); exception from
withholding on offshore obligations ceases to apply; pre‑FATCA
Form W‑8BEN no longer valid
Watson, Farley & Williams June 2014
"...this exception
should be viewed
as a "last resort,"
to be relied upon
only when there is
no other
exemption from
Should you wish to discuss any of the matters raised in this Briefing, please speak with one of the authors
below, or your regular contact at Watson, Farley & Williams.
Daniel Pilarski
New York
+1 212‑922‑2234
Stephen Millman
New York
+1 212‑922‑2205
All references to 'Watson, Farley & Williams' and 'the firm' in this publication mean Watson, Farley & Williams LLP and/or its affiliated undertakings.
Any reference to a 'partner' means a member of Watson, Farley & Williams LLP, or a member of or partner in an affiliated undertaking of either of
them, or an employee or consultant with equivalent standing and qualification.
This publication is produced by Watson, Farley & Williams. It provides a summary of the legal issues, but is not intended to give specific legal advice.
The situation described may not apply to your circumstances. If you require advice or have questions or comments on its subject, please speak to your
usual contact at Watson, Farley & Williams.
This publication constitutes attorney advertising.
© Watson, Farley & Williams 2014 100‑000‑2619 NEW KW KW 25/06/2014

subset: commoncrawl


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WALK TO THE BEACH!!! Have an enjoyable and fun vacation experience in this very comfortable beachside vacation home in Daytona Beach. Just renoveded, looks like a brand new home, at walking distance to the most famous beach of Florida, Halifax River and very closed to the most popular racing track; THE DAYTONA BEACH INTERNATIONAL SPEEDWAY (NASCAR). Very close to MAIN STREET, Boardwalk and shoppings.
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11 Borland Circuit
Wodonga VIC 3690
- 3 Bed
- 2 Bath
- 2 Parks
Cutting Edge Design With Sensational Indoor & Outdoor EntertainingDefinite use of natural light both inside and outside is the hallmark of this contemporary home which offers 3 bedrooms, study, 2 bathrooms and sophisticated 2 pak kitchen.
The open plan formal lounge and dining flow seamlessly to an indoor alfresco room with log fire and opens to an undercover all weather entertaining area completing this perfect mix of formal, casual and alfresco living.
Quality fittings include plantation shutters, stackable sliding doors and double glazed windows.
Your comfort is assured year round with ducted evaporative cooling and gas heating.
Double garage with auto door and internal access.
Fully established professionally landscaped maintenance free gardens.
Call today inspection will impress!
General Features
- Property Type: House
- Bedrooms: 3
- Bathrooms: 2
Indoor Features
- Toilets: 2
Outdoor Features
- Garage Spaces: 2
Nearby schools
Can I afford 11 Borland Circuit?
With access to the best on offer from 30 lenders and complete support and advice from pre-approval to settlement, you can trust an Elders Home Loans broker to find a quick and simple solution.Get a Quote
Pam Shaw
Elders Real Estate WodongaContact Agent
Elders Real Estate Wodonga
Enquire about 11 Borland Circuit, Wodonga, VIC, 3690


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Stainless steel Omega Seamaster 120M Automatic Silver dial. Watch runs great, case crystal and bracelet are mint, buckle shows wear. Comes with box.
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- News19th February 2007
New taxes will be unfair and harm the local environment, warns Conservative Group Leader Serena Croad. read more »
- News9th February 2007
No ID card office planned in the whole of Worcestershire - ID cards won't work, and won't even create work in Worcestershire read more »
- Harriett Baldwin welcomes disillusioned Liberal Democrat District Councillor into Conservative PartyNews7th February 2007
Harriett Baldwin, Conservative Parliamentary Candidate West Worcestershire this week welcomed news that Pickersleigh District Councillor Patrick Mewton has decided to cross the floor to join the Conservative Group on Malvern Hills District Council. read more »
- News3rd February 2007
Council tax revaluation taking place by stealth across England warns Harriett Baldwin read more »
- News30th January 2007
Sir Michael Spicer MP and Harriett Baldwin, Parliamentary Candidate for West Worcestershire, visited Pershore College on Friday 26th January 2007. read more »
- Harriett Baldwin invited to Worcestershire Acute Hospitals' Patient and Public Involvement in Health ForumNews29th January 2007
Harriett Baldwin, Conservative Party Parliamentary Candidate in West Worcestershire attended a meeting this week of the Worcestershire Acute Hospital Patient and Public Involvement. read more »
- News29th January 2007
Harriett Baldwin, Conservative Party Parliamentary Candidate in West Worcestershire today attended David Cameron's speech on community cohesion at the New Testament Church of God in Lozells, Birmingham. read more »
- News28th January 2007
Harriett Baldwin, Conservative Parliamentary Candidate for West Worcestershire today expressed concern at Government's decision to abandon a manifesto pledge to recruit 24,000 Police Community Support Officers (PCSOs) by March 2008. read more »


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Bangla Adhunik
We have extended our invitation to these eminent performers.
Jayati Chakraborty
Jayati Chakraborty, a versatile singer, has a unique voice quality and a dedication and passion for music, which are her claim to fame. In her repertoire, are a wide range of compositions representing different genres from Tagore songs, songs of Nazrul, Atulprasad, Rajanikanto, Dwijendralal to modern Bengali songs, jingles, band music and songs in Bengali film and television. Jayati has also judged prestigious singing competitions including Dover Lane Music Conference & Sa-Re-Ga-Ma-Pa preliminaries.
Anweshaa Datta Gupta, winner of the Best Female Playback Singer award for Bengali song in Tele Cine Awards 2011, is one of the youngest playback singers in India. She renders playback songs in Hindi, Bengali, Tamil, Kannada and Telugu movies. She has many musical albums to her credit.
Raghab Chattopadhyay
Raghab Chattopadhyay started his musical journey under the tutelage of a student of Pt Ajoy Chakraborty and Ustad Rashid Khan. In his repertoire, are a broad range of renditions, from jazz and fusion to pure Indian classical music. Raghab has won a number of distinguished awards in music.
Srikanto Acharya
Srikanto Acharya is a noted musician and songwriter from Bengal, whose renditions include Rabindrasangeet and contemporary Bengali songs. He has received a number of distinguished awards in Bengali music and also has musical albums to his credit.
Jimut Ray
Young Jimut Roy, a versatile and mellifluous singer, has recently joined the commercial music arena of Kolkata after being crowned the winner of 2017 Zee Bangla Sa-Re-Ga-Ma-Pa competition. The classically trained singer Jimut switches effortlessly between semi-classical to adhunik, from both yesteryears to the most recent ones.
Shamik Pal
An alumnus of Dakshinee, the eminent school of Tagore music, Shamik Pal had his initial training in the rendition of Tagore songs. However, he also deftly performs contemporary Bengali songs. Apart from his distinguished musical career, Shamik is a faculty in a management school in Kolkata.


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The Marsh Foundation is the official provider of the Bridges program for Northwest Ohio. Bridges is a voluntary program available to young adults who left foster care in Ohio at ages 18, 19 or 20.
Dyadic Developmental Psychotherapy
The Marsh Foundation's clinical supervisor, Annette Hermann has been specifically trained in this method of attachment focused treatment for childhood trauma and abuse.
Foster Family Based Treatment Association
The Foster Family-based Treatment Association (FFTA) was founded in 1988 and exists to define, support and promote quality Treatment Foster Care services within a family context. The FFTA is composed exclusively of Treatment Foster Care Agencies in North America.
Ohio Children's Alliance
The Ohio Children's Alliance is a statewide Association of private, non-profit agencies which provides a wide array of services to children and families in crisis across Ohio.
The Teaching Family Association
The Teaching-Family Association (TFA) was founded in 1975 to ensure the quality of care provided by professionals who actively pursue the goals of humane, effective, individualized treatment for children, families, and dependent adults using the common framework of the Teaching-Family Model for treatment and support.
In the event a Van Wert community member wishes to express concerns or other relevant information, regarding The Marsh Foundation facilities or services, they may contact:
Public Relations/Marketing Specialist
Phone: (419)238-1695 ext. 233
Email: email@example.com
Marsh Holds Foster Care & Adoption Center Grand Opening Just Ahead of National Foster Care Appreciation Month
VAN WERT, Ohio – As The Marsh Foundation Foster Care and Adoption division continues to grow, a grand opening and ribbon cutting was held last week at their new location downtown. The Foster Care and Adoption Center, 102 W. Main Street in Van Wert, will now house office space as well as a training and […][More]


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Home > Virtualization Architect
About the roleYou work on projects around server virtualization technologies (Vmware, Citrix ...), storage (Netapp, EMC, ...), desktop virtualization (Xendesktop, View, ...). secure access infrastructure (Citrix products, ...) or Directory and messaging infrastructure.
To carry out these projects, you intervene at different stages and will be brought to:
In the upstream phase and in collaboration with the pre-sales BU:Participate in the technical validation of architectures proposed to clientsParticipate in the defensesDuring the integration phases:Gather the functional and technical needs of the clientElaborate the technical architecture corresponding most closely to customer needs and based on the hardware and software soldAccompany the project manager on the monitoring and management of technical risksDuring the study phases:Gather information collected (metrology, inventory, needs, ...)Elaborate the different technical architecture scenarios (HLD)Define the lists of hardware and software to acquire according to the scenariosOut of project:Participate in the development of the company's technical document templatesParticipate in the definition of good integration practices NeoclesAbout youWith a Bac +4 / 5 training, you have at least 5 years of proven technical experience in virtualization integration with the technologies mentioned at the beginning of the offer.
You demonstrate analytical and analytical skills as well as editorial qualityYou speak English (written and oral)You are tenacious, responsive and have good interpersonal skills (many contacts: technical / clients / management).DepartmentNeocles Corporate
A Orange entity dedicated to businesses, Orange Business Services is both a telecom operator and a digital services company (ESN) in France and internationally. More than 2 million professionals, companies and communities in France as well as 3,000 multinationals trust us every day. Our ambition is to help companies transform their business by giving their employees and their organization the means to work in an innovative way.Within Orange Business Services, NEOCLES CORPORATE, a virtualization and cloud computing subsidiary of Orange Business Services, has been supporting the biggest accounts for more than 15 years in its two core businesses: the integration (build) of innovative projects and the run Private Clouds (Datacenters and Virtual Stations) in situ at our customers or shared in our datacenters via our tailor-made offers.Our 200 employees offer full coverage of the project lifecycle: upstream studies, architectural design, deployments, in-house outsourcing, delegation and technical assistance. We support companies in transforming their IS and work environment through our partnerships with Cisco Cloud Builder and Provider, Citrix (1st integrator), Netapp, EMC, HP, Microsoft and VMware.
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Rainy Day SEO
Hardcover, 154 Pages
Price: $79.99
Prints in 3-5 business days
Rainy Days - some businesses have them, others fear them. This book teaches you how to effectively deal with them... using Search Engine Optimization: The process of optimizing your Website for maximum visibility and traffic from search engines. This book will teach you in a straightforward, step-by-step manner how to get your site ranked in Google, Bing, and Yahoo using simple, low-cost (and sometimes even free) methods. Learn the secrets of linkbuilding, article syndication, directory submission, press releases, competitor research, keyword optimization, and more... The comprehensive techniques we provide make this an invaluable reference resource, whether you're new to SEO or a seasoned search engine optimization veteran.
Ratings & ReviewsLog in to review this item
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Product Details
- Copyright
- Supersoftware, Inc (Standard Copyright License)
- Edition
- First Edition
- Published
- July 21, 2011
- Language
- English
- Pages
- 154
- Binding
- Hardcover (casewrap)
- Interior Ink
- Black & white
- Weight
- 1.05 lbs.
- Dimensions (inches)
- 8.25 wide x 10.75 tall
- Product ID
- 16315222
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Join Lawrence McMillan LIVE at TradersEXPO Las Vegas!
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Major Trend Goes Bearish
05/24/2010 12:00 pm EST
Focus: MARKETS
Lawrence McMillan, editor of the Option Strategist, says the big sell-off a couple of weeks ago triggered sell signals from some indicators he watches closely.
When [the Standard and Poor's 500 index] broke down below the 1180 level last week, it changed the technical picture from bullish/neutral to bearish.
There have been several oversold, bullish signals springing up since then, but the most important indicator—price—is in a bearish trend. Thus, that dominates our outlook. After breaking support at 1180, the S&P 500 plunged rapidly (and somewhat artificially) to the 1065 level.
As is often the case in a bearish market phase, the S&P 500 declined well below its 20-day moving average, creating a massive oversold condition. Those conditions propelled the market back towards that breakdown level and the now-declining 20-day moving average.
The S&P 500 failed at the 1170-1175 zone, and now has fallen back. (It closed Friday above 1087—Editor.) Thus, the resistance area extends from about 1170 to 1185, and the S&P would have to close above that level to reverse itself out of the bearish chart pattern that exists.
The equity-only put-call ratios remain solidly on Sell signals. These were the first indicators to turn bearish, a few weeks ago (which is somewhat unusual, because they are 21-day moving averages).
In contrast, however, there is another put-call ratio—the total ratio (of all stock and index options)—that occasionally gives important signals. When the total ratio is above 1.00 for the day, it is a short-term Buy signal.
On each of the last three trading days of [the week the market took its big fall], the total ratio was above 1.00, and that marked a severe oversold Buy signal. Finally, the weighted [Nasdaq 100] ratio [has been] getting oversold.
Breadth was very negative during the decline. Breadth swings have been volatile, as well, as there was a difference of at least 2,000 issues between advances and declines ten times between April 27th and May 12th.
The frequency of "90% days" has exploded as well, with three down days and two up days. The breadth oscillators declined to very oversold levels, and issued Buy signals [last] week, which are still in effect.
Volatility indices spiked upward during the sharp market decline, rising above 40—which was quite extreme for what is, to date, only a modest percentage correction in the S&P 500. They reversed back down [the following week], forming a spike peak Buy signal. VIX futures have supported the bullish case, to a certain extent, for over a year now.
In summary, the signals are mixed. Equity-only put/call ratios, the trend of VIX, and the S&P 500 chart are bearish. Positive signs include the spike peak in VIX, the breadth oscillator buy signals, and the total put-call ratio.
When signals are mixed, we defer to the price chart of the S&P 500, and that is now in a down trend as long as the S&P 500 remains below resistance (1170-1180) and below its 20-day moving average (1185).
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Categorical Data Analysis
Alan Agresti
Praise for the second one Edition
"A must-have publication for an individual watching for to do study and/or functions in specific info analysis."
—Statistics in Medicine
"It is a complete satisfaction interpreting this book."
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"If you do any research of express info, this is often a vital laptop reference."
The use of statistical tools for studying specific facts has elevated dramatically, relatively within the biomedical, social sciences, and fiscal industries. Responding to new advancements, this booklet deals a finished remedy of crucial tools for express facts analysis.
Categorical facts research, 3rd Edition summarizes the most recent tools for univariate and correlated multivariate specific responses. Readers will discover a unified generalized linear versions procedure that connects logistic regression and Poisson and damaging binomial loglinear types for discrete information with general regression for non-stop info. This version additionally features:
- An emphasis on logistic and probit regression equipment for binary, ordinal, and nominal responses for autonomous observations and for clustered information with marginal versions and random results models
- Two new chapters on replacement tools for binary reaction info, together with smoothing and regularization tools, category equipment comparable to linear discriminant research and class timber, and cluster analysis
- New sections introducing the Bayesian technique for ways in that chapter
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Categorical facts research, 3rd Edition is a useful device for statisticians and methodologists, corresponding to biostatisticians and researchers within the social and behavioral sciences, drugs and public future health, advertising and marketing, schooling, finance, organic and agricultural sciences, and commercial caliber control.
an infection, and d the quantity that didn't obtain a major an infection. permit be the likelihood of a main an infection. examine the speculation that the chance of an infection at time t, given an infection every now and then 1, . . . , t y 1, is usually , for t s 2, three. express that ˆ s Ž3a q 2 b q c .rŽ3a q 3b q 2 c q d .. 1.33 discuss with quadratic shape Ž1.16.. a. be certain that the matrix quoted within the textual content for ⌺y1 is the inverse of zero ⌺0. b. exhibit that Ž1.16. simplifies to Pearson's statistic Ž1.15.. c. For the z S.
dialogue refers to a unmarried multinomial pattern, however the similar checks follow with self sufficient multinomial samples. 3.2.1 Pearson and Likelihood-Ratio Chi-Squared exams In part 1.5.2 we brought the Pearson X 2 statistic Ž1.15. for exams approximately multinomial chances. A try out of H0 : independence makes use of X 2 with n i j as opposed to n i and with i j s n iq qj instead of i . the following i j s E Ž n i j . less than H0 . frequently, Ä iq four and Äqj four are unknown. Their ML estimates are the pattern.
1. to the contrary, in view that Ä ˆ i j four require estimating Ä iq four and Äqj four, through part 1.5.6 df s Ž IJ y 1 . y Ž I y 1 . y Ž J y 1 . s Ž I y 1 . Ž J y 1 . . the scale of Ä iq four and Äqj four replicate the restrictions Ý i iqs Ý jqj s 1. R. A. Fisher Ž1922. corrected Pearson's blunders Žsee part 16.2.. His article brought the suggestion of levels of freedom. ŽPearson had handled an listed kinfolk of chi-squared distributions yet had now not dealt explicitly with ''degrees of freedom.''. The.
probability we use the priceless end result E ž Ѩ 2 Li Ѩ␤ h Ѩ␤ j / ž /ž / s yE Ѩ Li Ѩ Li Ѩ␤ h Ѩ␤ j , 138 creation TO GENERALIZED LINEAR versions which holds for exponential households ŽCox and Hinkley 1974, Sec. 4.8.. hence, E ž Ѩ 2 Li Ѩ␤ h Ѩ␤ j / s yE s Ž Yi y i . x i h Ѩ i Ž Yi y i . x i j Ѩ i var Ž Yi . Ѩi var Ž Yi . Ѩi yx i h x i j var Ž Yi . ž / from Ž 4.21 . 2 Ѩ i . Ѩi when you consider that LŽ␤ . s Ý i L i , ž E y Ѩ 2 LŽ ␤ . Ѩ␤ h Ѩ␤ j / N s xih xi j Ý is1 var Ž Yi .
Ž yi y i . x i j Ѩ i s zero, ® Ž i . Ѩi j s 1, . . . , p, Ž 4.45 . the place i s gy1 ŽÝ j ␤ j x i j . and ®Ž i . s varŽ Yi .. those equations set the rating services Ä u j Ž␤ .4 , that are derivatives of the log chance with admire to Ä ␤ j four , equivalent to zero. As we famous in part 4.4.4, the chance equations rely on the assumed distribution for Yi basically via i and ®Ž i .. the alternative of distribution determines the mean᎐variance dating ®Ž i .. 4.7.1 Mean–Variance.


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Espanyol are preparing to sell Manchester United target Hector Moreno, according to the TMW website.
Moreno has been heavily linked with a move for the midfielder as Louis Van Gaal seeks to add some more to his squad.
And they have been boosted by reports that the Catalans have already identified a replacement for the Mexico international ahead of the January market.
Fiorentina's Egypt defender Ahmed Hagazi is on Espanyol's radar and a winter transfer window move could be on with the 23 year-old struggling for minutes.


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Published 11 months ago by JanakaDombawela
I created my symbolic link with
php artisan storage:link
I save my files in following function:
Storage::put( Carbon::now()->format( 'Y' ) . '/' . Carbon::now()->format( 'm' ), 'file.txt' );
config/filesystems.php configurations:
'local' => [
'driver' => 'local',
'root' => storage_path('uploads'),
'public' => [
'driver' => 'local',
'root' => storage_path('uploads'),
'url' => env('APP_URL').'/storage',
'visibility' => 'public',
The files are saved in the
storage/uploads/2017/10 directory, which is what I want.
I access them as follows:
which outputs:
http://localhost/mysite/public/storage/2017/10/file.txt and it gives 404.
When I try to enter
http://localhost/mysite/public/storage it shows empty directory, not a 404.
Can you guys give any suggestions or ideas? Help is appreciated. Thanks.
@Dry7 This outputs:
/storage/2017/10/file.txt but still 404 :(
the symbolic link command makes a link to storage/public so you should put your files there (or in a subfolder) or make an additional symbolic link
Please sign in or create an account to participate in this conversation.


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The race is open to all, licensed or non-licensed athletes, who are at least 14 years old on race day and form a team with an adult. Two underage children who are both at least 16 years old on race day can compete in the same team. A parental permission is mandatory for underage children (example available here).
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The 2018 Triathlete's guide is available here.


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Do You Lose Weight When You're Sleeping
It is used to treat indigestion, gas pains, soothing a churning stomach, and to cure low stomach acidity.
Experts are warning about the dangerous consequences of a weight loss method known as the Sleeping Beauty diet. If you do manage to wake up two pounds lighter you will wake up being potentially addicted to sedative pills which is not good news. Being addicted to sedative pills means one day. When it comes to weight loss, there are plenty of pieces to the puzzle. And the big ones include diet, exercise, and sleep. If youre skimping on your zzzs, the price that you pay could be more than a grumpy morning. Time and again, research has shown that lack of sleep can lead to weight gain. Why? These habits can wreak havoc with their weight-loss plan because there is less access to nutritious meals at night. And, again, nature is working against you When youre sleep deprived, youre more likely to crave food high in fat and calories, says Belenky. He also says that when you are lacking sleep, your body ends up. While quietly sleeping someone who weighs 150 will burn at least 95 calories per hour, and if you weight 115 you will burn 42 calories in that same hour. Calories. If you do not experience REM sleep, you are not sleeping deeply enough to burn optimum calories. Avoid using the snooze button on your alarm clock this. Just because youre resting doesnt mean you cant burn fat! If you get your metabolism and nutrition in check, sleep can be a time to burn fat. Learn how!. If your diet focuses on getting lots of good quality protein and fats, youre well on the way to both good health and weight loss. This isnt the whole story. What about when you are too depressed to exercise, eat right, or work. How do you simply get out of bed?. And I wondered why running made me gain weight. 4. Best detox drink for weight loss fast.
7 Ways You're Destroying Your Sleep Cycle
Are you concerned about your weight and you think that you could avoid gaining weight while sleeping? You are. It loads your body up with calories that it wont be able to burn, making you gain more fat. Whats. Whats more, skipping dinner can increase your feelings of anxiety, and make you lose muscle and gain fat. Can sleep disorders cause weight gain? Well, if sleeping well can help you lose weight, it would make sense.
Sleeping better can help you lose weight
When it comes to weight loss, there are plenty of pieces to the puzzle. And the big ones include diet, exercise, and sleep. If youre skimping on your zzzs, the price that you pay could be more than a grumpy morning. Time and again, research has shown that lack of sleep can lead to weight gain. Why?
Best and easiest diet for weight loss
If you want to lose weight you should get more sleep, says the Daily Mail. The newspaper says that going on. While the idea of sleeping yourself thin seem like a dream come true, these claims are rather unfortunately not wholly supported by the research behind them. They are based on a study that.If you are asking yourself how many calories do you burn sleeping. During sleep, a persons weight and the number of hours he or she sleeps determines.How lack of sleep could be stalling your ability to lose weight and keep it off. But once youre in your thirties, ghrelins effects can seem pretty.Read Should You Be Trying The Whole30 Diet? Ladies and gents, meet the Sleeping Beauty diet a programme that promotes weight loss through sleep. Famous fans have included the late Elvis Presley, and in theory were 100 on board come on, even we cant polish off a family sized bag of Doritos.So this is my 3rd pregnancy (its a girl) and throughout this whole pregnancy I have only gained a total of 5lbs on and off. Im measuring just fine, baby isAnd though he cant say for sure, Elder believes that one of the main reasons getting enough sleep is linked to successful weight loss is that it provides you with the drive you need to stick to your goals. Other research has shown that people who are sleepy often say they exercise less, opting instead for.
How much weight did you lose first week slimming world
Hopefully the do you lose weight when you're sleeping of people would have found that as fishy as I did. We combine the old-world charm of exemplary customer service with the most advanced of medical technology to help our customers achieve perfect health, wellness and fitness. Generally, what we do know about consumer do you lose weight when you're sleeping is that as many persons are attempting to lose weight (40 percent of women, 25 percent of men) as are actively seeking to maintain current weight (30 percent each) (Schlundt).


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To the Editor:
"You're Out! Clean Out Your Office! Now for Some Nice Parting Gifts" (June 11) astutely lists feelings of guilt and old ties of loyalty among the reasons for companies' largess in offering millions of dollars to separated executives. A single parent with two young children and elderly parents, I, too, along with the mentioned 10,000 workers, have been thrown in the street by well-to-do firms for unstated reasons, and in one case was not even handed required notice or the typical two or four weeks' worth of pay.
After reading the article, it occurred to me that company managers might be more inclined to be generous with someone perceived to be like themselves, someone they identify with more readily. After all, with all the corporate restructuring, their own heads could be next on the chopping block -- in which case, given the historical lack of compassion, bitterly wept tears would satisfy a sense of justice more than, say, two months' worth of increased salary and a renamed board room. CRISTINA C. DILLON Seattle, June 11 The writer is a doctoral candidate in English at the University of Maryland.Continue reading the main story


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