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Founded in 1883, Board of Church Extension was the ministry of the Christian Church (Disciples of Christ) in the United States and Canada that helped congregations with capital project planning and financing. We have come to realize that for your congregation to be strong in the 21st century, you need more than just a building and financial plan to carry out God’s mission in your local community.
In 2012, Board of Church Extension (dba Church Extension) created a new organizational model to better serve the needs of contemporary Disciples congregations through two independent, but related ministries:
Hope Partnership for Missional Transformation, in partnership with Higher Education Leadership Ministries, Disciples Home Missions, regions, seminaries and ecumenical partners, provides leader development and congregational ministry planning.
Disciples Church Extension Fund (DCEF) provides building and capital planning services, fundraising consultations, and makes loans for capital projects.
Church Extension Financial and Missional Resources, Inc. (Church Extension Resources) provides administrative support to both Hope Partnership and Disciples Church Extension Fund, which report to the General Assembly of the Christian Church (Disciples of Christ) through Church Extension Resources.
This new model seeks to achieve the outcome of thriving communities of faith who bear witness to God’s love. The design is based on the premise that implementation of clear and vital congregational mission will be achieved most effectively when DCEF focuses on helping congregational leaders generate and leverage capital assets and resources for this mission.
Likewise, strong congregational mission requires the calling, forming and support of leaders, who, with the help of Hope Partnership for Missional Transformation (now Hope Partnership Services), can effectively use these assets and resources to help their congregations live out God’s mission how and where they feel called to do so. | 2023-14/0000/en_head.json.gz/1300 | {"url": "https://www.hopepmt.org/history/", "partition": "head_middle", "language": "en", "source_domain": "www.hopepmt.org", "date_download": "2023-03-20T08:47:22Z", "digest": "sha1:KFF4HHZCUUTRWB5EOYRDF65SGWYFJR3M"} | {"ccnet_length": [[0, 1997, 1997.0]], "ccnet_original_length": [[0, 1997, 3741.0]], "ccnet_nlines": [[0, 1997, 7.0]], "ccnet_original_nlines": [[0, 1997, 93.0]], "ccnet_language_score": [[0, 1997, 0.92]], "ccnet_perplexity": [[0, 1997, 267.6]], "ccnet_bucket": [[0, 1997, 0.0]], "rps_doc_curly_bracket": [[0, 1997, 0.0]], "rps_doc_ldnoobw_words": [[0, 1997, 0.0]], "rps_doc_lorem_ipsum": [[0, 1997, 0.0]], "rps_doc_stop_word_fraction": [[0, 1997, 0.35240964]], "rps_doc_ut1_blacklist": [[0, 1997, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1997, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1997, 0.09335727]], "rps_doc_frac_chars_dupe_6grams": [[0, 1997, 0.04428486]], "rps_doc_frac_chars_dupe_7grams": [[0, 1997, 0.04428486]], "rps_doc_frac_chars_dupe_8grams": [[0, 1997, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1997, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1997, 0.07181329]], "rps_doc_frac_chars_top_3gram": [[0, 1997, 0.01555955]], "rps_doc_frac_chars_top_4gram": [[0, 1997, 0.02633154]], "rps_doc_frac_all_caps_words": [[0, 1997, 0.0060241]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1997, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1997, 0.13253012]], "rps_doc_frac_unique_words": [[0, 1997, 0.52264808]], "rps_doc_mean_word_length": [[0, 1997, 5.82229965]], "rps_doc_symbol_to_word_ratio": [[0, 1997, 0.0]], "rps_doc_unigram_entropy": [[0, 1997, 4.63588655]], "rps_doc_word_count": [[0, 1997, 287.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 400, 1.0], [400, 608, 0.0], [608, 851, 1.0], [851, 1004, 1.0], [1004, 1303, 1.0], [1303, 1664, 1.0], [1664, 1997, 1.0]], "rps_lines_javascript_counts": [[0, 400, 0.0], [400, 608, 0.0], [608, 851, 0.0], [851, 1004, 0.0], [1004, 1303, 0.0], [1303, 1664, 0.0], [1664, 1997, 0.0]], "rps_lines_num_words": [[0, 400, 67.0], [400, 608, 29.0], [608, 851, 27.0], [851, 1004, 19.0], [1004, 1303, 39.0], [1303, 1664, 56.0], [1664, 1997, 50.0]], "rps_lines_numerical_chars_fraction": [[0, 400, 0.01526718], [400, 608, 0.01980198], [608, 851, 0.0], [851, 1004, 0.0], [1004, 1303, 0.0], [1303, 1664, 0.0], [1664, 1997, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 400, 0.0], [400, 608, 0.0], [608, 851, 0.0], [851, 1004, 0.0], [1004, 1303, 0.0], [1303, 1664, 0.0], [1664, 1997, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 400, 0.0325], [400, 608, 0.03365385], [608, 851, 0.04526749], [851, 1004, 0.05228758], [1004, 1303, 0.08026756], [1303, 1664, 0.01939058], [1664, 1997, 0.02702703]], "rps_doc_ml_palm_score": [[0, 1997, 0.00143462]], "rps_doc_ml_wikipedia_score": [[0, 1997, null]], "rps_doc_ml_wikiref_score": [[0, 1997, 0.0278129]], "rps_doc_books_importance": [[0, 1997, -127.7767455]], "rps_doc_openwebtext_importance": [[0, 1997, -15.74589558]], "rps_doc_wikipedia_importance": [[0, 1997, -28.08425175]], "rps_doc_num_sentences": [[0, 1997, 9.0]]} |
Healing is for
We are so glad you're here.
We are a small, affirming private mental health care practice tucked into the Research Triangle region of North Carolina.
We specialize in LGBTQIA+ individuals, families, and relationships. With over 10 years experience in mental healthcare, we are happy to serve a diverse clientele motivated toward improving their relationships and lives, while maintaining alignment with their values. | 2023-14/0000/en_head.json.gz/1301 | {"url": "https://www.horizonsmft.com/", "partition": "head_middle", "language": "en", "source_domain": "www.horizonsmft.com", "date_download": "2023-03-20T10:27:49Z", "digest": "sha1:D73FNFZW564XILQNGAK7LR75RKBHR4EF"} | {"ccnet_length": [[0, 431, 431.0]], "ccnet_original_length": [[0, 431, 805.0]], "ccnet_nlines": [[0, 431, 4.0]], "ccnet_original_nlines": [[0, 431, 25.0]], "ccnet_language_score": [[0, 431, 0.93]], "ccnet_perplexity": [[0, 431, 179.5]], "ccnet_bucket": [[0, 431, 0.0]], "rps_doc_curly_bracket": [[0, 431, 0.0]], "rps_doc_ldnoobw_words": [[0, 431, 0.0]], "rps_doc_lorem_ipsum": [[0, 431, 0.0]], "rps_doc_stop_word_fraction": [[0, 431, 0.33766234]], "rps_doc_ut1_blacklist": [[0, 431, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 431, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 431, 0.04213483]], "rps_doc_frac_chars_top_3gram": [[0, 431, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 431, 0.0]], "rps_doc_frac_all_caps_words": [[0, 431, 0.01298701]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 431, 0.0]], "rps_doc_frac_no_alph_words": [[0, 431, 0.15584416]], "rps_doc_frac_unique_words": [[0, 431, 0.81538462]], "rps_doc_mean_word_length": [[0, 431, 5.47692308]], "rps_doc_symbol_to_word_ratio": [[0, 431, 0.0]], "rps_doc_unigram_entropy": [[0, 431, 3.88907843]], "rps_doc_word_count": [[0, 431, 65.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 15, 0.0], [15, 43, 1.0], [43, 165, 1.0], [165, 431, 1.0]], "rps_lines_javascript_counts": [[0, 15, 0.0], [15, 43, 0.0], [43, 165, 0.0], [165, 431, 0.0]], "rps_lines_num_words": [[0, 15, 3.0], [15, 43, 6.0], [43, 165, 19.0], [165, 431, 37.0]], "rps_lines_numerical_chars_fraction": [[0, 15, 0.0], [15, 43, 0.0], [43, 165, 0.0], [165, 431, 0.00772201]], "rps_lines_start_with_bulletpoint": [[0, 15, 0.0], [15, 43, 0.0], [43, 165, 0.0], [165, 431, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 15, 0.06666667], [15, 43, 0.03571429], [43, 165, 0.04098361], [165, 431, 0.03383459]], "rps_doc_ml_palm_score": [[0, 431, 0.0918138]], "rps_doc_ml_wikipedia_score": [[0, 431, null]], "rps_doc_ml_wikiref_score": [[0, 431, 0.00045455]], "rps_doc_books_importance": [[0, 431, -8.65629544]], "rps_doc_openwebtext_importance": [[0, 431, 1.7478996]], "rps_doc_wikipedia_importance": [[0, 431, -24.85052421]], "rps_doc_num_sentences": [[0, 431, 4.0]]} |
Hotel Massage Hong Kong
Hotel Massage service in Hong Kong
Questions & Essential info
Thai massage is a type of massage in Thai style that involves stretching and deep massage. This form of bodywork is usually performed on the floor, and the client wears comfortable clothes that allow for movement. No oils are used in Thai massage. It is known in Thailand as “nuat phaen boran”, literally translated to “the ancient-manner massage.” In Thailand, Thai massage is one of the branches of Traditional Thai Medicine (TTM), now recognized and regulated by the government, and is widely considered to be a medical discipline used for the treatment of a wide variety of ailments.
The founder of Thai massage and medicine is said to have been Shivago Komarpaj, who is said in the Pali Buddhist Canon to have been the Buddha’s physician over 2500 years ago. In fact, the history Thai massage is more complex than this legend of a single founded would suggest. Thai massage, like Traditional Thai Medicine more generally, is a combination of influences from Indian, Chinese, Southeast Asian cultural spheres and traditions of medicine. The art as it is practiced today is likely to be the product of a 19th century synthesis of various healing traditions from all over the kingdom.
Generally speaking, practitioners of modern Thai massage operate on the theory that the body is permeated with “lom,” or “air,” which is inhaled into the lungs and which subsequently travels throughout the body along 72,000 pathways called “sen,” or “vessels.” Typically, massage therapists manipulate a handful of major sen lines by pressing certain points along the lines. In most models, the sen originate at the navel and spread throughout the body to terminate at the orifices. A significant part of the practice of Thai massage also includes yoga-like stretches which are intended to stimulate the sen and move lom through the body via a pumping action which is connected with the patient’s breathing.
The theory of sen and lom is often translated into English as “meridians” and “energy.” While there are some superficial similarities to Chinese meridian theory, the Thai system is markedly different as the sen are unconnected from the internal organs.
* Your Hotel:
* Your Room Number:
Hotel Phone Number:
When would you like your massage? (Date and time)
Full body massage - 30min. $200 60min. $400 90min. $550 120min. $700 180min. $1000
Foot massage - 30min. $200 60min. $400 90min. $550 120min. $700
Spa Massage - 120min. $700
* Field Label
The total time of the service must be at least 60 minutes. You can make any combination.
We will respond immediately, we have a really fast service! | 2023-14/0000/en_head.json.gz/1302 | {"url": "https://www.hotelmassage.hk/services/thai-massage/", "partition": "head_middle", "language": "en", "source_domain": "www.hotelmassage.hk", "date_download": "2023-03-20T09:25:32Z", "digest": "sha1:4Z7A774E3A3XSZNU6PYOYI5KISSTEDRJ"} | {"ccnet_length": [[0, 2674, 2674.0]], "ccnet_original_length": [[0, 2674, 2967.0]], "ccnet_nlines": [[0, 2674, 17.0]], "ccnet_original_nlines": [[0, 2674, 31.0]], "ccnet_language_score": [[0, 2674, 0.95]], "ccnet_perplexity": [[0, 2674, 261.6]], "ccnet_bucket": [[0, 2674, 0.0]], "rps_doc_curly_bracket": [[0, 2674, 0.0]], "rps_doc_ldnoobw_words": [[0, 2674, 0.0]], "rps_doc_lorem_ipsum": [[0, 2674, 0.0]], "rps_doc_stop_word_fraction": [[0, 2674, 0.35227273]], "rps_doc_ut1_blacklist": [[0, 2674, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2674, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2674, 0.03712297]], "rps_doc_frac_chars_dupe_6grams": [[0, 2674, 0.03712297]], "rps_doc_frac_chars_dupe_7grams": [[0, 2674, 0.03712297]], "rps_doc_frac_chars_dupe_8grams": [[0, 2674, 0.03712297]], "rps_doc_frac_chars_dupe_9grams": [[0, 2674, 0.03712297]], "rps_doc_frac_chars_top_2gram": [[0, 2674, 0.04083527]], "rps_doc_frac_chars_top_3gram": [[0, 2674, 0.01809745]], "rps_doc_frac_chars_top_4gram": [[0, 2674, 0.01856148]], "rps_doc_frac_all_caps_words": [[0, 2674, 0.00378788]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2674, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2674, 0.1875]], "rps_doc_frac_unique_words": [[0, 2674, 0.53424658]], "rps_doc_mean_word_length": [[0, 2674, 4.92009132]], "rps_doc_symbol_to_word_ratio": [[0, 2674, 0.0]], "rps_doc_unigram_entropy": [[0, 2674, 4.94888823]], "rps_doc_word_count": [[0, 2674, 438.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 24, 0.0], [24, 59, 0.0], [59, 86, 0.0], [86, 674, 1.0], [674, 1273, 1.0], [1273, 1981, 1.0], [1981, 2234, 1.0], [2234, 2248, 0.0], [2248, 2268, 0.0], [2268, 2288, 0.0], [2288, 2338, 0.0], [2338, 2421, 0.0], [2421, 2485, 0.0], [2485, 2512, 0.0], [2512, 2526, 0.0], [2526, 2615, 1.0], [2615, 2674, 1.0]], "rps_lines_javascript_counts": [[0, 24, 0.0], [24, 59, 0.0], [59, 86, 0.0], [86, 674, 0.0], [674, 1273, 0.0], [1273, 1981, 0.0], [1981, 2234, 0.0], [2234, 2248, 0.0], [2248, 2268, 0.0], [2268, 2288, 0.0], [2288, 2338, 0.0], [2338, 2421, 0.0], [2421, 2485, 0.0], [2485, 2512, 0.0], [2512, 2526, 0.0], [2526, 2615, 0.0], [2615, 2674, 0.0]], "rps_lines_num_words": [[0, 24, 4.0], [24, 59, 6.0], [59, 86, 3.0], [86, 674, 98.0], [674, 1273, 101.0], [1273, 1981, 113.0], [1981, 2234, 40.0], [2234, 2248, 2.0], [2248, 2268, 3.0], [2268, 2288, 3.0], [2288, 2338, 9.0], [2338, 2421, 13.0], [2421, 2485, 10.0], [2485, 2512, 4.0], [2512, 2526, 2.0], [2526, 2615, 17.0], [2615, 2674, 10.0]], "rps_lines_numerical_chars_fraction": [[0, 24, 0.0], [24, 59, 0.0], [59, 86, 0.0], [86, 674, 0.0], [674, 1273, 0.01020408], [1273, 1981, 0.00719424], [1981, 2234, 0.0], [2234, 2248, 0.0], [2248, 2268, 0.0], [2268, 2288, 0.0], [2288, 2338, 0.0], [2338, 2421, 0.4], [2421, 2485, 0.39622642], [2485, 2512, 0.27272727], [2512, 2526, 0.0], [2526, 2615, 0.02325581], [2615, 2674, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 24, 0.0], [24, 59, 0.0], [59, 86, 0.0], [86, 674, 0.0], [674, 1273, 0.0], [1273, 1981, 0.0], [1981, 2234, 0.0], [2234, 2248, 0.0], [2248, 2268, 0.0], [2268, 2288, 0.0], [2288, 2338, 0.0], [2338, 2421, 0.0], [2421, 2485, 0.0], [2485, 2512, 0.0], [2512, 2526, 0.0], [2526, 2615, 0.0], [2615, 2674, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 24, 0.16666667], [24, 59, 0.11428571], [59, 86, 0.07407407], [86, 674, 0.02721088], [674, 1273, 0.03171953], [1273, 1981, 0.00847458], [1981, 2234, 0.01976285], [2234, 2248, 0.14285714], [2248, 2268, 0.15], [2268, 2288, 0.15], [2288, 2338, 0.04], [2338, 2421, 0.01204819], [2421, 2485, 0.015625], [2485, 2512, 0.07407407], [2512, 2526, 0.14285714], [2526, 2615, 0.02247191], [2615, 2674, 0.01694915]], "rps_doc_ml_palm_score": [[0, 2674, 0.52810776]], "rps_doc_ml_wikipedia_score": [[0, 2674, null]], "rps_doc_ml_wikiref_score": [[0, 2674, 0.20219445]], "rps_doc_books_importance": [[0, 2674, -91.1778863]], "rps_doc_openwebtext_importance": [[0, 2674, 33.65594741]], "rps_doc_wikipedia_importance": [[0, 2674, -17.82353998]], "rps_doc_num_sentences": [[0, 2674, 29.0]]} |
Sterling, Virginia Hours and Locations
Category: Automobile Renting
Automobile Renting
Get all the latest information about Avis
Avis Car Rental and its subsidiaries operate one of the world's best-known car rental brands with approximately 5,500 locations in more than 165 countries. Avis has a long history of innovation in the car rental industry and is one of the world's top brands for customer loyalty. Avis is owned by Avis Budget Group, Inc. (NASDAQ: CAR), which operates and licenses the brand throughout the world.
Founded in 1946 by Warren
There are over 1,000 Avis Rent A Car locations in the US.
https://www.avis.com
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Avis Rent A Car Hours And Locations for Sterling, Virginia VA
1. Avis Car Rental - Sterling
20990 Dulles Town Circle
23480 Autopilot Drive | 2023-14/0000/en_head.json.gz/1303 | {"url": "https://www.hoursmap.com/c/sterling-va/avis+rent+a+car-hours-locations-s1257595", "partition": "head_middle", "language": "en", "source_domain": "www.hoursmap.com", "date_download": "2023-03-20T10:37:20Z", "digest": "sha1:73K3QO36UKR6J2NVL7J4ILAUPM6VBYEW"} | {"ccnet_length": [[0, 898, 898.0]], "ccnet_original_length": [[0, 898, 4165.0]], "ccnet_nlines": [[0, 898, 16.0]], "ccnet_original_nlines": [[0, 898, 201.0]], "ccnet_language_score": [[0, 898, 0.85]], "ccnet_perplexity": [[0, 898, 338.3]], "ccnet_bucket": [[0, 898, 0.0]], "rps_doc_curly_bracket": [[0, 898, 0.0]], "rps_doc_ldnoobw_words": [[0, 898, 0.0]], "rps_doc_lorem_ipsum": [[0, 898, 0.0]], "rps_doc_stop_word_fraction": [[0, 898, 0.24590164]], "rps_doc_ut1_blacklist": [[0, 898, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 898, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 898, 0.10584958]], "rps_doc_frac_chars_dupe_6grams": [[0, 898, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 898, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 898, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 898, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 898, 0.06685237]], "rps_doc_frac_chars_top_3gram": [[0, 898, 0.07520891]], "rps_doc_frac_chars_top_4gram": [[0, 898, 0.10027855]], "rps_doc_frac_all_caps_words": [[0, 898, 0.06010929]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 898, 0.0625]], "rps_doc_frac_no_alph_words": [[0, 898, 0.18579235]], "rps_doc_frac_unique_words": [[0, 898, 0.52980132]], "rps_doc_mean_word_length": [[0, 898, 4.75496689]], "rps_doc_symbol_to_word_ratio": [[0, 898, 0.00546448]], "rps_doc_unigram_entropy": [[0, 898, 4.01946929]], "rps_doc_word_count": [[0, 898, 151.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 39, 0.0], [39, 68, 0.0], [68, 87, 0.0], [87, 129, 0.0], [129, 525, 1.0], [525, 551, 0.0], [551, 609, 1.0], [609, 630, 0.0], [630, 660, 0.0], [660, 695, 0.0], [695, 730, 1.0], [730, 760, 0.0], [760, 822, 0.0], [822, 852, 0.0], [852, 877, 0.0], [877, 898, 0.0]], "rps_lines_javascript_counts": [[0, 39, 0.0], [39, 68, 0.0], [68, 87, 0.0], [87, 129, 0.0], [129, 525, 0.0], [525, 551, 0.0], [551, 609, 0.0], [609, 630, 0.0], [630, 660, 0.0], [660, 695, 0.0], [695, 730, 0.0], [730, 760, 0.0], [760, 822, 0.0], [822, 852, 0.0], [852, 877, 0.0], [877, 898, 0.0]], "rps_lines_num_words": [[0, 39, 5.0], [39, 68, 3.0], [68, 87, 2.0], [87, 129, 7.0], [129, 525, 66.0], [525, 551, 5.0], [551, 609, 12.0], [609, 630, 1.0], [630, 660, 6.0], [660, 695, 9.0], [695, 730, 5.0], [730, 760, 7.0], [760, 822, 11.0], [822, 852, 5.0], [852, 877, 4.0], [877, 898, 3.0]], "rps_lines_numerical_chars_fraction": [[0, 39, 0.0], [39, 68, 0.0], [68, 87, 0.0], [87, 129, 0.0], [129, 525, 0.01832461], [525, 551, 0.16], [551, 609, 0.07272727], [609, 630, 0.0], [630, 660, 0.0], [660, 695, 0.0], [695, 730, 0.0], [730, 760, 0.0], [760, 822, 0.0], [822, 852, 0.03846154], [852, 877, 0.20833333], [877, 898, 0.23809524]], "rps_lines_start_with_bulletpoint": [[0, 39, 0.0], [39, 68, 0.0], [68, 87, 0.0], [87, 129, 0.0], [129, 525, 0.0], [525, 551, 0.0], [551, 609, 0.0], [609, 630, 0.0], [630, 660, 0.0], [660, 695, 0.0], [695, 730, 0.0], [730, 760, 0.0], [760, 822, 0.0], [822, 852, 0.0], [852, 877, 0.0], [877, 898, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 39, 0.1025641], [39, 68, 0.10344828], [68, 87, 0.10526316], [87, 129, 0.04761905], [129, 525, 0.04545455], [525, 551, 0.07692308], [551, 609, 0.12068966], [609, 630, 0.0], [630, 660, 0.2], [660, 695, 0.28571429], [695, 730, 0.05714286], [730, 760, 0.2], [760, 822, 0.17741935], [822, 852, 0.13333333], [852, 877, 0.12], [877, 898, 0.0952381]], "rps_doc_ml_palm_score": [[0, 898, 0.00140822]], "rps_doc_ml_wikipedia_score": [[0, 898, null]], "rps_doc_ml_wikiref_score": [[0, 898, 0.09733069]], "rps_doc_books_importance": [[0, 898, -78.62494861]], "rps_doc_openwebtext_importance": [[0, 898, -21.34879418]], "rps_doc_wikipedia_importance": [[0, 898, -22.99117835]], "rps_doc_num_sentences": [[0, 898, 10.0]]} |
Tag Archives: David Tyler
Sainsbury’s appoints new non-executive chairman
16th July 2018 News Comments Off on Sainsbury’s appoints new non-executive chairman
Sainsbury’s has appointed Martin Scicluna as its new non-executive chairman. He will join the board as chairman-designate and non-executive director on November 1. Martin is chairman of RSA Insurance and also currently chairman of Great Portland Estates. Previous roles include senior independent director and chair of the audit committee of …
Sainsbury’s appoints Jo Harlow as a non-executive director
12th September 2017 News Comments Off on Sainsbury’s appoints Jo Harlow as a non-executive director
Sainsbury’s has announced that Jo Harlow will join its board as a non-executive director with immediate effect. She will be a member of the remuneration committee and the nomination committee. A US national, Jo has a background in consumer-facing businesses having spent eight years at P&G and 11 years at … | 2023-14/0000/en_head.json.gz/1304 | {"url": "https://www.housewareslive.net/tag/david-tyler/", "partition": "head_middle", "language": "en", "source_domain": "www.housewareslive.net", "date_download": "2023-03-20T09:22:58Z", "digest": "sha1:BIXMIWUK5QEVVD4QGPAMEHFCNZ6ZLFTQ"} | {"ccnet_length": [[0, 968, 968.0]], "ccnet_original_length": [[0, 968, 3911.0]], "ccnet_nlines": [[0, 968, 7.0]], "ccnet_original_nlines": [[0, 968, 115.0]], "ccnet_language_score": [[0, 968, 0.97]], "ccnet_perplexity": [[0, 968, 277.9]], "ccnet_bucket": [[0, 968, 0.0]], "rps_doc_curly_bracket": [[0, 968, 0.0]], "rps_doc_ldnoobw_words": [[0, 968, 0.0]], "rps_doc_lorem_ipsum": [[0, 968, 0.0]], "rps_doc_stop_word_fraction": [[0, 968, 0.34054054]], "rps_doc_ut1_blacklist": [[0, 968, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 968, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 968, 0.27047146]], "rps_doc_frac_chars_dupe_6grams": [[0, 968, 0.1898263]], "rps_doc_frac_chars_dupe_7grams": [[0, 968, 0.12406948]], "rps_doc_frac_chars_dupe_8grams": [[0, 968, 0.12406948]], "rps_doc_frac_chars_dupe_9grams": [[0, 968, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 968, 0.0942928]], "rps_doc_frac_chars_top_3gram": [[0, 968, 0.08560794]], "rps_doc_frac_chars_top_4gram": [[0, 968, 0.08560794]], "rps_doc_frac_all_caps_words": [[0, 968, 0.02702703]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 968, 0.28571429]], "rps_doc_frac_no_alph_words": [[0, 968, 0.15675676]], "rps_doc_frac_unique_words": [[0, 968, 0.54109589]], "rps_doc_mean_word_length": [[0, 968, 5.52054795]], "rps_doc_symbol_to_word_ratio": [[0, 968, 0.01081081]], "rps_doc_unigram_entropy": [[0, 968, 4.12311395]], "rps_doc_word_count": [[0, 968, 146.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 26, 0.0], [26, 74, 0.0], [74, 158, 0.0], [158, 502, 0.0], [502, 561, 0.0], [561, 661, 0.0], [661, 968, 0.0]], "rps_lines_javascript_counts": [[0, 26, 0.0], [26, 74, 0.0], [74, 158, 0.0], [158, 502, 0.0], [502, 561, 0.0], [561, 661, 0.0], [661, 968, 0.0]], "rps_lines_num_words": [[0, 26, 4.0], [26, 74, 5.0], [74, 158, 12.0], [158, 502, 51.0], [502, 561, 8.0], [561, 661, 15.0], [661, 968, 51.0]], "rps_lines_numerical_chars_fraction": [[0, 26, 0.0], [26, 74, 0.0], [74, 158, 0.07317073], [158, 502, 0.00296736], [502, 561, 0.0], [561, 661, 0.06122449], [661, 968, 0.00664452]], "rps_lines_start_with_bulletpoint": [[0, 26, 0.0], [26, 74, 0.0], [74, 158, 0.0], [158, 502, 0.0], [502, 561, 0.0], [561, 661, 0.0], [661, 968, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 26, 0.15384615], [26, 74, 0.02083333], [74, 158, 0.05952381], [158, 502, 0.04069767], [502, 561, 0.05084746], [561, 661, 0.07], [661, 968, 0.03257329]], "rps_doc_ml_palm_score": [[0, 968, -1.07e-06]], "rps_doc_ml_wikipedia_score": [[0, 968, null]], "rps_doc_ml_wikiref_score": [[0, 968, 0.04174072]], "rps_doc_books_importance": [[0, 968, -115.44372327]], "rps_doc_openwebtext_importance": [[0, 968, 13.82927127]], "rps_doc_wikipedia_importance": [[0, 968, -17.63999704]], "rps_doc_num_sentences": [[0, 968, 6.0]]} |
הזדמנות // פוסטדוק: פילוסופיה של המדע, מדעי החינוך [טורינו 09/18] דדליין=3.5.18
מוסד מעניק: אוניברסיטת טורינו
מיקום: טורינו, איטליה
מועד: 01-09-2018
קהל יעד: בתר-דוקטורנטים/ות, דוקטורנטים/ות
פקולטות: חינוך, מדעי הרוח
דיסציפלינות: חינוך והוראה, פילוסופיה
מחקר אינטרדיסציפלינרי: היסטוריה ופילוסופיה של המדעים והרעיונות
Web address for more information
https://msio.wordpress.com/contact/open-positions/
Jan Sprenger
[email protected]
Postdoctoral Research Fellow at the University of Turin
Postdoctoral Research Fellow at the University of Turin, Italy (two years) – Department of Philosophy and Educational Sciences, University of Turin
Job category – Postdoc or similar / Fixed term
AOS – Philosophy of Science (e.g., statistics, metascience, scientific method and reform)
AOS categories – Philosophy of Science
Vacancies – 1
Location – Turin, Piedmont, Italy
Start date – 1 September 2018 (or possibly earlier)
The University of Turin (Università degli Studi di Torino) is inviting applications for a postdoctoral researcher (“assegnista di ricerca”) in the field of philosophy of science and related disciplines.
The successful candidate will work in the project “Making Scientific Inferences More Objective” (https://msio.wordpress.com/), funded by the European Research Council (ERC) and directed by Professor Jan Sprenger. He or she will be affiliated to the Department of Philosophy and Educational Sciences and the Center for Logic, Language and Cognition (LLC).
The duration of the position is two years (24 months), starting 1 September 2018. An earlier starting date can be fixed in mutual agreement.
Profile and Evaluation Criteria
Candidates must hold a PhD degree, or provide evidence of obtaining it before the end of 2018. They must be able to demonstrate their research excellence in philosophy of science. Candidates with PhD degrees outside philosophy (e.g., statistics, psychology, metascience) are welcome if they can demonstrate their aptness for the project and their expertise in philosophy of science.
Candidates are invited to check the ERC project description (https://msio.wordpress.com/project-description/). The successful candidate will primarily work on Subproject A and D. Candidates are encouraged to propose their own research plan, but it should cover one or more of the following topics: statistical inference, either from a foundational perspective or applied to particular scientific disciplines, experimental method, replication crisis, statistical and scientific reform.
Applications will be primarily evaluated on the basis of the candidates research credentials (=publications and other research activities), their fit with the project, their motivation, and the originality and soundness of the research plan. The research plan should make explicit how the proposed research will contribute to meeting the project’s goals. Generic applications or those with an obvious misfit will be discarded in the first step of the selection procedure, regardless of the candidate’s other credentials.
Members of groups that are underrepresented in academia are especially encouraged to apply.
Institutional Embedding
The University of Turin is one of Italy’s biggest universities, and one of the strongest in research, as evidenced by publication and citation track record, and various national evaluations.
The successful candidate will be a member of the Department of Philosophy and Educational Sciences (DFE, website in Italian only) at the University of the Turin, which has recently won an Department of Excellence award by the National Agency of Research Evaluation. DFE was one of only two philosophy departments in Italy that received the excellence award.
DFE is also home to several active research centers (e.g., LabOnt), among which theCenter for Logic, Language and Cognition (LLC) is closest to the profile of the position. LLC organizes diverse seminar and conference series, sustains a large international network and it hosts an outstanding group of researchers in logic, epistemology, philosophy of language and philosophy of science. The successful candidate will conduct his or her work within the structures of the LLC. Both the project and the LLC conduct their research activities in English.
Employment Terms and Conditions
The selected candidate will be appointed as a research fellow (assegnista di ricerca) for a period of two years (24 months). The fellowship (assegno) is exempt from regular income tax under Italian legislation; only social security contributions apply. The gross amount of the fellowship is 40,500 € per year, which corresponds to ca. 36,000 € net. Office space and equipment will be provided; the project also provides sufficient travel funds.
The candidate is expected to reside in Turin and to collaborate with other project members on a daily basis. Furthermore, he or she is expected to contribute to the research activities of the LLC.
For further information on the position, please contact the project leader, Professor Jan Sprenger, at [email protected]. Please make sure to include the string “ERC postdoc” in the subject line.
The only way to apply is online, via the official site for applying for open positions in the Italian academic system (Piattaforma Integrata Concorsi Atenei, in short: PICA). The official call will be visible at https://pica.cineca.it/unito/tipologia/assegni under the name “Bando assegni di ricerca – Tornata II 2018”¸ with the code “ASSEGNI-II-2018”.
Candidates should submit the following documents, preferably (=to the extent that the electronic system allows) in a single pdf file:
–a cover letter;
–a writing sample;
–a research plan (about two pages, max. 1200 words);
–exactly two letters of recommendation.
If candidates need to choose between three or more referees, they are advised to prioritize his or her familiarity with their work over scholarly fame. Letters need not be confidential, but if referees prefers a confidential reference, they should send an email to [email protected] with “ERC Postdoc: Letter of Recommendation for [candidate’s name]” in the subject line.
Presumably, the deadline for applications will be 3 May 2018 at 13:00 Italian time (TBC, please check again once the call is officially published). Skype interviews will be held later in May and information about the outcome will be sent as soon as possible afterwards.
More information on the application and selection process will be given on the project website (https://msio.wordpress.com/contact/open-positions/) once the call is officially published and the application window is opening up.
Web address to apply
https://pica.cineca.it/unito/tipologia/assegni
Hard deadline
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Hummel Winters Insurance Blog
Client Meeting by Goodluz
When it comes to buying insurance, you have two primary options available to you: independent agents like us, and captive agents. While both can provide insurance services, these two types of insurance agents are not the same, and it's important to understand the differences.
Captive Insurance Agents
A captive agent works for a single insurance company, either as an employee of that company or as an independent contractor. This means that a captive insurance agent will be limited to the specific insurance products offered by that particular company, so they won't be able to help you if you need a type of insurance they don't offer, or shop around to find the best deals on the market.
The insurance company may also push certain products, so there is no guarantee that you are truly getting what is best for you, and not just what is best for the company.
Independent Insurance Agents
An independent agent is not controlled by any one insurance company, and instead works with multiple insurers. This means independent agents have access to all of the insurance products and services offered by all of the companies they represent.
As a result, it's often the case that an independent agent will be able to help you with all of the products you need, even if those products come from multiple insurance companies.
As an independent insurance agency, we are not bound to a single company and can assist you with insurance products from multiple providers. This enables us to shop around to get you the best possible rates for you. We offer a wide range of insurance products, and we can help tailor a plan that fits your specific needs and budget.
We also take customer service very seriously. If you need to file a claim, we’ll walk with you and work on your behalf throughout the process. We’re available for questions, and we can even regularly review your policy to ensure it is still the best possible fit for you.
To see how an independent insurance agent can help you, or to find out how much you might save by switching, get in touch with us today.
Independent Insurance Agent | 2023-14/0000/en_head.json.gz/1306 | {"url": "https://www.hummelinsurance-milan.com/blog/2021/09/how-independent-agents-are-different-from-captive-agents", "partition": "head_middle", "language": "en", "source_domain": "www.hummelinsurance-milan.com", "date_download": "2023-03-20T08:58:56Z", "digest": "sha1:PISNN6KAYJ73UOQJ7YRLR3656UANXT6A"} | {"ccnet_length": [[0, 2147, 2147.0]], "ccnet_original_length": [[0, 2147, 3878.0]], "ccnet_nlines": [[0, 2147, 13.0]], "ccnet_original_nlines": [[0, 2147, 91.0]], "ccnet_language_score": [[0, 2147, 0.97]], "ccnet_perplexity": [[0, 2147, 234.0]], "ccnet_bucket": [[0, 2147, 0.0]], "rps_doc_curly_bracket": [[0, 2147, 0.0]], "rps_doc_ldnoobw_words": [[0, 2147, 0.0]], "rps_doc_lorem_ipsum": [[0, 2147, 0.0]], "rps_doc_stop_word_fraction": [[0, 2147, 0.52757794]], "rps_doc_ut1_blacklist": [[0, 2147, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2147, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2147, 0.01725129]], "rps_doc_frac_chars_dupe_6grams": [[0, 2147, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2147, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2147, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2147, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2147, 0.0373778]], "rps_doc_frac_chars_top_3gram": [[0, 2147, 0.01380104]], "rps_doc_frac_chars_top_4gram": [[0, 2147, 0.01380104]], "rps_doc_frac_all_caps_words": [[0, 2147, 0.00239808]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2147, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2147, 0.09592326]], "rps_doc_frac_unique_words": [[0, 2147, 0.42587601]], "rps_doc_mean_word_length": [[0, 2147, 4.68733154]], "rps_doc_symbol_to_word_ratio": [[0, 2147, 0.0]], "rps_doc_unigram_entropy": [[0, 2147, 4.62451983]], "rps_doc_word_count": [[0, 2147, 371.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 30, 0.0], [30, 56, 0.0], [56, 333, 1.0], [333, 358, 0.0], [358, 749, 1.0], [749, 920, 1.0], [920, 949, 0.0], [949, 1196, 1.0], [1196, 1378, 1.0], [1378, 1711, 1.0], [1711, 1983, 1.0], [1983, 2120, 1.0], [2120, 2147, 0.0]], "rps_lines_javascript_counts": [[0, 30, 0.0], [30, 56, 0.0], [56, 333, 0.0], [333, 358, 0.0], [358, 749, 0.0], [749, 920, 0.0], [920, 949, 0.0], [949, 1196, 0.0], [1196, 1378, 0.0], [1378, 1711, 0.0], [1711, 1983, 0.0], [1983, 2120, 0.0], [2120, 2147, 0.0]], "rps_lines_num_words": [[0, 30, 4.0], [30, 56, 4.0], [56, 333, 44.0], [333, 358, 3.0], [358, 749, 70.0], [749, 920, 32.0], [920, 949, 3.0], [949, 1196, 39.0], [1196, 1378, 33.0], [1378, 1711, 60.0], [1711, 1983, 49.0], [1983, 2120, 27.0], [2120, 2147, 3.0]], "rps_lines_numerical_chars_fraction": [[0, 30, 0.0], [30, 56, 0.0], [56, 333, 0.0], [333, 358, 0.0], [358, 749, 0.0], [749, 920, 0.0], [920, 949, 0.0], [949, 1196, 0.0], [1196, 1378, 0.0], [1378, 1711, 0.0], [1711, 1983, 0.0], [1983, 2120, 0.0], [2120, 2147, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 30, 0.0], [30, 56, 0.0], [56, 333, 0.0], [333, 358, 0.0], [358, 749, 0.0], [749, 920, 0.0], [920, 949, 0.0], [949, 1196, 0.0], [1196, 1378, 0.0], [1378, 1711, 0.0], [1711, 1983, 0.0], [1983, 2120, 0.0], [2120, 2147, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 30, 0.13333333], [30, 56, 0.11538462], [56, 333, 0.00722022], [333, 358, 0.12], [358, 749, 0.00511509], [749, 920, 0.00584795], [920, 949, 0.10344828], [949, 1196, 0.00809717], [1196, 1378, 0.00549451], [1378, 1711, 0.00900901], [1711, 1983, 0.01102941], [1983, 2120, 0.00729927], [2120, 2147, 0.11111111]], "rps_doc_ml_palm_score": [[0, 2147, 0.01106578]], "rps_doc_ml_wikipedia_score": [[0, 2147, null]], "rps_doc_ml_wikiref_score": [[0, 2147, 0.00126559]], "rps_doc_books_importance": [[0, 2147, -53.60658758]], "rps_doc_openwebtext_importance": [[0, 2147, 17.83267645]], "rps_doc_wikipedia_importance": [[0, 2147, -176.33020177]], "rps_doc_num_sentences": [[0, 2147, 16.0]]} |
Intellectual Property Portfolio Boosts Value
Trademarks & Copyrights
Before it was sold, military equipment maker Eagle Industries needed an assessment of its intellectual property portfolio. We were brought in to complete a due diligence analysis of the company’s patents, trademarks, copyrights and domain names worldwide.
Eagle’s strong patent and trademark portfolio and its ability to retain market share in the key sector of the advanced technology market greatly increased the overall value of the company during its acquisition by ATK, an aerospace and defense corporation. | 2023-14/0000/en_head.json.gz/1307 | {"url": "https://www.huschblackwell.com/clientsuccesses/Intellectual-Property-Portfolio-Boosts-Value", "partition": "head_middle", "language": "en", "source_domain": "www.huschblackwell.com", "date_download": "2023-03-20T10:40:49Z", "digest": "sha1:63GY4KGHSM4VYAZQPR2M53CHPGIWSUEN"} | {"ccnet_length": [[0, 581, 581.0]], "ccnet_original_length": [[0, 581, 3219.0]], "ccnet_nlines": [[0, 581, 4.0]], "ccnet_original_nlines": [[0, 581, 78.0]], "ccnet_language_score": [[0, 581, 0.94]], "ccnet_perplexity": [[0, 581, 227.0]], "ccnet_bucket": [[0, 581, 0.0]], "rps_doc_curly_bracket": [[0, 581, 0.0]], "rps_doc_ldnoobw_words": [[0, 581, 0.0]], "rps_doc_lorem_ipsum": [[0, 581, 0.0]], "rps_doc_stop_word_fraction": [[0, 581, 0.33333333]], "rps_doc_ut1_blacklist": [[0, 581, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 581, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 581, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 581, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 581, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 581, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 581, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 581, 0.03067485]], "rps_doc_frac_chars_top_3gram": [[0, 581, 0.11860941]], "rps_doc_frac_chars_top_4gram": [[0, 581, 0.0]], "rps_doc_frac_all_caps_words": [[0, 581, 0.01041667]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 581, 0.0]], "rps_doc_frac_no_alph_words": [[0, 581, 0.10416667]], "rps_doc_frac_unique_words": [[0, 581, 0.72619048]], "rps_doc_mean_word_length": [[0, 581, 5.82142857]], "rps_doc_symbol_to_word_ratio": [[0, 581, 0.0]], "rps_doc_unigram_entropy": [[0, 581, 3.97598504]], "rps_doc_word_count": [[0, 581, 84.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 45, 0.0], [45, 69, 0.0], [69, 325, 1.0], [325, 581, 1.0]], "rps_lines_javascript_counts": [[0, 45, 0.0], [45, 69, 0.0], [69, 325, 0.0], [325, 581, 0.0]], "rps_lines_num_words": [[0, 45, 5.0], [45, 69, 2.0], [69, 325, 37.0], [325, 581, 40.0]], "rps_lines_numerical_chars_fraction": [[0, 45, 0.0], [45, 69, 0.0], [69, 325, 0.0], [325, 581, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 45, 0.0], [45, 69, 0.0], [69, 325, 0.0], [325, 581, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 45, 0.11111111], [45, 69, 0.08333333], [69, 325, 0.015625], [325, 581, 0.015625]], "rps_doc_ml_palm_score": [[0, 581, 0.00998712]], "rps_doc_ml_wikipedia_score": [[0, 581, null]], "rps_doc_ml_wikiref_score": [[0, 581, 0.00708091]], "rps_doc_books_importance": [[0, 581, -20.35795912]], "rps_doc_openwebtext_importance": [[0, 581, 12.01556283]], "rps_doc_wikipedia_importance": [[0, 581, 9.16992165]], "rps_doc_num_sentences": [[0, 581, 3.0]]} |
Department of Asian and African Studies
Regional Departments
Central Asian Seminar
Bachelor Area Studies Asia/Africa
Master African Studies
Information for Teaching Staff
Transregional Departments
Humboldt-Universität zu Berlin - Faculty of Humanities and Social Sciences - Institute of Asian and African Studies
Humboldt-Universität zu Berlin | Faculty of Humanities and Social Sciences | Department of Asian and African Studies | Regional Departments | African Studies | Studies | Study Abroad
Dar-es-Salaam
Université de Lomé
Information during the introductory lecture
Université Cheikh Anta Diop
University of Stellenbosch
Why go abroad at all?
We recommend all students of the Bachelor of Regional Studies with a focus on Africa and the Master of African Studies to plan a study period abroad. This offers students the opportunity to get to know other scientific and knowledge systems than the German, to expand their professional knowledge, to gain foreign language practice and, last but not least, to gain their own experience of life in other cultural contexts. With far-sighted planning and good organization, a stay abroad does not necessarily lead to an extension of the study period. However, if it does, the invaluable experience gained will be well worth it. In the Bachelor's program, it is advisable to plan the second or third year of study or the third, fourth or fifth semester for studying abroad. In the Master's program, the third semester or second year is best. In the final semester, i.e. in the research phase for the bachelor's/master's thesis, a targeted research stay in an African country or in an archive/specific research institution abroad may be useful. Even if you have already completed your bachelor's degree and are still unsure whether (or which) master's you want to study in Germany, there are opportunities to squeeze in a year of study abroad, not to mention that you can, of course, apply to a variety of master's programs around the world with your bachelor's degree in regional studies.
With a major in African Studies, the obvious choice is to study on the African continent itself. This not only has the advantage of learning about African perspectives on Africa-related fields of knowledge, but also of immersing oneself in the everyday life of the country in question beyond touristy sojourns. Alternatively, studying at a European or American/Australian/Asian institution may be useful. The staff of the Seminar for African Studies will try to advise you as individually as possible. For specific countries you can contact the following staff members at the seminar: Tanzania, Kenya, Uganda: Dr. Lutz Diegner; Nigeria: Yusuf Baba Gar, Susanne Gehrmann; South Africa: Dr. Annekie Joubert, Dr. Christfried Naumann; Senegal, Democratic Republic of Congo: Prof. Susanne Gehrmann; Cameroon: Dr. Pepetual Mforbe Chiangong. For all questions concerning the organization of a semester abroad, an internship, research or a language course abroad and especially for the application for study places and DAAD scholarships, the International Office[ https://www.international.hu-berlin.de/de/studierende/ins-ausland/beratung, Kontakt: [email protected] ].
In principle, there are no restrictions on the choice of host country/university; however, the recognition of examination achievements for the BA Regional Studies/the MA African Studies must be discussed individually with the student advisors/subject representatives. Existing partnership programs of the Humboldt-Universität Berlin with African universities as well as the European Erasmus programs considerably ease the organizational effort of studying abroad. Therefore, we provide below some further information on those universities/institutions with which exchange relations already exist, as well as on scholarship opportunities.
The application deadlines for study places in East and West Africa via the HU partnership programs regularly end on 31 January each year, for South Africa on 15 June each year.
[ To the application portal:[ https://www.international.hu-berlin.de/de/studierende/ins-ausland/beratung, contact: [email protected] ] will give advice.
The application deadlines for study places in East and West Africa via the HU partnership programs regularly end on 31 January each year, for South Africa on 15 June each year.[ https://www.international.hu-berlin.de/de/studierende/ins-ausland/weltweit-uv/afrika ]
Semester abroad at a partner university
University of Dar-es-Salaam, Tanzania
The University of Dar es Salaam (UDSM), founded in 1970 (its predecessor was the University College, 1961-1970), has been known as a focal point of critical academic thinking in East Africa since the beginning of its existence. Since 1998, UDSM has been a partner university of HU, so that almost every year several Humboldt students could go to Dar es Salaam for a semester abroad.
Since 2011, Tanzanian students have been able to participate in the HU Summer School for the first time, and there is an exchange of academics in both directions. The College of Arts and Social Sciences is particularly attractive, as are the Departments of Foreign Languages and Linguistics, History and Literature. In addition, Sociology, the Department of Fine and Performing Arts and Development Studies enjoy a very good reputation.
A particular asset of this primarily Anglophone university for African Studies students is the Swahili teaching and research housed at Taasisi ya Taaluma za Kiswahili (TATAKI), the national and East Africa's leading Swahili research institute.
Even regardless of subject knowledge and interests, Swahili (pre-)knowledge is a great advantage for studying at UDSM. A semester abroad is recommended for the fourth or fifth semester; in the decision-making process, experience reports of fellow students who have already done so can be viewed.
You should inform yourself in detail about the written application formalities for the exchange place of the partner university as well as the scholarship programs of the DAAD on the web pages of the International Department and then seek personal advice there from Ms. Brodien. Afterwards or parallel to this, you will receive advice on the content of your studies as well as assistance in networking with other students from Dr. Lutz Diegner.
Université Cheikh Anta Diop, Senegal
The university in Senegal's capital Dakar is named after the Senegalese Egyptologist Cheikh Anta Diop (1923-1986), a researcher who has helped shape the profile of what is probably the most renowned francophone university in West Africa to this day. UCAD was founded in 1957 and is still Senegal's largest university with a current student population of approximately 80,000. The language of instruction is exclusively French; a very good knowledge of French is therefore essential even before beginning studies in Dakar. However, it is also possible to attend in-depth French courses at the INSTITUT DE FRANÇAIS POUR LES ETUDIANTS ETRANGERS (IFE).
There is no "African Studies" subject at UCAD; rather, all of the humanities represented offer Africa-related teaching, often with a focus on francophone West Africa. The history, literature, and linguistics disciplines you are familiar with from Berlin are concentrated at the FACULTE DES LETTRES ET SCIENCES HUMAINES (FLSH). In addition to the corresponding courses at the Département d'histoire (History Department), the Département de Lettres modernes (Modern Literatures; by which is meant here primarily French-language literatures), the Département d'anglais (Anglophone Literatures), and the Département de linguistique (Linguistics Department), you can also take philosophy, sociology, geography, Arabic, or intercultural German studies at FLSH. At the Faculty of Education, FASTEF, which is in charge of teacher training, literary studies, history, geography and philosophy are also taught. It may be useful to choose something suitable from the courses offered here as well.
Foreign students are generally free to choose which seminars they would like to participate in; however, it should be discussed individually with the lecturers whether participation is possible and which examination options exist. The CENTRE DE LINGUISTIQUE APPLIQUÉE DE DAKAR (CLAD)/Language Center, which is affiliated with FLSH, offers courses in the national languages Wolof, Peul (Fulfulde), Serer and Joola for a fee. Also affiliated with UCAD is the renowned humanities research center IFAN (Institut Fondamental d'Afrique Noire), which offers its own research library in addition to the central university library and the smaller libraries of the individual subjects.
With a population of more than one million - including the surrounding sprawling suburbs such as Pikine and Guediawaye - and an infrastructure that has been modernized in the inner city in recent years, Dakar is a lively metropolis with a wide range of cultural activities and the presence of numerous local and international organizations where internships can also be completed. The cost of living is relatively high, but places in the overcrowded student dormitories are rare. The academic year begins in October, but often a few weeks later due to student or faculty strikes.
Internet presence of the university: www.ucad.sn
Contact person: Prof. Dr. Susanne Gehrmann
Fig.: Anne Schelhorn
Faculté des lettres © Anne M. Carovani
Institut Fondamental de l'Afrique
Noire (IFAN) © Anne M. Carovani
University of Stellenbosch, Südafrika
Stellenbosch University has a long tradition in the Cape region and its beginnings date back to the late 17th century. Even today, one can find traces of its historical heritage, which persists among numerous modern facilities. Stellenbosch is a well-organized university town with just over 30,000 students (with about 3,000 international students). It is located in the middle of the Boland wine-growing region, and the town is surrounded by a picturesque mountain backdrop that invites hiking and exploring. Cape Town is just under an hour away by car (50km; it takes a bit longer by train), so it's easy to visit the Cape metropolis from Stellenbosch. Students dominate the cityscape in Stellenbosch and populate the numerous bars and cafes.
The university has an excellent reputation, both in South Africa and beyond. The arts and social sciences form one of the ten faculties. Here, students of the Department of African Studies will find good connections in one of the numerous institutes:
Art Studies: Theater, Music, Visual Arts, Visual Studies
Literary Studies: Afrikaans, English, French
Linguistics: Dutch, General Linguistics and Modern Foreign Languages
Social Sciences: Geography and Environmental Studies, History, Information Sciences, Journalism, Philosophy, Political Sciences, Psychology, Social Work, Sociology and Social Anthropology
In addition, there are various research centers dedicated to specific subject areas. An insight into current cultural activities and debates at the Institute of English Studies can be found in the online magazine SLiP(Literary Project Stellenbosch).
Since the successful student protests of 'Open Stellenbosch' in 2015, English has replaced Afrikaans as the language of instruction. The International Office of Stellenbosch University offers all-round support, from arrival and departure and accommodation to study arrangements and other details.
Internet presence of the university: http://www.sun.ac.za
Contact person: Dr. Annekie Joubert
Campus Stellenbosch © Susanne & Sadiki Gehrmann
Université de Lomé, Togo
The cooperation agreement with the Université de Lomé was signed in 2013. A stay at this francophone university in the lively capital of Togo is particularly interesting due to the German-Togolese colonial past, which plays a major role in research and teaching, especially in the subjects of history and intercultural German studies. Lomé is an important commercial metropolis in West Africa.
The university was initially founded in 1970 under the name Université du Bénin (after the Gulf of Benin, on which the city of Lomé is located) and is the largest university in the country with more than 40,000 students. Students of African Studies can choose from the subjects at the Faculté des lettres et des sciences humaines (in addition to the classical subjects of linguistics, history, literature (lettres modernes = French-language literatures, English studies, German studies) also communication and media studies, sociology and anthropology) to put together an individual and interesting program. Advanced students have the opportunity to conduct research in the archives of the city's German colonial era.
The program can also be combined with an internship at the Goethe-Institut, the only German cultural institution in Africa to date that is run exclusively by local staff and provides an important forum for theater, literature and art in Togo. Instead of a full course of study, it is also possible to take French courses for foreigners at the Village du Bénin, which is affiliated with the university, during the semester break.
Internet presence of the university: www.univ-lome.tg
Further information through Prof. Dr. Susanne Gehrmann
University of Nairobi, Kenia
The University of Nairobi, abbreviated UoN, is the largest university in Kenya. Its roots date back to 1956; like the University of Dar es Salaam, it was part of the University of East Africa together with Makerere University in Kampala, Uganda, before 1970, and has since been an independent flagship of teaching and research in the entire East Africa region. Famous personalities who have worked at UoN include the continent-wide known philosopher Henry Odera Oruka (1944-1995) and the environmental activist and Nobel Peace Prize laureate Wangari Maathai (1940-2011).
Former loose partnership relations of HU with the University of Nairobi have been intensified since 2013 at the instigation of the Seminar for African Studies. Within the framework of student and scholar exchanges, UoN colleagues and students have been regular guests at our seminar since 2015; a joint research project on 'Labour and Leisure in Artistic Production and Performance' is currently being developed by UoN and HU colleagues.
The partnership activities of the Seminar for African Studies focus on the Faculty of Arts and Social Sciences of the UoN, in particular the Department of History, the Department of Linguistics and African Languages, the Kiswahili Department and the very broad Department of Literature. Thanks to the exceptionally good cooperation with Prof. Peter Wasamba (Department of African Oral Literatures), annual cooperation symposia and workshops have been organized since 2016.
All subjects are taught in English at the UoN; students with an East African focus will benefit most from a semester abroad at the UoN. As with our other African partner universities, we generally recommend the fourth (Master's) or fifth semester (Bachelor's) as the ideal time for such an endeavor.
You should inform yourself in detail about the written application formalities for the exchange place of the partner university as well as the scholarship programs of the DAAD on the web pages of the International Department and then first seek personal advice from Ms. Brodien. For your decision-making process, you can consult the experience reports of fellow students. Afterwards, or parallel to this, you can seek advice from Dr. Lutz Diegner on the content of your studies and on networking with other students.
Internet presence of the university: //www.uonbi.ac.ke
Contact person: Dr. Lutz Diegner
Eindrücke vom Campus der Universität Nairobi © Isabel Schröder
University of Pretoria, Südafrika
The University of Pretoria prides itself in offering international students a safe and stimulating environment in which to learn, and also to experience the vibrant culture of South Africa’s capital city. Situated in Gauteng Province, the University offers easy access to no less than five neighbouring universities, the National Library, national, institutional and private archives, museums, galleries and other arts and culture precincts.
International students can choose from a vast offering of undergraduate and postgraduate modules (both lecture and seminar-styled) in the Faculty of Humanities. The Department of Historical and Heritage Studies offers students modules in Global history, South African History and Heritage and Cultural Tourism. At postgraduate level, Prof Alois Mlambo’s seminar on modern African history has enjoyed great popularity from students from South Africa, Africa and further abroad. Dr Thula Simpson offers courses related to his research on the history of the African National Congress and Dr Nisa Paleker offers opportunities in African Film History. The Department of Anthropology and Archaeology has experienced impressive growth over the past few years thanks to the initiatives and input of Prof John Sharp with the Human Economy Programme. Archaeologists like Prof Innocent Pikirayi , Dr Alexander Antonites and Dr Ceri Ashley expose students to practical work on sites ranging from late Iron Age World Heritage Sites like Mapungubwe to failed mission stations in Botswana. The Sociology Department offers courses popular with exchange students, especially the Industrial Sociology programme with its focus on the platinum mining complexes around Rustenburg, led by Prof Andries Bezuidenhout. The Division for Visual Culture Studies presents undergraduate courses on visual colonialisms, visual and textual literacies, gender and feminism in postcolonial spaces. At postgraduate level they teach visual research methodologies and also focus on the politics of space. The co-ordinator of this division is Prof Amanda du Preez.
Representatives from all three clusters in the humanities recently also joined forces to launch a taught Master’s programme in African-European Cultural Relations. The courses in cultural theory, cultural history and philosophy offered in this programme already proved highly relevant to exchange students, because of the aim of de-centering the European Gaze in these courses. Besides the formal courses, this MA programme also includes a Legotla component, which offers students a highly interactive discussion forum
The School for Languages in the UP Humanities Faculty enable undergraduate students to study Afrikaans, English, Northern Sotho (SePedi), isiZulu, isiNdebele, Spanish, French, Portuguese and German. French specialist Annemarie de Beer coordinates research on genocide narratives in Francophone Africa, and offers an honours course on biography writing, Germanist Stephan Muehr's research on genocide literature in Namibia also resonates in his postgraduate teaching. Marcelline Massoua teaches courses in translation. As from 2014, this Department also offers courses in Portuguese, increasing the Department's embeddedness in the Southern African region and its commitment to facilitating research in and on Africa.
For further information, students are welcome to write directly to Prof Lize Kriel, Visual Culture Studies, Department of Visual Arts: [email protected].
Please also visit the website of the University of Pretoria: Faculty of Humanities and Department of Visual Arts.
Eindrücke vom Campus der Universität Pretoria © Laura Mareski
University of Ibadan, Nigeria
The cooperation agreement with the University of Ibadan exists since 2016; several delegation visits, workshops and research stays as exchange between HU African Studies and colleagues from Ibadan have already taken place.
The University of Ibadan was founded in 1948 and is the oldest university in Nigeria, which is reflected in its motto 'The oldest is the best'. Well-known alumni of the university include Chinua Achebe and Wole Soyinka. During the British colonial period, the institution was still part of the University of London before it was granted the status of an independent state university in 1962. In the same year, the Institute of African Studies (IAS) was opened as an interdisciplinary research institute. Also affiliated with the university is the Yoruba Language Centre, where (paid) Yoruba language courses can be taken (https://www.facebook.com/pg/Yoruba-Language-Centre-University-of-Ibadan-Ibadan-Nigeria-692246664152579/about/).
The University of Ibadan is considered one of the best universities in Nigeria, and enjoys an excellent reputation worldwide, especially in the humanities. With approximately 35,000 students, it is also one of the largest universities in the country.
Bachelor's and master's students can study at the Faculty of Arts (https://arts.ui.edu.ng/) in one of the many departments: Arabic and Islamic Studies, English, European Studies (German, Russian, French> Francophone African literature is also taught here), History, Linguistics and African Languages, and Theatre Art. Master students can additionally choose from the courses offered by the Institute of African Studies (https://ias-ibadan.org/).
There, students have the opportunity to earn master's degrees in African studies with the following concentrations: Anthropology, African History, African Visual Arts, African Music, African Law, Traditional African Medicine, Cultural and Media Studies, Diaspora and Transnational Studies, Gender Studies, and Transformation Studies in Africa.
As a typical campus university with good infrastructure (on-campus housing and shopping), the University of Ibadan is located 8 km from the city center. With over 3 million inhabitants, Ibadan is one of the largest cities in Nigeria, but life is somewhat quieter than in the 20 million metropolis of Lagos, which can be reached by car in two or three hours.
Consultation: Prof. Dr. Susanne Gehrmann
[email protected]
Universität Ibadan © Susanne Gehrmann
The ERASMUS program offers the possibility for study stays at partner universities in other European countries. After completion of the first year of study, a study stay of between three and twelve months at a foreign partner university can be funded up to and including the doctorate.
All important information about stays at European universities and the ERASMUS program can be found on the International Office page. Seite des International Office
Short infop
Institut national des langues et civilisations orientales (INALCO), Paris
Institute for languages and cultures in Africa, among others, as well as geography, history, politics and economics.
www.inalco.fr
B.A. on African Languages and Cultures, M.A. African Studies
Official language of the B.A. Dutch, of the M.A. English
www.leiden.edu
University Vienna
Department of African Studies: history, language, and literature; language offerings: Hausa, Bambara, Swahili
www.univie.ac.at
Dalarna University, Falun
There is the Dalarna University Centre for African Studies (Master's program only; languages: Amharic, Swahili)
(Swedish), English
www.du.se
The ERASMUS representative at the Institute for Asian and African Studies and the Seminar for African Studies is Dr. Chanfi Ahmed.
Financial aid abroad (BAföG)
The Federal Training Assistance Act/Financial Aid (Bafög) supports students during semesters abroad. This means that studying abroad is not only supported within the EU, but also worldwide. Semesters abroad are supported for a maximum of one year. In justified individual cases, funding can also cover a period of two and a half years.
The prerequisite for the financial aid abroad (Auslandsbafög) is a) that you study with a cooperation partner of the HU or b) that the study abroad is completed as part of the education in Germany. The financial aid abroad "Auslandsbafög" will cover living expenses, tuition fees (up to 4600 € p.a.), travel expenses (outward and return journey of max. 500€ each) and additional costs for health insurance. Advice on financial aid abroad (Auslandsbafög) is provided by the international offices (Auslandsämter). There are 17 of these in Germany. Each office is responsible for other countries.
Further information can be found on the website of the Federal Ministry of Education and Research. Seite des Bundesministeriums für Bildung und Forschung.
If you would much rather gain practical experience through an internship abroad instead of a semester abroad, the brochure from the DAAD, IJAB, InWent, eurodesk and the German Federal Employment Agency ("Wege ins Auslandspraktikum") is a good guide. The brochure lists step by step which ToDo's should be done to organize an internship abroad.
It offers information ranging from clarifying the desired format (internship, work-placement, stage, ...) to important aspects of an application. Furthermore, the brochure contains various contact points for obtaining financial support for the internship abroad. In addition to EU funding (Leonardo Da-Vinci) and academic funding (DAAD), private organizations are also mentioned that support students in their plans for an internship abroad.
One contact point for funding internships at HU Berlin is the International Office, which supports students in their internship abroad through the Promos program. Humboldt-Universität awards monthly partial scholarship installments and/or one-time travel allowances.
Thesis abroad
Many students want to collect data and material for their thesis on site. The Promos program provides support for this. They can apply for monthly partial scholarship installments (300 €) as well as travel allowances. The amount varies according to the destination country. Information on the Promos - program at Humboldt-Universiity is available from the International Office.
Language course abroad
Students planning to take a language course can also apply to the International Office at Humboldt-Universität for funding under the Promos program. The monthly partial scholarship rates are a uniform 500 EUR. The amount of the travel allowance depends on the destination country.
If you want to study Bambara directly in Mali, you have the possibility to attend courses at the University of Bamako or courses given by employees of the former DNAFLA (Institution for Literacy and Applied Linguistics of the National Languages of Mali), who work as experienced Bambara teachers and give courses. Anke Nehring also arranges contacts with families in Mali who take in language students and integrate them into their families.
Unfortunately, the language course in Bamako has to be suspended at the moment due to the political situation.
Contact person: Anke Nehring
For advanced courses in Hausa the following universities in Nigeria are available: College of Education Azare Bauchi State Nigeria (there are two-month intensive courses), Bayero University Kano Kano State Nigeria or University of Maiduguri Borno State Nigeria.
Contact person: Yusuf Baba Gar
Nord-Sotho
For more than twenty years, students of African Studies from all over Germany have been learning Swahili with the support of the DAAD at the most appropriate place in the world: the Taasisi ya Kiswahili na Lugha za Kigeni (TAKILUKI; Swahili Institute) of the State University of Zanzibar (SUZA). After the discontinuation of a centrally and nationally organized course and the requirement of the DAAD Promos program, HU was able to successfully continue this tradition and organize an intensive Swahili course with family accommodation for a smaller number of Swahili students each year. The course takes place every year in August and lasts 4 weeks; the PROMOS scholarship (-> application formalities on the web pages of the International Affairs Department) covers about two thirds of the expected costs. It is strongly recommended to take the course only after the fourth semester of Swahili.
The registration for the course is done by Dr. Lutz Diegner
Student contribution: "The Zine of Global Knowledges"
Colloquium on African languages and linguistics (summer 2022)
News - More…
Applicants for a university place
Bachelor Degree Course
Current Courses offered by the Department (pdf)
University Catalogue of Courses
Institute Library
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The parenting parody of Adele’s “Hello” is here and it’s amazing
Singer Emily Mills turns Adele’s ‘Hello’ into a hysterical spoof about motherhood titled “Hello from the Motherside”. As if the song wasn’t good enough on its own, the video brings it to a whole other level. This may be one of the most relatable parenting parodies to date.
This is what we’ve been waiting for!
Written by: Nikki Waring
… Keep Reading!!! | 2023-14/0000/en_head.json.gz/1309 | {"url": "https://www.iamnotthebabysitter.com/tag/adele/", "partition": "head_middle", "language": "en", "source_domain": "www.iamnotthebabysitter.com", "date_download": "2023-03-20T10:18:10Z", "digest": "sha1:VEQS7S3NEUTCFBBBGLXUUPQ557YT3ZTI"} | {"ccnet_length": [[0, 418, 418.0]], "ccnet_original_length": [[0, 418, 1025.0]], "ccnet_nlines": [[0, 418, 5.0]], "ccnet_original_nlines": [[0, 418, 26.0]], "ccnet_language_score": [[0, 418, 0.89]], "ccnet_perplexity": [[0, 418, 236.0]], "ccnet_bucket": [[0, 418, 0.0]], "rps_doc_curly_bracket": [[0, 418, 0.0]], "rps_doc_ldnoobw_words": [[0, 418, 0.0]], "rps_doc_lorem_ipsum": [[0, 418, 0.0]], "rps_doc_stop_word_fraction": [[0, 418, 0.41052632]], "rps_doc_ut1_blacklist": [[0, 418, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 418, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 418, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 418, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 418, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 418, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 418, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 418, 0.0]], "rps_doc_frac_chars_top_3gram": [[0, 418, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 418, 0.0]], "rps_doc_frac_all_caps_words": [[0, 418, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 418, 0.0]], "rps_doc_frac_no_alph_words": [[0, 418, 0.18947368]], "rps_doc_frac_unique_words": [[0, 418, 0.84931507]], "rps_doc_mean_word_length": [[0, 418, 4.61643836]], "rps_doc_symbol_to_word_ratio": [[0, 418, 0.01052632]], "rps_doc_unigram_entropy": [[0, 418, 4.04729163]], "rps_doc_word_count": [[0, 418, 73.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 65, 0.0], [65, 339, 1.0], [339, 376, 1.0], [376, 401, 0.0], [401, 418, 1.0]], "rps_lines_javascript_counts": [[0, 65, 0.0], [65, 339, 0.0], [339, 376, 0.0], [376, 401, 0.0], [401, 418, 0.0]], "rps_lines_num_words": [[0, 65, 11.0], [65, 339, 48.0], [339, 376, 7.0], [376, 401, 4.0], [401, 418, 3.0]], "rps_lines_numerical_chars_fraction": [[0, 65, 0.0], [65, 339, 0.0], [339, 376, 0.0], [376, 401, 0.0], [401, 418, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 65, 0.0], [65, 339, 0.0], [339, 376, 0.0], [376, 401, 0.0], [401, 418, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 65, 0.04615385], [65, 339, 0.03284672], [339, 376, 0.02702703], [376, 401, 0.12], [401, 418, 0.11764706]], "rps_doc_ml_palm_score": [[0, 418, 0.03392285]], "rps_doc_ml_wikipedia_score": [[0, 418, null]], "rps_doc_ml_wikiref_score": [[0, 418, 0.00093204]], "rps_doc_books_importance": [[0, 418, -54.70855086]], "rps_doc_openwebtext_importance": [[0, 418, 14.60397153]], "rps_doc_wikipedia_importance": [[0, 418, -54.66017152]], "rps_doc_num_sentences": [[0, 418, 5.0]]} |
Tom Brown's Schooldays by Thomas Hughes
Guardian 1000 Novels Everyone Must Read - Family and Self
Guardian Top 10s: Isabel Wolff's top 10 books set in the Midlands | 2023-14/0000/en_head.json.gz/1310 | {"url": "https://www.ibrowsebooks.com/bookoftheday/20th-october-2022", "partition": "head_middle", "language": "en", "source_domain": "www.ibrowsebooks.com", "date_download": "2023-03-20T08:56:26Z", "digest": "sha1:BRR2QVACYHUDGZHIOZ5R27FYH6DCMMMM"} | {"ccnet_length": [[0, 163, 163.0]], "ccnet_original_length": [[0, 163, 26780.0]], "ccnet_nlines": [[0, 163, 3.0]], "ccnet_original_nlines": [[0, 163, 895.0]], "ccnet_language_score": [[0, 163, 0.83]], "ccnet_perplexity": [[0, 163, 276.0]], "ccnet_bucket": [[0, 163, 0.0]], "rps_doc_curly_bracket": [[0, 163, 0.0]], "rps_doc_ldnoobw_words": [[0, 163, 0.0]], "rps_doc_lorem_ipsum": [[0, 163, 0.0]], "rps_doc_stop_word_fraction": [[0, 163, 0.18181818]], "rps_doc_ut1_blacklist": [[0, 163, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 163, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 163, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 163, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 163, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 163, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 163, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 163, 0.0]], "rps_doc_frac_chars_top_3gram": [[0, 163, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 163, 0.0]], "rps_doc_frac_all_caps_words": [[0, 163, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 163, 0.0]], "rps_doc_frac_no_alph_words": [[0, 163, 0.18181818]], "rps_doc_frac_unique_words": [[0, 163, 0.92592593]], "rps_doc_mean_word_length": [[0, 163, 4.88888889]], "rps_doc_symbol_to_word_ratio": [[0, 163, 0.0]], "rps_doc_unigram_entropy": [[0, 163, 3.19314839]], "rps_doc_word_count": [[0, 163, 27.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 40, 0.0], [40, 98, 0.0], [98, 163, 0.0]], "rps_lines_javascript_counts": [[0, 40, 0.0], [40, 98, 0.0], [98, 163, 0.0]], "rps_lines_num_words": [[0, 40, 6.0], [40, 98, 9.0], [98, 163, 12.0]], "rps_lines_numerical_chars_fraction": [[0, 40, 0.0], [40, 98, 0.07272727], [98, 163, 0.06349206]], "rps_lines_start_with_bulletpoint": [[0, 40, 0.0], [40, 98, 0.0], [98, 163, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 40, 0.125], [40, 98, 0.12068966], [98, 163, 0.07692308]], "rps_doc_ml_palm_score": [[0, 163, -5.01e-06]], "rps_doc_ml_wikipedia_score": [[0, 163, null]], "rps_doc_ml_wikiref_score": [[0, 163, -6.79e-06]], "rps_doc_books_importance": [[0, 163, -10.64466521]], "rps_doc_openwebtext_importance": [[0, 163, -1.85913425]], "rps_doc_wikipedia_importance": [[0, 163, -2.68885071]], "rps_doc_num_sentences": [[0, 163, 1.0]]} |
Categories: Careers, Management
The terms construction engineer and project engineer normally relate to the same person or job function. Construction engineering is the application of engineering, management, and business sciences to the processes of construction, through which designers’ plans and specifications are converted into physical structures and facilities. The construction or project engineer engages in the design of temporary structures, site planning and layout, cost estimating, planning and scheduling, management, materials procurement, equipment selection, cost control, and quality management.These processes involve the organization, administration, and coordination of all the elements involved in construction labor, temporary and permanent materials, equipment, supplies and utilities, money, technology and methods, and time in order to complete construction projects on schedule, within the budget, and according to specified standards of quality and performance. Depending upon the size and complexity of a project, the construction engineer may be responsible for one to several jobs. This means that travel to many different work sites is part of this occupation. Many project engineers work on-site in temporary offices and spend a good deal of time out of doors, planning and checking work.
Construction engineers must have a strong fundamental knowledge of engineering and management principles, and knowledge of business procedures, economics, and human behavior. Students who wish to pursue a career as a construction or project engineer should concentrate on math and science courses, and must earn above average grades in high school. A bachelor’s degree is virtually required for this career, and students must be very careful in selecting an accredited academic engineering degree program with a major emphasis or concentration in construction. Those who do not concentrate in construction engineering at the undergraduate level may return to school for a master’s degree in engineering management or business administration.
Advancement Potential
Construction engineers typically begin their careers in a training capacity as engineers-in training. They may begin as assistants to project superintendents, project managers, estimators, or field engineers. Advancement and responsibility are quickly earned for those who excel. It is not unusual for construction engineers to be in total charge of small projects within five years of employment. Construction/project engineers frequently become the chief operating officer of companies.
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Next Post: Project Manager » | 2023-14/0000/en_head.json.gz/1311 | {"url": "https://www.ibuildamerica-ohio.com/careers/project-engineer/", "partition": "head_middle", "language": "en", "source_domain": "www.ibuildamerica-ohio.com", "date_download": "2023-03-20T08:57:10Z", "digest": "sha1:S5OEMEXUBMWX3Q6KOZARTLGYRO2DU2CA"} | {"ccnet_length": [[0, 2630, 2630.0]], "ccnet_original_length": [[0, 2630, 3532.0]], "ccnet_nlines": [[0, 2630, 7.0]], "ccnet_original_nlines": [[0, 2630, 57.0]], "ccnet_language_score": [[0, 2630, 0.94]], "ccnet_perplexity": [[0, 2630, 226.6]], "ccnet_bucket": [[0, 2630, 0.0]], "rps_doc_curly_bracket": [[0, 2630, 0.0]], "rps_doc_ldnoobw_words": [[0, 2630, 0.0]], "rps_doc_lorem_ipsum": [[0, 2630, 0.0]], "rps_doc_stop_word_fraction": [[0, 2630, 0.34642032]], "rps_doc_ut1_blacklist": [[0, 2630, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2630, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2630, 0.02038967]], "rps_doc_frac_chars_top_3gram": [[0, 2630, 0.01903036]], "rps_doc_frac_chars_top_4gram": [[0, 2630, 0.02628002]], "rps_doc_frac_all_caps_words": [[0, 2630, 0.00230947]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2630, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2630, 0.13625866]], "rps_doc_frac_unique_words": [[0, 2630, 0.53783784]], "rps_doc_mean_word_length": [[0, 2630, 5.96486486]], "rps_doc_symbol_to_word_ratio": [[0, 2630, 0.0]], "rps_doc_unigram_entropy": [[0, 2630, 4.83628135]], "rps_doc_word_count": [[0, 2630, 370.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 32, 0.0], [32, 1324, 1.0], [1324, 2066, 1.0], [2066, 2088, 0.0], [2088, 2577, 1.0], [2577, 2602, 0.0], [2602, 2630, 0.0]], "rps_lines_javascript_counts": [[0, 32, 0.0], [32, 1324, 0.0], [1324, 2066, 0.0], [2066, 2088, 0.0], [2088, 2577, 0.0], [2577, 2602, 0.0], [2602, 2630, 0.0]], "rps_lines_num_words": [[0, 32, 3.0], [32, 1324, 181.0], [1324, 2066, 108.0], [2066, 2088, 2.0], [2088, 2577, 67.0], [2577, 2602, 4.0], [2602, 2630, 5.0]], "rps_lines_numerical_chars_fraction": [[0, 32, 0.0], [32, 1324, 0.0], [1324, 2066, 0.0], [2066, 2088, 0.0], [2088, 2577, 0.0], [2577, 2602, 0.0], [2602, 2630, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 32, 0.0], [32, 1324, 0.0], [1324, 2066, 0.0], [2066, 2088, 0.0], [2088, 2577, 0.0], [2577, 2602, 0.0], [2602, 2630, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 32, 0.09375], [32, 1324, 0.00541796], [1324, 2066, 0.00539084], [2066, 2088, 0.09090909], [2088, 2577, 0.01022495], [2577, 2602, 0.12], [2602, 2630, 0.14285714]], "rps_doc_ml_palm_score": [[0, 2630, 0.02305394]], "rps_doc_ml_wikipedia_score": [[0, 2630, null]], "rps_doc_ml_wikiref_score": [[0, 2630, 0.01674509]], "rps_doc_books_importance": [[0, 2630, -46.90274717]], "rps_doc_openwebtext_importance": [[0, 2630, 21.2914948]], "rps_doc_wikipedia_importance": [[0, 2630, 1.25977012]], "rps_doc_num_sentences": [[0, 2630, 17.0]]} |
Accurate vision is an important part of performing well at work, school, and in other everyday activities. In certain cases, however, medical conditions or injury may lead to visual impairment. For individuals with functional limitations resulting from visual impairment, visual rehabilitation can improve or restore everyday abilities. The most effective model for visual rehabilitation is one in which a patient receives input from his or her optometrist, medical doctor, psychologist, neurologist, and other allied health professionals to create an individualized visual rehabilitation plan.
Visual Rehabilitation Procedures
Visual rehabilitation involves constructing an individualized treatment plan to address each person’s unique issues. In some cases, this may involve occupational therapy to make a person’s environment easier to navigate. For many patients, however, vision therapy offered by an optometrist is an excellent way to improve or fully restore visual functioning.
Analogous to physical therapy for the vision system, vision therapy involves special exercises designed to retrain eye-brain circuits to perform more normally. Patients may be asked to view objects through special prism lenses, focus on an object as it moves, coordinate eye-body movements, or perform computerized tasks. Over time, these exercises improve visual deficits and reduce functional impairment.
Post-Concussive Vision Syndrome
Category: Visual Rehabilitation
More than 300,000 sports-related concussions occur each year, according to research. Many more concussions result from motor vehicle accidents, falls, and other non-sports related incidents. In addition to causing cognitive difficulties, concussions may result in a cluster of problems called post-concussive
The cognitive differences of special needs children and adults are well-documented, but vision issues often receive less attention. People with special needs have the same range of vision issues as their neurotypical counterparts; however, these vision problems occur at a much higher rate in special
Traumatic Injury
Accurate vision involves much more than good eye health. The brain integrates signals from the eyes with information from the motor, balance, and auditory systems to create an accurate view of the world. Following traumatic injury, one or more components of this complex system may be damaged. Receiving | 2023-14/0000/en_head.json.gz/1312 | {"url": "https://www.icareforeyewear.com/community-content/general/category/39796", "partition": "head_middle", "language": "en", "source_domain": "www.icareforeyewear.com", "date_download": "2023-03-20T08:44:25Z", "digest": "sha1:I7PRKEGACSB5JVRCU2UKRUXGLUH4EF23"} | {"ccnet_length": [[0, 2387, 2387.0]], "ccnet_original_length": [[0, 2387, 5528.0]], "ccnet_nlines": [[0, 2387, 10.0]], "ccnet_original_nlines": [[0, 2387, 191.0]], "ccnet_language_score": [[0, 2387, 0.94]], "ccnet_perplexity": [[0, 2387, 296.7]], "ccnet_bucket": [[0, 2387, 0.0]], "rps_doc_curly_bracket": [[0, 2387, 0.0]], "rps_doc_ldnoobw_words": [[0, 2387, 0.0]], "rps_doc_lorem_ipsum": [[0, 2387, 0.0]], "rps_doc_stop_word_fraction": [[0, 2387, 0.31421446]], "rps_doc_ut1_blacklist": [[0, 2387, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2387, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2387, 0.06003002]], "rps_doc_frac_chars_top_3gram": [[0, 2387, 0.010005]], "rps_doc_frac_chars_top_4gram": [[0, 2387, 0.0]], "rps_doc_frac_all_caps_words": [[0, 2387, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2387, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2387, 0.13965087]], "rps_doc_frac_unique_words": [[0, 2387, 0.5578635]], "rps_doc_mean_word_length": [[0, 2387, 5.93175074]], "rps_doc_symbol_to_word_ratio": [[0, 2387, 0.0]], "rps_doc_unigram_entropy": [[0, 2387, 4.94400513]], "rps_doc_word_count": [[0, 2387, 337.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 595, 1.0], [595, 628, 0.0], [628, 986, 1.0], [986, 1393, 1.0], [1393, 1425, 0.0], [1425, 1457, 0.0], [1457, 1766, 0.0], [1766, 2067, 0.0], [2067, 2084, 0.0], [2084, 2387, 0.0]], "rps_lines_javascript_counts": [[0, 595, 0.0], [595, 628, 0.0], [628, 986, 0.0], [986, 1393, 0.0], [1393, 1425, 0.0], [1425, 1457, 0.0], [1457, 1766, 0.0], [1766, 2067, 0.0], [2067, 2084, 0.0], [2084, 2387, 0.0]], "rps_lines_num_words": [[0, 595, 83.0], [595, 628, 3.0], [628, 986, 51.0], [986, 1393, 58.0], [1393, 1425, 3.0], [1425, 1457, 3.0], [1457, 1766, 41.0], [1766, 2067, 45.0], [2067, 2084, 2.0], [2084, 2387, 48.0]], "rps_lines_numerical_chars_fraction": [[0, 595, 0.0], [595, 628, 0.0], [628, 986, 0.0], [986, 1393, 0.0], [1393, 1425, 0.0], [1425, 1457, 0.0], [1457, 1766, 0.02013423], [1766, 2067, 0.0], [2067, 2084, 0.0], [2084, 2387, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 595, 0.0], [595, 628, 0.0], [628, 986, 0.0], [986, 1393, 0.0], [1393, 1425, 0.0], [1425, 1457, 0.0], [1457, 1766, 0.0], [1766, 2067, 0.0], [2067, 2084, 0.0], [2084, 2387, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 595, 0.00672269], [595, 628, 0.09090909], [628, 986, 0.00837989], [986, 1393, 0.00737101], [1393, 1425, 0.125], [1425, 1457, 0.09375], [1457, 1766, 0.00970874], [1766, 2067, 0.00664452], [2067, 2084, 0.11764706], [2084, 2387, 0.01320132]], "rps_doc_ml_palm_score": [[0, 2387, 0.1720131]], "rps_doc_ml_wikipedia_score": [[0, 2387, null]], "rps_doc_ml_wikiref_score": [[0, 2387, 0.06819159]], "rps_doc_books_importance": [[0, 2387, -84.59854949]], "rps_doc_openwebtext_importance": [[0, 2387, 4.94166824]], "rps_doc_wikipedia_importance": [[0, 2387, -13.41834552]], "rps_doc_num_sentences": [[0, 2387, 17.0]]} |
Traditional Individual Retirement Accounts (IRA), which were created in 1974, are owned by roughly 36.6 million U.S. households. And Roth IRAs, created as part of the Taxpayer Relief Act in 1997, are owned by nearly 27.3 million households.1
Both are IRAs. And yet, each is quite different.
Up to certain limits, traditional IRAs allow individuals to make tax-deductible contributions into their account(s). Distributions from traditional IRAs are taxed as ordinary income, and if taken before age 59½, may be subject to a 10% federal income tax penalty. Generally, once you reach age 73, you must begin taking required minimum distributions.2,3
For individuals covered by a retirement plan at work, the deduction for a traditional IRA in 2022 is phased out for incomes between $109,000 and $129,000 for married couples filing jointly, and between $68,000 and $78,000 for single filers.4
Also, within certain limits, individuals can make contributions to a Roth IRA with after-tax dollars. To qualify for a tax-free and penalty-free withdrawal of earnings, Roth IRA distributions must meet a five-year holding requirement and occur after age 59½.
Like a traditional IRA, contributions to a Roth IRA are limited based on income. For 2022, contributions to a Roth IRA are phased out between $204,000 and $214,000 for married couples filing jointly and between $129,000 and $144,000 for single filers.5
In addition to contribution and distribution rules, there are limits on how much can be contributed each year to either IRA. In fact, these limits apply to any combination of IRAs; that is, workers cannot put more than $6,000 per year into their Roth and traditional IRAs combined. So, if a worker contributed $3,500 in a given year into a traditional IRA, contributions to a Roth IRA would be limited to $2,500 in that same year.6
Individuals who reach age 50 or older by the end of the tax year can qualify for "catch-up" contributions. The combined limit for these is $7,000.6
Both traditional and Roth IRAs can play a part in your retirement plans. And once you’ve figured out which will work better for you, only one task remains: open an account.7
Features of Traditional and Roth IRAs
Tax-deductible contributions *
Tax-deferred growth
Tax-free withdrawals ** ***
Income limit for 2022 contributions Deduction phases out for adjusted gross incomes between $109,000 and $129,000 (married filing jointly) or between $68,000 and $78,000 (single filer)4 Eligibility phases out for adjusted gross incomes between $204,000 and $214,000 (married filing jointly) or between $129,000 and $144,000 (single filer)5
Distributions required at age 73?
* Up to certain limits
** Distributions from traditional IRAs are taxed as ordinary income, and if taken before age 59½, may be subject to a 10% federal income tax penalty. Generally, once you reach age 73, you must begin taking required minimum distributions.
*** To qualify, Roth IRA distributions must meet a five-year holding requirement and occur after age 59½.
1. ICI.org, 2022
2. IRS.gov, March 12, 2021. Under the SECURE Act, in most circumstances, once you reach age 73, you must begin taking required minimum distributions from a Traditional Individual Retirement Account (IRA). You may continue to contribute to a Traditional IRA past age 70½ under the SECURE Act as long as you meet the earned-income requirement.
3. Up to certain limits, traditional IRAs allow individuals to make tax-deductible contributions into their account(s). Distributions from traditional IRAs are taxed as ordinary income, and if taken before age 59½, may be subject to a 10% federal income tax penalty. Generally, once you reach age 73, you must begin taking required minimum distributions.
7. The Tax Cuts and Jobs Act of 2017 eliminated the ability to "undo" a Roth conversion.
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Islamic Republic Of Iran To Criminalize Comments On Social Networks
Forbidden Freedom | News / Atrocities Human Rights Violation /
▌▌
The Iranian parliament plans to add an article to the Islamic Penal Code that would criminalize “expressing opinions on social networks,” state media reported, in an attempt to further limit freedom of speech.
The main targets of the proposed Article 512 are influential people in Iran.
The draft legislation says that people who hold “a social, political, scientific and cultural position” and use social media to comment on issues that “require” an official response will be sentenced to prison if their posts get “widespread feedback” and “disrupt public order.”
The head of parliament’s Judicial Commission has said that Article 512 is aimed at dealing with “lies” and that its provisions are still under review.
A growing number of celebrities have used their social media accounts to voice support for protests that have swept Iran for more than four months and criticize the Islamic Republic’s brutal response to the wave of public anger.
Some of these celebrities have been thrown behind bars, interrogated and had their passports confiscated, with Islamic Republic officials accusing them of “fanning the flames of the riots.”
Meanwhile, Iranian authorities have heavily disrupted Internet access in large parts of the country and blocked or periodically disrupted access to social media and messaging platforms to quash the protest movement.
Mosa Barzin Khalifelou, IranWire’s legal advisor, says that, according to Iran’s laws, “commenting on the Internet is not considered a crime as long as it does not insult a person or promote violence.”
“But like many other things, there is a big difference between what is written in the law and what happens in practice,” Khalifelou adds.
Charges such as “insulting sacred things,” which can include expressing opinions about security officers or the prophet of Islam, is punishable by Iran’s legal system.
Iranian citizens have been arrested and are facing the death penalty after writing about their own interpretation of Islam on social media.
Many activists have been accused of “insulting the sacred things” on social media. Those who set fire to pictures of Islamic Republic figures such as Supreme Leader Ali Khamenei or General Ghasem Soleimani have also been targeted.
If Article 512 is approved, will comments on social and political issues become as dangerous as expressing views on religious issues?
“In the law, sacred things mean religious sacred issues. People have been charged during recent protests for burning Khamenei’s and Suleimani’s pictures due to the unwillingness of the courts to correctly interpret the law,” Khalifelou said.
“Judges who deal with these types of cases are often not qualified to judge, in the sense that their appointment followed a process that was based on their alignment with political and security trends rather than their legal knowledge and experience. Some of them don’t even have a legal education,” he added.
Source » iranwire
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Gunjal, Aparna B., et al., editors. Global Initiatives for Waste Reduction and Cutting Food Loss. IGI Global, 2019. https://doi.org/10.4018/978-1-5225-7706-5
Gunjal, A. B., Waghmode, M. S., Patil, N. N., & Bhatt, P. (Eds.). (2019). Global Initiatives for Waste Reduction and Cutting Food Loss. IGI Global. https://doi.org/10.4018/978-1-5225-7706-5
Gunjal, Aparna B., et al., eds. Global Initiatives for Waste Reduction and Cutting Food Loss. Hershey, PA: IGI Global, 2019. https://doi.org/10.4018/978-1-5225-7706-5
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Global Initiatives for Waste Reduction and Cutting Food Loss
Aparna B. Gunjal (Dr. D.Y. Patil Arts, Commerce, and Science College, Pune, India), Meghmala S. Waghmode (Annasaheb Magar Mahavidyalaya, India), Neha N. Patil (Annasaheb Magar Mahavidyalaya, India), and Pankaj Bhatt (Dolphin (P.G) College of Biomedical and Natural Sciences Dehradun, India)
Release Date: March, 2019|Copyright: © 2019 |Pages: 328
DOI: 10.4018/978-1-5225-7706-5
ISBN13: 9781522577065|ISBN10: 1522577068|EISBN13: 9781522577072|ISBN13 Softcover: 9781522592136
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The world population is expected to increase exponentially within the next decade, which means that the food demand will increase and so will waste production. There is a need for effective food waste management as wasted food leads to overutilization of water and fossil fuels and increasing greenhouse gas emissions from the degradation of food.
Global Initiatives for Waste Reduction and Cutting Food Loss explores methods for reducing waste and cutting food loss in order to help the environment and support local communities, as well as solve issues including that of land space. Covering topics that include food degradation, enzymes, and microorganisms, this publication is designed for policymakers, environmentalists, engineers, government officials, researchers, scientists, academicians, and students.
The many academic areas covered in this publication include, but are not limited to:
Food Degradation
Food Demand
Aparna Gunjal has completed her B.Sc. from Annasaheb Magar Mahavidyalaya, Hadapsar; M.Sc. from Modern College Arts, Commerce and Science College, Ganeshkhind and PhD in Environmental Sciences subject from Savitribai Phule Pune University, Pune, Maharashtra, India. She is working as an Assistant Professor in the Department of Microbiology at Dr. D.Y. Patil, Arts, Commerce and Science College, Pimpri, Pune, Maharashtra, India. Her research areas of expertise are solid waste management; plant growth-promoting rhizobacteria, e-waste management, bioremediation, etc. Aparna has 115 publications to her credit. She has received 10 Awards for the Best Paper presentations and also received travel grants. Aparna has also received Pune Municipal Corporation Award for excellent work in Environmental Sciences Research in 2015, The Elsevier Foundation - TWAS Sustainability Visiting Expert Programme” in 2018 and the Young Researcher award with Innovative Technology. She has worked on composting aspect as a Senior Researcher Assistant at Hongkong Baptist University, Hongkong. Aparna is an Editor Member of the International Journal of Microbial Science; Frontiers in Environmental Microbiology; Journal of Microbiology and Biotechnology Reports and Reviewer.
Meghmala Sheshrao Waghmode is currently working as Lecturer in Annasaheb Magar Mahavidyalaya, Pune, India. She has 11 years of teaching experience and 10 years of research experience. Her research areas of expertise are waste management; bioremediation; nanotechnology and fungal pigments.
Neha Nitin Patil is Associate Professor and Head of Dept of Microbiology at Waghire College, Saswad, Pune, India. She has 30 years of teaching experience and 10 years of research experience. She has 10 publications to her credit and is also a life member of Biotech Research Society, India and many others. She has many awards and honors to her credit.
Pankaj Bhatt did his Bachelor in Biotechnology from Kumaun University Naintal in 2009. He completed Master in Microbiology in 2012 from Department of Biotechnology Kumaun University Nainital Uttarakhand. He have completed Ph.D in Microbiology from G.B Pant University of Agriculture and Technology Pantnagar, U.S Nagar, India. His research areas of expertise are Microbial and molecular aspect of biodegradation, pesticide biodegradation, food microbiology, plant microbe interaction. Currently he is working as Assistant Professor in Dolphin (P.G) College of Biomedical and Natural Sciences Dehradun, India.
All of IGI Global's content is archived via the CLOCKSS and LOCKSS initiative. 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Top construction ideas to build new building in Katni
30 60 house design
Residential cum commercial front elevation
100 50 North
Elevation designs
45x60 House map
Home design front look
1500sqft modern duplex house design
Apartment 3d design
40 150 West
30x55 Duplex floor plan drawing
House design small
The main idea behind finding the best Construction company in Katni, always choose the one which provides you with Top construction ideas to build new building. This will help you in constructing new buildings and achieving your dreams to create the top construction company in Katni!
It’s not enough that you want to create something special or you want to do something different from all other companies of Katni, but it’s also important that how much effort are you ready to put in it?
As a Katni building construction contractor, there are some things you'll need to know when it comes time to break ground. One of the first steps is an excavation on the property you intend on using for the building. You'll be hiring someone or a company that specializes in excavating which will need to dig a ditch and expose bedrock.
If you are doing your research, you need a civil contractor in Katni who can help you put together a team of professionals who know how to execute the project with expertise and attention to detail.
You will want to make sure that you have worked out all the details for both civil construction company in Katni. You need to have an understanding of these things before starting so there aren't any surprises down the line.
Contractors in Katni can help find the right framing for your style home so that you get just what you are looking for.
There are many companies that offer windows and doors installation services in Katni, but you should go with a company that offers quality materials and craftsmanship that one is Imagination Shaper Company. They have been doing this for years and can be trusted for their service excellence.
The civil contractors in Katni are experts at executing the best construction company in Katni. They have years of experience, the best equipment, and get your job done quickly and efficiently.
The construction company in Katni is one of the biggest industries in Katni and it's not just about constructing buildings. Civil contractors in Katni are responsible for many more things, from laying foundations and building roads, to excavating earthworks and erecting scaffolding.
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Imlay City Christian Reformed Church
Children & Youth Ministries
2023 Bulletins
Email Prayer Line
Children and Youth are highly valued here at ICCRC. We offer many programs and activities for kids of all ages.
Sunday mornings after worship is a great opportunity for all school-age children to learn more about God’s love for them and dig deeper into God’s word. Sunday school meets on Sundays during the school year (September-May) from 11:30 am – 12:15 pm.
Children’s Worship
All children ages 3-8 are invited to join Children’s Worship, which takes place during the church service. A Praise Team Member will announce the Children’s Message, after which the children will be dismissed from the sanctuary for Children’s Worship.
Youth Group is a time for Middle and High School student to grow closer to the Lord, while having a good time socializing with each other. We meet weekly during the school year (September-May) on Wednesday evenings for a time of Bible study and discussion. We also do fun things outside of our weeknight meetings, such as Whirlyball, Airtime Trampoline, mini-golf, and a yearly trip to Michigan’s Adventure.
Young Adults is a great time of food and fellowship for 20’s and 30’s. It is every other Tuesday night at 6:30 PM.
Cadets is for boys in grades 3-8 and meets on the 2nd & 4th Mondays during the school year. | 2023-14/0000/en_head.json.gz/1317 | {"url": "https://www.imlaycitycrc.org/ministries/children-youth-ministries/?mobileOn=0", "partition": "head_middle", "language": "en", "source_domain": "www.imlaycitycrc.org", "date_download": "2023-03-20T08:47:05Z", "digest": "sha1:DFU44G6BVZAPAZG3J5M3AHZDPCNHC6XZ"} | {"ccnet_length": [[0, 1344, 1344.0]], "ccnet_original_length": [[0, 1344, 1770.0]], "ccnet_nlines": [[0, 1344, 11.0]], "ccnet_original_nlines": [[0, 1344, 39.0]], "ccnet_language_score": [[0, 1344, 0.96]], "ccnet_perplexity": [[0, 1344, 172.8]], "ccnet_bucket": [[0, 1344, 0.0]], "rps_doc_curly_bracket": [[0, 1344, 0.0]], "rps_doc_ldnoobw_words": [[0, 1344, 0.0]], "rps_doc_lorem_ipsum": [[0, 1344, 0.0]], "rps_doc_stop_word_fraction": [[0, 1344, 0.34265734]], "rps_doc_ut1_blacklist": [[0, 1344, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1344, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1344, 0.05719557]], "rps_doc_frac_chars_dupe_6grams": [[0, 1344, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 1344, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1344, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1344, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1344, 0.03321033]], "rps_doc_frac_chars_top_3gram": [[0, 1344, 0.04151292]], "rps_doc_frac_chars_top_4gram": [[0, 1344, 0.05258303]], "rps_doc_frac_all_caps_words": [[0, 1344, 0.01048951]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1344, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1344, 0.1993007]], "rps_doc_frac_unique_words": [[0, 1344, 0.61777778]], "rps_doc_mean_word_length": [[0, 1344, 4.81777778]], "rps_doc_symbol_to_word_ratio": [[0, 1344, 0.0]], "rps_doc_unigram_entropy": [[0, 1344, 4.66773825]], "rps_doc_word_count": [[0, 1344, 225.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 37, 0.0], [37, 65, 0.0], [65, 80, 0.0], [80, 98, 0.0], [98, 210, 1.0], [210, 459, 1.0], [459, 478, 0.0], [478, 730, 1.0], [730, 1138, 1.0], [1138, 1253, 1.0], [1253, 1344, 1.0]], "rps_lines_javascript_counts": [[0, 37, 0.0], [37, 65, 0.0], [65, 80, 0.0], [80, 98, 0.0], [98, 210, 0.0], [210, 459, 0.0], [459, 478, 0.0], [478, 730, 0.0], [730, 1138, 0.0], [1138, 1253, 0.0], [1253, 1344, 0.0]], "rps_lines_num_words": [[0, 37, 5.0], [37, 65, 3.0], [65, 80, 2.0], [80, 98, 3.0], [98, 210, 20.0], [210, 459, 42.0], [459, 478, 2.0], [478, 730, 39.0], [730, 1138, 68.0], [1138, 1253, 23.0], [1253, 1344, 18.0]], "rps_lines_numerical_chars_fraction": [[0, 37, 0.0], [37, 65, 0.0], [65, 80, 0.28571429], [80, 98, 0.0], [98, 210, 0.0], [210, 459, 0.03333333], [459, 478, 0.0], [478, 730, 0.00813008], [730, 1138, 0.0], [1138, 1253, 0.06306306], [1253, 1344, 0.04597701]], "rps_lines_start_with_bulletpoint": [[0, 37, 0.0], [37, 65, 0.0], [65, 80, 0.0], [80, 98, 0.0], [98, 210, 0.0], [210, 459, 0.0], [459, 478, 0.0], [478, 730, 0.0], [730, 1138, 0.0], [1138, 1253, 0.0], [1253, 1344, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 37, 0.13513514], [37, 65, 0.10714286], [65, 80, 0.06666667], [80, 98, 0.16666667], [98, 210, 0.07142857], [210, 459, 0.02811245], [459, 478, 0.10526316], [478, 730, 0.04365079], [730, 1138, 0.04166667], [1138, 1253, 0.05217391], [1253, 1344, 0.02197802]], "rps_doc_ml_palm_score": [[0, 1344, 0.00339705]], "rps_doc_ml_wikipedia_score": [[0, 1344, null]], "rps_doc_ml_wikiref_score": [[0, 1344, 0.05763239]], "rps_doc_books_importance": [[0, 1344, -153.41922013]], "rps_doc_openwebtext_importance": [[0, 1344, -8.03654061]], "rps_doc_wikipedia_importance": [[0, 1344, -68.58367016]], "rps_doc_num_sentences": [[0, 1344, 12.0]]} |
HomeTechnology Policy Statement 1983 by Department of Science and Technology
Technology Policy Statement 1983 by Department of Science and Technology
Information on Technology Policy Statement 1983 by the Department of Science and Technology (DST), Ministry of Science and Technology is given. Users can get details related to policy, its preamble, aims, objectives, priorities, etc. Detailed information about indigenous technology, technology acquisition, technology transfer, implementation, etc. is also available.
Intensification of Research in High Priority Areas
Get detailed information about the Intensification of Research in High Priority Areas (IRHPA). Users can find information about this programme and its objectives. Details of facilities created with the help of this programme are also provided.
Website of Indian Institute of Remote Sensing
The Indian Institute of Remote Sensing under the Indian Space Research Organisation is a premier training and educational institute set up for developing trained professionals in the field of remote sensing, Geo-informatics and GPS Technology for Natural Resources, environmental and disaster management. Detailed information is provided on the Indian Institute of Remote Sensing. Information is given on the academic programmes, administration,...
Citizen's Charter of Department of Science and Technology
Get the Citizen's Charter of Department of Science and Technology, Ministry of Science and Technology. Detailed information about the Department's values, commitments, work standards, etc. is given. Contact details of officials are also available.
Kishore Vaigyanik Protsahan Yojana by Department of Science and Technology
The Kishore Vaigyanik Protsahan Yojana (KVPY) is an on-going National Program of Fellowships in Basic Sciences by Department of Science and Technology, Ministry of Science and Technology. Information about KVPY, its aim, committees, etc. is given. Details related to fellowships, eligibility for fellowship, selection procedure, application forms, fellow, etc. are given. Access to question papers is also available.
Website of Antrix Corporation Limited
Antrix Corporation Limited is engaged in providing space products and services to international customers worldwide. Users can find information on the launch services. One can also get information on satellites. Get details of earth observation, transponder provision and mission support by the Antrix Corporation Limited. Information on various services like space craft testing, training and consultancy, etc is available. Users can find...
Website of Department of Science and Technology
Get information about the Department of Science and Technology (DST). Users can get information about scientific programmes, institutions, scientific and engineering research, technology missions, women scientists programme etc. Details of scientific services and projects are available.
Information on Fund for Industrial Research Engagement (FIRE), Science and Engineering Research Board
Fund for Industrial Research Engagement (FIRE), intends to address the challenges in the research and innovation space in India, by creating an ecosystem that would accelerate the growth in the research work and drive the R&D landscape efficiently and effectively with close co-ordination with Industry.
Information on Empowerment and Equity Opportunities for Excellence in Science (EMEQ), Science and Engineering Research Board
The Empowerment and Equity Opportunities for Excellence in Science (EMEQ) scheme is aimed at providing research support to researchers belonging to the Scheduled Caste and Scheduled Tribe in undertaking research in frontier areas of science and engineering.
Information on Start-up Research Grant (SRG), Science and Engineering Research Board
The Start-up Research Grant (SRG) scheme aims to assist researchers to initiate their research career in a new institution. It is a two-year grant meant to enable researchers working in frontier areas of science and engineering to establish themselves and move on to the mainstream core research grant. Criteria for selection would be based on the track record of the applicant and the proposed research plan.
Annual Reports of Department on Science and Technology
User can get an access to Annual Reports for Department of Science and Technology with their various activities and achievements from 2009 onwards. Downloadable reports are available in English as well as Hindi.
Information on Mathematical Research Impact Centric Support (MATRICS), Science and Engineering Research Board
The main attribute of this scheme would be submission of a simple 1-2 page mathematical/theoretical proposal. The funding provided would cater to the specific needs of Mathematical/Theoretical Sciences research.
Technology Development under Department of Science and Technology
Information on Technology Development under the Department of Science and Technology. User can get the information on the Drugs & Pharmaceutical Research, Good Laboratory Practice Authority, Instrumentation Development Programme, Inter-Sectoral Science & Technology Advisory Committee (STAC /IS-STAC) Participation of Youth in Real-Time Observation to Benefit Education (PROBE), Natural Resources Data Management System (NRDMS), National...
Information on Accelerate Vigyan, Science and Engineering Research Board
The aim is to expand the research base in the country, with three broad goals - consolidation / aggregation of all scientific training programs, initiating High end Orientation Workshops and creating opportunities for Research Internships.
Directory of Department of Science and Technology
Find online contact details of the Ministers, Secretary, Chief Vigilance Officer, Directors, Deputy Secretary, Scientists and other officials of the Department are available. Name of the officer, designation, programme area, telephone numbers, email ids, etc. are also provided.
Information on State University Research Excellence, Science and Engineering Research Board
State University Research Excellence (SERB-SURE) is a new scheme of the Science and Engineering Research Board (SERB) to augment the research capabilities in a structured way to create a robust R&D ecosystem in state universities and colleges by fostering collaboration for high-end research. 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If you own a rental property but had a tenant trash it when they leave then make sure you read this article because we’re addressing the all-too-common problem that landlords have when they say, “Help! My last tenant trashed my New Jersey house!”
Do you own a rental property? Did you have a tenant leave it in less-than-perfect condition? It happens! In fact, it’s an experience that probably every landlord has faced at least once. If you looked at your empty rental property and said, “Help! My tenant trashed my New Jersey house” then here are some things you can do about it…
Is it worth going after the tenant?
You need to first assess the damage and decide if it’s worth going after the tenant. Unfortunately, it often isn’t worth the hassle because it may be a time consuming and even expensive effort to get the tenant to pay you back. However, if the damage is significant enough, you may choose to do this.
Is it worth repairing the damage?
From holes in the walls to missing toilets – we’ve heard of just about everything you can imagine! Sometimes a bit of drywall and paint will fix the problem, in which case you may want to fix it up and rent it out again, and then just accept the inconvenience as the cost of doing business. However, if the damage is not worth repairing yourself then you might be interested in a couple of other options:
You could rent your house to a handyman
One little-known option that is actually really helpful is to find a handyman who wants to rent the house. In exchange for a discount on rent (or even free rent) they can fix up the house for you to make it a nice rental property again. Make sure you have a timeline all spelled out, though, to avoid then staying too long without a lot of work getting done.
You could sell the house
Another option is to sell the house and move on from owning a frustrating rental property. However, be aware that if you try to sell the house on the open market, you may have to fix it up first in order for the agent to list it. Another option is to sell privately to a house-buying team like ours. (We buy houses in as-is condition and we’ll fix them up ourselves).
To get a fair cash offer for your property, no matter what condition it’s in, just get in touch with us and we’ll give you a no-obligation offer and we can even buy your property from you fast. Click here now and fill out the form or call our office at (973) 870-4509 and we’ll get back to you right away. | 2023-14/0000/en_head.json.gz/1319 | {"url": "https://www.infiniarealty.com/blog/help-my-last-tenant-trashed-my-new-jersey-house/", "partition": "head_middle", "language": "en", "source_domain": "www.infiniarealty.com", "date_download": "2023-03-20T09:21:49Z", "digest": "sha1:K7JM45E6KQSGCDYDTD2GES2IOF2ODDOK"} | {"ccnet_length": [[0, 2454, 2454.0]], "ccnet_original_length": [[0, 2454, 5722.0]], "ccnet_nlines": [[0, 2454, 11.0]], "ccnet_original_nlines": [[0, 2454, 66.0]], "ccnet_language_score": [[0, 2454, 0.95]], "ccnet_perplexity": [[0, 2454, 319.4]], "ccnet_bucket": [[0, 2454, 0.0]], "rps_doc_curly_bracket": [[0, 2454, 0.0]], "rps_doc_ldnoobw_words": [[0, 2454, 0.0]], "rps_doc_lorem_ipsum": [[0, 2454, 0.0]], "rps_doc_stop_word_fraction": [[0, 2454, 0.52110092]], "rps_doc_ut1_blacklist": [[0, 2454, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2454, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2454, 0.11958763]], "rps_doc_frac_chars_dupe_6grams": [[0, 2454, 0.03092784]], "rps_doc_frac_chars_dupe_7grams": [[0, 2454, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2454, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2454, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2454, 0.03608247]], "rps_doc_frac_chars_top_3gram": [[0, 2454, 0.0185567]], "rps_doc_frac_chars_top_4gram": [[0, 2454, 0.01340206]], "rps_doc_frac_all_caps_words": [[0, 2454, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2454, 0.09090909]], "rps_doc_frac_no_alph_words": [[0, 2454, 0.12844037]], "rps_doc_frac_unique_words": [[0, 2454, 0.46203905]], "rps_doc_mean_word_length": [[0, 2454, 4.20824295]], "rps_doc_symbol_to_word_ratio": [[0, 2454, 0.00183486]], "rps_doc_unigram_entropy": [[0, 2454, 4.88357267]], "rps_doc_word_count": [[0, 2454, 461.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 247, 1.0], [247, 581, 0.0], [581, 617, 1.0], [617, 918, 1.0], [918, 952, 1.0], [952, 1357, 0.0], [1357, 1397, 0.0], [1397, 1756, 1.0], [1756, 1781, 0.0], [1781, 2149, 1.0], [2149, 2454, 1.0]], "rps_lines_javascript_counts": [[0, 247, 0.0], [247, 581, 0.0], [581, 617, 0.0], [617, 918, 0.0], [918, 952, 0.0], [952, 1357, 0.0], [1357, 1397, 0.0], [1397, 1756, 0.0], [1756, 1781, 0.0], [1781, 2149, 0.0], [2149, 2454, 0.0]], "rps_lines_num_words": [[0, 247, 43.0], [247, 581, 60.0], [581, 617, 7.0], [617, 918, 55.0], [918, 952, 6.0], [952, 1357, 76.0], [1357, 1397, 8.0], [1397, 1756, 69.0], [1756, 1781, 5.0], [1781, 2149, 71.0], [2149, 2454, 61.0]], "rps_lines_numerical_chars_fraction": [[0, 247, 0.0], [247, 581, 0.0], [581, 617, 0.0], [617, 918, 0.0], [918, 952, 0.0], [952, 1357, 0.0], [1357, 1397, 0.0], [1397, 1756, 0.0], [1756, 1781, 0.0], [1781, 2149, 0.0], [2149, 2454, 0.03367003]], "rps_lines_start_with_bulletpoint": [[0, 247, 0.0], [247, 581, 0.0], [581, 617, 0.0], [617, 918, 0.0], [918, 952, 0.0], [952, 1357, 0.0], [1357, 1397, 0.0], [1397, 1756, 0.0], [1756, 1781, 0.0], [1781, 2149, 0.0], [2149, 2454, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 247, 0.02024291], [247, 581, 0.02694611], [581, 617, 0.02777778], [617, 918, 0.00996678], [918, 952, 0.02941176], [952, 1357, 0.00740741], [1357, 1397, 0.025], [1397, 1756, 0.00835655], [1756, 1781, 0.04], [1781, 2149, 0.01086957], [2149, 2454, 0.00655738]], "rps_doc_ml_palm_score": [[0, 2454, 0.15220153]], "rps_doc_ml_wikipedia_score": [[0, 2454, null]], "rps_doc_ml_wikiref_score": [[0, 2454, 0.00632089]], "rps_doc_books_importance": [[0, 2454, -127.10795968]], "rps_doc_openwebtext_importance": [[0, 2454, 24.47906643]], "rps_doc_wikipedia_importance": [[0, 2454, -315.38915631]], "rps_doc_num_sentences": [[0, 2454, 23.0]]} |
Professional Services Advancement Support Scheme opens for application
The Government will launch the Professional Services Advancement Support Scheme (PASS) tomorrow (November 24) to provide funding support for non-profit-making industry-led projects aimed at increasing the exchanges and co-operation of Hong Kong's professional services with their counterparts in external markets and promoting relevant publicity activities.
The $200 million PASS was announced by the Chief Executive in his 2016 Policy Address and was approved by the Legislative Council in July. In addition to the aforementioned outreaching projects, PASS is also open to projects seeking to enhance the standards and external competitiveness of professional services in Hong Kong.
For each project under PASS, the Government will fund up to 90 per cent of the total eligible project cost, or $3 million, whichever is lower. "This higher percentage of government contribution is designed to encourage more organisations, especially those with lesser means, to undertake projects and bring early benefits to the professional services sector," a spokesman for the Commerce and Economic Development Bureau said.
A wide range of professional services are eligible for funding under PASS. Non-profit-distributing professional, trade or industrial organisations, as well as research institutes, may apply for funding.
Applications will normally be invited four times a year. Urgent applications may be considered outside the normal application cycle where justified. The first tranche of applications will be accepted from tomorrow to February 28, 2017. Applications may be sent to the PASS Secretariat under the Commerce and Economic Development Bureau.
Applications received will be assessed by a Vetting Committee, which will also monitor approved projects. The following members have been appointed to the Vetting Committee for a term of two years from January 1, 2017, to December 31, 2018:
Dr Jonathan Choi Koon-shum
Mr Lau Ping-cheung
Dr Sunny Chai Ngai-chiu
Professor Chetwyn Chan Che-hin
Mr Chan Chi-chiu
Mr Dennis Ho Chiu-ping
Mr Stephen Hung Wan-shun
Dr Sigmund Leung Sai-man
Ms Edith Shih
Mr Peter Sun Kwok-wah
Professor Tam Kar-yan
Executive Director of the Hong Kong Productivity Council or her representative
Executive Director of the Hong Kong Trade Development Council or her representative
Deputy Secretary for Commerce and Economic Development (Commerce and Industry)
For further information, please visit the PASS website at www.pass.gov.hk or contact the PASS Secretariat at 3655 5418 or [email protected].
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Music has a profound effect on your emotions and gambling is no different. The music of a casino can have […] | 2023-14/0000/en_head.json.gz/1321 | {"url": "https://www.inheaven.co/2023/03/08", "partition": "head_middle", "language": "en", "source_domain": "www.inheaven.co", "date_download": "2023-03-20T09:17:12Z", "digest": "sha1:ML6TUJNP7R2BENV63CILWUSQUNHMJ4II"} | {"ccnet_length": [[0, 109, 109.0]], "ccnet_original_length": [[0, 109, 2919.0]], "ccnet_nlines": [[0, 109, 1.0]], "ccnet_original_nlines": [[0, 109, 119.0]], "ccnet_language_score": [[0, 109, 0.97]], "ccnet_perplexity": [[0, 109, 128.4]], "ccnet_bucket": [[0, 109, 0.0]], "rps_doc_curly_bracket": [[0, 109, 0.0]], "rps_doc_ldnoobw_words": [[0, 109, 0.0]], "rps_doc_lorem_ipsum": [[0, 109, 0.0]], "rps_doc_stop_word_fraction": [[0, 109, 0.54545455]], "rps_doc_ut1_blacklist": [[0, 109, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 109, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 109, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 109, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 109, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 109, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 109, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 109, 0.0]], "rps_doc_frac_chars_top_3gram": [[0, 109, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 109, 0.0]], "rps_doc_frac_all_caps_words": [[0, 109, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 109, 0.0]], "rps_doc_frac_no_alph_words": [[0, 109, 0.09090909]], "rps_doc_frac_unique_words": [[0, 109, 0.9047619]], "rps_doc_mean_word_length": [[0, 109, 4.0952381]], "rps_doc_symbol_to_word_ratio": [[0, 109, 0.04545455]], "rps_doc_unigram_entropy": [[0, 109, 2.9124944]], "rps_doc_word_count": [[0, 109, 21.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 109, 0.0]], "rps_lines_javascript_counts": [[0, 109, 0.0]], "rps_lines_num_words": [[0, 109, 21.0]], "rps_lines_numerical_chars_fraction": [[0, 109, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 109, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 109, 0.01834862]], "rps_doc_ml_palm_score": [[0, 109, -1.001e-05]], "rps_doc_ml_wikipedia_score": [[0, 109, null]], "rps_doc_ml_wikiref_score": [[0, 109, -1.001e-05]], "rps_doc_books_importance": [[0, 109, -5.98510611]], "rps_doc_openwebtext_importance": [[0, 109, -0.13829028]], "rps_doc_wikipedia_importance": [[0, 109, -4.29960199]], "rps_doc_num_sentences": [[0, 109, 2.0]]} |
SUMMARY: What you need to know about paywalls from 2022 research testing 473 Web sites in 33 countries, analysing subscription performance of 160 brands benchmarking with INMA. Also, what happened when Dennik N published AI-generated illustration on its front page?
Are the most popular paywalls also the most effective?
Readers First | 01 February 2023
By Greg Piechota
Researcher-in-Residence
In this newsletter, I discuss exclusive INMA research on paywall models and present a case study about AI-generated images used at scale.
If you have questions or suggestions, e-mail me today at [email protected] or meet me in person in Stockholm in March at the INMA Media Subscriptions Summit.
Which paywall models are most popular and which are most effective?
Freemium paywall model is most frequent internationally. Hybrid models are on the rise. However, brands with different models grew subscriber base in 2022 at a similar rate.
This is based on original multi-year research, testing 473 Web sites in 33 countries and analysing subscription performance of 160 brands benchmarking with INMA in 2022.
Paywall models describe criteria for labelling content or segmenting readers, and targeting them with subscription or membership offers.
Popularity trends: Every two years since 2018, we tested top 15 news Web sites ranked by reach in each of 33 countries surveyed by Oxford’s Reuters Institute.
In mid-2022, we found 192, or 41% of the total of 473 Web sites, featured some kind of a paywall restricting access to news content:
53% offered some articles for free and some for a fee (freemium model).
9% triggered a paywall after reading a few articles (metered model).
15% used a combination of the two or more criteria for targeting (hybrid model).
10% did not restrict access but asked for support (membership model).
9% kept free access to the Web content but charged for print e-replica.
4% restricted access to most or all content (hard wall model).
Our multi-year study showed some clear trends:
An increase in popularity of hybrid models, from 3% in 2018 and 5% in 2020.
A decrease in popularity of charging only for print e-replica, from 32% in 2018 and 18% in 2020. E-replicas are usually bundled today with the Web access.
Popularity of membership models is dwindling, rising from 1% in 2018 but falling from 12% in 2020.
Effectiveness trends: Every quarter since 2021, we collected current and historic performance indicators from INMA corporate members, benchmarking 160 national and regional news brands in 31 countries.
The distribution of paywall models in the INMA sample was different than in the Reuters Institute-inspired sample. The freemium wall was the most frequent too (38%), but the proportion of brands with hybrid or hard walls was much higher (29% and 22%, respectively).
In 2022, brands with different paywall models enjoyed a similar growth rate of the total number of digital-only subscriptions. At the end of September, they saw 8.9%-10.4% more subscriptions than in January, depending on a model.
In simple terms, all paywall models worked similarly well.
INMA saw bigger differences when indexing growth to January 2020. Brands with hard and metered walls seem to have grown the fastest (162% and 148%), and hybrid and freemium sites seem to have grown more slowly (100% and 86%).
Does it mean that the least popular paywall models delivered the best performance in the long term? Correlation doesn’t indicate causation.
The general logic of a paywall likely impacts the performance. However, brand awareness, product qualities, news cycle, actual offers (such as price and other terms), or specific paywall rules (such as its selectivity) impact the performance too, based on INMA research.
Individual publishers can test causal hypotheses through business experiments.
Brief history of paywalls: In the past, top news executives were sometimes deliberating paywall models for months before choosing one. Last year, some were changing targeting criteria every few weeks or months — South China Morning Post, for example. After exhausting one segment, they are simply targeting another, adjusting the paywall rules.
The most sophisticated paywalls today are automated systems, driven by predictive algorithms and fueled by data about readers, their behaviours, and context of visits. Initially, these hybrid models were the domain of the largest publishers, such as The New York Times, but recently software vendors have democratised access to predictive analytics and personalised paywalls.
Since the 2010s, the decision about whom to ask for a payment slowly moved from the strategic to tactical level — and now often is taken at the transactional level by an algorithm, locking and unlocking articles for each user.
Paywall rules used to be optimised to maximise new conversions, but today they often balance different objectives, such as growing market share vs. lifetime value. Other revenue lines are also considered, as some readers may be unlikely to subscribe but monetised with advertisements. The Wall Street Journal is doing this, for example.
The decision about whether to charge online readers remains a strategic choice, exclusive to executives defining the business model of a company.
Considering change in a paywall model? Join INMA Benchmarks to see how different models impact reader funnels and business lines.
What happened when Dennik N published AI-generated illustration on its front page?
Dennik N’s chief digital officer sees the potential of AI-generated art to supplement traditional illustrators rather than replace them.
In December 2022, Slovakia’s national newspaper Dennik N published its first AI-generated drawing. By January 2023, it was using generative AI to illustrate 10%-12% articles every day.
“We don’t use AI because it is cheaper than original photos or art,” explained Tomas Bella, chief digital officer of Dennik N, in an interview with INMA. “We use it because it is quicker and helps to replace bad stock photos and improve overall visual quality.”
The visual workflow: In Bella’s 100-person newsroom, reporters and editors select photos from the wires and stock libraries under only general supervision of a design director. Every day they file 30 to 40 new articles that need illustrations.
70% articles are news reports, illustrated with original photos from staff photographers or the wires.
30% articles are features or analyses that used to be illustrated most frequently with photos from libraries, such as Adobe Stock.
“Some topics are hard to illustrate — for example, about mortgages — and when we write about them repeatedly, reporters sometimes use the same stock photo over and over,” Bella said.
Dennik N hires freelance artists to illustrate longer, more important pieces, but it is more expensive and usually takes days from the assignment to the delivery. Therefore, original art is not believed to be viable for the daily grind at a newspaper with 68,000 digital subscribers.
Onboarding AI to the newsroom: Last autumn, the capabilities of generative AI to create visually stunning and unique images caught the attention of Bella, who started playing with Midjourney, an AI model similar to OpenAI’s DALL-E or Stable Diffusion.
Bella became fascinated by the images he saw on the Web and used Midjourney to illustrate his own articles. Then he talked to others in the newsroom about the potential of using it to replace bad stock photos with AI-generated drawings and sketches.
The design director was sceptical, but the editor-in-chief was intrigued enough to try it out. Soon, 10 journalists began using Midjourney, which they found easy to learn and affordable for the publication. They set up a Slack channel to share effective prompts.
The subscription to Midjourney with a commercial licence costs US$600 per year, or as much as only three months of Adobe Stock’s most comprehensive plan.
Over time, the team got comfortable to illustrate with AI its front page story in print and digital.
High hopes and concerns: “The reaction from the audience, and especially technology enthusiasts, has been positive,” noted Bella. The illustrations are clearly labelled as created with the assistance of AI.
Some readers raised ethical questions about, for example, the impact of AI on human illustrators. “We continue to commission human artists for signature articles,” answered Bella, declaring to follow a global debate on responsible use of AI.
He acknowledged copyright lawsuits against AI companies for scraping artists’ work from the Web without their consent, which are not resolved yet.
Non-artists like himself benefitted from AI because it helped them to express themselves in ways they never could. The results, he admitted, were rather basic and lacked consistent style.
“As real artists learn how to use this technology, the possibilities for creating visually stunning and unique images are endless,” he said, adding there was also the potential for a combination of AI-generated art and traditional illustration methods to create a unique style for the publication and its marketing.
“We need to find our own style before everybody starts using AI and readers get bored with it.”
Tomas Bella of Dennik N and Lukas Görög of Die Presse will host a workshop on generative AI at the INMA Media Subscriptions Summit in Stockholm on March 8-10.
Download “AI Guide and ChatGPT Promptbook for News Marketers,” Greg Piechota’s new report. It’s free to INMA members.
About this newsletter
Today’s newsletter is written by Grzegorz “Greg” Piechota, INMA’s researcher-in-residence and lead for the Readers First Initiative. In his letters, Greg shares original research, analysis, and best practices in growing reader revenue.
E-mail Greg at [email protected], message him on Slack, meet him at the next online meet-up or in person at the INMA Media Subscription Summit in March.
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Some Sept. 11 Questions Go Unanswered
By Larry Abramson
Published July 23, 2004 at 12:00 AM EDT
While Sept. 11 commission co-chairman Thomas Kean considers the panel's report definitive, he concedes many details remain cloudy. Some groups say more investigation is needed to answer critical questions. NPR's Larry Abramson reports.
Larry Abramson
Larry Abramson is NPR's National Security Correspondent. He covers the Pentagon, as well as issues relating to the thousands of vets returning home from the wars in Afghanistan and Iraq. | 2023-14/0000/en_head.json.gz/1323 | {"url": "https://www.innovationtrail.org/2004-07-23/some-sept-11-questions-go-unanswered", "partition": "head_middle", "language": "en", "source_domain": "www.innovationtrail.org", "date_download": "2023-03-20T10:16:58Z", "digest": "sha1:MJ6BSTS5CP3GRGMSKTTNW2DWJK6MW235"} | {"ccnet_length": [[0, 533, 533.0]], "ccnet_original_length": [[0, 533, 894.0]], "ccnet_nlines": [[0, 533, 6.0]], "ccnet_original_nlines": [[0, 533, 35.0]], "ccnet_language_score": [[0, 533, 0.95]], "ccnet_perplexity": [[0, 533, 255.4]], "ccnet_bucket": [[0, 533, 0.0]], "rps_doc_curly_bracket": [[0, 533, 0.0]], "rps_doc_ldnoobw_words": [[0, 533, 0.0]], "rps_doc_lorem_ipsum": [[0, 533, 0.0]], "rps_doc_stop_word_fraction": [[0, 533, 0.23529412]], "rps_doc_ut1_blacklist": [[0, 533, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 533, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 533, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 533, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 533, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 533, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 533, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 533, 0.11899314]], "rps_doc_frac_chars_top_3gram": [[0, 533, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 533, 0.0]], "rps_doc_frac_all_caps_words": [[0, 533, 0.03921569]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 533, 0.0]], "rps_doc_frac_no_alph_words": [[0, 533, 0.20588235]], "rps_doc_frac_unique_words": [[0, 533, 0.7804878]], "rps_doc_mean_word_length": [[0, 533, 5.32926829]], "rps_doc_symbol_to_word_ratio": [[0, 533, 0.0]], "rps_doc_unigram_entropy": [[0, 533, 4.05169264]], "rps_doc_word_count": [[0, 533, 82.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 38, 0.0], [38, 56, 0.0], [56, 96, 0.0], [96, 332, 1.0], [332, 347, 0.0], [347, 533, 1.0]], "rps_lines_javascript_counts": [[0, 38, 0.0], [38, 56, 0.0], [56, 96, 0.0], [96, 332, 0.0], [332, 347, 0.0], [347, 533, 0.0]], "rps_lines_num_words": [[0, 38, 6.0], [38, 56, 3.0], [56, 96, 8.0], [96, 332, 33.0], [332, 347, 2.0], [347, 533, 30.0]], "rps_lines_numerical_chars_fraction": [[0, 38, 0.05555556], [38, 56, 0.0], [56, 96, 0.27027027], [96, 332, 0.00881057], [332, 347, 0.0], [347, 533, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 38, 0.0], [38, 56, 0.0], [56, 96, 0.0], [96, 332, 0.0], [332, 347, 0.0], [347, 533, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 38, 0.13157895], [38, 56, 0.16666667], [56, 96, 0.175], [96, 332, 0.04237288], [332, 347, 0.13333333], [347, 533, 0.06451613]], "rps_doc_ml_palm_score": [[0, 533, 3.302e-05]], "rps_doc_ml_wikipedia_score": [[0, 533, null]], "rps_doc_ml_wikiref_score": [[0, 533, 0.0048337]], "rps_doc_books_importance": [[0, 533, -25.23177367]], "rps_doc_openwebtext_importance": [[0, 533, -6.69484095]], "rps_doc_wikipedia_importance": [[0, 533, 7.84471008]], "rps_doc_num_sentences": [[0, 533, 7.0]]} |
Union’s centerback rotation a rarity and a luxury in jam-packed MLS season
Most soccer teams don't rotate their centerbacks often. But the Union have three starting-caliber players in Mark McKenzie, Jack Elliott, and Jakob Glesnes, and Jim Curtin has willingly used them all.
Union centerback Jakob Glesnes ranks No. 2 in MLS in clearances per game, and No. 5 in accurate long ball passes per game.Read moreELIZABETH ROBERTSON / Staff Photographer
by Jonathan Tannenwald
In much of the soccer world, when managers write down their starting lineups, they start with their centerbacks.
That pairing or trio is the starting point for the formation as a whole, and the top unit is usually written in ink. Consistency matters as much as talent when defenders work together to cover opposing attackers.
You might expect Union manager Jim Curtin, a former centerback, to think that way. But this year he hasn’t. He has three starting-caliber centerbacks in Mark McKenzie, Jack Elliott, and Jakob Glesnes, and he hasn’t been afraid to rotate them. McKenzie and Elliott have been the most used pairing, to be sure, but Glesnes has played in eight of the team’s 13 games this year — including six starts.
Statistical analysis of centerbacks isn’t as straightforward as it is for other positions, but there are a few significant numbers to know. Glesnes ranks No. 2 in all of MLS in clearances per game (6.4), McKenzie ranks No. 5 (6.0), and Elliott ranks No. 13 (5.3). Glesnes also ranks No. 5 in accurate long ball passes per game (7.4).
And there’s the number that matters most: goals conceded. The Union are one of only six teams in MLS that have let in fewer than 10 in regular-season games. (Yes, they let in three in the MLS tournament knockout rounds, but not every team played in them.)
» READ MORE: Top soccer games to watch this weekend, with Christian Pulisic and Rose Lavelle in the spotlight
“I’m a very lucky coach in MLS,” Curtin said. “Not many coaches, not just in MLS but all over the world, can say that they have three [centerbacks] that are able to play at the level that these guys are playing.”
He believes he’ll have to pick a top pairing “when the weather gets cold and the time comes for the final stretch" of the regular season, but right now “you’d be flipping a coin” to choose exactly which two would top the depth chart.
There are good reasons to hold off making the choice, beyond the impact of global warming. MLS has set its regular-season schedule only through the end of September, announcing Friday the slate for the rest of this month. The Union will have to play three games in a week again soon, and probably at least once in October.
So continued rotation of players will be necessary, not just helpful.
“There’s no reason to drive [players] into the ground right now,” Curtin said, a point emphasized by the Union’s unusually long injury list. Elliott, Kai Wagner, Sergio Santos, and Warren Creavalle are all questionable for the home game Saturday against New England (7:30 p.m., PHL17), and Aurélien Collin remains out while rehabbing a long-term leg injury.
The three new games on the schedule were announced Friday: Sept. 20 vs. Montreal at Red Bull Arena, Sept. 23 at FC Cincinnati, and Sept. 27 at home vs. Inter Miami, which just added a new star in striker Gonzalo Higuaín. The Argentine left Italian giant Juventus this week and arrived in Miami on Friday to begin a 10-day quarantine. (The Montreal game will be at Red Bull Arena so the Impact can stay in the U.S. for an extended time.)
All three games will be 7:30 p.m. kickoffs, televised on PHL17 and streamed online free on the Union’s website.
» READ MORE: Matt Real, Andrew Wooten stepped up and showed potential in Union’s win over Red Bulls
MLS sets playoff format
In addition to announcing games through the end of September, MLS confirmed the format of this year’s playoffs. Because of the shortened regular season, 18 of the league’s 26 teams will qualify for the postseason.
The unbalancing of conferences for the year caused by Nashville’s temporary move to the Eastern Conference means the number of playoff qualifiers from each conference won’t be equal. Eight of the Western Conference’s 12 teams will make it, seeded 1 through 8, while 10 of the Eastern Conference’s 14 teams will make it. The East’s top six teams will get a bye and the 7 through 10 seeds will go to a play-in bracket.
That will lead to each conference having eight teams in the quarterfinal round. The worse seed of the play-in winners will face the No. 1 team, while the better seed will face the No. 2 team.
All rounds will be single-elimination, culminating in the championship game Dec. 12. As of now, the top team in the final will host the game, but it won’t be surprising if weather and the pandemic force the game to a neutral site.
Published Sept. 11, 2020
Jonathan Tannenwald
I'm the Inquirer's soccer reporter, covering the Union, MLS, the NWSL, the U.S. men's and women's national teams, and Philadelphia's place in the world's game. 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Video Conferencing for Business
Click to Register: https://www.eventbrite.ca/e/video-conferencing-for-business-tickets-174462330527
Join us on this workshop to help you decide which video conferencing solution is best for your work and business (Zoom, Teams, Google Meet)
Video conferencing software and apps are an essential means of communication for all sorts of people and businesses.
If you are working from home, you need a way to connect over video conferencing with others. Products like Zoom, Microsoft Teams, and Google Meet (formerly Hangouts Meet) are among the most popular video conferencing solutions.
To help you decide which is best, we’ve pitted these three apps against each other and compared what they have to offer.
About the Speaker: Sergey Poltev
Sergey obtained his M.Sc. in Computer Science with Honors in 2005 and was the recipient of a national scholarship. He’s been fixing computers since he was 12 years old and has been working in IT for his entire career. In 2008 he launched CAPITALTEK as a solo entrepreneur. Through his dedication to serving clients with quality service, honesty and transparent pricing, his firm has grown over the years and is projected to further expand in 2021 and beyond. Sergey volunteers as the Virtual CIO for Ability First Ottawa, a charitable organization that provides services and support to individuals with developmental disabilities. As well, he’s a volunteer Career Mentor with Ottawa Community Immigration Services where he helps new Canadian immigrants find jobs in the tech sector.
About CAPITALTEK
CAPITALTEK is an Ottawa-based professional IT services firm serving small and mid-sized clients (5-50 users). Since 2008, we’ve been providing affordable computer maintenance, managed network services, hardware, VOIP, data backup & recovery and web hosting. Our clients include solo entrepreneurs, small firms, professional services and not-for-profit organizations. We take a proactive approach with IT, Cloud and Phone systems to keep your operations running smoothly. Think of us as your virtual IT Department.
2021-10-12 11:00:00 2021-10-12 12:00:00 America/Toronto Video Conferencing for Business Details Date: October 12 Time: 11:00 am - 12:00 pm Event Category: Invest Ottawa Events Click to Register: https://www.eventbrite.ca/e/video-conferencing-for-business-tickets-174462330527 Organizer Invest Ottawa Education Centre Website: https://www.eventbrite.ca/o/invest-ottawa-education-centre-1492863402 Join us on this workshop to help you decide which video conferencing solution is best for your work and business (Zoom, Teams, Google Meet) Video conferencing software and apps […]
Details Date: Oct 12 @ 11:00 am - 12:00 pm Cost: Free Registration: https://www.eventbrite.ca/e/video-conferencing-for-business-tickets-174462330527 Organizer: Invest Ottawa Education Centre | 2023-14/0000/en_head.json.gz/1325 | {"url": "https://www.investottawa.ca/eventbrite-event/video-conferencing-for-business/", "partition": "head_middle", "language": "en", "source_domain": "www.investottawa.ca", "date_download": "2023-03-20T09:10:19Z", "digest": "sha1:C3USOPFQ5LR7GODOZTSBXKNG34TB4TF3"} | {"ccnet_length": [[0, 2852, 2852.0]], "ccnet_original_length": [[0, 2852, 21103.0]], "ccnet_nlines": [[0, 2852, 12.0]], "ccnet_original_nlines": [[0, 2852, 188.0]], "ccnet_language_score": [[0, 2852, 0.93]], "ccnet_perplexity": [[0, 2852, 268.4]], "ccnet_bucket": [[0, 2852, 0.0]], "rps_doc_curly_bracket": [[0, 2852, 0.0]], "rps_doc_ldnoobw_words": [[0, 2852, 0.0]], "rps_doc_lorem_ipsum": [[0, 2852, 0.0]], "rps_doc_stop_word_fraction": [[0, 2852, 0.27700348]], "rps_doc_ut1_blacklist": [[0, 2852, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2852, 0.12360515]], "rps_doc_frac_chars_dupe_5grams": [[0, 2852, 0.22145923]], "rps_doc_frac_chars_dupe_6grams": [[0, 2852, 0.21287554]], "rps_doc_frac_chars_dupe_7grams": [[0, 2852, 0.12360515]], "rps_doc_frac_chars_dupe_8grams": [[0, 2852, 0.12360515]], "rps_doc_frac_chars_dupe_9grams": [[0, 2852, 0.12360515]], "rps_doc_frac_chars_top_2gram": [[0, 2852, 0.0583691]], "rps_doc_frac_chars_top_3gram": [[0, 2852, 0.01158798]], "rps_doc_frac_chars_top_4gram": [[0, 2852, 0.0193133]], "rps_doc_frac_all_caps_words": [[0, 2852, 0.0174216]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2852, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2852, 0.26829268]], "rps_doc_frac_unique_words": [[0, 2852, 0.54846939]], "rps_doc_mean_word_length": [[0, 2852, 5.94387755]], "rps_doc_symbol_to_word_ratio": [[0, 2852, 0.00174216]], "rps_doc_unigram_entropy": [[0, 2852, 5.08492157]], "rps_doc_word_count": [[0, 2852, 392.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 32, 0.0], [32, 132, 0.0], [132, 272, 0.0], [272, 389, 1.0], [389, 617, 1.0], [617, 738, 1.0], [738, 771, 0.0], [771, 1554, 1.0], [1554, 1571, 0.0], [1571, 2085, 1.0], [2085, 2662, 0.0], [2662, 2852, 0.0]], "rps_lines_javascript_counts": [[0, 32, 0.0], [32, 132, 0.0], [132, 272, 0.0], [272, 389, 0.0], [389, 617, 0.0], [617, 738, 0.0], [738, 771, 0.0], [771, 1554, 0.0], [1554, 1571, 0.0], [1571, 2085, 0.0], [2085, 2662, 0.0], [2662, 2852, 0.0]], "rps_lines_num_words": [[0, 32, 4.0], [32, 132, 4.0], [132, 272, 24.0], [272, 389, 18.0], [389, 617, 36.0], [617, 738, 22.0], [738, 771, 5.0], [771, 1554, 125.0], [1554, 1571, 2.0], [1571, 2085, 71.0], [2085, 2662, 64.0], [2662, 2852, 17.0]], "rps_lines_numerical_chars_fraction": [[0, 32, 0.0], [32, 132, 0.13953488], [132, 272, 0.0], [272, 389, 0.0], [389, 617, 0.0], [617, 738, 0.0], [738, 771, 0.0], [771, 1554, 0.01818182], [1554, 1571, 0.0], [1571, 2085, 0.01425662], [2085, 2662, 0.11342155], [2662, 2852, 0.13095238]], "rps_lines_start_with_bulletpoint": [[0, 32, 0.0], [32, 132, 0.0], [132, 272, 0.0], [272, 389, 0.0], [389, 617, 0.0], [617, 738, 0.0], [738, 771, 0.0], [771, 1554, 0.0], [1554, 1571, 0.0], [1571, 2085, 0.0], [2085, 2662, 0.0], [2662, 2852, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 32, 0.09375], [32, 132, 0.02], [132, 272, 0.03571429], [272, 389, 0.00854701], [389, 617, 0.03947368], [617, 738, 0.00826446], [738, 771, 0.12121212], [771, 1554, 0.04725415], [1554, 1571, 0.64705882], [1571, 2085, 0.05447471], [2085, 2662, 0.04852686], [2662, 2852, 0.05789474]], "rps_doc_ml_palm_score": [[0, 2852, 0.00291693]], "rps_doc_ml_wikipedia_score": [[0, 2852, null]], "rps_doc_ml_wikiref_score": [[0, 2852, 0.03575677]], "rps_doc_books_importance": [[0, 2852, -363.11386051]], "rps_doc_openwebtext_importance": [[0, 2852, -118.30681041]], "rps_doc_wikipedia_importance": [[0, 2852, -204.63366862]], "rps_doc_num_sentences": [[0, 2852, 26.0]]} |
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Internal Revenue Bulletin: 2019-01
Highlights of This Issue
The IRS Mission
Part III. Administrative, Procedural, and Miscellaneous
Rev. Proc. 20191
Definition of Terms and Abbreviations
Numerical Finding List
Effect of Current Actions on Previously Published Items
Finding List of Current Actions on Previously Published Items
INTERNAL REVENUE BULLETIN
We Welcome Comments About the Internal Revenue Bulletin
These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
Rev. Proc. 2019–1 Rev. Proc. 2019–1
This procedure contains revised procedures for letter rulings and information letters issued by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), Associate Chief Counsel (Procedure and Administration), and Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). This procedure also contains revised procedures for determination letters issued by the Large Business and International Division, Small Business/Self Employed Division, Wage and Investment Division, and Tax Exempt and Government Entities Division. Rev. Proc. 2018–1 is superseded.
This procedure explains when and how an Associate office within the Office of Chief Counsel provides technical advice, conveyed in technical advice memoranda (TAMs). It also explains the rights that a taxpayer has when a field office requests a TAM regarding a tax matter. Rev. Proc. 2018–2 is superseded.
This procedure provides a revised list of areas of the Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) relating to matters on which the Service will not issue letter rulings or determination letters. Rev. Proc. 2018–3 is superseded.
This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 2018–4 is superseded.
This procedure sets forth procedures for issuing determination letters on issues under the jurisdiction of the Director, Exempt Organizations (EO) Rulings and Agreements. Specifically, it explains the procedures for issuing determination letters on exempt status (in response to applications for recognition of exemption from Federal income tax under § 501 or § 521 other than those subject to Rev. Proc. 2019–4, this Bulletin (relating to pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans)), private foundation status, and other determinations related to exempt organizations. These procedures also apply to revocation or modification of determination letters. This revenue procedure also provides guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under § 7428. Finally, this revenue procedure provides guidance on applicable user fees for requesting determination letters.
Areas in which rulings will not be issued. Associate Chief Counsel (International).
Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).
Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 7
.01 Description of terms used in this revenue procedure 7
.02 Updated annually 8
SECTION 2. WHAT ARE THE FORMS IN WHICH THE SERVICE PROVIDES ADVICE TO TAXPAYERS? 8
.01 Letter ruling 8
.02 Closing agreement 8
.03 Determination letter 9
.04 Information letter 9
.05 Oral advice 9
(1) No oral rulings and no written rulings in response to oral requests 9
(2) Discussion possible on substantive issues 10
(3) Oral guidance is advisory only, and the Service is not bound by it. 10
SECTION 3. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS REVENUE PROCEDURE? 10
.01 Issues under the jurisdiction of the Associate Chief Counsel (Corporate) 10
.02 Issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products) 10
.03 Issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting) 11
.04 Issues under the jurisdiction of the Associate Chief Counsel (International) 11
.05 Issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries) 11
.06 Issues under the jurisdiction of the Associate Chief Counsel (Procedure and Administration) 11
.07 Issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) 11
SECTION 4. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES? 12
.01 Issues involving alcohol, tobacco, and firearms taxes 12
.02 Certain issues involving employee plans, individual retirement accounts (IRAs), and exempt organizations 12
SECTION 5. UNDER WHAT CIRCUMSTANCES DO THE ASSOCIATE OFFICES ISSUE LETTER RULINGS? 12
.01 In income and gift tax matters 12
.02 Special relief for late S corporation and related elections in lieu of letter ruling process 13
.03 A § 301.9100 request for extension of time for making an election or for other relief 13
(1) Format of request 13
(2) Period of limitation 14
(3) Taxpayer must notify the Associate office if examination of its return begins while the request is pending 15
(4) Associate office will notify the examination agent, appeals officer, or attorney of a § 301.9100 request if the taxpayer’s return is being examined by a Field office or is being considered by an Appeals office or a Federal court 13
(5) Inclusion of statement required by section 4.04 of Rev. Proc. 2009–41 14
(6) Relief for late initial classification election 14
.04 Determinations under § 999(d) 14
.05 In matters involving § 367 14
.06 In estate tax matters 14
.07 In matters involving additional estate tax under § 2032A(c) 15
.08 In matters involving qualified domestic trusts under § 2056A 15
.09 In generation-skipping transfer tax matters 15
.10 In employment and excise tax matters 15
.11 In procedural and administrative matters 16
.12 In Indian tribal government matters 16
(1) Definition of Indian tribal government 16
(2) Inclusion in list of tribal governments 16
.13 On constructive sales price under § 4216(b) or § 4218(c) 16
.14 In exempt organizations matters 16
.15 In qualified retirement plan and IRA matters 17
.16 A request to revoke an election 17
.17 Under some circumstances before the issuance of a regulation or other published guidance 17
(1) Answer is clear or is reasonably certain 17
(2) Answer is not reasonably certain 18
SECTION 6. UNDER WHAT CIRCUMSTANCES DOES THE SERVICE NOT ISSUE LETTER RULINGS OR DETERMINATION LETTERS? 18
.01 Ordinarily not if the request involves an issue under examination or consideration or in litigation 18
.02 Ordinarily not in certain areas because of factual nature of the problem or for other reasons 18
.03 Ordinarily not on part of an integrated transaction 19
(1) General rule 19
(2) Significant issue ruling 19
(3) Submission requirements 19
.04 Ordinarily not on which of two entities is a common law employer 20
.05 Ordinarily not to business associations or groups 20
.06 Ordinarily not where the request does not address the tax status, liability, or reporting obligations of the requester 20
.07 Ordinarily not to foreign governments 20
.08 Ordinarily not on Federal tax consequences of proposed legislation 21
.09 Ordinarily not before issuance of a regulation or other published guidance 21
.10 Not on frivolous issues 21
.11 No “comfort” letter rulings 22
.12 Not on alternative plans or hypothetical situations 22
.13 Not on property conversions after return filed 22
.14 Circumstances under which determination letters are not issued by a Director 22
SECTION 7. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS? 23
.01 Documents and information required in all requests 23
(1) Complete statement of facts and other information 23
(2) Copies of all contracts, wills, deeds, agreements, instruments, other documents pertinent to the transaction, and foreign laws 23
(3) Analysis of material facts 24
(4) Statement regarding whether same issue is in an earlier return and additional information required for § 301.9100 requests 24
(5) Statement regarding whether same or similar issue was previously ruled on or whether a request involving it was submitted or is currently pending 25
(6) Statement regarding interpretation of a substantive provision of an income or estate tax treaty 26
(7) Statement regarding involvement of a transactional party located in a foreign country 26
(8) Letter from Bureau of Indian Affairs relating to a letter ruling request for recognition of Indian tribal government status or status as a political subdivision of an Indian tribal government. 26
(9) Statement of supporting authorities 27
(10) Statement of contrary authorities 27
(11) Statement identifying pending legislation 27
(12) Statement identifying information to be deleted from the public inspection copy of letter ruling or determination letter 27
(13) Signature by taxpayer or authorized representative 29
(14) Authorized representatives 29
(15) Power of attorney and declaration of representative 31
(16) Penalties of perjury statement 31
(17) Number of copies of request to be submitted 32
(18) Sample format for a letter ruling request 32
(19) Checklist for letter ruling requests 32
.02 Additional procedural information required with request 32
(1) To request separate letter rulings for multiple issues in a single situation 32
(2) Power of attorney used to indicate recipient of a copy or copies of a letter ruling or a determination letter 33
(3) To request a particular conclusion on a proposed transaction 33
(4) To request expedited handling 34
(5) To request the receipt of any document related to letter ruling request by fax 35
(6) To request a conference 35
.03 Additional information required in letter ruling requests involving welfare benefit funds (including voluntary employees’ beneficiary associations (VEBAs)) 35
(1) Request for letter rulings on the tax consequences of a proposed transaction involving a welfare benefit fund 35
(2) Code sections to consider 35
.04 Address to which to send request for letter ruling or determination letter 36
(1) Request for letter ruling 36
(2) Request for determination letter 37
.05 Pending letter ruling requests 37
(1) Circumstances under which the taxpayer with a pending letter ruling request must notify the Associate office 37
(2) Taxpayer must notify the Associate office if a return is filed and must attach the request to the return 38
.06 When to attach letter ruling or determination letter to return 38
.07 How to check on status of request for letter ruling or determination letter 38
.08 Request for letter ruling or determination letter may be withdrawn or Associate office may decline to issue letter ruling 38
(1) In general 38
(2) Notification of appropriate Service official 39
SECTION 8. HOW DO THE ASSOCIATE OFFICES HANDLE LETTER RULING REQUESTS? 39
.01 Docket, Records, and User Fee Branch receives, initially controls, and refers the requests to the appropriate Associate office 39
.02 Branch representative of the Associate office contacts taxpayer within 21 calendar days 39
.03 Determines if transaction can be modified to obtain favorable letter ruling 40
.04 Not bound by informal opinion expressed 40
.05 May request additional information 40
(1) Additional information must be submitted within 21 calendar days 40
(2) Extension of reply period if justified and approved 41
(3) Letter ruling request closed if the taxpayer does not submit additional information 41
(4) Penalties of perjury statement 41
(5) Faxing request and additional information 41
(6) Address to which to send additional information 41
(7) Identifying information 42
(8) Number of copies 42
.06 Near the completion of the ruling process, advises the taxpayer of conclusions and, if the Associate offices will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling request 42
.07 May request that taxpayer submit draft proposed letter ruling near the completion of the ruling process 42
.08 Issues separate letter rulings for substantially identical letter rulings, but generally issues a single letter ruling for related § 301.9100 letter rulings 43
(1) Substantially identical letter rulings 43
(2) Related § 301.9100 letter rulings 43
.09 Sends a copy of the letter ruling to appropriate Service official 43
SECTION 9. WHAT ARE THE SPECIFIC AND ADDITIONAL PROCEDURES FOR A REQUEST FOR A CHANGE IN METHOD OF ACCOUNTING FROM THE ASSOCIATE OFFICES? 43
.01 Automatic and non-automatic change in method of accounting requests 43
(1) Automatic change in method of accounting 43
(2) Non-automatic change in method of accounting 44
.02 Ordinarily only one change in method of accounting on a Form 3115, Application for Change in Accounting Method, and a separate Form 3115 for each taxpayer and for each separate and distinct trade or business 44
.03 Information required with a Form 3115 44
(1) Facts and other information requested on Form 3115 and in applicable revenue procedures 44
(2) Statement of contrary authorities 45
(3) Copies of all contracts, agreements, and other documents 45
(5) Information regarding whether same issue is in an earlier return 45
(6) Statement regarding prior requests for a change in method of accounting and other pending requests 46
(7) Statement identifying pending legislation 46
(8) Authorized representatives 46
(9) Power of attorney and declaration of representative 46
(10) Tax Information Authorization 46
.04 Additional procedural information required in certain circumstances 47
(1) Recipients of original and copy of change in method of accounting correspondence 47
(3) To receive the change in method of accounting letter ruling or any other correspondence related to Form 3115 by fax 47
.05 Addresses to which to send Forms 3115 48
(1) Non-automatic Form 3115 48
(2) Automatic change request 49
.06 A Form 3115 must not be submitted by fax 49
.07 Docket, Records, and User Fee Branch receives, initially controls, and refers the Form 3115 to the appropriate Associate office 49
.08 Additional information 49
(1) Reply period. 49
(2) Request for extension of reply period. 49
(3) Penalties of perjury statement for additional information 50
(4) Identifying information included in additional information 50
(5) Faxing information request and additional information 50
(6) Address to which to send additional information to an Associate office 50
(7) Failure to timely submit additional information to an Associate office 51
.09 Circumstances in which the taxpayer must notify the Associate office 51
.10 Determines if proposed method of accounting can be modified to obtain favorable letter ruling 52
.11 Near the completion of processing the Form 3115, advises the taxpayer if the Associate office will rule adversely and offers the taxpayer the opportunity to withdraw Form 3115 52
.12 Non-automatic Form 3115 may be withdrawn or Associate office may decline to issue a change in method of accounting letter ruling 52
(2) Notification of appropriate Service official. 52
.13 How to check status of a pending non-automatic Form 3115 53
.14 Service is not bound by informal opinion 53
.15 Single letter ruling issued to a taxpayer or consolidated group for qualifying identical change in method of accounting 53
.16 Letter ruling ordinarily not issued for one of two or more interrelated items or submethods 53
.17 Consent Agreement 53
.18 A copy of the change in method of accounting letter ruling is sent to appropriate Service official 54
.19 Consent to change a method of accounting may be relied on subject to limitations 54
.20 Change in method of accounting letter ruling does not apply to another taxpayer 54
.21 Associate office discretion to permit requested change in method of accounting 54
.22 List of automatic change in method of accounting request procedures 54
.23 Other sections of this revenue procedure that are applicable to Form 3115 56
SECTION 10. HOW ARE CONFERENCES FOR LETTER RULINGS SCHEDULED? 57
.01 Schedules a conference if requested by taxpayer 57
.02 Permits taxpayer one conference of right 58
.03 Disallows verbatim recording of conferences 58
.04 Makes tentative recommendations on substantive issues 58
.05 May offer additional conferences 58
.06 Requires written confirmation of information presented at conference 59
.07 May schedule a pre-submission conference 59
(1) Taxpayer may request a pre-submission conference in writing or by telephone 59
(2) Pre-submission conference held in person or by telephone 60
(3) Certain information required to be submitted to the Associate office prior to the pre-submission conference 60
(4) Discussion of substantive issues not binding on the Service 60
.08 May schedule a conference to be held by telephone 60
SECTION 11. WHAT EFFECT WILL A LETTER RULING HAVE? 61
.01 May be relied on subject to limitations 61
.02 Will not apply to another taxpayer 61
.03 Will be used by a Field office in examining the taxpayer’s return 61
.04 May be revoked or modified if found to be in error or there has been a change in law 61
.05 Letter ruling revoked or modified based on material change in facts applied retroactively 62
.06 Not otherwise generally revoked or modified retroactively 62
.07 Will not apply to a similar transaction in same year or any other year 63
.08 Retroactive effect of revocation or modification applied to a continuing action or series of actions 63
.09 Generally not retroactively revoked or modified if related to sale or lease subject to excise tax 63
.10 May be retroactively revoked or modified when transaction is entered into before the issuance of the letter ruling 64
.11 Taxpayer may request that retroactivity be limited 64
(1) Request for relief under § 7805(b) must be made in required format 64
(2) Taxpayer may request a conference on application of § 7805(b) 65
SECTION 12. UNDER WHAT CIRCUMSTANCES DO DIRECTORS ISSUE DETERMINATION LETTERS? 65
.05 Requests concerning income, estate, or gift tax returns 66
.06 Review of determination letters 66
SECTION 13. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 66
.01 Has same effect as a letter ruling 66
.02 Taxpayer may request that retroactive effect of revocation or modification be limited 67
SECTION 14. UNDER WHAT CIRCUMSTANCES ARE MATTERS REFERRED BETWEEN A DIRECTOR AND AN ASSOCIATE OFFICE? 67
.01 Requests for determination letters 67
.02 No-rule areas 68
.03 Requests for letter rulings 68
.04 Letter ruling request mistakenly sent to a Director 68
SECTION 15. WHAT ARE THE USER FEE REQUIREMENTS FOR REQUESTS FOR LETTER RULINGS AND DETERMINATION LETTERS? 68
.01 Legislation authorizing user fees 68
.02 Requests to which a user fee applies 68
.03 Requests to which a user fee does not apply 69
.04 Exemptions from the user fee requirements 69
.05 Fee schedule 70
.06 Applicable user fee for a request involving multiple offices, fee categories, issues, transactions, or entities 70
(1) Requests involving several offices 70
(2) Requests involving several fee categories 70
(3) Requests involving several issues 70
(4) Requests involving several unrelated transactions 70
(5) Requests involving several entities 70
(6) Requests made by married taxpayers who file jointly 70
.07 Applicable user fee for requests for substantially identical letter rulings or closing agreements, or identical changes in method of accounting 71
(2) Substantially identical letter rulings and closing agreements 71
(3) Substantially identical plans under § 25(c)(2)(B) 72
(4) Identical changes in method of accounting and related § 301.9100 letter rulings 72
.08 Method of payment 73
.09 Effect of nonpayment or payment of incorrect amount 73
.10 Refunds of user fee 73
.11 Request for reconsideration of user fee 74
SECTION 16. WHAT SIGNIFICANT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–1? 75
SECTION 17. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS? 76
SECTION 18. WHAT IS THE EFFECTIVE DATE OF THIS REVENUE PROCEDURE? 76
SECTION 19. PAPERWORK REDUCTION ACT 76
DRAFTING INFORMATION 76
APPENDIX A—SCHEDULE OF USER FEES 81
APPENDIX B—SAMPLE FORMAT FOR A LETTER RULING REQUEST 86
APPENDIX C—CHECKLIST FOR A LETTER RULING REQUEST 89
APPENDIX D—ADDITIONAL CHECKLIST FOR GOVERNMENT PICK-UP PLAN RULING REQUESTS 93
APPENDIX E—ADDITIONAL CHECKLIST FOR CHURCH PLAN RULING REQUESTS 94
APPENDIX F—LIST OF SMALL BUSINESS/SELF-EMPLOYED OPERATING DIVISION (SB/SE) OFFICES TO WHICH TO SEND REQUESTS FOR DETERMINATION LETTERS 95
APPENDIX G—CHECKLISTS, GUIDELINE REVENUE PROCEDURES, NOTICES, SAFE HARBOR REVENUE PROCEDURES, AND AUTOMATIC CHANGE REVENUE PROCEDURES 96
.01 Checklists, guideline revenue procedures, and notices 96
.02 Safe harbor revenue procedures 101
.03 Automatic change in accounting period revenue procedures 105
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE?
This revenue procedure explains how the Service provides advice to taxpayers on issues under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). It explains the forms of advice and the manner in which advice is requested by taxpayers and provided by the Service. A sample format for a letter ruling request is provided in Appendix B. See section 4 of this revenue procedure for information on certain issues outside the scope of this revenue procedure on which advice may be requested under a different revenue procedure.
Description of terms used in this revenue procedure
.01 For purposes of this revenue procedure—
(1) the term “Service” includes the four operating divisions of the Internal Revenue Service and the Associate offices. The four operating divisions are:
(a) Large Business & International Division (LB&I), which generally serves corporations, including S corporations, and partnerships, with assets in excess of $10 million;
(b) Small Business/Self-Employed Division (SB/SE), which generally serves corporations, including S corporations, and partnerships, with assets less than or equal to $10 million; filers of gift, estate, excise, employment and fiduciary returns; individuals filing an individual Federal income tax return with accompanying Schedule C (Profit or Loss From Business (Sole Proprietorship)), Schedule E (Supplemental Income and Loss), Schedule F (Profit or Loss From Farming), Form 2106, Employee Business Expenses, or Form 2106–EZ, Unreimbursed Employee Business Expenses;
(c) Wage and Investment Division (W&I), which generally serves individuals with wage and investment income only (and with no international tax returns) filing an individual Federal income tax return without accompanying Schedule C, E, or F, or Form 2106 or Form 2106–EZ; and
(d) Tax Exempt and Government Entities Division (TE/GE), which serves three distinct taxpayer segments: employee plans (including IRAs), exempt organizations, and government entities.
(2) the term “Associate office” refers to the Office of Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions and Products), the Office of Associate Chief Counsel (Income Tax and Accounting), the Office of Associate Chief Counsel (International), the Office of Associate Chief Counsel (Passthroughs and Special Industries), the Office of Associate Chief Counsel (Procedure and Administration), or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), as appropriate.
(3) the term “Director” refers to the Director, Field Operations, LB&I; Director, Field Examination, SB/SE; Director, Specialty Examination Policy, SB/SE; Program Manager, Estate & Gift Tax Policy, SB/SE; Program Manager, Employment Tax Policy, SB/SE; Program Manager, Excise Tax Policy, SB/SE; Director, Return Integrity & Compliance Services, W&I; Director, Employee Plans; Director, Employee Plans, Rulings and Agreements; Director, Employee Plans Examinations; Director, Exempt Organizations; Director, Exempt Organizations, Rulings and Agreements; Director, Exempt Organizations Examinations; Director, Indian Tribal Governments and Tax Exempt Bonds, as appropriate.
(4) the term “Field office” refers to the respective offices of the Directors, as appropriate.
(5) the term “taxpayer” includes all persons subject to any provision of the Internal Revenue Code and, when appropriate, their representatives. More specifically, the term includes tax-exempt organizations, as well as issuers of tax-exempt obligations, mortgage credit certificates, and tax credit bonds.
Updated annually
.02 This revenue procedure is updated annually as the first revenue procedure of the year, but it may be modified, amplified or clarified during the year.
SECTION 2. WHAT ARE THE FORMS IN WHICH THE SERVICE PROVIDES ADVICE TO TAXPAYERS?
The Service provides advice in the form of letter rulings, closing agreements, determination letters, information letters, and oral advice.
Letter ruling
.01 A “letter ruling” is a written determination issued to a taxpayer by an Associate office in response to the taxpayer’s written inquiry, filed prior to the filing of returns or reports that are required by the tax laws, about its status for tax purposes or the tax effects of its acts or transactions. A letter ruling interprets the tax laws and applies them to the taxpayer’s specific set of facts. A letter ruling is issued when appropriate in the interest of sound tax administration. One type of letter ruling is an Associate office’s response granting or denying a request for a change in a taxpayer’s method of accounting or accounting period. Once issued, a letter ruling may be revoked or modified for a number of reasons. See section 11 of this revenue procedure. A letter ruling may be issued with a closing agreement, however, and a closing agreement is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown. See section 2.02 of this revenue procedure.
Letter rulings are subject to exchange of information under U.S. tax treaties or tax information exchange agreements in accordance with the terms of such treaties and agreements (including terms regarding relevancy, confidentiality, and the protection of trade secrets.)
Closing agreement
.02 A “closing agreement” is a final agreement between the Service and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121, and it is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A taxpayer may request a closing agreement with a letter ruling or in lieu of a letter ruling, with respect to a transaction that would be eligible for a letter ruling. In such situations, the Associate Chief Counsel with subject matter jurisdiction signs the closing agreement on behalf of the Service.
A closing agreement may be entered into when it is advantageous to have the matter permanently and conclusively closed or when a taxpayer can show that there are good reasons for an agreement and that making the agreement will not prejudice the interests of the Government. In appropriate cases, a taxpayer may be asked to enter into a closing agreement as a condition for the issuance of a letter ruling.
If, in a single case, a closing agreement is requested for each person or entity in a class of taxpayers, separate agreements are entered into only if the class consists of 25 or fewer taxpayers. If the issue and holding are identical for the class and there are more than 25 taxpayers in the class, a “mass closing agreement” will be entered into with the taxpayer who is authorized by the others to represent the class.
Determination letter
.03 A “determination letter” is a written determination issued by a Director that applies the principles and precedents previously announced by the Service to a specific set of facts. It is issued only when a determination can be made based on clearly established rules in a statute, a tax treaty, the regulations, a conclusion in a revenue ruling, or an opinion or court decision that represents the position of the Service.
.04 An “information letter” is a statement issued by an Associate office or Director that calls attention to a well-established interpretation or principle of tax law (including a tax treaty) without applying it to a specific set of facts. An information letter may be issued if the taxpayer’s inquiry indicates a need for general information or if the taxpayer’s request does not meet the requirements of this revenue procedure and the Service concludes that general information will help the taxpayer. An information letter is advisory only and has no binding effect on the Service. If the Associate office issues an information letter in response to a request for a letter ruling that does not meet the requirements of this revenue procedure, the information letter is not a substitute for a letter ruling. The taxpayer should provide a daytime telephone number with the taxpayer’s request for an information letter.
Information letters that are issued by the Associate offices to members of the public are made available to the public. Information letters that are issued by the Field offices are generally not made available to the public.
Because information letters do not constitute written determinations as defined in § 6110, they are not subject to public inspection under § 6110. The Service makes the information letters available to the public under the Freedom of Information Act (the “FOIA”). Before any information letter is made available to the public, an Associate office will redact any information exempt from disclosure under the FOIA. See, e.g., 5 U.S.C. § 552(b)(6) (exemption for information the disclosure of which would constitute a clearly unwarranted invasion of personal privacy); 5 U.S.C. § 552(b)(3) in conjunction with § 6103 (exemption for returns and return information as defined in § 6103(b)).
The following documents also will not be available for public inspection as part of this process:
(1) transmittal letters in which the Service furnishes publications or other publicly available material to taxpayers, without any significant legal discussion;
(2) responses to taxpayer or third party contacts that are inquiries with respect to a pending request for a letter ruling, technical advice memorandum, or Chief Counsel Advice (which are subject to public inspection under § 6110 after their issuance); and
(3) responses to taxpayer or third party communications with respect to any investigation, audit, litigation, or other enforcement action.
Oral Advice
(1) No oral rulings and no written rulings in response to oral requests. The Service does not orally issue letter rulings or determination letters, nor does it issue letter rulings or determination letters in response to oral requests from taxpayers. Service employees ordinarily will discuss with taxpayers or their representatives inquiries about whether the Service will rule on particular issues and about procedural matters regarding the submission of requests for letter rulings or determination letters for a particular case.
(2) Discussion possible on substantive issues. At the discretion of the Service and as time permits, Service employees may also discuss substantive issues with taxpayers or their representatives. Such a discussion will not bind the Service or the Office of Chief Counsel, and it cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
Service employees who are not directly involved in the examination, appeal, or litigation of particular substantive tax issues will not discuss those issues with taxpayers or their representatives unless the discussion is coordinated with Service employees who are directly involved. The taxpayer or the taxpayer’s representative ordinarily will be asked whether an oral request for advice or information relates to a matter pending before another office of the Service or before a Federal court.
If a tax issue is not under examination, in appeals, or in litigation, the tax issue may be discussed even though the issue is affected by a nontax issue pending in litigation.
A taxpayer may seek oral technical guidance from a taxpayer service representative in a Field office or Service Center when preparing a return or report.
The Service does not respond to letters seeking to confirm the substance of oral discussions, and the absence of a response to such a letter is not a confirmation.
(3) Oral guidance is advisory only, and the Service is not bound by it. Oral guidance is advisory only, and the Service is not bound by it, for example, when examining the taxpayer’s return.
SECTION 3. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS REVENUE PROCEDURE?
Taxpayers may request letter rulings, information letters, and closing agreements under this revenue procedure on issues within the jurisdiction of the Associate offices. Taxpayers uncertain as to whether an Associate office has jurisdiction with regard to a specific factual situation may call the telephone number for the Associate office listed in section 10.07(1) of this revenue procedure.
Except as provided in section 6.14 of this revenue procedure, taxpayers also may request determination letters from the Director in the appropriate operating division. See sections 7 and 12 of this revenue procedure. For determination letters from TE/GE, see Rev. Proc. 2019–4 and Rev. Proc. 2019–5, this Bulletin.
Issues under the jurisdiction of the Associate Chief Counsel (Corporate)
.01 Issues under the jurisdiction of the Associate Chief Counsel (Corporate) include those that involve consolidated returns, corporate acquisitions, reorganizations, liquidations, redemptions, spinoffs, transfers to controlled corporations, distributions to shareholders, corporate bankruptcies, the effect of certain ownership changes on net operating loss carryovers and other tax attributes, debt vs. equity determinations, allocation of income and deductions among taxpayers, acquisitions made to evade or avoid income tax, and certain earnings and profits questions.
Issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products)
.02 Issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products) include those that involve income taxes and changes in method of accounting of banks, savings and loan associations, real estate investment trusts (REITs), regulated investment companies (RICs), real estate mortgage investment conduits (REMICs), insurance companies and products, tax-exempt obligations, mortgage credit certificates, tax credit bonds (including specified tax credit bonds), build America bonds, and financial products.
For the procedures to obtain private letter rulings involving tax-exempt state and local obligations, see Rev. Proc. 96–16, 1996–1 C.B. 630.
Issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting)
.03 Issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting) include those that involve recognition and timing of income and deductions of individuals and corporations, sales and exchanges, capital gains and losses, installment sales, equipment leasing, long-term contracts, inventories, amortization, depreciation, the alternative minimum tax, net operating losses generally, including changes in method of accounting for these issues, and accounting periods. (Note that certain issues involving individual retirement accounts (IRAs) are under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. See section 4.02, this revenue procedure).
Issues under the jurisdiction of the Associate Chief Counsel (International)
.04 Issues under the jurisdiction of the Associate Chief Counsel (International) include the tax treatment of nonresident aliens and foreign corporations, withholding of tax on nonresident aliens and foreign corporations, foreign tax credit, determination of sources of income, income from sources outside the United States, subpart F questions, domestic international sales corporations (DISCs), foreign sales corporations (FSCs), exclusions under § 114 for extraterritorial income (ETI), international boycott determinations, treatment of certain passive foreign investment companies, income affected by treaty, U.S. possessions, and other matters relating to the activities of non-U.S. persons within the United States or U.S.-related persons outside the United States, and changes in method of accounting for these persons.
For the procedures to obtain advance pricing agreements under § 482, see Rev. Proc. 2015–41, 2015–35 I.R.B. 263.
For competent authority procedures related to bilateral and multilateral advance pricing agreements, see Rev. Proc. 2015–40, 2015–35 I.R.B. 236.
Issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries)
.05 Issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries) include those that involve income taxes of S corporations (except accounting periods and methods) and certain noncorporate taxpayers (including partnerships, common trust funds, and trusts), entity classification, estate (excluding § 6166), gift, generation-skipping transfer, and certain excise taxes, depletion, and other engineering issues, cooperative housing corporations, farmers’ cooperatives under § 521, the low-income housing credit under § 42, the New Markets Tax Credit under § 45D, the rehabilitation credit under § 47, disabled access credit, qualified electric vehicle credits, research and experimental expenditures, shipowners’ protection and indemnity associations under § 526, and certain homeowners associations under § 528.
Issues under the jurisdiction of the Associate Chief Counsel (Procedure and Administration)
.06 Issues under the jurisdiction of the Associate Chief Counsel (Procedure and Administration) include those that involve Federal tax procedure and administration, disclosure and privacy law, reporting and paying taxes (including payment of taxes under § 6166), assessing and collecting taxes (including interest and penalties), abating, crediting, or refunding overassessments or overpayments of tax, and filing information returns.
Issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes)
.07 Issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) include those that involve the application of employment taxes and taxes on self-employment income, exemption requirements for tax-exempt organizations, tax treatment (including application of the unrelated business income tax) of tax-exempt organizations (including federal, state, local, and Indian tribal governments), political organizations described in § 527, qualified tuition programs described in § 529, qualified ABLE programs described in § 529A, trusts described in § 4947(a), certain excise taxes, disclosure obligations and information return requirements of tax-exempt organizations, employee benefit programs (including executive compensation arrangements, qualified retirement plans, deferred compensation plans, and health and welfare benefit programs) and IRAs, issues integrally related to employee benefit programs and IRAs (such as, for example, the sale of stock to employee stock ownership plans or eligible worker-owned cooperatives under § 1042), and changes in method of accounting associated with employee benefit programs.
Note that certain issues involving exempt organizations, employee plans, and government entities fall under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division of the Internal Revenue Service. See Rev. Proc. 2019–4 and Rev. Proc. 2019-5 this Bulletin.
SECTION 4. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES?
Issues involving alcohol, tobacco, and firearms taxes
.01 The procedures for obtaining letter rulings, closing agreements, determination letters, information letters, and oral advice that apply to Federal alcohol, tobacco, and firearms taxes under subtitle E of the Code are under the jurisdiction of the Alcohol and Tobacco Tax and Trade Bureau of the Department of the Treasury.
Certain issues involving qualified retirement plans, individual retirement accounts (IRAs), and exempt organizations
.02 The procedures for obtaining certain letter rulings, closing agreements, determination letters, information letters, and oral advice on qualified retirement plans and IRAs that are under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division are provided in Rev. Proc. 2019–4, this Bulletin. Rev. Proc. 2019–4, this Bulletin, also includes the procedures for issuing determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans under §§ 401, 403(a), 409, and 4975(e)(7), and the status for exemption of any related trusts or custodial accounts under § 501(a). See also Rev. Proc. 2019–5, this Bulletin, for the procedures for issuing determination letters on the tax-exempt status of organizations under § 501 and § 521, the foundation status of organizations described in § 501(c)(3) and the foundation status of nonexempt charitable trusts described in § 4947(a)(1).
For the user fee requirements applicable to requests under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, see Section 30 of Rev. Proc. 2019–4, and Section 14 of Rev. Proc. 2019–5 this Bulletin.
SECTION 5. UNDER WHAT CIRCUMSTANCES DO THE ASSOCIATE OFFICES ISSUE LETTER RULINGS?
In income and gift tax matters
.01 In income and gift tax matters, an Associate office generally issues a letter ruling on a proposed transaction or on a completed transaction if the letter ruling request is submitted before the return is filed for the year in which the transaction is completed. An Associate office will not ordinarily issue a letter ruling on a completed transaction if the letter ruling request is submitted after the return is filed for the year in which the transaction is completed. “Not ordinarily” means that unique and compelling reasons must be demonstrated to justify the issuance of a letter ruling submitted after the return is filed for the year in which the transaction is completed. The taxpayer must contact the Field office having audit jurisdiction over their return and obtain the Field’s consent to the issuance of such a letter ruling.
Special relief for late S corporation and related elections in lieu of letter ruling process
.02 In lieu of requesting a letter ruling under this revenue procedure, a taxpayer may obtain relief for certain late S corporation and related elections by following the procedure in Rev. Proc. 2013–30, 2013–36 I.R.B. 173. This procedure is in lieu of the letter ruling process and does not require payment of any user fee. See section 3.01 of Rev. Proc. 2013–30, and section 15.03(3) of this revenue procedure.
A § 301.9100 request for extension of time for making an election or for other relief
.03 An Associate office will consider a request for an extension of time for making an election or other application for relief under § 301.9100–3 of the Treasury Regulations, even if submitted after the return covering the issue presented in the § 301.9100 request has been filed, an examination of the return has begun, or the issues in the return are being considered by Appeals or a Federal court. Except for certain requests pertaining to applications for recognition of tax exemption under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, a § 301.9100 request is a letter ruling request. Therefore, the § 301.9100 request should be submitted pursuant to this revenue procedure. However, a § 301.9100 request involving recharacterization of an IRA (see § 1.408A–5, Q&A–6) should be submitted pursuant to Rev. Proc. 2019–4. An election made pursuant to § 301.9100–2 for an automatic extension of time is not a letter ruling request and does not require payment of any user fee. See § 301.9100–2(d) and section 15.03(1) of this revenue procedure.
(1) Format of request. A § 301.9100 request (other than an election made pursuant to § 301.9100–2 and certain requests pertaining to applications for recognition of tax exemption under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division) must be in the general form of, and meet the general requirements for, a letter ruling request. These requirements are given in section 7 of this revenue procedure. A § 301.9100 request must include an affidavit and declaration from the taxpayer and other parties having knowledge or information about the events that led to the failure to make a valid regulatory election and to the discovery of the failure. See §§ 301.9100–3(e)(2) and (e)(3). In addition, a § 301.9100 request must include the information required by § 301.9100–3(e)(4).
(2) Period of limitation. The filing of a request for relief under § 301.9100 does not suspend the running of any applicable period of limitation. See § 301.9100–3(d)(2). The Associate office ordinarily will not issue a § 301.9100 ruling if the period of limitation on assessment under § 6501(a) for the taxable year in which an election should have been made, or for any taxable years that would have been affected by the election had it been timely made, will expire before receipt of a § 301.9100 letter ruling. See § 301.9100–3(c)(1)(ii). If, however, the taxpayer consents to extend the period of limitation on assessment under § 6501(c)(4) for the taxable year in which the election should have been made and for any taxable years that would have been affected by the election had it been timely made, the Associate office may issue the letter ruling. See § 301.9100–3(d)(2). Note that the filing of a claim for refund under § 6511 does not extend the period of limitation on assessment. If § 301.9100–3 relief is granted, the Associate office may require the taxpayer to consent to an extension of the period of limitation on assessment. See § 301.9100–3(d)(2).
(3) Taxpayer must notify the Associate office if examination of its return begins while the request is pending. The taxpayer must notify the Associate office if the Service begins an examination of the taxpayer’s return for the taxable year in which an election should have been made, or for any taxable years that would have been affected by the election had it been timely made, while a § 301.9100–3 request is pending. This notification must include the name and telephone number of the examining agent. See § 301.9100–3(e)(4)(i) and section 7.05(1)(b) of this revenue procedure.
(4) Associate office will notify examination agent, appeals officer, or attorney of a § 301.9100 request if the taxpayer’s return is being examined by a Field office or is being considered by an Appeals office or a Federal court. If the taxpayer’s return for the taxable year in which an election should have been made, or for any taxable years that would have been affected by the election had it been timely made, is being examined by a Field office or considered by an Appeals office or a Federal court, the Associate office will notify the appropriate examination agent, appeals officer, or attorney that a § 301.9100 request has been submitted to the Associate office. The examination agent, appeals officer, or attorney is not authorized to deny consideration of a § 301.9100 request. The letter ruling will be mailed to the taxpayer and a copy will be sent to the appeals officer, attorney, or appropriate Service official in the operating division that has examination jurisdiction over the taxpayer’s tax return.
(5) Inclusion of statement required by section 4.04 of Rev. Proc. 2009–41. Eligible entities requesting a letter ruling because they do not meet all of the eligibility requirements of section 4.01 of Rev. Proc. 2009–41, 2009–39 I.R.B. 439, must include either the following representation as part of the entity’s request for a letter ruling or an explanation regarding why they do not qualify to do so: “All required U.S. tax and information returns of the entity (or, if the entity was not required to file any such returns under the desired classification, then all required U.S. tax and information returns of each affected person as defined in Section 4.02 of Rev. Proc. 2009–41) were filed timely or within 6 months of the due date of the respective return (excluding extensions) as if the entity classification election had been in effect on the requested date. No U.S. tax or information returns were filed inconsistently with those described in the prior sentence.”
(6) Relief for late initial classification election. In lieu of requesting a letter ruling under § 301.9100–1 through § 301.9100–3 and this revenue procedure, entities that satisfy the requirements set forth in section 4.01 of Rev. Proc. 2009–41, 2009–39 I.R.B. 439, may apply for late classification election relief under Rev. Proc. 2009–41. Requests for such relief are not subject to user fees. See section 3.01 of Rev. Proc. 2009–41 and section 15.03(2) of this revenue procedure.
Determinations under § 999(d)
.04 As provided in Rev. Proc. 77–9, 1977–1 C.B. 542, the Associate Chief Counsel (International) issues determinations under § 999(d) that a particular operation of a person, or of a member of a controlled group (within the meaning of § 993(a)(3)) that includes that person, or a foreign corporation of which a member of the controlled group is a U.S. shareholder, constitutes participation in or cooperation with an international boycott. The effect of that determination is to deny certain benefits of the foreign tax credit and the deferral of earnings of foreign subsidiaries and domestic international sales corporations (DISCs) to that person. The same principles shall apply with respect to exclusions under § 114 for exterritorial income (ETI). Requests for determinations under Rev. Proc. 77–9 are letter ruling requests and should be submitted to the Associate office pursuant to this revenue procedure.
In matters involving § 367
.05 Unless the issue is covered by section 6 of this revenue procedure, the Associate Chief Counsel (International) may issue a letter ruling under § 367 even if the taxpayer does not request a letter ruling as to the characterization of the transaction under the reorganization provisions of the Code. The Associate office will determine the § 367 consequences of a transaction but may indicate in the letter ruling that it expresses no opinion as to the characterization of the transaction under the reorganization. The Associate office may decline to issue a § 367 ruling in situations in which the taxpayer inappropriately characterizes the transaction under the reorganization provisions.
In estate tax matters
.06 In general, the Associate Chief Counsel (Passthroughs and Special Industries) issues letter rulings on transactions affecting the estate tax on the prospective estate of a living person. The Associate office will not issue letter rulings for prospective estates on computations of tax, actuarial factors, or factual matters. With respect to the transactions affecting the estate tax of the decedent’s estate, generally the Associate office issues letter rulings before the decedent’s estate tax return is filed.
If the taxpayer is requesting a letter ruling regarding a decedent’s estate tax and the estate tax return is due to be filed before the letter ruling is expected to be issued, the taxpayer should obtain an extension of time for filing the return and should notify the Associate office branch considering the letter ruling request that an extension has been obtained.
If the return is filed before the letter ruling is received from the Associate office, the taxpayer must disclose on the return that a letter ruling has been requested, attach a copy of the pending letter ruling request to the return, and notify the Associate office that the return has been filed. See section 7.05(2) of this revenue procedure. The Associate office will make every effort to issue the letter ruling within 3 months of the date the return was filed.
If the taxpayer requests a letter ruling after the return is filed, but before the return is examined, the taxpayer must notify the Field office having jurisdiction over the return that a letter ruling has been requested, attach a copy of the pending letter ruling request, and notify the Associate office that a return has been filed. See section 7.05(2) of this revenue procedure. The Associate office will make every effort to issue the letter ruling within 3 months of the date the return has been filed.
If the letter ruling cannot be issued within that 3-month period, the Associate office will notify the Field office having jurisdiction over the return, which may, by memorandum to the Associate office, grant an additional period for the issuance of the letter ruling.
In matters involving additional estate tax under § 2032A(c)
.07 In matters involving additional estate tax under § 2032A(c), the Associate Chief Counsel (Passthroughs and Special Industries) issues letter rulings on proposed transactions and on completed transactions that occurred before the return is filed.
In matters involving qualified domestic trusts under § 2056A
.08 In matters involving qualified domestic trusts under § 2056A, the Associate Chief Counsel (Passthroughs and Special Industries) issues letter rulings on proposed transactions and on completed transactions that occurred before the return is filed.
In generation-skipping transfer tax matters
.09 In general, the Associate Chief Counsel (Passthroughs and Special Industries) issues letter rulings on proposed transactions that affect the generation-skipping transfer tax and on completed transactions that occurred before the return is filed. In the case of a generation-skipping trust or trust equivalent, letter rulings are issued either before or after the trust or trust equivalent has been established.
In employment and excise tax matters
.10 In employment and excise tax matters, the Associate offices issue letter rulings on proposed transactions and on completed transactions, if the letter ruling request is submitted before the return is filed for the year in which the transaction is completed.
Letter ruling requests regarding employment status (employer/employee relationship) from Federal agencies and instrumentalities or their workers must be submitted to the Internal Revenue Service at the address set forth on the current Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding. If the Federal agency or instrumentality service recipient (the firm) makes the request, the firm will receive any issued letter ruling. A copy will also be sent to any identified workers. If the worker makes the request and the firm has been contacted for information, both the worker and the firm will receive any issued letter ruling. The letter ruling will apply to any individuals engaged by the firm under substantially similar circumstances. See section 12.04 of this revenue procedure for requests regarding employment status made by taxpayers other than Federal agencies and instrumentalities or their workers.
In procedural and administrative matters
11 The Associate Chief Counsel (Procedure and Administration) issues letter rulings on matters arising under the Code and related statutes and regulations that involve the time, place, manner, and procedures for reporting and paying taxes; or the filing of information returns.
In Indian tribal government matters
.12 Pursuant to Rev. Proc. 84–37, 1984–1 C.B. 513, as modified by Rev. Proc. 86–17, 1986–1 C.B. 550, and this revenue procedure, the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) issues determinations recognizing a tribal entity as an Indian tribal government within the meaning of § 7701(a)(40) or as a political subdivision of an Indian tribal government under § 7871(d) if it determines, after consultation with the Secretary of the Interior, that the entity satisfies the statutory definition of an Indian tribal government or has been delegated governmental functions of an Indian tribal government. Requests for determinations under Rev. Proc. 84–37 are letter ruling requests, and, therefore, should be submitted to the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) pursuant to this revenue procedure.
(1) Definition of Indian tribal government. The term “Indian tribal government” is defined under § 7701(a)(40) to mean the governing body of any tribe, band, community, village, or group of Indians, or (if applicable) Alaska Natives, which is determined by the Secretary of the Treasury, after consultation with the Secretary of the Interior, to exercise governmental functions. Section 7871(d) provides that, for purposes of § 7871(a), a subdivision of an Indian tribal government shall be treated as a political subdivision of a state if the Secretary of the Treasury determines, after consultation with the Secretary of the Interior, that the subdivision has been delegated the right to exercise one or more of the substantial governmental functions of the Indian tribal government.
(2) Inclusion in list of tribal governments. Rev. Proc. 2008–55, 2008–2 C.B. 768, designates the Indian tribal entities that appear on the current or future lists of federally recognized Indian tribes published annually by the Department of the Interior, Bureau of Indian Affairs, as Indian tribal governments that are treated similarly to states for certain Federal tax purposes. Rev. Proc. 84–36, 1984–1 C.B. 510, as modified by Rev. Proc. 86–17, 1986–1 C.B. 550, provides a list of political subdivisions of Indian tribal governments that are treated as political subdivisions of states for certain Federal tax purposes. Under Rev. Proc. 84–37, as modified by Rev. Proc. 86–17, tribal governments or subdivisions recognized under § 7701(a)(40) or § 7871(d) will be included in the list of recognized tribal government entities in future lists of federally recognized Indian tribes published annually by the Department of the Interior, Bureau of Indian Affairs, or revised versions of Rev. Proc. 84–36.
On constructive sales price under § 4216(b) or § 4218(c)
.13 The Associate Chief Counsel (Passthroughs and Special Industries) will issue letter rulings in all cases on the determination of a constructive sales price under § 4216(b) or § 4218(c) and in all other cases on prospective transactions if the law or regulations require a determination of the effect of a proposed transaction for Federal tax purposes. See section 6.14(5) of this revenue procedure.
In exempt organizations matters
.14 In exempt organizations matters, the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) generally issues letter rulings on proposed transactions or on completed transactions if the letter ruling request is submitted before the return is filed for the year in which the transaction is completed. The Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) will not ordinarily issue a letter ruling on a completed transaction if the letter ruling request is submitted after the return is filed for the year in which the transaction is completed. “Not ordinarily” means that unique and compelling reasons must be demonstrated to justify the issuance of a letter ruling submitted after the return is filed for the year in which the transaction is completed. The taxpayer must contact the Field office having audit jurisdiction over their return and obtain the Field’s consent to the issuance of such a letter ruling.
See Rev. Proc. 2019–5, this Bulletin, for the procedures for issuing determination letters on issues under the jurisdiction of the Director Exempt Organizations Rulings and Agreements, including determination letters on the tax-exempt status of organizations under § 501 and § 521, the foundation status of organizations described in § 501(c)(3), and the foundation status of nonexempt charitable trusts described in § 4947(a)(1).
In qualified retirement plan and IRA matters
.15 In qualified retirement plan and IRA matters, (other than those listed in Rev. Proc. 2019–4), the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) will generally issue letter rulings on proposed transactions and on completed transactions, if the letter ruling request is submitted before the return is filed for the year in which the transaction is completed, including those involving:
(1) §§ 72 (other than the computation of the exclusion ratio), 219, 381(c)(11), 402, 403(b) (except with respect to whether the form of a plan satisfies the requirements of § 403(b) as provided in Rev. Proc. 2019–4, this Bulletin), 404, 408, 408A, 412, 414(e) and (h), 511 through 514, 4971(b) and (g), 4972, 4973, 4974 (other than requests for a waiver under § 4974(d)), 4978, 4979, and 4980;
(2) Waiver of the minimum funding standard (see Rev. Proc. 2004–15, 2004–1 C.B. 490, section 3.04 of which is modified by Rev. Proc. 2019–4);
(3) Whether a plan amendment is reasonable and provides for only de minimis increases in plan liabilities in accordance with §§ 401(a)(33) and 412(c)(7)(B)(i) of the Code (see Rev. Proc. 79–62, 1979–2 C.B. 576);
(4) With respect to employee stock ownership plans and tax credit employee stock ownership plans, §§ 409, 1042, 4975(d)(3) and 4975(e)(7). Qualification issues arising under these sections (as well as under §§ 401–420 generally) are generally within the jurisdiction of Employee Plans Determinations. However, see Rev. Proc. 2019–3, section 4.02(12);
(5) Abatement of first tier excise taxes under § 4962;
(6) Relief under § 301.9100–1 that is not related to Roth IRA recharacterizations; and
(7) Grants of extensions of time other than pursuant to § 301.9100–1.
A request to revoke an election
.16 If a taxpayer is required to file a letter ruling request to obtain consent to revoke an election made on a return, an Associate office will consider the request, even if an examination of the return has begun or the issues in the return are being considered by Appeals or a Federal court. The procedures in this revenue procedure applicable to a § 301.9100 request apply to a letter ruling request to revoke the election.
Under some circumstances before the issuance of a regulation or other published guidance
.17 In general, the Service will not issue a letter ruling or determination letter on an issue that it cannot readily resolve before the promulgation of a regulation or other published guidance. See section 6.09 of this revenue procedure.
However, an Associate office may issue letter rulings under the following conditions:
(1) Answer is clear or is reasonably certain. If the letter ruling request presents an issue for which the answer seems clear by applying the statute, regulations, and applicable case law to the facts or for which the answer seems reasonably certain but not entirely free from doubt.
(2) Answer is not reasonably certain. If the letter ruling request presents an issue for which the answer does not seem reasonably certain, the Associate office may issue the letter ruling, using its best efforts to arrive at a determination, if it is in the best interest of tax administration.
SECTION 6. UNDER WHAT CIRCUMSTANCES DOES THE SERVICE NOT ISSUE LETTER RULINGS OR DETERMINATION LETTERS?
Ordinarily not if the request involves an issue under examination or consideration or in litigation
.01 The Service ordinarily does not issue a letter ruling or a determination letter if, at the time of the request, the identical issue is involved in the taxpayer’s return for an earlier period and that issue—
(1) is being examined by a Field office;
(2) is being considered by Appeals;
(3) is pending in litigation in a case involving the taxpayer or a related taxpayer;
(4) has been examined by a Field office or considered by Appeals and the statutory period of limitations on assessment or on filing a claim for refund or credit of tax has not expired; or
(5) has been examined by a Field office or considered by Appeals and a closing agreement covering the issue or liability has not been entered into by a Field office or by Appeals.
If a return dealing with an issue for a particular year is filed while a request for a letter ruling on that issue is pending, an Associate office will issue the letter ruling unless it is notified by the taxpayer or otherwise learns that an examination of that issue or the identical issue on an earlier year’s return has been started by a Field office. See section 7.05 of this revenue procedure. In income and gift tax matters, as well as in qualified retirement plan, IRA, and exempt organizations matters, even if an examination has begun, an Associate office ordinarily will issue the letter ruling if the Field office agrees by memorandum to the issuance of the letter ruling.
Ordinarily not in certain areas because of factual nature of the problem or for other reasons
.02 The Service ordinarily does not issue letter rulings or determination letters in certain areas because of the factual nature of the matter involved or for other reasons. Rev. Proc. 2019–3, this Bulletin, and Rev. Proc. 2019–7, this Bulletin, provide a list of these areas. This list is not all-inclusive because the Service may decline to issue a letter ruling or a determination letter when appropriate in the interest of sound tax administration, including due to resource constraints, or on other grounds whenever warranted by the facts or circumstances of a particular case.
Instead of issuing a letter ruling or determination letter, the Service may, when it is considered appropriate and in the interest of sound tax administration, issue an information letter calling attention to well-established principles of tax law.
If the Service determines that it is not in the interest of sound tax administration to issue a letter ruling or determination letter due to resource constraints, it will adopt a consistent approach with respect to taxpayers that request a ruling on the same issue. The Service will also consider adding the issue to the no rule list at the first opportunity. See sections 2.01 and 3.02 of Rev. Proc. 2019–3, this Bulletin.
Ordinarily not on part of an integrated transaction
.03 (1) General rule. An Associate office ordinarily will not issue a letter ruling on only part of an integrated transaction. If a part of a transaction falls under a no-rule area, a letter ruling on other parts of the transaction may be issued. Before preparing the letter ruling request, a taxpayer should call a branch having jurisdiction for the matters on which the taxpayer is seeking a letter ruling to discuss whether the Associate office will issue a letter ruling on part of the transaction.
(2) Significant issue ruling. (a) No rule areas. The Service will not rule on the qualification of any transaction under § 332, § 351, or § 1036, or (except as provided in paragraph (b) of this section 6.03(2)) on whether a transaction constitutes a reorganization within the meaning of § 368 (other than under §§ 368(a)(1)(D) and 355), regardless of whether such transaction is part of an integrated transaction (see section 3.01(55) of Rev. Proc. 2019–3, this bulletin). Instead, the Associate Chief Counsel (Corporate) will only issue a letter ruling on significant issues (within the meaning of section 3.01(55) of Rev. Proc. 2019–3, this bulletin) presented in a transaction described in § 332, § 351, § 368 (other than under §§ 368(a)(1)(D) and 355), or § 1036. For example, the Service may rule on significant issues under § 1.368–1(d) (continuity of business enterprise) and § 1.368–1(e) (continuity of interest). Letter rulings requested under this section 6.03(2)(a) are subject to the no-rule policies of Rev. Proc. 2019–3, this bulletin.
(b) Section 355 distributions and related transactions. Pursuant to section 4 of Rev. Proc. 2017–52, 2017–41 I.R.B. 283, in lieu of requesting a Transactional Ruling regarding a Covered Transaction, a taxpayer may request a Significant Issue Ruling. Letter rulings requested under this section 6.03(2)(b) are subject to the policies of Rev. Proc. 2019–3, this bulletin.
(3) Submission requirements. Before preparing a letter ruling request under section 6.03(2) of this revenue procedure involving significant issues presented in a transaction described in § 332, § 351, § 355, § 368, or § 1036, the taxpayer is encouraged to call the Office of Associate Chief Counsel (Corporate) at the telephone number provided in section 10.07(1)(a) of this revenue procedure to discuss whether the Service will entertain a letter ruling request under section 6.03(2). The Service reserves the right to rule on any other aspect of the transaction (including ruling adversely) to the extent the Service believes it is in the best interests of tax administration. Cf. section 2.01 of Rev. Proc. 2019–3, this bulletin.
The taxpayer may request rulings on one or more significant issues in a single letter ruling request. Letter ruling requests under section 6.03(2) must include the following for each significant issue:
(a) A narrative description of the transaction that puts the issue in context;
(b) A statement identifying the issue;
(c) An analysis of the relevant law, which should set forth the authorities most closely related to the issue and explain why these authorities do not resolve the issue, and an explanation concerning why the issue is significant within the meaning of section 3.01(55) of Rev. Proc. 2019–3, this bulletin; and
(d) The precise ruling(s) requested.
The taxpayer should consult other published authorities (see, for example, Appendix G of this revenue procedure, which identifies certain checklist and guideline revenue procedures including Rev. Proc. 2017–52, 2017–41 I.R.B. 283, and Rev. Proc. 2018–53, 2018–43 I.R.B. 667, to identify representations, information, and analysis that may be required.)
If the Service issues a letter ruling on a significant issue under section 6.03(2), then the letter ruling will state that no opinion is expressed as to any issue or step not specifically addressed by the letter. In addition, letter rulings issued under section 6.03(2) will contain the following (or similar) language:
This letter is issued pursuant to section 6.03(2) of Rev. Proc. 2019–1, 2019–1 I.R.B. 1, regarding one or more significant issues under § 332, § 351, § 355, § 368, or § 1036. The ruling[s] contained in this letter only address[es] one or more significant issues involved in the transaction. This Office expresses no opinion as to the overall tax consequences of the transactions described in this letter or as to any issue not specifically addressed by the ruling[s] below.
Ordinarily not on which of two entities is a common law employer
.04 The Service ordinarily does not issue a letter ruling or a determination letter on which of two entities, under common law rules applicable in determining the employer-employee relationship, is the employer, when one entity is treating the worker as an employee.
Ordinarily not to business associations or groups
.05 The Service ordinarily does not issue letter rulings or determination letters to business, trade, or industrial associations or to similar groups concerning the application of the tax laws to members of the group. Groups and associations, however, may submit suggestions of generic issues that could be appropriately addressed in revenue rulings. See Rev. Proc. 89–14, 1989–1 C.B. 814, which states the objectives of, and standards for, the publication of revenue rulings and revenue procedures in the Internal Revenue Bulletin.
The Service may issue letter rulings or determination letters to groups or associations on their own tax status or liability if the request meets the requirements of this revenue procedure.
Ordinarily not where the request does not address the tax status, liability, or reporting obligations of the requester
.06 The Service ordinarily does not issue letter rulings or determination letters regarding the tax consequences of a transaction for taxpayers who are not directly involved in the request if the requested letter ruling or determination letter would not address the tax status, liability, or reporting obligations of the requester. For example, a taxpayer may not request a letter ruling relating to the tax consequences of a transaction to a customer or client, if the tax status, liability, or reporting obligations of the taxpayer would not be addressed in the ruling, because the customer or client is not directly involved in the letter ruling request. The tax liability of each shareholder is, however, directly involved in a letter ruling on the reorganization of a corporation. Accordingly, a corporate taxpayer could request a letter ruling that solely addressed the tax consequences to its shareholders of a proposed reorganization.
Rev. Proc. 96–16, 1996–1 C.B. 630, sets forth rules for letter ruling requests involving tax-exempt state and local government obligations.
Ordinarily not to foreign governments
.07 The Service ordinarily does not issue letter rulings or determination letters to foreign governments or their political subdivisions about the U.S. tax effects of their laws. The Associate offices also do not issue letter rulings on the effect of a tax treaty on the tax laws of a treaty country for purposes of determining the tax of the treaty country. See section 13.02 of Rev. Proc. 2015–40, 2015–35 I.R.B. 236. Treaty partners can continue to address matters such as these under the provisions of the applicable tax treaty. In addition, the Associate offices may issue letter rulings to foreign governments or their political subdivisions on their own tax status or liability under U.S. law if the request meets the requirements of this revenue procedure.
Ordinarily not on Federal tax consequences of proposed legislation
.08 The Associate offices ordinarily do not issue letter rulings on a matter involving the Federal tax consequences of any proposed Federal, state, local, municipal, or foreign legislation. The Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) may issue letter rulings regarding the effect of proposed state, local, or municipal legislation upon an eligible deferred compensation plan under § 457(b) provided that the letter ruling request relating to the plan complies with the other requirements of this revenue procedure. The Associate offices also may provide general information in response to an inquiry.
Ordinarily not before issuance of a regulation or other published guidance
.09 Generally, the Service will not issue a letter ruling or a determination letter if the request presents an issue that cannot be readily resolved before a regulation or any other published guidance is issued. When the Service has closed a regulation project or any other published guidance project that might have answered the issue or decided not to open a regulation project or any other published guidance project, the Associate offices may consider all letter ruling requests unless the issue is covered by section 6 of this revenue procedure, Rev. Proc. 2019–3, this Bulletin, or Rev. Proc. 2019–7, this Bulletin.
Not on frivolous issues
.10 The Service will not issue a letter ruling or a determination letter on frivolous issues. A “frivolous issue” is one without basis in fact or law or one that asserts a position that courts have held frivolous or groundless. Examples of frivolous or groundless issues include, but are not limited to:
(1) frivolous “constitutional” claims, such as claims that the requirement to file tax returns and pay taxes constitutes an unreasonable search barred by the Fourth Amendment, violates Fifth and Fourteenth Amendment protections of due process, violates Thirteenth Amendment protections against involuntary servitude, or is unenforceable because the Sixteenth Amendment does not authorize nonapportioned direct taxes or was never ratified;
(2) claims that income taxes are voluntary, that the term “income” is not defined in the Internal Revenue Code, or that preparation and filing of Federal income tax returns violates the Paperwork Reduction Act;
(3) claims that tax may be imposed only on coins minted under a gold or silver standard or that receipt of Federal Reserve Notes does not cause an accretion to wealth;
(4) claims that a person’s income is not taxable because he or she falls within a class entitled to “reparation claims” or an extra-statutory class of individuals exempt from tax, e.g., “free-born” individuals;
(5) claims that a taxpayer can refuse to pay taxes on the basis of opposition to certain Governmental expenditures;
(6) claims that taxes apply only to Federal employees; only to residents of Puerto Rico, Guam, the U.S. Virgin Islands, the District of Columbia, or “Federal enclaves;” or that §§ 861 through 865 or any other provision of the Code imposes taxes on U.S. citizens and residents only on income derived from foreign based activities;
(7) claims that wages or personal service income are “not income,“ are ”nontaxable receipts,“ or are a “nontaxable exchange for labor;”
(8) claims that income tax withholding by an employer on wages is optional; or
(9) other claims that the courts have characterized as frivolous or groundless.
Additional examples of frivolous or groundless issues may be found in IRS publications and other guidance (including, but not limited to, Notice 2010–33, Frivolous Positions, and I.R.M. Exhibit 25.25.10–1, Frivolous Arguments).
No “comfort” letter rulings
.11 Except with respect to a Covered Transaction within the meaning of Rev. Proc. 2017–52, 2017–41 I.R.B. 283, a letter ruling will not be issued with respect to an issue that is clearly and adequately addressed by statute, regulations, decision of a court, revenue rulings, revenue procedures, notices, or other authority published in the Internal Revenue Bulletin (Comfort Ruling). However, except with respect to issues under § 332, § 351, § 368, or § 1036 and the tax consequences resulting from the application of such Code sections (see generally section 6.03(2) of this revenue procedure), the Associate office may, in its discretion, decide to issue a Comfort Ruling if the Associate office is otherwise issuing a letter ruling to the taxpayer on another issue arising in the same transaction.
Not on alternative plans or hypothetical situations
.12 The Service will not issue a letter ruling or a determination letter on alternative plans of proposed transactions or on hypothetical situations.
Not on property conversion after return filed
.13 An Associate office will not issue a letter ruling on the replacement of involuntarily converted property, whether or not the property has been replaced, if the taxpayer has already filed a Federal tax return for the first taxable year in which any of the gain was realized from the converted property. A Director may issue a determination letter in this case. See section 12.01 of this revenue procedure.
Circumstances under which determination letters are not issued by a Director
.14 A Director will not issue a determination letter if—
(1) the taxpayer has directed a similar inquiry to an Associate office;
(2) the same issue, involving the same taxpayer or a related taxpayer, is pending in a case in litigation or before Appeals;
(3) the request involves an industry-wide problem;
(4) the specific employment tax question at issue in the request has been, or is being, considered by the Central Office of the Social Security Administration or the Railroad Retirement Board for the same taxpayer or a related taxpayer; or
(5) the request is for a determination of constructive sales price under § 4216(b) or § 4218(c), which deal with special provisions applicable to the manufacturers excise tax. The Associate Chief Counsel (Passthroughs and Special Industries) will, in certain circumstances, issue letter rulings in this area. See section 5.13 of this revenue procedure.
SECTION 7. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS?
This section provides the general instructions for requesting letter rulings and determination letters. See section 9 of this revenue procedure for the specific and additional procedures for requesting a change in method of accounting.
Requests for letter rulings, closing agreements, and determination letters require the payment of the applicable user fee listed in Appendix A of this revenue procedure. Certain changes in method of accounting under the automatic change request procedures (see section 9.01(1) of this revenue procedure) and certain changes in accounting periods made under automatic change request procedures do not require payment of a user fee (see Appendix G of this revenue procedure). For additional user fee requirements, see section 15 of this revenue procedure.
Specific and additional instructions also apply to requests for letter rulings and determination letters on certain matters. Those matters are listed in Appendix G of this revenue procedure with a reference (usually to another revenue procedure) where more information can be obtained.
Documents and information required in all requests
(1) Complete statement of facts and other information. Each request for a letter ruling or a determination letter must contain a complete statement of all facts relating to the transaction. These facts include—
(a) names, addresses, telephone numbers, and taxpayer identification numbers of all interested parties (the term “all interested parties” does not mean all shareholders of a widely held corporation requesting a letter ruling relating to a reorganization or all employees where a large number may be involved);
(b) the annual accounting period, and the overall method of accounting (cash or accrual) for maintaining the accounting books and filing the Federal income tax return, of all interested parties;
(c) a description of the taxpayer’s business operations;
(d) a complete statement of the business reasons for the transaction;
(e) a detailed description of the transaction; and
(f) all other facts relating to the transaction or to the taxpayer’s requested tax treatment thereof.
Documents and foreign laws
(2) Copies of all contracts, wills, deeds, agreements, instruments, other documents pertinent to the transaction, and foreign laws.
(a) Documents. True copies of all contracts, wills, deeds, agreements, instruments, trust documents, proposed disclaimers, and other documents pertinent to the transactions must be submitted with the request. But see section 3.02 and section 4 of Rev. Proc. 2017–52, 2017–41 I.R.B. 283, for requirements relating to ruling requests under § 355, and section 3.04 of Rev. Proc. 2018–53, 2018–43 I.R.B. 667, for requirements relating to ruling requests involving assumption or satisfaction of the distributing corporation’s debt in connection with § 355 distributions.
If the request concerns a corporate distribution, reorganization, or similar transaction, the corporate balance sheet and profit and loss statement should also be submitted. If the request relates to a prospective transaction, the most recent balance sheet and profit and loss statement should be submitted. But see section 3.02 and section 4 of Rev. Proc. 2017–52 for requirements relating to ruling requests under § 355.
If any document, including any balance sheet and profit and loss statement, is in a language other than English, the taxpayer must also submit a certified English translation of the document, along with a true copy of the document. For guidelines on the acceptability of such documents, see paragraph (c) of this section 7.01(2).
Each document other than the request should be labeled and attached to the request in alphabetical sequence. Original documents such as contracts, wills, etc., should not be submitted because they become part of the Service’s file and will not be returned.
(b) Foreign laws. The taxpayer must submit with the request a copy of the relevant parts of all foreign laws, including statutes, regulations, administrative pronouncements, and any other relevant legal authority. The documents submitted must be in the official language of the country involved and must be copied from an official publication of the foreign government or another widely available and generally accepted publication. If English is not the official language of the country involved, the taxpayer must also submit a copy of an English language version of the relevant parts of all foreign laws. This translation must be: (i) from an official publication of the foreign government or another widely available, generally accepted publication; or (ii) a certified English translation submitted in accordance with paragraph (c) of this section 7.01(2).
The taxpayer must identify the title and date of publication, including updates, of any widely available and generally accepted publication that the taxpayer (or the taxpayer’s qualified translator) uses as a source for the relevant parts of the foreign law.
(c) Standards for acceptability of submissions of documents in a language other than English and certified English translations of laws in a language other than English. The taxpayer must submit with the request an accurate and complete certified English translation of the relevant parts of all contracts, wills, deeds, agreements, instruments, trust documents, proposed disclaimers, and other documents pertinent to the transaction that are in a language other than English. If the taxpayer chooses to submit certified English translations of foreign laws, those translations must be based on an official publication of the foreign government or another widely available and generally accepted publication. In either case, the translation must be that of a qualified translator and must be attested to by the translator. The attestation must contain: (i) a statement that the translation submitted is a true and accurate translation of the foreign language document or law; (ii) a statement as to the attestant’s qualifications as a translator and as to that attestant’s qualifications and knowledge regarding tax matters or foreign law if the law is not a tax law; and (iii) the attestant’s name and address.
Analysis of material facts
(3) Analysis of material facts. The request must be accompanied by an analysis of facts and their bearing on the issue or issues. If documents attached to a request contain material facts, they must be included in the taxpayer’s analysis of facts in the request rather than merely incorporated by reference.
Same issue in an earlier return under Examination, before Appeals, before a Federal Court, or being Considered by the Pension Benefit Guaranty Corporation, by the Department of Labor, or by the Department of Health and Human Services
(4) Statement regarding whether same issue is in an earlier return and additional information required for § 301.9100 requests. The request must state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, the same issue is addressed in any return of the taxpayer, a related taxpayer within the meaning of § 267, or of a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504, or any predecessor that-
(a) is currently under examination, before Appeals, or before a Federal court;
(b) was previously under examination, before Appeals, or before a Federal court;
(c) in qualified retirement plan matters, is being considered by the Pension Benefit Guaranty Corporation or the Department of Labor; or
(d) in health care matters, is being considered by the Department of Labor or the Department of Health and Human Services.
The Service will not ordinarily issue a letter ruling or determination letter if, at the time of the request, the identical issue is under examination or consideration or in litigation. See section 6.01 in this revenue procedure. A limited exception to the above rule is made for a § 301.9100 request. See section 5.03 in this revenue procedure.
If a § 301.9100 request involves a tax year that is currently under examination, before Appeals, or before a Federal court, the taxpayer must notify the Service, as outlined above. This notification must include the name and telephone number of the examining agent or appeals officer.
Same or similar issue in a request previously submitted or currently pending
(5) Statement regarding whether same or similar issue was previously ruled on or whether a request involving it was submitted or is currently pending. The request must state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives—
(a) the Service previously ruled on the same or a similar issue for the taxpayer, a related taxpayer within the meaning of § 267, or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504, or a predecessor;
(b) the taxpayer, a related taxpayer, a predecessor, or any of their representatives previously submitted a request (including an application for change in method of accounting) involving the same or a similar issue but no letter ruling or determination letter was issued;
(c) the taxpayer, a related taxpayer, or a predecessor previously submitted a request (including an application for change in method of accounting) involving the same or a similar issue that is currently pending with the Service;
(d) at the same time as this request, the taxpayer or a related taxpayer is presently submitting another request (including an application for change in method of accounting) involving the same or a similar issue; or
(e) the taxpayer or a related taxpayer had, or has scheduled, a pre-submission conference involving the same or a similar issue.
If the statement is affirmative for (a), (b), (c), (d), or (e) of this section 7.01(5), the statement must give the date the request was submitted, the date the request was withdrawn or ruled on, if applicable, and other details of the Service’s consideration of the issue.
Interpretation of a substantive provision of an income or estate tax treaty
(6) Statement regarding interpretation of a substantive provision of an income or estate tax treaty. If the request involves the interpretation of a substantive provision of an income or estate tax treaty, the request must state whether—
(a) the tax authority of the treaty jurisdiction has issued a ruling on the same or similar issue for the taxpayer, a related taxpayer within the meaning of § 267, or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504, or any predecessor;
(b) the same or similar issue for the taxpayer, a related taxpayer, or any predecessor is being examined or has been settled by the tax authority of the treaty jurisdiction or is otherwise the subject of a closing agreement in that jurisdiction; and
(c) the same or similar issue for the taxpayer, a related taxpayer, or any predecessor is being considered by the competent authority of the treaty jurisdiction.
Interpretation of a transaction involving a party in a foreign country
(7) Statement regarding involvement of a transactional party located in a foreign country. If the request involves a transaction between a taxpayer and a related party and either the taxpayer or the related party is located in a foreign country, the request must state whether the ruling potentially relates to any one of these categories—
>(a) Preferential Regime, defined as one that meets the following three requirements: (1) the regime relates to business taxation of income from geographically mobile activities (such as, financial and other service activities, including the provision of intangibles); (2) the regime offers a form of tax preference, such as, a reduction in the rate of tax or tax base compared to general principles of U.S. taxation; and (3) the regime imposes no or low effective tax rates on income from geographically mobile, financial, and other service activities;
(b) Transfer Pricing, meaning the letter ruling covers transfer pricing or the application of transfer pricing principles under section 482 and the regulations thereunder;
(c) Downward Adjustment, meaning the letter ruling provides for a downward adjustment to the taxpayer’s taxable profit that is not directly reflected in its financial accounts. Examples include excess profits rulings or informal capital rulings that provide an adjustment that reduces taxable profits;
(d) Treaty Permanent Establishment, meaning the letter ruling determines the existence or absence of a permanent establishment under an income tax treaty or provides how much profit will be attributed to a permanent establishment;
(e) Related Party Conduit, meaning the letter ruling covers the cross-border flow of funds or income through a U.S. entity that is a conduit under common law principles or Treas. Reg. § 1.881–3, whether those funds or income flow to another country directly or indirectly.
Letter from Bureau of Indian Affairs relating to certain letter ruling requests
(8) Letter from Bureau of Indian Affairs relating to a letter ruling request for recognition of Indian tribal government status or status as a political subdivision of an Indian tribal government. To facilitate prompt action on a letter ruling request for recognition of Indian tribal government status or status as a political subdivision of an Indian tribal government, the taxpayer must submit with the letter ruling request a letter from the Department of the Interior, Bureau of Indian Affairs (BIA), verifying that the tribe is recognized by BIA as an Indian tribe and that the tribal government exercises governmental functions or that the political subdivision of the Indian tribal government has been delegated substantial governmental functions. A letter ruling request that does not contain this letter from BIA cannot be resolved until the Service obtains a letter from BIA regarding the tribe’s status.
The taxpayer should send a request to verify tribal status to the following address:
Branch of General Indian Legal Activity
Division of Indian Affairs
Office of the Solicitor
1849 C Street, NW
Statement of authorities supporting taxpayer’s views
(9) Statement of supporting authorities. If the taxpayer advocates a particular conclusion, the taxpayer must include an explanation of the grounds for that conclusion and the relevant authorities to support it. Even if the taxpayer is not advocating a particular tax treatment of a proposed transaction, the taxpayer must furnish views on the tax results of the proposed transaction and a statement of relevant authorities to support those views.
>In all events, the request must include a statement of whether the law in connection with the request is uncertain and whether the issue is adequately addressed by relevant authorities.
Statement of authorities contrary to taxpayer’s views
(10) Statement of contrary authorities. To avoid a delay in the ruling process, contrary authorities should be brought to the attention of the Service at the earliest possible opportunity. If there are significant contrary authorities, it is usually helpful to discuss them in a pre-submission conference prior to submitting the ruling request. See section 10.07 of this revenue procedure regarding pre-submission conferences. The taxpayer is strongly encouraged to inform the Service about, and discuss the implications of, any authority believed to be contrary to the position advanced, such as legislation, tax treaties, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements. If the taxpayer determines that there are no contrary authorities, a statement in the request to this effect should be included. If the taxpayer does not furnish either contrary authorities or a statement that none exist, the Service in complex cases or those presenting difficult or novel issues may request submission of contrary authorities or a statement that none exist. Failure to comply with this request may result in the Service’s refusal to issue a letter ruling or determination letter.
The taxpayer’s identification of and discussion of contrary authorities will generally enable Service personnel to more quickly understand the issue and relevant authorities. Having this information should make research more efficient and lead to earlier action by the Service. If the taxpayer does not disclose and distinguish significant contrary authorities, the Service may need to request additional information, which will delay action on the request.
Statement identifying pending legislation
(11) Statement identifying pending legislation. When filing the request, the taxpayer must identify any pending legislation that may affect the proposed transaction. In addition, the taxpayer must notify the Service if any such legislation is introduced after the request is filed but before a letter ruling or determination letter is issued.
Deletion statement required by § 6110
(12) Statement identifying information to be deleted from the public inspection copy of letter ruling or determination letter. The text of letter rulings and determination letters is open to public inspection under § 6110. The Service makes deletions from the text before it is made available for inspection. To help the Service make the deletions required by § 6110(c), a request for a letter ruling or determination letter must be accompanied by a statement indicating the deletions desired, except where a letter ruling or determination letter is open to public inspection under § 6104. If the deletion statement is not submitted with the request, a Service representative will tell the taxpayer that the request will be closed if the Service does not receive the deletion statement within 21 calendar days. See section 8.05 of this revenue procedure.
Section 6110(l)(1) provides that § 6110 disclosure provisions do not apply to any matter to which § 6104 applies. Therefore, letter rulings, determination letters, technical advice memoranda, and related background file documents dealing with the following matters (covered by § 6104) are not subject to § 6110 disclosure provisions—
(i) An approved application for exemption under § 501(a) as an organization described in § 501(c) or (d), or notice of status as a political organization under § 527, together with any papers submitted in support of such application or notice;
(ii) An application for exemption under § 501(a) with respect to the qualification of a pension, profit sharing or stock bonus plan, or an individual retirement account described in § 408 or § 408A, or any application for exemption under § 501(a) by an organization forming part of such a plan or account;
(iii) Any document issued by the Internal Revenue Service in which the qualification or exempt status of a plan or account is granted, denied, or revoked or the portion of any document in which technical advice with respect thereto is given;
(iv) Any application filed and any document issued by the Internal Revenue Service with respect to the qualification or status of master and prototype retirement plans; and
(v) The portion of any document issued by the Internal Revenue Service with respect to the qualification or exempt status of a retirement plan or account of a proposed transaction by such plan or account.
(a) Format of deletion statement. A taxpayer who wants only names, addresses, and identifying numbers to be deleted should state this in the deletion statement. If the taxpayer wants more information deleted, the deletion statement must be accompanied by a copy of the request and supporting documents on which the taxpayer should bracket the material to be deleted. The deletion statement must include the statutory basis under § 6110(c) for each proposed deletion.
If the taxpayer decides to ask for additional deletions before the letter ruling or determination letter is issued, additional deletion statements may be submitted.
(b) Location of deletion statement. The deletion statement must be made in a separate document from the request for a letter ruling or determination letter and must be placed on top of the request.
(c) Signature. The deletion statement must be signed and dated by the taxpayer or the taxpayer’s authorized representative. A stamped signature or faxed signature is not permitted.
(d) Additional information. The taxpayer should follow the same procedures of this section 7.01(12) to propose deletions from any additional information submitted after the initial request. An additional deletion statement is not required with each submission of additional information if the taxpayer’s initial deletion statement requests that only names, addresses, and identifying numbers are to be deleted and the taxpayer wants only the same information deleted from the additional information.
(e) Taxpayer may protest deletions not made. After receiving from the Service the notice under § 6110(f)(1) of intention to disclose the letter ruling or determination letter (including a copy of the version proposed to be open to public inspection and notation of third-party communications under § 6110(d)), the taxpayer may protest the disclosure of certain information in the letter ruling or determination letter. The taxpayer must send a written statement to the Service office indicated on the notice of intention to disclose, within 20 calendar days of the date the notice of intention to disclose is mailed to the taxpayer. The statement must identify those deletions that the Service has not made and that the taxpayer believes should have been made. The taxpayer must also submit a copy of the version of the letter ruling or determination letter and bracket the proposed deletions that have not been made by the Service. Generally, the Service will not consider deleting any material that the taxpayer did not propose to be deleted before the letter ruling or determination letter was issued.
Within 20 calendar days after the Service receives the response to the notice under § 6110(f)(1), the Service will mail to the taxpayer its final administrative conclusion regarding the deletions to be made. The taxpayer does not have the right to a conference to resolve any disagreements concerning material to be deleted from the text of the letter ruling or determination letter. These matters may, however, be taken up at any conference that is otherwise scheduled regarding the request.
(f) Taxpayer may request delay of public inspection. After receiving the notice of intention to disclose under § 6110(f)(1), but no later than 60 calendar days after the date of the notice, the taxpayer may send a written request for delay of public inspection under either § 6110(g)(3) or (4). The request for delay must be sent to the Service office indicated on the notice of intention to disclose. A request for delay under § 6110(g)(3) must contain the date on which it is expected that the underlying transaction will be completed. The request for delay under § 6110(g)(4) must contain a statement from which the Commissioner of Internal Revenue may determine whether there are good reasons for the continued delay.
Signature on request
(13) Signature by taxpayer or authorized representative. The request for a letter ruling or determination letter must be signed and dated by the taxpayer or the taxpayer’s authorized representative. A stamped signature or faxed signature is not permitted. However, an electronically transmitted signature (e.g., faxed or digitally-signed PDF) is permitted for determinations requested under section 12.04 regarding the Form SS–8 program.
(14) Authorized representatives.
(a) To sign the request or to appear before the Service in connection with the request, the taxpayer’s authorized representative must be (for rules on who may practice before the Service, see Treasury Department Circular No. 230, 31 C.F.R. part 10):
(1) An attorney who is a member in good standing of the bar of the highest court of any state, possession, territory, commonwealth, or the District of Columbia and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as an attorney and current authorization to represent the taxpayer;
(2) A certified public accountant who is duly qualified to practice in any state, possession, territory, commonwealth, or the District of Columbia and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as a certified public accountant and current authorization to represent the taxpayer;
(3) An enrolled agent is a person who is currently enrolled as an agent to practice before the Service and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current enrollment and authorization to represent the taxpayer. The enrollment number must be included in the declaration;
(4) An enrolled actuary is an individual currently enrolled as an actuary by the Joint Board for the Enrollment of Actuaries pursuant to 29 U.S.C. § 1242 and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as an enrolled actuary and current authorization to represent the taxpayer. Practice before the Service as an enrolled actuary is limited to representation with respect to issues involving §§ 401, 403(a), 404, 405, 412, 413, 414, 419, 419A, 420, 4971, 4972, 4976, 4980, 6057, 6058, 6059, 6652(d), 6652(e), 6692, and 7805(b); former § 405; and 29 U.S.C. § 1083;
(5) An enrolled retirement plan agent is an individual currently enrolled as a retirement plan agent who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration as an enrolled retirement plan agent and current authorization to represent the taxpayer. Practice before the Service as an enrolled retirement plan agent is limited to representation with respect to issues involving the following programs: Employee Plans Determination Letter program; Employee Plans Compliance Resolution System; and Employee Plans Pre-approved program. Enrolled retirement plan agents also are generally permitted to represent taxpayers with respect to IRS forms under the 5300 and 5500 series, which are filed by retirement plans and plans sponsors, but not with respect to actuarial forms and schedules; or
(6) Any other person, including a foreign representative, who has received a “Letter of Authorization” from the Director of the Office of Professional Responsibility under section 10.7(d) of Treasury Department Circular No. 230. A person may make a written request for a “Letter of Authorization” to: Office of Professional Responsibility, SE:OPR, Internal Revenue Service, 1111 Constitution Ave., NW, Washington, DC 20224. Section 10.7(d) of Circular No. 230 authorizes the Commissioner to allow an individual who is not otherwise eligible to practice before the Service to represent another person in a particular matter.
(b) A regular full-time employee representing his or her employer; a general partner representing his or her partnership; a bona fide officer representing his or her corporation, association, or organized group; a trustee, receiver, guardian, personal representative, administrator, executor, or regular full-time employee representing a trust, receivership, guardianship, or estate; or an individual representing an immediate family member may sign the request or appear before the Service in connection with the request if the individual provides current authorization to represent the taxpayer. See section 7.01(15) of this revenue procedure.
A taxpayer may be required to file a Form 8821, Tax Information Authorization, for certain employees not authorized to represent the taxpayer to receive taxpayer information from the Service.
(c) Tax return preparers, including registered tax return preparers, that are not described in subsections (a) and (b) of this section may not sign the request, appear before the Service, or represent a taxpayer in connection with a request for a letter ruling or a determination letter. See section 10.3(f)(3) of Treasury Department Circular No. 230.
(d) A foreign representative, other than a person referred to in subsections (a) and (b) of this section, is not authorized to practice before the Service within the United States and must withdraw from representing a taxpayer in a request for a letter ruling or a determination letter. In this situation, the nonresident alien or foreign entity must submit the request for a letter ruling or a determination letter on the individual’s or the entity’s own behalf or through a person referred to in subsections (a) and (b) of this section.
Power of attorney and declaration of representative
(15) Power of attorney and declaration of representative. Form 2848, Power of Attorney and Declaration of Representative, should be used to provide the representative’s authority (Part I of Form 2848, Power of Attorney) and the representative’s qualification (Part II of Form 2848, Declaration of Representative). The name of the person signing Part I of Form 2848 should also be typed or printed on this form. A stamped or electronic signature is not permitted. An original, a copy, or fax of the power of attorney is acceptable so long as its authenticity is not reasonably disputed. For additional information regarding the power of attorney form, see section 7.02(2) of this revenue procedure.
The taxpayer’s authorized representative, whether or not enrolled, must comply with Treasury Department Circular No. 230, which provides the rules for practice before the Service. In situations where the Service believes that the taxpayer’s representative is not in compliance with Circular 230, the Service will bring the matter to the attention of the Office of Professional Responsibility.
Penalties of perjury statement
(16) Penalties of perjury statement.
(a) Format of penalties of perjury statement. A request for a letter ruling or determination letter and any change in the request submitted at a later time must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined [Insert, as appropriate: this request or this modification to the request], including accompanying documents, and, to the best of my knowledge and belief, [Insert, as appropriate: the request or the modification] contains all the relevant facts relating to the request, and such facts are true, correct, and complete.”
See section 8.05(4) of this revenue procedure for the penalties of perjury statement applicable for submissions of additional information.
(b) Signature by taxpayer. The declaration must be signed and dated by the taxpayer, not the taxpayer’s representative. A stamped signature or faxed signature is not permitted. However, an electronically transmitted signature (e.g., faxed or digitally-signed PDF) is permitted for determinations requested under section 12.04 regarding the Form SS–8 program.
The person who signs for a corporate taxpayer must be an officer of the corporate taxpayer who has personal knowledge of the facts and whose duties are not limited to obtaining a letter ruling or determination letter from the Service. If the corporate taxpayer is a member of an affiliated group filing consolidated returns, a penalties of perjury statement must also be signed and submitted by an officer of the common parent of the group.
The person signing for a trust, a state law partnership, or a limited liability company must be, respectively, a trustee, general partner, or member-manager who has personal knowledge of the facts.
Number of copies of request to be submitted
(17) Number of copies of request to be submitted. Generally, a taxpayer needs to submit the original and one copy of the request for a letter ruling or determination letter. If more than one issue is presented in the letter ruling request, the taxpayer is encouraged to submit additional copies of the request.
Further, the original and two copies of the request for a letter ruling or determination letter are required if—
(a) the taxpayer is requesting separate letter rulings or determination letters on multiple issues as explained later under section 7.02(1) of this revenue procedure;
(b) the taxpayer is requesting deletions other than names, addresses, and identifying numbers, as explained in section 7.01(12)(a) of this revenue procedure (one copy is the request for the letter ruling or determination letter and the second copy is the deleted version of such request); or
(c) the taxpayer is requesting a closing agreement (as defined in section 2.02 of this revenue procedure) on the issue presented.
Sample format for a letter ruling request
(18) Sample format for a letter ruling request. To assist a taxpayer or the taxpayer’s representative in preparing a letter ruling request, a sample format for a letter ruling request is provided in Appendix B of this revenue procedure. This format is not required to be used.
(19) Checklist for letter ruling requests. An Associate office will be able to respond more quickly to a taxpayer’s letter ruling request if the request is carefully prepared and complete. The checklist in Appendix C of this revenue procedure is designed to assist taxpayers in preparing a request by reminding them of the essential information and documents to be furnished with the request. The checklist in Appendix C must be completed to the extent required by the instructions in the checklist, signed and dated by the taxpayer or the taxpayer’s representative, and placed on top of the letter ruling request. If the checklist in Appendix C is not received, a branch representative will ask the taxpayer or the taxpayer’s representative to submit the checklist; this may delay action on the letter ruling request.
For letter ruling requests on certain matters, specific checklists supplement the checklist in Appendix C. These checklists are in Appendix D, Appendix E, or are listed in section 1 of Appendix G of this revenue procedure and must also be completed and placed on top of the letter ruling request along with the checklist in Appendix C.
Taxpayers can obtain copies of the checklists by accessing this revenue procedure in Internal Revenue Bulletin 2019–1 on the IRS website at www.irs.gov. Taxpayers can access this revenue procedure on the website by following the “News” link, the “IRS Guidance” link, and the “Internal Revenue Bulletins (after June 2003)” link to obtain Internal Revenue Bulletin 2019–1. A copy of this checklist may be used.
Additional procedural information required with request
Multiple issues
(1) To request separate letter rulings for multiple issues in a single situation. If more than one issue is presented in a request for a letter ruling, the Associate office generally will issue a single letter ruling covering all the issues. If the taxpayer requests separate letter rulings on any of the issues (because, for example, one letter ruling is needed sooner than another), the Associate office usually will comply with the request unless doing so is not feasible or not in the best interest of the Service. A taxpayer who wants separate letter rulings on multiple issues should make this clear in the request and submit the original and two copies of the request. See section 15.06(3) regarding whether a single user fee will be charged.
In issuing each letter ruling, the Associate office will state that it has issued separate letter rulings or that requests for other letter rulings are pending.
Power of attorney used to indicate recipient of a copy or copies of a letter ruling or a determination letter
(2) Power of attorney used to indicate recipient or recipients of a copy or copies of a letter ruling or a determination letter. Once the Service signs the letter ruling or determination letter, it will send the original to the taxpayer. The Service will not send the original letter ruling or determination letter to the taxpayer’s representative.
At the taxpayer’s request, the Service will send one copy of the letter ruling or determination letter to up to two authorized representatives. At the discretion of the Service, the Service may provide a copy of the letter ruling or determination letter to up to two authorized representatives, even though the taxpayer did not request that the Service send a copy of notices and communications to the taxpayer’s representatives. Taxpayers that use Form 2848, Power of Attorney and Declaration of Representative, to designate representatives, may request that copies of notices and communications be sent to the representatives listed at Line 2 by checking the corresponding box on Line 2. Taxpayers may use Line 5 of Form 2848 to advise the Service that a copy of the letter ruling or determination letter should not be sent to the taxpayer’s representative(s). If no box is checked on Line 2 and the taxpayer does not indicate otherwise on Line 5, the Service may in its discretion provide a copy of the letter ruling or determination letter to up to two authorized representatives.
“Two-part” letter ruling requests
(3) To request a particular conclusion on a proposed transaction. A taxpayer who requests a particular conclusion on a proposed transaction may make the request for a letter ruling in two parts. This type of request is referred to as a “two-part” letter ruling request. The first part must include the complete statement of facts and related documents described in section 7.01 of this revenue procedure. The second part must include a summary statement of the facts the taxpayer believes to be controlling in reaching the conclusion requested.
If the Associate office accepts the taxpayer’s statement of controlling facts, it will base its letter ruling on these facts. Ordinarily, this statement will be incorporated into the letter ruling. The Associate office reserves the right to rule on the basis of a more complete statement of the facts and to seek more information in developing the facts and restating them.
A taxpayer who chooses this two-part procedure has all the rights and responsibilities provided in this revenue procedure.
Taxpayers may not use the two-part procedure if it is inconsistent with other procedures, such as those dealing with requests for permission to change accounting methods or periods, applications for recognition of exempt status under § 501(a) or § 521, or requests for rulings on employment tax status.
After the Associate office has resolved the issues presented by a letter ruling request, the Associate office representative may request that the taxpayer submit a proposed draft of the letter ruling to expedite the issuance of the ruling. See section 8.07 of this revenue procedure.
Expedited handling
(4) To request expedited handling. The Service ordinarily processes requests for letter rulings and determination letters in order of the date received. Expedited handling means that a request is processed ahead of requests received before it. Expedited handling is granted only in rare and unusual cases, both out of fairness to other taxpayers and because the Service seeks to process all requests as expeditiously as possible and to give appropriate deference to normal business exigencies in all cases not involving expedited handling.
A taxpayer with a compelling need to have a request processed ahead of requests received before it may request expedited handling. This request must explain in detail the need for expedited handling. The request for expedited handling must be made in writing, preferably in a separate letter included with the request for the letter ruling or determination letter or provided soon after its filing. If the request for expedited handling is contained in the letter requesting the letter ruling or determination letter, the letter should state at the top of the first page “Expedited Handling Is Requested. See page ___ of this letter.”
A request for expedited handling will not be forwarded to a branch for action until the user fee has been paid
Whether a request for expedited handling will be granted is within the Service’s discretion. The Service may grant the request when a factor outside a taxpayer’s control creates a real business need to obtain a letter ruling or determination letter before a certain date to avoid serious business consequences. Examples include situations in which a court or governmental agency has imposed a specific deadline for the completion of a transaction, or where a transaction must be completed expeditiously to avoid an imminent business emergency (such as the hostile takeover of a corporate taxpayer), provided that the taxpayer can demonstrate that the deadline or business emergency, and the need for expedited handling, resulted from circumstances that could not reasonably have been anticipated or controlled by the taxpayer. To qualify for expedited handling in such situations, the taxpayer must also demonstrate that the taxpayer submitted the request as promptly as possible after becoming aware of the deadline or emergency. The extent to which the letter ruling or determination letter request complies with all of the applicable requirements of this revenue procedure, and fully and clearly presents the issues, is a factor in determining whether expedited treatment will be granted. When the Service agrees to process a request out of order, it cannot give assurance that any letter ruling or determination letter will be processed by the date requested.
The scheduling of a closing date for a transaction or a meeting of the board of directors or shareholders of a corporation, without regard for the time it may take to obtain a letter ruling or determination letter, will not be considered a sufficient reason to process a request ahead of its regular order. Also, the possible effect of fluctuation in the market price of stocks on a transaction will not be considered a sufficient reason to process a request out of order.
Because most requests for letter rulings and determination letters cannot be processed out of order, the Service urges all taxpayers to submit their requests well in advance of the contemplated transaction. In addition, to facilitate prompt action on letter ruling requests, taxpayers are encouraged to ensure that their initial submissions comply with all of the requirements of this revenue procedure (including the requirements of other applicable guidelines set forth in Appendix G of this revenue procedure), to prepare “two-part” requests described in section 7.02(3) of this revenue procedure when possible, and to promptly provide any additional information requested by the Service.
Fax to taxpayer or taxpayer’s authorized representative of any document related to letter ruling request
(5) To request the receipt of any document related to letter ruling request by fax. If the taxpayer so requests, the Associate office may fax to the taxpayer or the taxpayer’s authorized representative a copy of any document related to the letter ruling request (for example, the letter ruling itself or a request for additional information).
A request to fax to the taxpayer or the taxpayer’s authorized representative a copy of any document related to the letter ruling request must be made in writing, preferably as part of the original request for the letter ruling. The request may be submitted at a later date, but such a request will only be respected prospectively with respect to documents generated after it is received, and must be received prior to the signing of the letter ruling. The request must contain the fax number of the taxpayer or the taxpayer’s authorized representative to whom the document is to be faxed.
A document other than the letter ruling will be faxed by a branch representative. The copy of the letter ruling may be faxed by either a branch representative or the Disclosure and Litigation Support Branch of the Legal Processing Division of the Office of Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DLS). For purposes of § 301.6110–2(h), however, a letter ruling is not issued until the ruling is mailed.
Requesting a conference
(6) To request a conference. A taxpayer who wants to have a conference on the issues involved in a request for a letter ruling should indicate this in writing when filing the request or soon thereafter. See sections 10.01, 10.02, and 11.11(2) of this revenue procedure.
Additional information required in letter ruling requests involving welfare benefit funds (including voluntary employees’ beneficiary associations (VEBAs))
Requests for letter rulings on the tax consequences of a proposed transaction involving a welfare benefit fund
(1) Requests for letter rulings on the tax consequences of a proposed transaction involving a welfare benefit fund. If a letter ruling is sought on the tax consequences to both the welfare benefit fund and an employer that contributed to the fund, each taxpayer (the fund and each contributing employer) must submit a separate letter ruling request and pay the applicable user fee listed in Appendix A of this revenue procedure.
Code sections to consider
(2) Code sections to consider. In addition to any other applicable Code sections, taxpayers should consider whether there are tax consequences under the following Code sections—
(a) For taxpayers that are VEBAs. VEBAs requesting a letter ruling on a proposed transaction involving the use or transfer of VEBA assets should consider the tax consequences under §§ 501(c)(9), 505, 511, and 512, and should also include with the request a copy of the VEBA’s most recent letter addressing its status under § 501(c)(9).
(b) For taxpayers that are contributing employers. Contributing employers requesting a letter ruling on a proposed transaction involving the disposition of fund assets should consider the tax consequences under §§ 61, 111, 419, 419A, and 4976.
(i) Special considerations for § 4976 rulings.
(A) Tax Benefit Rule. A contributing employer that deducted contributions to a welfare benefit fund and requests a letter ruling as to the tax consequences under § 4976 must either (1) address why no amount should be included in income under the tax benefit rule, or (2) represent that it is including in income amounts that are subject to the tax benefit rule.
(B) Standing. In the case of a trade association (an organization described in § 501(c)(6)) that sponsors a welfare benefit fund, the association does not have standing to request a ruling under § 4976 on behalf of employers who contributed to the fund. However, a trade association generally has standing to request a ruling under § 4976 on its own behalf as an employer if the trade association contributed to the fund and the fund provided benefits to the trade association’s own employees.
(C) Additional use of welfare benefit fund assets or transfer of assets between two or more welfare benefit funds. If the proposed transaction involves either an additional use of welfare benefit fund assets (for example, providing benefits to a new group of employees or providing a new type of benefit) or a transfer of assets between or among two or more welfare benefit funds, the application should state whether the employer has an obligation, in the current or any future year, to provide the benefits. For situations in which a use or transfer of assets would involve assets or benefits subject to one or more collective bargaining agreements, the application should include a copy of each applicable collective bargaining agreement. For a transfer of assets, the application should also address whether the welfare benefit funds could be merged.
Address to which to send request for letter ruling or determination letter
Request for letter ruling
(1) Request for letter ruling. Original letter ruling requests must be sent to the appropriate Associate office. The packages should be marked RULING REQUEST SUBMISSION.
(a) If a private delivery service is not used, requests for letter rulings should be sent to the following address:
Attn: CC:PA:LPD:DRU
Ben Franklin Station
If a private delivery service is used, the address is:
Attn: CC:PA:LPD:DRU, Room 5336
1111 Constitution Ave., NW
(b) Requests for letter rulings may also be hand delivered between the hours of 8:00 a.m. and 4:00 p.m. to the courier’s desk at the loading dock of 1111 Constitution Avenue, NW, Washington, DC. A receipt will be given at the courier’s desk. The package should be addressed to:
Courier’s Desk
(c) Requests for letter rulings must not be submitted by fax.
Request for determination letter
(2) Request for determination letter.
(a) Taxpayers under the jurisdiction of LB&I should send a request for a determination letter to the following address:
Large Business and International Division
LB&I:ACDDI:PMO, IR 1135
or via email to:
*[email protected]
(b) SB/SE and W&I taxpayers should send requests for determination letters to the appropriate SB/SE office listed in Appendix F of this revenue procedure.
(c) For a determination letter under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, see Rev. Proc. 2019–4 and Rev. Proc. 2019–5, this Bulletin.
Pending letter ruling requests
Circumstances under which the taxpayer with a pending letter ruling request must notify the Associate office
(1) Circumstances under which the taxpayer with a pending letter ruling request must notify the Associate office. The taxpayer must notify the Associate office if, after the letter ruling request is filed but before a letter ruling is issued, the taxpayer knows that—
(a) a Field office has started an examination of the issue or the identical issue on an earlier year’s return;
(b) in the case of a § 301.9100 request, a Field office has started an examination of the return for the taxable year in which an election should have been made or any taxable year that would have been affected by the election had it been timely made. See § 301.9100–3(e)(4)(i) and section 5.03(3) of this revenue procedure;
(c) legislation that may affect the transaction has been introduced. See section 7.01(11) of this revenue procedure;
(d) another letter ruling request (including an application for change in method of accounting), involving the same or similar issue as that pending with the Service, has been submitted by the taxpayer or a related party within the meaning of § 267 or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504;
(e) in qualified retirement plan matters, the issue is being considered by the Pension Benefit Guaranty Corporation or the Department of Labor; or
(f) in health care matters, the issue is being considered by the Department of Labor or the Department of Health and Human Services.
Taxpayer must notify the Associate office if a return is filed and must attach the request to the return
(2) Taxpayer must notify the Associate office if a return is filed and must attach the request to the return. If the taxpayer files a return before a letter ruling is received from the Associate office concerning an issue in the return, the taxpayer must notify the Associate office that the return has been filed. The taxpayer must also attach a copy of the letter ruling request (Form 3115, if for a non-automatic change in method of accounting) to the return to alert the Field office and avoid premature field action on the issue. Taxpayers filing their returns electronically may satisfy this requirement by attaching to their return a statement providing the date of the letter ruling request and the control number of the letter ruling.
If, under the limited circumstances permitted in section 5 of this revenue procedure, the taxpayer requests a letter ruling after the return is filed, but before the return is examined, the taxpayer must notify the Associate office that the return has been filed. The taxpayer must also notify the Field office having jurisdiction over the return and attach a copy of the letter ruling request to the notification to alert the Field office and avoid premature field action on the issue.
This section 7.05 also applies to pending requests for a closing agreement on a transaction for which a letter ruling is not requested or issued.
For purposes of this section 7.05, the term “return” includes an original return, amended return, or claim for refund.
When to attach letter ruling or determination letter to return
.06 A taxpayer who, before filing a return, receives a letter ruling or determination letter about any transaction that has been consummated and that is relevant to the return being filed must attach to the return a copy of the letter ruling or determination letter. Taxpayers filing their returns electronically may satisfy this requirement by attaching a statement to their return that provides the date and control number of the letter ruling or determination letter.
How to check on status of request for letter ruling or determination letter
.07 The taxpayer or the taxpayer’s authorized representative may obtain information regarding the status of a request for a letter ruling or determination letter by calling the person whose name and telephone number are shown on the acknowledgment of receipt of the request or, in the case of a request for a letter ruling, the appropriate branch representative who contacts the taxpayer as explained in section 8.02 of this revenue procedure.
Request for letter ruling or determination letter may be withdrawn or Associate office may decline to issue letter ruling
(1) In general. A taxpayer may withdraw a request for a letter ruling or determination letter at any time before the letter ruling or determination letter is signed by the Service. Correspondence and exhibits related to a request that is withdrawn or related to a letter ruling request for which an Associate office declines to issue a letter ruling will not be returned to the taxpayer. See section 7.01(2)(a) of this revenue procedure. In appropriate cases, an Associate office may publish its conclusions in a revenue ruling or revenue procedure.
Notification of appropriate Service official
(2) Notification of appropriate Service official.
(a) Letter ruling requests. If a taxpayer withdraws a letter ruling request or if the Associate office declines to issue a letter ruling, the Associate office generally will notify, by memorandum, the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return. For taxpayers under the jurisdiction of the Division Counsel (Large Business & International), the Associate office will also send a copy of the memorandum to the Assistant Deputy Commissioner, Compliance Integration. In doing so, the Associate office may give the Service official its views on the issues in the request for consideration in any later examination of the return. This section 7.08(2)(a) generally does not apply if the taxpayer withdraws the letter ruling request and submits a written statement that the transaction has been, or is being, abandoned and if the Associate office has not already formed an adverse opinion. See section 7.08(1) of this revenue procedure.
(b) Notification of Service official may constitute Chief Counsel Advice. If the memorandum to the Service official referred to in paragraph (a) of this section 7.08(2) provides more than the fact that the request was withdrawn and that the Associate office was tentatively adverse, or more than the fact that the Associate office declines to issue a letter ruling, the memorandum may constitute Chief Counsel Advice, as defined in § 6110(i)(1), and may be subject to disclosure under § 6110.
SECTION 8. HOW DO THE ASSOCIATE OFFICES HANDLE LETTER RULING REQUESTS?
The Associate offices will issue letter rulings on the matters and under the circumstances explained in sections 3 and 5 of this revenue procedure and in the manner explained in this section and section 11 of this revenue procedure. See section 9 of this revenue procedure for procedures for change in method of accounting requests.
Docket, Records, and User Fee Branch receives, initially controls, and refers the request to the appropriate Associate office
.01 All requests for letter rulings will be received and initially controlled by the Docket, Records, and User Fee Branch of the Legal Processing Division of the Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DRU). That office will process the incoming documents and the user fee, and it will forward the file to the appropriate Associate office for assignment to a branch that has jurisdiction over the specific issue involved in the request.
Branch representative of the Associate office contacts taxpayer within 21 calendar days
.02 Within 21 calendar days after a letter ruling request has been received in the branch of the Associate office that has jurisdiction over the issue, a representative of the branch will contact the taxpayer or, if the request includes a properly executed power of attorney, the authorized representative, unless the power of attorney provides otherwise. During such contact, the branch representative will discuss the procedural issues in the letter ruling request. If the case is complex or a number of issues are involved, it may not be possible for the branch representative to discuss the substantive issues during this initial contact. When possible, for each issue within the branch’s jurisdiction, the branch representative will tell the taxpayer—
(1) whether the branch representative will recommend that the Associate office rule as the taxpayer requested, rule adversely on the matter, or not rule;
(2) whether the taxpayer should submit additional information to enable the Associate office to rule on the matter;
(3) whether the letter ruling complies with all of the provisions of this revenue procedure, and if not, which requirements have not been met; or
(4) whether, because of the nature of the transaction or the issue presented, a tentative conclusion on the issue cannot be reached.
If the letter ruling request involves matters within the jurisdiction of more than one branch or Associate office, a representative of the branch that received the original request will tell the taxpayer within the initial 21 calendar days—
(1) that the matters within the jurisdiction of another branch or Associate office have been referred to that branch or Associate office for consideration, and the date the referral was made, and
(2) that a representative of that branch or Associate office will contact the taxpayer within 21 calendar days after receiving the referral to discuss informally the procedural and, to the extent possible, the substantive issues in the request.
This section 8.02 applies to all matters except for cases within the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products) concerning insurance issues requiring actuarial computations.
Determines if transaction can be modified to obtain favorable letter ruling
.03 If less than a fully favorable letter ruling is indicated, the branch representative will tell the taxpayer whether minor changes in the transaction or adherence to certain published positions would bring about a favorable ruling. The branch representative may also tell the taxpayer the facts that must be furnished in a document to comply with Service requirements. The branch representative will not suggest precise changes that would materially alter the form of the proposed transaction or materially alter a taxpayer’s proposed accounting period.
If, at the end of this discussion, the branch representative determines that a meeting in the Associate office would be more helpful to develop or exchange information, a meeting will be offered and an early meeting date arranged. When offered, this meeting is in addition to the taxpayer’s conference of right that is described in section 10.02 of this revenue procedure.
Not bound by informal opinion expressed
.04 The Service will not be bound by the informal opinion expressed by the branch representative or any other Service representative, and such an opinion cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
May request additional information
Must be submitted within 21 calendar days
(1) Additional information must be submitted within 21 calendar days. If the request lacks essential information, which may include additional information needed to satisfy the procedural requirements of this revenue procedure as well as substantive changes to transactions or documents needed from the taxpayer, the branch representative will request such information during the initial or subsequent contacts with the taxpayer or its authorized representative. The representative will inform the taxpayer or its authorized representative that the request will be closed if the Associate office does not receive the requested information within 21 calendar days from the date of the request unless an extension of time is granted. To facilitate prompt action on letter ruling requests, taxpayers may request that the Associate office request additional information by fax. See section 7.02(5) of this revenue procedure.
Material facts furnished to the Associate office by telephone or fax, or orally at a conference, must be promptly confirmed by letter to the Associate office. This confirmation, and any additional information requested by the Associate office that is not part of the information requested during the initial contact, must be furnished within 21 calendar days from the date the Associate office makes the request.
Extension of reply period if justified and approved
(2) Extension of reply period if justified and approved. The Service will grant an extension of the 21-day period for providing additional information only if the extension is justified in writing by the taxpayer and approved by the branch reviewer. A request for an extension should be submitted before the end of the 21-day period. If unusual circumstances close to the end of the 21-day period make a written request impractical, the taxpayer should notify the Associate office within the 21-day period that there is a problem and that the written request for extension will be provided shortly. The taxpayer will be told promptly of the approval or denial of the requested extension. If the extension request is denied, there is no right of appeal.
Letter ruling request closed if the taxpayer does not submit additional information
(3) Letter ruling request closed if the taxpayer does not submit additional information. If the taxpayer does not submit the information requested during the initial or subsequent contacts within the time provided, the letter ruling request will be closed and the taxpayer will be notified in writing. If the information is received after the request is closed, the request will be reopened and treated as a new request as of the date the information is received. The taxpayer must pay another user fee before the case can be reopened.
Penalties of perjury statement for additional information
(4) Penalties of perjury statement. Additional information submitted to the Service must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request for the information, and such facts are true, correct, and complete.” This declaration must be signed in accordance with the requirements in section 7.01(16)(b) of this revenue procedure.
Faxing request and additional information
(5) Faxing request and additional information. To facilitate prompt action on letter ruling requests, taxpayers may request that the Associate office request additional information by fax. See section 7.02(5) of this revenue procedure. Taxpayers may also submit additional information by fax as soon as the information is available. The Associate office representative who requests additional information can provide a fax number to which the information can be faxed. The original of the faxed material and a signed penalties of perjury statement must be mailed or delivered to the Associate office.
Address to which to send additional information
(6) Address to which to send additional information
(a) If a private delivery service is not used, the additional information should be sent to:
Attn: [Name, office symbols, and
room number of the Associate office representative who requested
the information]
For cases involving a request for change in method of accounting or period, see section 9.08 of this revenue procedure for the address to which to send additional information.
(b) If a private delivery service is used, the additional information for all cases should be sent to:
Identifying information included in additional information
(7) Identifying information. For all cases, the additional information should include the taxpayer’s name and the case control number and the name, office symbols, and room number of the Associate office representative who requested the information. The Associate office representative can provide the latter information to the taxpayer.
Number of copies of additional information to be submitted
(8) Number of copies. A taxpayer only needs to submit one copy of the additional information unless the Associate office requests additional copies.
Near the completion of the ruling process, advises the taxpayer of conclusions and, if the Associate office will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling request
.06 Generally, after the conference of right is held but before the letter ruling is issued, the branch representative will orally notify the taxpayer or the taxpayer’s representative of the Associate office’s conclusions. See section 10 of this revenue procedure for a discussion of conferences of right. If the Associate office is going to rule adversely, the taxpayer will be offered the opportunity to withdraw the letter ruling request. If, within ten calendar days of the notification by the branch representative, the taxpayer or the taxpayer’s representative does not notify the branch representative that the taxpayer wishes to withdraw the ruling request, the adverse letter ruling will be issued unless an extension is granted. See section 15.10 of this revenue procedure for information regarding refunds of user fees.
May request that taxpayer submit draft proposed letter ruling near the completion of the ruling process
.07 To accelerate the issuance of letter rulings, in appropriate cases near the completion of the ruling process, the Associate office representative may request that the taxpayer or the taxpayer’s representative submit a proposed draft of the letter ruling. Such draft would be based on the discussions of the issues between the representative and the taxpayer or the taxpayer’s representative. The taxpayer is not required to prepare a draft letter ruling to receive a letter ruling.
The format of the submission should be discussed with the Associate office representative who requests the draft letter ruling. The representative usually can provide a sample format of a letter ruling and will discuss with the taxpayer or the taxpayer’s representative the facts, analysis, and letter ruling language to be included.
Taxpayers are encouraged to submit this draft in a printed copy that is in a computer scannable format. The printed copy will become part of the permanent files of the Associate office. The printed copy should be sent to the same address as any additional information and should contain in the transmittal the information that should be included with any additional information (for example, a penalties of perjury statement is required). See section 8.05(4) of this revenue procedure.
Issues separate letter rulings for substantially identical letter rulings, but generally issues a single letter ruling for related § 301.9100 letter rulings
Substantially identical letter rulings
(1) Substantially identical letter rulings. For letter ruling requests qualifying for the user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure for substantially identical letter rulings, a separate letter ruling will generally be issued for each requester or entity as the Associate office deems necessary.
Related § 301.9100 letter rulings
(2) Related § 301.9100 letter rulings.
(a) For a § 301.9100 letter ruling request for an extension of time to file a Form 3115 qualifying under section 15.07(4) for the user fee provided in paragraph (A)(5)(d) of Appendix A of this revenue procedure for an identical change in method of accounting, the Associate office generally will issue a single letter on behalf of all applicants on Form 3115 that are the subject of the request.
(b) For a § 301.9100–3 letter ruling request for an extension of time to file an entity classification election for multiple entities qualifying under section 15.07(2) for the user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure, the Associate office generally will issue a single letter on behalf of all entities that are the subject of the request. The taxpayer may request that separate letters be issued to each entity that is the subject of the request. See generally section 5.03 of this revenue procedure.
Sends a copy of the letter ruling to appropriate Service official
.09 The Associate office will send a copy of the letter ruling, whether favorable or adverse, to the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return.
SECTION 9. WHAT ARE THE SPECIFIC AND ADDITIONAL PROCEDURES FOR A REQUEST FOR A CHANGE IN METHOD OF ACCOUNTING FROM THE ASSOCIATE OFFICES?
This section provides the specific and additional procedures applicable to a request for a change in method of accounting under Rev. Proc. 2015–13, 2015–5 I.R.B. 419 (or any successor), as clarified and modified by Rev. Proc. 2015–33, 2015–24 I.R.B. 1067, as modified by Section 17.02 of Rev. Proc. 2016–1, 2016–1 I.R.B. 1, and as modified by Rev. Proc. 2017–59, 2017–48 I.R.B. 543, or other automatic change request procedures.
A request for a change in method of accounting under Rev. Proc. 2015–13, (or any successor), or other automatic change request procedures is a type of request for a letter ruling. See section 2.01 of this revenue procedure.
Automatic and non-automatic change in method of accounting requests
Automatic change in method of accounting under Rev. Proc. 2015–13 (or any successor), or other automatic change request procedures
(1) Automatic change in method of accounting. Certain changes in methods of accounting must be made under automatic change request procedures. A change in method of accounting provided for in an automatic change request procedure must be made using that procedure if the taxpayer requesting the change is within the scope of the procedure, the change is an automatic change for the requested year of the change, and the taxpayer is eligible to make the change. The Commissioner’s consent to an otherwise qualifying automatic change in method of accounting is granted only if the taxpayer timely complies with the applicable automatic change request procedures. But see section 9.19 of this revenue procedure concerning review by an Associate office and a Field office. In general, a taxpayer requests an automatic change by filing a current Form 3115, Application for Change in Method of Accounting.
An application filed under the automatic change procedures in Rev. Proc. 2015–13 (or any successor) or other automatic change request procedure, and this revenue procedure, is hereinafter referred to as an “automatic change request.” See section 9.22 of this revenue procedure for a list of automatic change request procedures. See section 9.23 for a list of the sections and Appendices of this revenue procedure in addition to this section 9 that apply to an automatic change request. No user fee is required for a change made under an automatic change request procedure.
Non-automatic change in method of accounting
(2) Non-automatic change in method of accounting. If a change in method of accounting may not be made under an automatic change request procedure, the taxpayer may request a non-automatic letter ruling by filing a current Form 3115, Application for Change in Accounting Method, under the non-automatic change procedures in Rev. Proc. 2015–13 (or any successor), and this revenue procedure. A Form 3115 filed under Rev. Proc. 2015–13 (or any successor) and this revenue procedure for a non-automatic change request is hereinafter referred to as a “non-automatic Form 3115.” A taxpayer filing a non-automatic Form 3115 must submit the required user fee with the completed Form 3115. See section 15 and Appendix A of this revenue procedure for information about user fees. See section 9.23 for a list of the sections and Appendices of this revenue procedure in addition to this section 9 that apply to a non-automatic Form 3115.
Ordinarily only one change in method of accounting on a Form 3115, Application for Change in Accounting Method, and a separate Form 3115 for each taxpayer and for each separate and distinct trade or business
.02 Ordinarily, a taxpayer may request only one change in method of accounting on a Form 3115, Application for Change in Accounting Method. If the taxpayer wants to request a change in method of accounting for more than one unrelated item or submethod of accounting, the taxpayer must submit a separate Form 3115 for each unrelated item or submethod, except in certain situations in which the Service specifically permits certain unrelated changes to be included on a single Form 3115. For an example of such a situation, see section 15.03 of Rev. Proc. 2018–31, 2018–22 I.R.B. 637 (or its successor).
A separate Form 3115 (and, therefore, a separate user fee pursuant to section 15 and Appendix A of this revenue procedure) must be submitted for each taxpayer and each separate trade or business of a taxpayer, including a qualified subchapter S subsidiary (QSub) or a single-member limited liability company (single-member LLC), requesting a change in method of accounting, except as specifically permitted or required in guidance published by the Service. See, for example, section 15.07(4) of this revenue procedure.
Information required with a Form 3115
Facts and other information
(1) Facts and other information requested on Form 3115 and in applicable revenue procedures. In general, a taxpayer requesting a change in method of accounting must file a current Form 3115, unless the procedures applicable to the specific type of change in method of accounting do not require a Form 3115 to be submitted.
To be eligible for approval of the requested change in method of accounting, the taxpayer must provide all information requested on the Form 3115 and in its instructions and in Rev. Proc. 2015–13 (or any successor), and, if applicable, the automatic change request procedure. In addition, the taxpayer must provide all information requested in the applicable sections of this revenue procedure, including a detailed and complete description of the item being changed and of the taxpayer’s trade(s) or business(es), the taxpayer’s present and proposed method for the item being changed, information regarding whether the taxpayer has claimed any federal tax credit relating to the cost being changed, information regarding whether the taxpayer is under examination, or before Appeals or a Federal court, and a summary of the computation of the net § 481(a) adjustment, along with an explanation of the methodology used to determine the adjustment, sufficient to demonstrate that the net § 481(a) adjustment is computed correctly.
For a non-automatic Form 3115 or an automatic change request specified in the instructions for line 16 of the Form 3115, the taxpayer must also include a full explanation of the legal basis and relevant authorities supporting the proposed method, and a detailed and complete description of the facts and explanation of how the law applies to the taxpayer’s situation.
For a non-automatic Form 3115, the taxpayer must also include a statement of the applicant’s reasons for the proposed change, copies of all documents related to the proposed change, and a discussion of whether the law related to the request is uncertain or inadequately addresses the issue.
The applicant must provide the requested information to be eligible for approval of the requested change in method of accounting. The taxpayer may be required to provide information specific to the requested change in method of accounting, such as an attached statement. The taxpayer must provide all information relevant to the requested change in method of accounting, even if not specifically requested, including an explanation of all material facts relevant to the requested change in method of accounting.
See also sections 7.01(1) and 7.01(9) of this revenue procedure.
(2) Statement of contrary authorities. For a non-automatic Form 3115, the taxpayer is encouraged to inform the Associate office about, and discuss the implications of, any authority believed to be contrary to the proposed change in method of accounting, including legislation, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements.
If the taxpayer does not furnish either contrary authorities or a statement that none exist, the Associate office may request submission of contrary authorities or a statement that none exist. Failure to comply with this request may result in the Associate office’s refusal to issue a change in method of accounting letter ruling.
(3) Copies of all contracts, agreements, and other documents. True copies of all contracts, agreements, and other documents relevant to the requested change in method of accounting must be submitted with a non-automatic Form 3115. Original documents should not be submitted because they become part of the Associate office’s file and will not be returned.
(4) Analysis of material facts. When submitting any document with a Form 3115 or in a supplemental letter, the taxpayer must explain and provide an analysis of all material facts in the document. The taxpayer may not merely incorporate the document by reference. The analysis of the facts must include their bearing on the requested change in method of accounting and must specify the provisions that apply.
Same issue in an earlier return
(5) Information regarding whether same issue is in an earlier return. A Form 3115 must state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, any return of the taxpayer (or any return of a current or former consolidated group in which the taxpayer is or was a member) in which the taxpayer used the method of accounting being changed is under examination, before Appeals, or before a Federal court. See Rev. Proc. 2015–13 (or any successor).
Issue previously submitted or currently pending
(6) Statement regarding prior requests for a change in method of accounting and other pending requests.
(a) Other requests for a change in method of accounting within the past five years. A Form 3115 must state, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, whether the taxpayer or a related taxpayer within the meaning of § 267 or a member of a current or former affiliated group of which the taxpayer is or was a member within the meaning of § 1504 or a predecessor requested or made within the past five years (including the year of the requested change), or is currently filing, any request for a change in method of accounting.
If the statement is affirmative, for each separate and distinct trade or business, give a description of each request and the year of change and whether consent was obtained. If any application was withdrawn, not perfected, or denied, or if a Consent Agreement was sent to the taxpayer but was not signed and returned to the Associate office, or if the change was not made in the requested year of change, give an explanation.
(b) Any other pending request(s). A Form 3115 must state, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, whether the taxpayer or a related taxpayer within the meaning of § 267 or a member of a current or former affiliated group of which the taxpayer is or was a member within the meaning of § 1504 or a predecessor currently have pending any request (including any concurrently filed request) for a letter ruling, a change in method of accounting, or technical advice.
If the statement is affirmative, for each request, give the name(s) of the taxpayer, identification number(s), the type of request (letter ruling, request for change in method of accounting, or request for technical advice), and the specific issues in the request.
(7) Statement identifying pending legislation. At the time the taxpayer files a non-automatic Form 3115, the taxpayer must identify any pending legislation that may affect the proposed change in method of accounting. The taxpayer also must notify the Associate office if any such legislation is introduced after the request is filed but before a change in method of accounting letter ruling is issued.
(8) Authorized representatives. To appear before the Service in connection with a request for a change in method of accounting, the taxpayer’s authorized representative must be an attorney, a certified public accountant, an enrolled agent, an enrolled actuary, a person with a “Letter of Authorization,” an employee, general partner, bona fide officer, administrator, trustee, etc., as described in section 7.01(14) of this revenue procedure.
(9) Power of attorney and declaration of representative. Any authorized representative, whether or not enrolled to practice, must comply with Treasury Department Circular No. 230, which provides the rules for practice before the Service, and the conference and practice requirements of the Statement of Procedural Rules, which provide the rules for representing a taxpayer before the Service. See section 7.01(15) of this revenue procedure. A taxpayer should use Form 2848, Power of Attorney and Declaration of Representative, to provide the representative’s authority.
(10) Tax Information Authorization. A taxpayer may use Form 8821, Tax Information Authorization, to authorize an individual to receive a copy of the taxpayer’s change in method of accounting letter ruling and other related correspondence. If the taxpayer wishes to authorize a corporation, firm, organization, or partnership to receive the correspondence, an individual, identified by either name or title, must be specified on the Form 8821. A Form 8821 does not authorize the taxpayer’s appointee to advocate the taxpayer’s position or to otherwise represent the taxpayer before the Service.
(11) Penalties of perjury statement
(a) Format of penalties of perjury statement. A Form 3115, and any change to a Form 3115 submitted at a later time, must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this application, including accompanying schedules and statements, and to the best of my knowledge and belief, the application contains all the relevant facts relating to the application, and it is true, correct, and complete.”
See section 9.08(3) of this revenue procedure for the penalties of perjury statement required for submissions of additional information.
(b) Signature by taxpayer. A Form 3115 must be signed by, or on behalf of, the taxpayer requesting the change by an individual who has personal knowledge of the facts of, and authority to bind the taxpayer in, such matters. For example, an officer must sign on behalf of a corporation, a general partner on behalf of a state law partnership, a member-manager on behalf of a limited liability company, a trustee on behalf of a trust, or an individual taxpayer on behalf of a sole proprietorship. If the taxpayer is a member of a consolidated group, a Form 3115 should be submitted on behalf of the taxpayer by the common parent and must be signed by a duly authorized officer of the common parent. Refer to the signature requirements set forth in the instructions for the current Form 3115 regarding those who are to sign. See also section 6.02(8) of Rev. Proc. 2015–13 (or any successor). A stamped signature or faxed signature is not permitted.
(c) Signature by preparer. A declaration of preparer (other than the taxpayer) is based on all information of which the preparer has any knowledge.
Additional procedural information required in certain circumstances
Recipients of original and copy of correspondence
(1) Recipients of original and copy of change in method of accounting correspondence. The Service will send the signed original of the change in method of accounting letter ruling and other related correspondence to the taxpayer, and copies to the taxpayer’s representative, if so instructed on Form 2848. See section 7.02(2) of this revenue procedure for how to designate alternative routing of the copies of the letter ruling and other correspondence.
(2) To request expedited handling. The Associate offices ordinarily process non-automatic Forms 3115 in order of the date received. A taxpayer with a compelling need to have a non-automatic Form 3115 processed on an expedited basis may request expedited handling. See section 7.02(4) of this revenue procedure for procedures regarding expedited handling.
Fax of any document to the taxpayer or taxpayer’s authorized representative
(3) To receive the change in method of accounting letter ruling or any other correspondence related to a Form 3115 by fax. If the taxpayer wants a copy of the change in method of accounting letter ruling or any other correspondence related to a Form 3115, such as a request for additional information, faxed to the taxpayer or the taxpayer’s authorized representative, the taxpayer must submit a written request to fax the letter ruling or related correspondence, preferably as part of the Form 3115. The request may be submitted at a later date, but it must be received prior to the mailing of correspondence other than the letter ruling and prior to the signing of the change in method of accounting letter ruling.
The request to have correspondence relating to the Form 3115 faxed to the taxpayer or taxpayer’s authorized representative must contain the fax number of the taxpayer or the taxpayer’s authorized representative to whom the correspondence is to be faxed.
A document other than the change in method of accounting letter ruling will be faxed by a branch representative. The change in method of accounting letter ruling may be faxed by either a branch representative or the Disclosure and Litigation Support Branch of the Legal Processing Division of the Office of Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DLS).
For purposes of § 301.6110–2(h), a change in method of accounting letter ruling is not issued until the change in method of accounting letter ruling is mailed.
(4) To request a conference. The taxpayer must complete the appropriate line on the Form 3115 to request a conference, or must request a conference in a later written communication, if an adverse response is contemplated by the Associate office. See section 11.03(1) of Rev. Proc. 2015–13 (or any successor), and sections 10.01 and 10.02 of this revenue procedure.
Addresses to which to send Forms 3115
.05 Addresses to which to send Forms 3115. Submit the original Form 3115, in the case of a non-automatic Form 3115, or the copy of the Form 3115, in the case of an automatic change request, as follows:
(1) Non-automatic Form 3115.
(a) Associate office mailing address if private delivery service is not used. If a private delivery service is not used, a taxpayer, including an exempt organization, must send the original completed Form 3115 and the required user fee to:
Benjamin Franklin Station
(b) Mailing address if private delivery service is used. If a private delivery service is used, a taxpayer, including an exempt organization, must send the original completed Form 3115 and the required user fee to:
(c) Address if hand-delivered to the IRS Courier’s desk. For taxpayers, including an exempt organization, the original completed Form 3115 and the required user fee may be hand delivered between the hours of 8:00 a.m. and 4:00 p.m. to the courier’s desk at the loading dock of 1111 Constitution Ave., NW, Washington, DC. A receipt will be given at the courier’s desk. The package should be addressed to:
(2) Automatic change request. If the automatic change request procedure requires a taxpayer to file a duplicate copy of the completed Form 3115 for an automatic change request, send the duplicate copy of the automatic change request Form 3115 to:
201 West Rivercenter Blvd.
PIN Team Mail Stop 97
Covington, KY 41011-1424
A Form 3115 must not be submitted by fax
.06 A completed Form 3115 must not be submitted by fax.
Docket, Records, and User Fee Branch receives, initially controls, and refers the Form 3115 to the appropriate Associate office
.07 A non-automatic Form 3115 is received and controlled by the Docket, Records, and User Fee Branch, Legal Processing Division of the Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DRU) if the required user fee is submitted with the Form 3115. Once controlled, the Form 3115 is forwarded to the appropriate Associate office for assignment and processing.
Reply period
(1) Reply period.
(a) Non-automatic Form 3115–21-day rule. In general, for a non-automatic Form 3115, additional information requested by the Associate office and additional information furnished to the Associate office by telephone must be furnished in writing within 21 calendar days from the date of the information request. The Associate office may impose a shorter reply period for a request for additional information made after an initial request. See section 10.06 of this revenue procedure for the 21-day rule for submitting information after any conference.
(b) Automatic change request – 30-day rule. In general, for an automatic change request, additional information requested by the Associate office, and additional information furnished to the Associate office by telephone or fax, must be furnished in writing (other than a fax) within 30 calendar days from the date of the information request. The Associate office may impose a shorter reply period for a request for additional information made after an initial request. See section 10.06 of this revenue procedure for the 21-day rule for submitting information after any conference with the Associate office.
Extension of reply period
(2) Request for extension of reply period.
(a) Non-automatic Form 3115. For a non-automatic Form 3115, an additional period, not to exceed 15 calendar days, to furnish information may be granted to a taxpayer. Any request for an extension of time must be made in writing and submitted before the end of the original 21-day period. If unusual circumstances close to the end of the 21-day period make a written request impractical, the taxpayer should notify the Associate office within the 21-day period that there is a problem and that the written request for extension will be provided shortly. An extension of the 21-day period will be granted only if approved by a branch reviewer. An extension of the 21-day period ordinarily will not be granted to furnish information requested on Form 3115. The taxpayer will be told promptly, and later in writing, of the approval or denial of the requested extension. If the extension request is denied, there is no right of appeal.
(b) Automatic change request. For an automatic change request, an additional period, not to exceed 30 calendar days, to furnish information may be granted to a taxpayer. Any request for an extension of time must be made in writing and submitted before the end of the original 30-day period. If unusual circumstances close to the end of the 30-day period make a written request impractical, the taxpayer should notify the Associate office within the 30-day period that there is a problem and that the written request for extension will be coming soon. An extension of the 30-day period will be granted only if approved by a branch reviewer. An extension of the 30-day period ordinarily will not be granted to furnish information requested on Form 3115. The taxpayer will be told promptly of the approval or denial of the requested extension. If the extension request is denied, there is no right of appeal.
(3) Penalties of perjury statement for additional information. Additional information submitted to the Associate office must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request for the information, and such facts are true, correct, and complete.” This declaration must be signed in accordance with the requirements in section 9.03(11)(b) of this revenue procedure.
(4) Identifying information included in additional information. The additional information should also include the taxpayer’s name and the case control number and the name, office symbols, and room number of the Associate office representative who requested the information. The Associate office representative can provide the latter information to the taxpayer.
Faxing information request and additional information
(5) Faxing information request and additional information. To facilitate prompt action on a change in method of accounting ruling request, taxpayers may request that the Associate office request additional information by fax. See section 9.04(3) of this revenue procedure.
Taxpayers may also submit additional information by fax as soon as the information is available. The Associate office representative who requests additional information can provide a telephone number to which the information can be faxed. A copy of the requested information and an original signed penalties of perjury statement also must be mailed or delivered to the Associate office.
Address to which to send additional information to an Associate office
(6) Address to which to send additional information to an Associate office.
(a) Address if private delivery service is not used. For a request for change in method of accounting under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting), if a private delivery service is not used, the additional information should be sent to:
room number of the Associate office
representative who requested
For any other request for change in method of accounting, if a private delivery service is not used, the additional information should be sent to:
representative who requested the information]
(b) Address if private delivery service is used. For a request for a change in method of accounting, if a private delivery service is used, the additional information should be sent to:
Failure to timely submit additional information to an Associate office
(7) If taxpayer does not timely submit additional information.
(a) Non-automatic Form 3115. In the case of a non-automatic Form 3115, if the required information is not furnished to the Associate office within the reply period, the Form 3115 will not be processed and the case will be closed. The taxpayer or authorized representative will be so notified in writing.
(b) Automatic change request. In the case of an automatic change request, if the required information is not furnished to the Associate office within the reply period, the request does not qualify for the automatic change request procedure. In such a case, the Associate office will notify the taxpayer that consent to make the change in method of accounting is not granted.
(c) Submitting the additional information at a later date. If the taxpayer wants to submit the additional information at a later date, the taxpayer must submit it with a new completed Form 3115 (and user fee, if applicable) for a year of change for which such new Form 3115 is timely filed under the applicable change in method of accounting procedure.
Circumstances in which the taxpayer must notify the Associate office
.09 For a non-automatic Form 3115, the taxpayer must promptly notify the Associate office if, after the Form 3115 is filed but before a change in method of accounting letter ruling is issued, the taxpayer knows that—
(1) a Field office has started an examination of the present or proposed accounting;
(2) a Field office has started an examination of the proposed year of change;
(3) legislation that may affect the change in method of accounting has been introduced, see section 9.03(7) of this revenue procedure; or
(4) another letter ruling request (including another Form 3115) has been submitted by the taxpayer or a related party within the meaning of § 267 or a member of an affiliated group of which the taxpayer is a member within the meaning of § 1504.
Determines if proposed method of accounting can be modified to obtain favorable letter ruling
.10 For a non-automatic Form 3115, if a less than fully favorable change in method of accounting letter ruling is indicated, the branch representative will tell the taxpayer whether minor changes in the proposed method of accounting would bring about a favorable ruling. The branch representative will not suggest precise changes that materially alter a taxpayer’s proposed method of accounting.
Near the completion of processing the Form 3115, advises the taxpayer if the Associate office will rule adversely and offers the taxpayer the opportunity to withdraw Form 3115
.11 Generally, after the conference is held (or offered, in the event no conference is held) and before issuing any change in method of accounting letter ruling that is adverse to the requested change in method of accounting, the taxpayer will be offered the opportunity to withdraw the Form 3115. See section 9.12 of this revenue procedure. If, within 10 calendar days of the notification by the branch representative, the taxpayer or the taxpayer’s representative does not notify the branch representative of a decision to withdraw the Form 3115, the adverse change in method of accounting letter ruling will be issued unless an extension is granted. See section 15.10 for information regarding refunds of user fees.
Non-automatic Form 3115 may be withdrawn or Associate office may decline to issue a change in method of accounting letter ruling
(1) In general. A taxpayer may withdraw a non-automatic Form 3115 at any time before the change in method of accounting letter ruling is signed by the Associate office. The Form 3115, correspondence, and any documents relating to the Form 3115 that is withdrawn or for which the Associate office declines to issue a letter ruling will not be returned to the taxpayer. See section 9.03(3) of this revenue procedure. In appropriate cases, the Service may publish its conclusions in a revenue ruling or revenue procedure.
(2) Notification of appropriate Service official. If a taxpayer withdraws, or the Associate office declines to grant (for any reason), a request to change a method of accounting, the Associate office will notify, in writing, the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return and the Manager of the Methods of Accounting and Timing Practice Network, and may give its views on the issues in the request to the Service official to consider in any later examination of the return.
If the written notification to the Service official provides more than the fact that the request was withdrawn and the Associate office was tentatively adverse, or that the Associate office declines to grant a change in method of accounting, the memorandum may constitute Chief Counsel Advice, as defined in § 6110(i)(1), and may be subject to disclosure under § 6110.
How to check status of a pending non-automatic Form 3115
.13 The taxpayer or the taxpayer’s authorized representative may obtain information regarding the status of a non-automatic Form 3115 by calling the person whose name and telephone number are shown on the acknowledgement of receipt of the Form 3115.
Service is not bound by informal opinion
.14 The Service will not be bound by any informal opinion expressed by the branch representative or any other Service representative, and such an opinion cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
Single letter ruling issued to a taxpayer or consolidated group for qualifying identical change in method of accounting
.15 For a non-automatic Form 3115 qualifying under section 15.07(4) for the user fee provided in paragraph (A)(5)(b) of Appendix A of this revenue procedure for identical changes in method of accounting, the Associate office generally will issue a single letter ruling on behalf of all applicants on the Form 3115 that are the subject of the request.
Letter ruling ordinarily not issued for one of two or more interrelated items or submethods
.16 If two or more items or submethods of accounting are interrelated, the Associate office ordinarily will not issue a letter ruling on a change in method of accounting involving only one of the items or submethods.
.17 Ordinarily, for a non-automatic Form 3115, the Commissioner’s permission to change a taxpayer’s method of accounting is set forth in a letter ruling (original and a Consent Agreement copy). If the taxpayer agrees to the terms and conditions contained in the change in method of accounting letter ruling, the taxpayer must sign and date the Consent Agreement copy of the letter ruling in the appropriate space. The Consent Agreement must be signed by an individual with authority to bind the taxpayer in such matters. The Consent Agreement copy must not be signed by the taxpayer’s representative. The signed copy of the letter ruling will constitute an agreement (Consent Agreement) within the meaning of Treas. Reg. § 1.481–4(b). The signed Consent Agreement copy of the letter ruling must be returned to the Associate office within 45 calendar days of the date of the letter ruling. In addition, a copy of the signed Consent Agreement generally must be attached to the taxpayer’s income tax return for the year of change. See section 11.03(2)(a) of Rev. Proc. 2015–13 (or any successor). A taxpayer filing its return electronically should attach the Consent Agreement as a PDF file named “Form3115Consent.” If the taxpayer has filed its income tax return for the year of change before the letter ruling has been received and the Consent Agreement has been signed and returned, the copy of the signed Consent Agreement should be attached to the amended return for the year of change that the taxpayer files to implement the change in method of accounting.
A taxpayer must secure the consent of the Commissioner before changing a method of accounting for Federal income tax purposes. See Treas. Reg. § 1.446–1(e)(2)(i). For a change in method of accounting requested on a non-automatic Form 3115, a taxpayer has secured the consent of the Commissioner when the taxpayer timely signs and returns the Consent Agreement copy of the letter ruling from the Associate office granting permission to make the change in method of accounting and otherwise complies with Rev. Proc. 2015–13 (or any successor).
A taxpayer that timely files a non-automatic Form 3115 and takes the requested change in method of accounting into account in its federal income tax return for the year of change (and any subsequent taxable year) prior to receiving a letter ruling granting consent for that change has made a change in method of accounting without obtaining the consent of the Commissioner as required by § 446(e) (an “unauthorized change”). As provided in section 12.02 of Rev. Proc. 2015–13 (or any successor), the Director may determine when a change is not made in compliance with all applicable provisions of Rev. Proc. 2015–13 (or any successor) and may deny the unauthorized change. However, the Commissioner’s consent, issued subsequent to the requested year of change, applies back to the year of change (and any subsequent taxable year) as of the date of the letter ruling granting consent for that change if the taxpayer timely signs and returns the Consent Agreement copy and implements the change in accordance with all applicable provisions of Rev. Proc. 2015–13 (or any successor) and section 11 of this revenue procedure. If the Commissioner does not grant consent under Rev. Proc. 2015–13 (or any successor) for the change in method of accounting taken into account by the taxpayer, the taxpayer is subject to any interest, penalties, or other adjustments resulting from improper implementation of the change. See § 446(f). A taxpayer who timely files a non-automatic Form 3115 and takes the requested change into account in the taxpayer’s Federal income tax return for the year of change (and any subsequent taxable year), prior to receiving the letter ruling granting permission for the requested change, may nevertheless rely on the letter ruling received from the Associate office after it is received, as provided in section 9.19 of this revenue procedure. If, however, the requested change is modified or is withdrawn, denied, or similarly closed without the Associate office having granted consent, taxpayers are not relieved of any interest, penalties, or other adjustments resulting from improper implementation of the change.
A copy of the change in method of accounting letter ruling is sent to appropriate Service official
.18 The Associate office will send a copy of each change in method of accounting letter ruling, whether favorable or adverse, to the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return and the Manager of the Methods of Accounting and Timing Practice Network.
Consent to change a method of accounting may be relied on subject to limitations
.19 A taxpayer may rely on a change in method of accounting letter ruling received from the Associate office, subject to certain conditions and limitations. See sections 7, 8, 10, 11, and 12 of Rev. Proc. 2015–13 (or any successor).
A qualifying taxpayer complying timely with an automatic change request procedure may rely on the consent of the Commissioner as provided in the automatic change request procedure to change the taxpayer’s method of accounting, subject to certain conditions and limitations. See generally sections 7, 8, 10, 11, and 12 of Rev. Proc. 2015–13 (or any successor). An Associate office may review a Form 3115 filed under an automatic change request procedure and will notify the taxpayer if additional information is needed or if consent is not granted to the taxpayer for the requested change. See section 11 of Rev. Proc. 2015–13 (or any successor). Further, the Field office that has jurisdiction over the taxpayer’s return may review the Form 3115. See section 12 of Rev. Proc. 2015–13 (or any successor).
Change in method of accounting letter ruling does not apply to another taxpayer
.20 A taxpayer may not rely on a change in method of accounting letter ruling issued to another taxpayer. See § 6110(k)(3).
Associate office discretion to permit requested change in method of accounting
.21 The Associate office reserves the right to decline to process any non-automatic Form 3115 in situations in which it would not be in the best interest of sound tax administration to permit the requested change or it would not clearly reflect income. In this regard, the Associate office will consider whether the change in method of accounting would clearly and directly frustrate compliance efforts of the Service in administering the income tax laws. See section 11.02 of Rev. Proc. 2015–13 (or any successor).
List of automatic change in method of accounting request procedures
.22 For procedures regarding requests for an automatic change in method of accounting, refer to the following published automatic change request procedures. The Commissioner’s consent to an otherwise qualifying automatic change in method of accounting is granted only if the taxpayer complies timely with the applicable automatic change request procedure.
The automatic change request procedures for obtaining a change in method of accounting include:
(1) Rev. Proc. 2015–13 (or any successor). Rev. Proc. 2015–13 applies to the changes in method of accounting described in Rev. Proc. 2018–31, 2018–22 I.R.B. 637, as modified by Rev. Proc. 2018–29, 2018–22 I.R.B. 634, as modified by Rev. Proc. 2018–35, 2018–28 I.R.B 204, as modified and amplified by Rev. Proc. 2018–40, 2018–34 I.R.B. 320, and as modified by Rev. Proc. 2018–44, 2018–37 I.R.B. 426 (or any successor).
(2) The following automatic change request procedures, which require a completed Form 3115, provide both the procedures under which a change may be made automatically and the procedures under which such change must be made:
Treas. Reg. § 1.166–2(d)(3) (bank conformity for bad debts);
Treas. Reg. § 1.448–1 (to an overall accrual method for the taxpayer’s first taxable year it is subject to § 448) (this change may also be subject to the procedures of Rev. Proc. 2015–13 (or any successor));
Treas. Reg. § 1.458–1 and –2 (exclusion for certain returned magazines, paperbacks, or records);
Rev. Proc. 97–43, 1997–2 C.B. 494 (§ 475 – electing out of certain exemptions from securities dealer status); and
Rev. Proc. 91–51, 1991–2 C.B. 779 (§ 1286 – certain taxpayers under examination that sell mortgages and retain rights to service the mortgages).
(3) The following automatic change request procedures, which do not require a completed Form 3115, provide the type of change in method of accounting that may be made automatically and also provide the procedures under which such change must be made:
Notice 96–30, 1996–1 C.B. 378 (§ 446 – change to comply with Statement of Financial Accounting Standards No. 116);
Rev. Proc. 92–29, 1992–1 C.B. 748 (§ 461 – change in real estate developer’s method for including costs of common improvements in the basis of property sold);
Rev. Proc. 98–58, 1998–2 C.B. 712 (certain taxpayers seeking to change to the installment method of accounting under § 453 for alternative minimum tax purposes for certain deferred payment sales contracts relating to property used or produced in the trade or business of farming);
Treas. Reg. § 1.472–2 (taxpayers changing to the last-in, first-out (LIFO) inventory method);
Section 585(c) and Treas. Reg. §§ 1.585–6 and 1.585–7 (large bank changing from the reserve method of § 585); and
Rev. Proc. 92–67, 1992–2 C.B. 429 (election under § 1278(b) to include market discount in income currently or election under § 1276(b) to use constant interest rate to determine accrued market discount).
(4) See Appendix G for the list of revenue procedures for automatic changes in accounting period.
Other sections of this revenue procedure that are applicable to Form 3115
.23 In addition to this section 9, the following sections of this revenue procedure apply to automatic change requests and non-automatic change requests:
1 (purpose of Rev. Proc. 2019–1);
2.01 (definition of “letter ruling”);
2.02 (definition of “closing agreement”);
2.05 (oral guidance);
3.01 (issues under the jurisdiction of the Associate Chief Counsel (Corporate));
3.02 (issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products));
3.03 (issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting));
3.04 (issues under the jurisdiction of the Associate Chief Counsel (International));
3.05 (issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries));
3.07 (issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes));
5.03(2) (period of limitation when filing a request for extensions of time for making an election or for other relief under § 301.9100);
6.02 (letter rulings ordinarily not issued in certain areas because of the factual nature of the problem);
6.05 (letter rulings ordinarily not issued to business associations or groups);
6.06 (letter rulings ordinarily not issued where the request does not address the tax status, liability, or reporting obligations of the requester);
6.08 (letter rulings ordinarily not issued on Federal tax consequences of proposed legislation);
6.10 (letter rulings not issued on frivolous issues);
6.12 (letter rulings not issued on alternative plans or hypothetical situation);
7.01(1) (statement of facts and other information);
7.01(10) (statement of supporting authorities);
7.01(14) (authorized representatives);
7.01(15) (power of attorney and declaration of representative);
7.02(2) (power of attorney used to indicate recipient of a copy or copies of a letter ruling or a determination letter);
7.02(4) (expedited handling);
7.05(2) (notify Associate office if a return, amended return, or claim for refund is filed while request is pending and attach request to the return);
8.01 (receipt and control of the request, and referral to the appropriate Associate office);
8.02 (contact taxpayer within 21 calendar days);
8.04 (not bound by informal opinion expressed);
10 (scheduling conferences);
15 (user fees);
16 (significant changes to Rev. Proc. 2019–1);
17 (effect of Rev. Proc. 2019–1 on other documents);
18 (effective date of this revenue procedure);
Appendix A (schedule of user fees); and
Appendix G (revenue procedures and notices regarding letter ruling requests relating to specific Code sections and subject matters).
SECTION 10. HOW ARE CONFERENCES FOR LETTER RULINGS SCHEDULED?
Schedules a conference if requested by taxpayer
.01 A taxpayer may request a conference regarding a letter ruling request. Normally, a conference is scheduled only when the Associate office considers it to be helpful in deciding the case or when an adverse decision is indicated. If conferences are being arranged for more than one request for a letter ruling involving the same taxpayer, they will be scheduled so as to cause the least inconvenience to the taxpayer. As stated in sections 7.02(6) and 9.04(4) of this revenue procedure, a taxpayer who wants to have a conference on the issue or issues involved should indicate this in writing when, or soon after, filing the request.
If a conference has been requested, the taxpayer or the taxpayer’s representative will be notified by telephone, if possible, of the time and place of the conference, which must then be held within 21 calendar days after this contact. Instructions for requesting an extension of the 21-day period and notifying the taxpayer or the taxpayer’s representative of the Associate office’s approval or denial of the request for extension are the same as those explained in section 8.05(2) (section 9.08(2)(a) for a change in method of accounting request) of this revenue procedure regarding providing additional information.
Permits taxpayer one conference of right
.02 A taxpayer is entitled, as a matter of right, to only one conference in the Associate office, except as explained under section 10.05 of this revenue procedure. This conference is normally held at the branch level and is attended by a person who has the authority to sign the letter ruling in his or her own name or for the branch chief.
When more than one branch has taken an adverse position on an issue in a letter ruling request or when the position ultimately adopted by one branch will affect that adopted by another, a representative from each branch with the authority to sign in his or her own name or for the branch chief will attend the conference. If more than one subject is to be discussed at the conference, the discussion will constitute a conference on each subject.
No taxpayer has a right to appeal the action of a branch to an Associate Chief Counsel or to any other official of the Service. But see section 10.05 of this revenue procedure for situations in which the Associate office may offer additional conferences.
In employment tax matters, if the service recipient (the firm) requests the letter ruling, the firm is entitled to a conference. If the worker requests the letter ruling, both the worker and the firm are entitled to a conference. See section 5.10 of this revenue procedure.
Disallows verbatim recording of conferences
.03 Because conference procedures are informal, no tape, stenographic, or other verbatim recording of a conference may be made by any party.
Makes tentative recommendations on substantive issues
.04 The senior Associate office representative present at the conference ensures that the taxpayer has the opportunity to present views on all the issues in question. An Associate office representative explains the Associate office’s tentative decision on the substantive issues and the reasons for that decision. If the taxpayer asks the Associate office to limit the retroactive effect of any letter ruling or limit the revocation or modification of a prior letter ruling, an Associate office representative will discuss the recommendation concerning this issue and the reasons for the recommendation. The Associate office representatives will not make a commitment regarding the conclusion that the Associate office will finally adopt.
May offer additional conferences
.05 The Associate office will offer the taxpayer an additional conference if, after the conference of right, an adverse holding is proposed, but on a new issue, or on the same issue but on different grounds from those discussed at the first conference. There is no right to another conference when a proposed holding is reversed at a higher level with a result less favorable to the taxpayer, if the grounds or arguments on which the reversal is based were discussed at the conference of right.
Requires written confirmation of information presented at conference
.06 The taxpayer should furnish to the Associate office any additional data, reasoning, precedents, etc. that were proposed by the taxpayer and discussed at the conference but not previously or adequately presented in writing. The taxpayer must furnish the additional information within 21 calendar days from the date of the conference. If the additional information is not received within that time, a letter ruling will be issued on the basis of the information on hand or, if appropriate, no ruling will be issued. See section 8.05 of this revenue procedure for instructions on submission of additional information for a letter ruling request other than a change in method of accounting request. See section 9.08 of this revenue procedure for instructions on submitting additional information for a change in method of accounting request.
May schedule a pre-submission conference
.07 Sometimes it will be advantageous to both the Associate office and the taxpayer to hold a conference before the taxpayer submits the letter ruling request to discuss substantive or procedural issues relating to a proposed transaction. These conferences are held only if the identity of the taxpayer is provided to the Associate office, only if the taxpayer actually intends to make a request, only if the request involves a matter on which a letter ruling is ordinarily issued, and only at the discretion of the Associate office and as time permits. For example, a pre-submission conference will not be held on an income tax issue if, at the time the pre-submission conference is requested, the identical issue is involved in the taxpayer’s return for an earlier period and that issue is being examined by a Field office. See section 6.01(1) of this revenue procedure. A letter ruling request submitted following a pre-submission conference will not necessarily be assigned to the branch that held the pre-submission conference. Also, when a letter ruling request is not submitted following a pre-submission conference, the Associate office may notify, by memorandum, the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return and may give its views on the issues raised during the pre-submission conference. For LB&I taxpayers, a copy of the memorandum will be sent to the Assistant Deputy Commissioner, Compliance Integration. This memorandum may constitute Chief Counsel Advice, as defined in § 6110(i), and may be subject to disclosure under § 6110.
(1) Taxpayer may request a pre-submission conference in writing or by telephone. A taxpayer or the taxpayer’s representative may request a pre-submission conference in writing or by telephone. If the taxpayer’s representative is requesting the pre-submission conference, a power of attorney is required. A taxpayer should use Form 2848, Power of Attorney and Declaration of Representative, to provide the representative’s authority. If multiple taxpayers and/or their authorized representatives will attend or participate in the pre-submission conference, cross powers of attorney (or, as appropriate, tax information authorizations) are required. If the taxpayer’s representative is requesting the pre-submission conference by telephone, the Associate office’s representative (see list of phone numbers below) will provide the fax number to send the power of attorney (or, as appropriate, tax information authorizations) prior to scheduling the pre-submission conference.
The request must identify the taxpayer and briefly explain the primary issue so it can be assigned to the appropriate branch. If submitted in writing, the request should also identify the Associate office expected to have jurisdiction over the request for a letter ruling. A written request for a pre-submission conference should be sent to the appropriate address listed in section 7.04 of this revenue procedure.
To request a pre-submission conference by telephone, call:
(a) (202) 317-7700 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Corporate);
(b) (202) 317-3900 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Financial Institutions and Products);
(c) (202) 317-7002 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Income Tax and Accounting);
(d) (202) 317-3800 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (International);
(e) (202) 317-3100 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Passthroughs and Special Industries);
(f) (202) 317-3400 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Procedure and Administration); or
(g) (202) 317-6000 (not a toll-free call) for matters under the jurisdiction of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).
(2) Pre-submission conferences held in person or by telephone. Depending on the circumstances, pre-submission conferences may be held in person at the Associate office or may be conducted by telephone.
(3) Certain information required to be submitted to the Associate office prior to the pre-submission conference. Generally, the taxpayer will be asked to provide a statement of whether the issue is an issue on which a letter ruling is ordinarily issued and a draft of the letter ruling request or other detailed written statement explaining the proposed transaction, issue, and legal analysis, before scheduling the pre-submission conference. The Associate office will allow taxpayers to submit a statement after the conference is scheduled at its discretion. If the taxpayer’s authorized representative will attend or participate in the pre-submission conference, a power of attorney is required.
(4) Discussion of substantive issues is not binding on the Service. Any discussion of substantive issues at a pre-submission conference is advisory only, is not binding on the Service in general or on the Office of Chief Counsel in particular, and cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
May schedule a conference to be held by telephone
.08 Depending on the circumstances, conferences, including conferences of right and pre-submission conferences, may be held by telephone. This may occur, for example, when a taxpayer wants a conference of right but believes that the issue involved does not warrant incurring the expense of traveling to Washington, DC, or if it is believed that scheduling an in-person conference of right will substantially delay the ruling process. If a taxpayer makes such a request, the branch reviewer will decide if it is appropriate in the particular case to hold a conference by telephone. If the request is approved, the taxpayer will be advised when to call the Associate office representatives (not a toll-free call).
SECTION 11. WHAT EFFECT WILL A LETTER RULING HAVE?
May be relied on subject to limitations
.01 A taxpayer ordinarily may rely on a letter ruling received from the Associate office subject to the conditions and limitations described in this section.
Will not apply to another taxpayer
.02 A taxpayer may not rely on a letter ruling issued to another taxpayer. See § 6110(k)(3). However, shareholders and security holders of a corporation may rely on a letter ruling issued to the corporation for the limited purpose of determining the proper treatment of directly related tax items. For example, a letter ruling issued to a corporation with respect to the reorganization of that corporation may be relied upon by the corporation’s shareholders in determining their basis in the stock of the corporation following the reorganization. See also section 11.06(3) of this revenue procedure.
Will be used by a Field office in examining the taxpayer’s return
.03 When determining a taxpayer’s liability, the Field office must ascertain whether—
(1) the conclusions stated in the letter ruling are properly reflected in the return;
(2) the representations upon which the letter ruling was based reflect an accurate statement of the controlling facts;
(3) the transaction was carried out substantially as proposed; and
(4) there has been any change in the law that applies to the period during which the transaction or continuing series of transactions were consummated.
If, when determining the liability, the Field office finds that a letter ruling should be revoked or modified, the findings and recommendations of the Field office will be forwarded through the appropriate Director to the Associate office for consideration before further action is taken by the Field office. Such a referral to the Associate office will be treated as a request for technical advice and the provisions of Rev. Proc. 2019–2, this Bulletin, relating to requests for technical advice will be followed. See section 13.02 of Rev. Proc. 2019–2, this Bulletin. Otherwise, the Field office should apply the letter ruling in determining the taxpayer’s liability. If a Field office having jurisdiction over a return or other matter proposes to reach a conclusion contrary to a letter ruling previously issued to the taxpayer, it should coordinate the matter with the Associate office.
May be revoked or modified if found to be in error or there has been a change in law
.04 Unless it was part of a closing agreement as described in section 2.02 of this revenue procedure, a letter ruling found to be in error or not in accord with the current views of the Service may be revoked or modified. If a letter ruling is revoked or modified, the revocation or modification applies to all years open under the period of limitation unless the Service uses its discretionary authority under § 7805(b) to limit the retroactive effect of the revocation or modification.
A letter ruling may be revoked or modified by—
(1) a letter giving notice of revocation or modification to the taxpayer to whom the letter ruling was issued;
(2) the enactment of legislation or ratification of a tax treaty;
(3) a decision of the United States Supreme Court;
(4) the issuance of temporary or final regulations; or
(5) the issuance of a revenue ruling, revenue procedure, notice, or other statement published in the Internal Revenue Bulletin.
Consistent with these provisions, if a letter ruling relates to a continuing action or a series of actions, it ordinarily will be applied until any one of the events described above occurs or until it is specifically withdrawn.
Publication of a notice of proposed rulemaking will not affect the application of any letter ruling issued under this revenue procedure.
Where a letter ruling is revoked or modified by a letter to the taxpayer, the letter will state whether the revocation or modification is retroactive. Where a letter ruling is revoked or modified by the issuance of final or temporary regulations or by the publication of a revenue ruling, revenue procedure, notice, or other statement in the Internal Revenue Bulletin, the document may contain a statement as to its retroactive effect on letter rulings.
A letter ruling may be revoked even if the subject of the letter ruling is a matter that the Service currently does not issue rulings on.
Letter ruling revoked or modified based on material change in facts applied retroactively
.05 An Associate office will revoke or modify a letter ruling and apply the revocation retroactively to the taxpayer for whom the letter ruling was issued or to a taxpayer whose tax liability was directly involved in the letter ruling if—
(1) there has been a misstatement or omission of controlling facts;
(2) the facts at the time of the transaction are materially different from the controlling facts on which the letter ruling was based; or
(3) the transaction involves a continuing action or series of actions and the controlling facts change during the course of the transaction.
Not otherwise generally revoked or modified retroactively
.06 Where the revocation or modification of a letter ruling is for reasons other than a change in facts as described in section 11.05 of this revenue procedure, it will generally not be applied retroactively to the taxpayer for whom the letter ruling was issued or to a taxpayer whose tax liability was directly involved in the letter ruling provided that—
(1) there has been no change in the applicable law;
(2) the letter ruling was originally issued for a proposed transaction; and
(3) the taxpayer directly involved in the letter ruling acted in good faith in relying on the letter ruling, and revoking or modifying the letter ruling retroactively would be to the taxpayer’s detriment. For example, the tax liability of each shareholder is directly involved in a letter ruling on the reorganization of a corporation. Depending on all facts and circumstances, the shareholders’ reliance on the letter ruling may be in good faith. The tax liability of a member of an industry, however, is not directly involved in a letter ruling issued to another member of the same industry. Therefore, a nonretroactive revocation or modification of a letter ruling to one member of an industry will not extend to other members of the industry who have not received letter rulings. By the same reasoning, a tax practitioner may not extend to one client the non-retroactive application of a revocation or modification of a letter ruling previously issued to another client.
If a letter ruling is revoked or modified by a letter to the taxpayer with retroactive effect, the letter to the taxpayer will, except in fraud cases, state the grounds on which the letter ruling is being revoked or modified and explain the reasons why it is being revoked or modified retroactively.
Retroactive effect of revocation or modification applied to a particular transaction
.07 A letter ruling issued on a particular transaction represents a holding of the Service on that transaction only. It will not apply to a similar transaction in the same year or any other year. Except in unusual circumstances, the application of that letter ruling to the transaction will not be affected by the later issuance of regulations (either temporary or final) if conditions (1) through (3) in section 11.06 of this revenue procedure are met.
If a letter ruling on a transaction is later found to be in error or no longer in accord with the position of the Service, it will not protect a similar transaction of the taxpayer in the same year or later year.
Retroactive effect of revocation or modification applied to a continuing action or series of actions
.08 If a letter ruling is issued covering a continuing action or series of actions and the letter ruling is later found to be in error or no longer in accord with the position of the Service, the appropriate Associate Chief Counsel ordinarily will limit the retroactive effect of the revocation or modification to a date that is not earlier than that on which the letter ruling is revoked or modified. For example, the retroactive effect of the revocation or modification of a letter ruling covering a continuing action or series of actions ordinarily would be limited in the following situations when the letter ruling is in error or no longer in accord with the position of the Service:
(1) A taxpayer received a letter ruling that certain payments are excludable from gross income for Federal income tax purposes. The taxpayer ordinarily would be protected only for the payment received after the letter ruling was issued and before the revocation or modification of the letter ruling.
(2) A taxpayer rendered a service or provided a facility that is subject to the excise tax on services or facilities and, in relying on a letter ruling received, it did not pass the tax on to the user of the service or the facility.
(3) An employer incurred liability under the Federal Insurance Contributions Act but, in relying on a letter ruling received, neither collected the employee tax nor paid the employee and employer taxes under the Federal Insurance Contributions Act. The retroactive effect would be limited for both the employer and employee tax. The limitation would be conditioned on the employer furnishing wage data, as may be required by § 31.6011(a)–1 of the Treasury Regulations.
Generally not retroactively revoked or modified if related to sale or lease subject to excise tax
.09 A letter ruling holding that the sale or lease of a particular article is subject to the manufacturer’s excise tax or the retailer’s excise tax may not retroactively revoke or modify an earlier letter ruling holding that the sale or lease of such an article was not taxable if the taxpayer to whom the letter ruling was issued, in relying on the earlier letter ruling, gave up possession or ownership of the article without passing the tax on to the customer. See § 1108(b), Revenue Act of 1926.
May be retroactively revoked or modified when transaction is entered into before the issuance of the letter ruling
.10 A taxpayer is not protected against retroactive revocation or modification of a letter ruling involving a transaction completed before the issuance of the letter ruling or involving a continuing action or series of actions occurring before the issuance of the letter ruling, because the taxpayer did not enter into the transaction relying on a letter ruling.
Taxpayer may request that retroactivity be limited
.11 Under § 7805(b), the Service may prescribe any extent to which a revocation or modification of a letter ruling will be applied without retroactive effect.
A taxpayer to whom a letter ruling has been issued may request that the appropriate Deputy Associate Chief Counsel limit the retroactive effect of any revocation or modification of the letter ruling.
For letter rulings governed by Rev. Proc. 2019–4, this Bulletin, a taxpayer to whom a letter ruling has been issued by the Commissioner, Tax Exempt and Government Entities may request limiting the retroactive effect of any revocation or modification of the letter ruling pursuant to the procedures set forth in section 29 of Rev. Proc. 2019–4, this Bulletin.
Format of request
(1) Request for relief under § 7805(b) must be made in required format. A request to limit the retroactive effect of the revocation or modification of a letter ruling must be in the general form of, and meet the general requirements for, a letter ruling request. These requirements are given in section 7 of this revenue procedure. Specifically, the request must also
(a) state that it is being made under § 7805(b);
(b) state the relief sought;
(c) explain the reasons and arguments in support of the relief requested (including a discussion of section 11.05 of this revenue procedure, the three items listed in section 11.06 of this revenue procedure, and any other factors as they relate to the taxpayer’s particular situation); and
(d) include any documents bearing on the request.
A request that the Service limit the retroactive effect of a revocation or modification of a letter ruling may be made in the form of a separate request for a letter ruling when, for example, a revenue ruling has the effect of modifying or revoking a letter ruling previously issued to the taxpayer or when the Service notifies the taxpayer of a change in position that will have the effect of revoking or modifying the letter ruling.
When notice is given by the Field office during an examination of the taxpayer’s return or by Appeals, during consideration of the taxpayer’s return before Appeals, a request to limit retroactive effect must be made in the form of a request for technical advice as explained in section 14.02 of Rev. Proc. 2019–2, this Bulletin.
When germane to a pending letter ruling request, a request to limit the retroactive effect of a revocation or modification of a letter ruling may be made as part of the request for the letter ruling, either initially or at any time before the letter ruling is issued. When a letter ruling that concerns a continuing transaction is revoked or modified by, for example, a subsequent revenue ruling, a request to limit retroactive effect must be made before the examination of the return that contains the transaction that is the subject of the letter ruling request.
Request for conference
(2) Taxpayer may request a conference on application of § 7805(b). A taxpayer who requests the application of § 7805(b) in a separate letter ruling request has the right to a conference in the Associate office as explained in sections 10.02, 10.04, and 10.05 of this revenue procedure. If the request is made initially as part of a pending letter ruling request or is made before the conference of right is held on the substantive issues, the § 7805(b) issue will be discussed at the taxpayer’s one conference of right as explained in section 10.02 of this revenue procedure. If the request for the application of § 7805(b) relief is made as part of a pending letter ruling request after a conference has been held on the substantive issue and the Associate office determines that there is justification for having delayed the request, the taxpayer is entitled to one conference of right concerning the application of § 7805(b), with the conference limited to discussion of this issue only.
SECTION 12. UNDER WHAT CIRCUMSTANCES DO DIRECTORS ISSUE DETERMINATION LETTERS?
Directors issue determination letters only if the question presented is specifically answered by a statute, tax treaty, or regulations, a conclusion stated in a revenue ruling, or an opinion or court decision that represents the position of the Service.
Under no circumstances will a Director issue a determination letter unless it is clearly shown that the request concerns a return that has been filed or is required to be filed and over which the Director has, or will have, examination jurisdiction.
A determination letter does not include assistance provided by the U.S. competent authority pursuant to the mutual agreement procedure in tax treaties as set forth in Rev. Proc. 2015–40, 2015–35 I.R.B. 236.
.01 In income and gift tax matters, Directors issue determination letters in response to taxpayers’ written requests on completed transactions that affect returns over which they have examination jurisdiction. A determination letter usually is not issued for a question concerning a return to be filed by the taxpayer if the same question is involved in a return already filed.
Normally, Directors do not issue determination letters on the tax consequences of proposed transactions. A Director may issue a determination letter on the replacement of involuntarily converted property under § 1033, even if the replacement has not yet been made, if the taxpayer has filed an income tax return for the first taxable year in which any of the gain was realized from the converted property.
.02 In estate tax matters, Directors issue determination letters in response to written requests affecting the estate tax returns over which they have examination jurisdiction. They do not issue determination letters on matters concerning the application of the estate tax to the prospective estate of a living person.
.03 In generation-skipping transfer tax matters, Directors issue determination letters in response to written requests affecting the generation-skipping transfer tax returns over which they have examination jurisdiction. They do not issue determination letters on matters concerning the application of the generation-skipping transfer tax before the distribution or termination takes place.
.04 In employment and excise tax matters, Directors issue determination letters in response to taxpayers’ written requests on completed transactions over which they have examination jurisdiction.
All determination letter requests regarding employment status (employer/employee relationship) made by taxpayers that are not Federal agencies and instrumentalities or their workers, must be submitted to the Internal Revenue Service at the address set forth on the current instructions for Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding.
If the service recipient (the firm) requests the determination regarding employment status, the firm will receive any determination letter issued. A copy will also be sent to any workers identified in the request. If the worker makes the request and the firm has been contacted for information, both the worker and the firm will receive any issued determination letter. The determination letter will apply to any individuals engaged by the firm under substantially similar circumstances. See section 5.10 of this revenue procedure for requests regarding employment status made by Federal agencies and instrumentalities or their workers.
Requests concerning income, estate, or gift tax returns
.05 A request received by a Director on a question concerning an income, estate, or gift tax return already filed generally will be considered in connection with the examination of the return. If a response is made to the request before the return is examined, it will be considered a tentative finding in any later examination of that return.
Review of determination letters
.06 Determination letters issued under sections 12.01 through 12.04 of this revenue procedure are not reviewed by the Associate offices before they are issued. If a taxpayer believes that a determination letter of this type is in error, the taxpayer may ask the Director to reconsider the matter or to request technical advice from an Associate office as explained in Rev. Proc. 2019–2, this Bulletin.
The preceding sentence does not apply to SS–8 requests under section 12.04. If a taxpayer disagrees with a determination of employment status made in response to an SS–8 request, the taxpayer may request that the SS–8 Program reconsider the determination letter if the taxpayer has additional information concerning the relationship that was not part of the original submission or the taxpayer can identify facts that were part of the original submission that the taxpayer thinks were not fully considered.
SECTION 13. WHAT EFFECT WILL A DETERMINATION LETTER HAVE?
Has same effect as a letter ruling
.01 A determination letter issued by a Director has the same effect as a letter ruling issued to a taxpayer under section 11 of this revenue procedure.
If a Field office proposes to reach a conclusion contrary to that expressed in a determination letter, that office need not refer the matter to the Associate office as is required for a letter ruling found to be in error. The Field office must, however, refer the matter to the Associate office through the appropriate Director if it desires to have the revocation or modification of the determination letter limited under § 7805(b), except if the determination letter has been issued by the Commissioner, Tax Exempt and Government Entities. See Rev. Proc. 2019–4 and Rev. Proc. 2019–5.
Taxpayer may request that retroactive effect of revocation or modification be limited
.02 Under § 7805(b), the Service may prescribe the extent to which a revocation or modification of a determination letter will be applied without retroactive effect. For determination letters that are not issued by the Commissioner, Tax Exempt Government Entities, a Director does not have authority under § 7805(b) to limit the revocation or modification of the determination letter. Therefore, if the Field office proposes to revoke or modify a determination letter, the taxpayer may request limitation of the retroactive effect of the revocation or modification by asking the Director that issued the determination letter to seek technical advice from the Associate office. See section 14.02 of Rev. Proc. 2019–2, this Bulletin.
A taxpayer to whom a determination letter has been issued by the Commissioner, Tax Exempt and Government Entities may request limiting the retroactive effect of any revocation or modification of the determination letter pursuant to the procedures set forth in section 23 of Rev. Proc. 2019–4, or section 12.04 of 2019–5, this Bulletin.
(1) Request for relief under § 7805(b) must be made in required format. A taxpayer’s request to limit the retroactive effect of the revocation or modification of the determination letter must be in the form of, and meet the general requirements for, a technical advice request. See section 14.02 of Rev. Proc. 2019–2, this Bulletin. The request must also—
(c) explain the reasons and arguments in support of the relief sought (including a discussion of section 11.05 of this revenue procedure, the three items listed in section 11.06 of this revenue procedure, and any other factors as they relate to the taxpayer’s particular situation); and
(2) Taxpayer may request a conference on application of § 7805(b). When technical advice is requested regarding the application of § 7805(b), the taxpayer has the right to a conference with the Associate office to the same extent as does any taxpayer who is the subject of a technical advice request. See section 14.04 of Rev. Proc. 2019–2, this Bulletin.
SECTION 14. UNDER WHAT CIRCUMSTANCES ARE MATTERS REFERRED BETWEEN A DIRECTOR AND AN ASSOCIATE OFFICE?
Requests for determination letters
.01 If a Director receives a request for a determination letter, but it may not issue one under the provisions of this revenue procedure, the Director will forward the request to the appropriate Associate office for reply. The Field office will notify the taxpayer that the matter has been referred.
Directors will also refer to the appropriate Associate office any request for a determination letter that in their judgment should have the attention of the Associate office. The Field office will notify the taxpayer that the matter has been referred.
No-rule areas
.02 If the request involves an issue on which the Service will not issue a letter ruling or determination letter, the request will not be forwarded to an Associate office. The Director will notify the taxpayer that the Service will not issue a letter ruling or a determination letter on the issue. See section 6 of this revenue procedure for a description of no-rule areas.
.03 If an Associate office receives a request for a letter ruling that it may not act upon under section 6 of this revenue procedure, the Associate office may, in its discretion, forward the request to the Field office that has examination jurisdiction over the taxpayer’s return. The taxpayer will be notified of this action. If the request is on an issue or in an area of the type discussed in section 6 of this revenue procedure and the Service decides not to issue a letter ruling or a determination letter, the Associate office will notify the taxpayer and will then forward the request to the appropriate Field office for association with the related return.
Letter ruling request mistakenly sent to a Director
.04 If a request for a letter ruling is mistakenly sent to a Director, the Director will return it to the taxpayer so that the taxpayer can send it to an Associate office.
SECTION 15. WHAT ARE THE USER FEE REQUIREMENTS FOR REQUESTS FOR LETTER RULINGS AND DETERMINATION LETTERS?
Legislation authorizing user fees
.01 Section 7528 was added to the Internal Revenue Code by section 202 of the Extension of the Temporary Assistance for Needy Families Block Grant Program, Pub. L. No. 108–89, amended by section 891(a) of the American Jobs Creation Act of 2004, Pub. L. 108–357, and was made permanent by section 8244 of the U.S. Troop Readiness, Veterans’ Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007, Pub. L. No. 110–28.
Section 7528 provides that the Secretary of the Treasury or delegate (the “Secretary”) shall establish a program requiring the payment of user fees for requests to the Service for letter rulings, opinion letters, determination letters, and other similar requests. The fees charged under the program are to: (1) vary according to categories or subcategories established by the Secretary; (2) be determined after taking into account the average time for, and difficulty of, complying with requests in each category or subcategory; and (3) be payable in advance. The Secretary is to provide for exemptions and reduced fees under the program as the Secretary determines to be appropriate, but the average fee applicable to each category or subcategory must not be less than the amount specified in § 7528(b)(3).
Requests to which a user fee applies
.02 In general, user fees apply to all requests for—
(1) letter rulings (including non-automatic Forms 3115, Application for Change in Accounting Method), determination letters, and advance pricing agreements;
(2) closing agreements described in paragraph (A)(3)(d) of Appendix A of this revenue procedure and pre-filing agreements described in Rev. Proc. 2016–30, 2016–21 I.R.B. 981 (or its successor);
(3) renewal of advance pricing agreements;
(4) reconsideration of letter rulings or determination letters; and
(5) supplemental letter rulings, determination letters, etc. to correct mistakes in original letter rulings, determination letters, etc.
Requests to which a user fee applies must be accompanied by the appropriate fee as determined from the fee schedule provided in Appendix A of this revenue procedure. The fee may be refunded as provided in section 15.10 of this revenue procedure.
Requests to which a user fee does not apply
.03 User fees do not apply to—
(1) elections made pursuant to § 301.9100–2, pertaining to automatic extensions of time (see section 5.03 of this revenue procedure);
(2) late initial classification elections made pursuant to Rev. Proc. 2009–41, 2009–2 C.B. 439 (see section 5.03(6) of this revenue procedure);
(3) late S corporation and related elections made pursuant to Rev. Proc. 2013–30, 2013–36 I.R.B. 173 (see section 5.02 of this revenue procedure);
(4) requests for a change in accounting period or method of accounting permitted to be made by a published automatic change request revenue procedure (see section 9.01(1) of this revenue procedure);
(5) requests for harassment campaign letter rulings under Section 6104(d)(4);
(6) request for Neighborhood Land Use Rule letter rulings under Section 514(b)(3);
(7) information letters; or
(8) late elections under § 338 that qualify under the automatic provisions in sections 3, 4, and 5 of Rev. Proc. 2003–33, 2003–1 C.B. 803.
Exemptions from the user fee requirements
.04 The user fee requirements do not apply to—
(1) departments, agencies, or instrumentalities of the United States if they certify that they are seeking a letter ruling or determination letter on behalf of a program or activity funded by Federal appropriations. The fact that a user fee is not charged does not have any bearing on whether an applicant is treated as an agency or instrumentality of the United States for purposes of any provision of the Code; or
(2) requests as to whether a worker is an employee for Federal employment taxes and income tax withholding purposes (Subtitle C of the Code) submitted on Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding, or its equivalent.
.05 The schedule of user fees is provided in Appendix A of this revenue procedure. For the user fee requirements applicable to—
(1) requests for advance pricing agreements or renewals of advance pricing agreements, see section 3.05 of Rev. Proc. 2015–41, 2015–35 I.R.B. 263; or
(2) requests for letter rulings, determination letters, etc. under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division (which no longer include changes in method of accounting), see Rev. Proc. 2019–4 and Rev. Proc. 2019–5, this Bulletin.
Applicable user fee for a request involving multiple offices, fee categories, issues, transactions, or entities
(1) Requests involving several offices. If a request dealing with only one transaction involves more than one office within the Service (for example, one issue is under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries) and another issue is under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division), only one fee applies, namely the highest fee that otherwise would apply to each of the offices involved. See Rev. Proc. 2019–4 and Rev. Proc. 2019–5, this Bulletin, for the user fees applicable to issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. However, if a request is submitted after the original PLR is issued, regardless of whether it relates to the same transaction or facts at issue in the earlier request, a new user fee applies.
(2) Requests involving several fee categories. If a request dealing with only one transaction involves more than one fee category, only one fee applies, the highest fee that otherwise would apply to each of the categories involved.
(3) Requests involving several issues. If a request dealing with only one transaction involves several issues, a request for a change in method of accounting dealing with only one item or submethod of accounting involves several issues, or a request for a change in accounting period dealing with only one item involves several issues, the request is treated as one request. Therefore, only one fee applies, i.e., the fee that applies to the particular category or subcategory involved. The addition of a new issue relating to the same transaction, item, or submethod will not result in an additional fee unless the issue places the transaction, item, or submethod in a higher fee category. So long as the issues all relate to a single transaction, a request that the Service address one or more of the issues in a separate ruling will not result in an additional fee.
(4) Requests involving several unrelated transactions. If a request involves several unrelated transactions, a request for a change in method of accounting involves several unrelated items or submethods of accounting, or a request for a change in accounting period involves several unrelated items, each transaction or item is treated as a separate request. As a result, a separate fee will apply for each unrelated transaction, item, or submethod. An additional fee will apply if the request is changed by the addition of an unrelated transaction, item, or submethod not contained in the initial request. An example of a request involving unrelated transactions is a request involving relief under § 301.9100–3 and the underlying issue.
(5) Requests involving several entities. Each entity involved in a transaction (for example, a reorganization) that desires a separate letter ruling in its own name must pay a separate fee regardless of whether the transaction or transactions may be viewed as related. But see section 15.07 of this revenue procedure.
(6) Requests made by married taxpayers who file jointly. A married couple filing a joint return may jointly request a single letter ruling and pay a single user fee if the issues arise from a joint activity or if the spouses would otherwise qualify for substantially identical letter rulings. If a spouse desires a ruling to be individually issued to him or her, a separate fee must be paid for each individual request. But see section 15.07 of this revenue procedure (providing a reduced user fee for substantially identical letter rulings or substantially identical changes in method of accounting).
Applicable user fee for requests for substantially identical letter rulings or closing agreements, or identical changes in method of accounting
(1) In general. The user fees provided in paragraph (A)(5) of Appendix A of this revenue procedure apply to the situations described in sections 15.07(2) and 15.07(4) of this revenue procedure. To assist in the processing of these user fee requests, all letter ruling requests submitted under this section 15.07 should—
(a) except for non-automatic Forms 3115, include the following typed or printed language at the top of the letter ruling request: “REQUEST FOR USER FEE UNDER SECTION 15.07 OF REV. PROC. 2019–1”;
(b) list on the first page of the submission all taxpayers and entities, and separate and distinct trades or businesses, including qualified subchapter S subsidiaries (QSubs) or single member limited liability companies (single member LLCs), requesting a letter ruling (including the taxpayer identification number and the amount of user fee submitted for each taxpayer, entity, or separate and distinct trade or business); and
(c) make one payment to cover all user fees.
If the Service determines that the letter ruling requests do not qualify for the user fee provided in paragraph (A)(5) of Appendix A of this revenue procedure, the Service will request the proper fee. See section 15.09 of this revenue procedure.
(2) Substantially identical letter rulings and closing agreements. The user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure applies to a taxpayer or taxpayers requesting substantially identical letter rulings (including accounting period, method of accounting, and earnings and profits requests other than those submitted on Form 1128, Application to Adopt, Change, or Retain a Tax Year, Form 2553, Election by a Small Business Corporation, Form 3115, Application for Change in Accounting Method, and Form 5452, Corporate Report of Nondividend Distributions) in the following situations:
(a) The taxpayers to whom the letter rulings will be issued are multiple entities with a common member or sponsor, or multiple members of a common entity; or
(b) The taxpayers to whom the letter rulings will be issued are parties engaged together in the same transaction affecting all requesting taxpayers.
To qualify for this reduced user fee, all information and underlying documents must be substantially identical and all letter ruling requests must be submitted at the same time in a single submission. In addition, the taxpayer(s) must state that the letter ruling requests and all information and underlying documents are substantially identical, and must specifically identify the extent to which the letter ruling requests, information, and underlying documents are not identical.
If a taxpayer or taxpayers requesting reduced user fees pursuant to this section 15.07(2) also request a pre-submission conference pursuant to section 10.07, the taxpayer(s) should notify the Associate office at or before the pre-submission conference that the taxpayer(s) intend to request reduced user fees pursuant to this paragraph. At the pre-submission conference, the taxpayer(s) should discuss with the Associate office how the letter ruling requests will satisfy the requirements of this paragraph.
The reduced fee for substantially identical letter rulings is applicable to taxpayers requesting closing agreements as described in section 2.02 of this revenue procedure, assuming they meet the requirements described above for letter rulings.
(3) Substantially identical plans under § 25(c)(2)(B). The user fee provided in paragraph (A)(5)(c) of Appendix A of this revenue procedure shall apply to a taxpayer who submits substantially identical plans for administering the 95-percent requirement of § 143(d)(1) following the submission and approval of an initial plan for administering the requirement. The request for subsequent approvals of substantially identical plans must (1) state that a prior plan was submitted and approved and include a copy of the prior plan and approval; (2) state that the subsequent plan is substantially identical to the approved plan; and (3) describe any differences between the approved plan and the subsequent plan.
(4) Identical changes in method of accounting and related § 301.9100 letter rulings. A common parent of a consolidated group, or other taxpayer, is eligible for the user fees provided in paragraphs (A)(5)(b) and (d) of Appendix A of this revenue procedure when requesting an identical change in method of accounting on a single Form 3115, Application for Change in Accounting Method, or an extension of time to file Form 3115 under § 301.9100–3 for the identical change in method of accounting, for two or more of the following in any combination—
(a) members of that consolidated group;
(b) separate and distinct trades or businesses (for purposes of § 1.446–1(d)) of that taxpayer or member(s) of that consolidated group. Separate and distinct trades or businesses, include QSubs and single member LLCs;
(c) partnerships that are wholly-owned within that consolidated group; or
(d) controlled foreign corporations (CFCs) and noncontrolled § 902 corporations (10/50 corporations) that do not engage in a trade or business within the United States where (i) all controlling U.S. shareholders of the CFCs and all majority domestic corporate shareholders of the 10/50 corporations, as applicable, are members of that consolidated group; or (ii) the taxpayer is the sole controlling U.S. shareholder of the CFCs or the sole domestic corporate shareholder of that 10/50 corporation.
To qualify as an identical change in method of accounting, the multiple entities wholly owned or controlled by a consolidated group or other taxpayer, or separate and distinct trades or businesses (that is, the applicants) must request to change from an identical present method of accounting to an identical proposed method of accounting. All aspects of the requested change in method of accounting must be identical, including the year of change, the present and proposed methods, the underlying facts and the authority for the request, except for the § 481(a) adjustments. If the Associate office determines that the requested changes in method of accounting are not identical, additional user fees will be required before any letter ruling is issued.
The taxpayer or common parent must, for each applicant for which the change in method of accounting is being requested, attach to the Form 3115 a schedule providing the name, employer identification number (where applicable), and § 481(a) adjustment. If the request is on behalf of eligible CFCs or 10/50 corporations, the taxpayer or common parent must attach a statement that “[a]ll controlling U.S. shareholders (as defined in § 1.964–1(c)(5)(i)) of all the CFCs to which the request relates are members of the common parent’s consolidated group,” “[a]ll majority domestic corporate shareholders (as defined in § 1.964–1(c)(5)(ii)) of all the 10/50 corporations to which the request relates are members of the common parent’s consolidated group,” that “[t]he taxpayer filing the request is the sole controlling U.S. shareholder (as defined in § 1.964–1(c)(5)) of the CFCs to which the request relates,” or “[t]he taxpayer filing the request is the sole domestic corporate shareholder (as defined in § 1.964–1(c)(5)) of the 10/50 corporations to which the request relates,” as applicable. If the request is on behalf of eligible partnerships, the common parent must attach a statement that “[a]ll partnerships to which the request relates are wholly-owned by members of the common parent’s consolidated group.”
In the case of a § 301.9100 request for an extension of time to file a Form 3115 requesting an identical change in method of accounting for multiple members of a consolidated group and/or multiple separate and distinct trades or businesses of a taxpayer or member(s) of the consolidated group, or multiple eligible CFCs or 10/50 corporations (applicants), the taxpayer or common parent must submit the information required in the preceding paragraph in addition to the information required by section 5.03 of this revenue procedure.
.08 Each request to the Service that is subject to a user fee under this revenue procedure must be accompanied by full payment. The exclusive means for paying the user fees in this revenue procedure is through www.pay.gov.
Effect of nonpayment or payment of incorrect amount
.09 If a request is not matched with full payment through www.pay.gov, the office within the Service that is responsible for issuing the letter ruling, determination letter, information letter, advance pricing agreement, closing agreement, or reconsideration of a letter ruling or determination letter generally will exercise discretion in deciding whether to immediately return the request. If a request is not immediately returned, the taxpayer will be contacted and given a reasonable amount of time to submit the proper fee. If the proper fee is not received within a reasonable amount of time, the entire request will then be returned. The Service will usually defer substantive consideration of a request until proper payment has been received. The return of a request to the taxpayer may adversely affect substantive rights if the request is not perfected and resubmitted to the Service within 30 calendar days of the date of the cover letter returning the request.
If a payment is made for more than the correct amount, the request will be accepted and the amount of the excess payment will be returned to the taxpayer.
If a ruling is issued and because of the ruling the taxpayer’s gross income is reduced such that the taxpayer would have qualified for a reduced user fee in Appendix A, paragraph (A)(4), the amount of user fee paid in excess of the reduced fee is an excess payment and will be returned to the taxpayer.
Refunds of user fee
.10 In general, user fees will not be refunded. User fees, however, will be refunded in the following situations.
(1) A user fee paid with a request to correct a mistake or omission in a prior issued letter ruling, determination letter, etc., will be refunded if the Service determines that the Service was responsible for the mistake or omission.
(2) A user fee paid with a request for relief under § 7805(b) in connection with the revocation in whole or in part, of a previously issued letter ruling, determination letter, etc., will be refunded if the relief is granted. (The user fee paid for the letter ruling, determination letter, etc. that was revoked is never refunded.)
(3) A user fee paid with a request for reconsideration of the Service’s decision not to rule on an issue will be refunded if the Service agrees to rule on the issue and the user fee paid with the initial request was not refunded.
(4) If the requested ruling, determination letter, etc., is not issued for any reason, and the Service determines that a refund is appropriate after taking into account all the facts and circumstances, including the amount of the Service’s time and resources spent on the request, the user fee will be refunded.
Request for reconsideration of user fee
.11 A taxpayer who believes the user fee charged by the Service for its request for a letter ruling, determination letter, advance pricing agreement, or closing agreement is either inapplicable or incorrect and wishes to receive a refund of all or part of the amount paid (see section 15.10 of this revenue procedure) may request reconsideration and, if desired, the opportunity for an oral discussion by sending a letter to the Service at the appropriate address given in section 7.04 in this revenue procedure. Both the incoming envelope and the letter requesting such reconsideration should be prominently marked “USER FEE RECONSIDERATION REQUEST.” No user fee is required for these requests. The request should be marked for the attention of:
If the matter involves primarily:
Mark for the attention of:
Associate Chief Counsel (Corporate) letter ruling requests
Associate Chief Counsel (Corporate)
Associate Chief Counsel (Financial Institutions and Products) letter ruling requests
Associate Chief Counsel (Financial Institutions and Products)
Associate Chief Counsel (Income Tax and Accounting) letter ruling requests
Associate Chief Counsel (Income Tax and Accounting)
Associate Chief Counsel (International) letter ruling requests
Associate Chief Counsel (International)
Associate Chief Counsel (Passthroughs and Special Industries) letter ruling requests
Associate Chief Counsel (Passthroughs and Special Industries)
Associate Chief Counsel (Procedure and Administration) letter ruling requests
Associate Chief Counsel (Procedure and Administration)
Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) letter ruling requests
Deputy Associate Chief Counsel ( )
(Complete parenthetical by using the applicable designation “Employee Benefits” or “Exempt Organizations/Employment Tax/Government Entities”)
Determination letter requests submitted pursuant to this revenue procedure by taxpayers under the jurisdiction of LB&I
Assistant Deputy Commissioner, Compliance Integration
Determination letter requests submitted pursuant to this revenue procedure by taxpayers under the jurisdiction of SB/SE, W&I
The appropriate SB/SE official listed in Appendix F
Determination letter requests submitted pursuant to this revenue procedure by taxpayers under the jurisdiction of TE/GE
Director, Employee Plans Examinations
Director, Exempt Organizations Examinations
Director, Indian Tribal Governments and Tax Exempt Bonds
(Add name of Field office handling the request)
SECTION 16. WHAT SIGNIFICANT CHANGES HAVE BEEN MADE TO REV. PROC. 2018–1?
Editorial changes have been made throughout.
Sections 1, 1.01, 3.07, 5.12, 5.14, 5.15, 6.08, 9.23, 10.07, 15.11, Appendix A, Appendix B, Appendix C, Appendix D, and Appendix E have been amended to reflect the name change from “Associate Chief Counsel (Tax Exempt and Government Entities)” to “Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes)”.
Section 5.15(3) has been removed to reflect the transfer of authority to waive excise tax under section 4980F to the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Rulings and Agreements.
Section 8.02 has been amended to remove the exception for changes in accounting methods or accounting periods from the 21 day notification rule.
Appendix A (Schedule of User Fees) has been amended with increased user fees to match the increase in costs incurred by the Service.
Appendix E (Church Plan Checklist) has been amended to add a new item 11 to reflect the requirement that an applicant include a representation as to whether an election under § 1.410(d) –1 of the Federal Income Tax Regulations to apply certain provisions of the Code and ERISA to the plan has ever been made.
SECTION 17. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS?
.01 Rev. Proc. 2018–1, 2018–1 I.R.B. 1 is superseded.
SECTION 18. WHAT IS THE EFFECTIVE DATE OF THIS REVENUE PROCEDURE?
This revenue procedure is effective for all requests received on or after January 2, 2019. Rev. Proc. 2018–1 governs requests received prior to January 2, 2019.
SECTION 19. PAPERWORK REDUCTION ACT
approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act (44 U.S.C. § 3507) under control number 1545-1522.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid control number.
The collections of information in this revenue procedure are in sections 5.06, 6.03, 7.01, 7.02, 7.03, 7.04, 7.05, 7.07, 7.08, 8.02. 8.05, 8.07, 10.01, 10.06, 10.07, 11.11, 13.02, 15.02, 15.07, 15.08, 15.09, 15.11, paragraph (B)(1) of Appendix A, Appendix C, Appendix D, Appendix E, and Appendix G (subject matter—rate orders; regulatory agency; normalization). This information is required to evaluate and process the request for a letter ruling or determination letter. In addition, this information will be used to help the Service delete certain information from the text of the letter ruling or determination letter before it is made available for public inspection as required by § 6110. The collections of information are required to obtain a letter ruling or determination letter. The likely respondents are businesses or other for-profit institutions and tax exempt organizations.
The estimated total annual reporting and/or recordkeeping burden is 316,020 hours.
The estimated annual burden per respondent/recordkeeper varies from 1 to 200 hours, depending on individual circumstances, with an estimated average burden of 80 hours. The estimated number of respondents and/or recordkeepers is 3,956.
The estimated annual frequency of responses is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by § 6103.
DRAFTING INFORMATION
The principal author of this revenue procedure is Joseph T. Maher Jr. of the Office of Associate Chief Counsel (Procedure and Administration). For further information regarding this revenue procedure for matters under the jurisdiction of—
(1) the Associate Chief Counsel (Corporate), contact Ken Cohen or Jean R. Broderick at (202) 317-7700 (not a toll-free call),
(2) the Associate Chief Counsel (Financial Institutions and Products), contact K. Scott Brown at (202) 317-6945 (not a toll-free call),
(3) the Associate Chief Counsel (Income Tax and Accounting), contact R. Matthew Kelley at (202) 317-7002 (not a toll-free call),
(4) the Associate Chief Counsel (Passthroughs and Special Industries), contact Anthony McQuillen at (202) 317-6850 (not a toll-free call),
(5) the Associate Chief Counsel (Procedure and Administration), contact Jennifer Auchterlonie at (202) 317-3400 (not a toll-free call),
(6) the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), contact Michael B. Blumenfeld at (202) 317-6000 (not a toll-free call), or
(7) the Associate Chief Counsel (International), contact Nancy Galib at (202) 317-3800 (not a toll-free call).
For further information regarding user fees, contact the Docket, Records, and User Fee Branch at (202) 317-5221 (not a toll-free call).
For further information regarding determination letters:
SBSE and WI taxpayers should contact the offices listed in Appendix F of this Revenue Procedure;
LB&I taxpayers should contact Melanie Perrin in the Office of Compliance Integration, LB&I, at (202) 317-3157 (not a toll-free call);
TE/GE taxpayers should also refer to Revenue Procedures 2019–4 and 2019–5, this bulletin.
References are to sections in Rev. Proc. 2019–1
– penalties of perjury statement required 8.05(4)
– proposed deletions under § 6110 7.01(12)
– information requested during initial and subsequent contacts 8.05
failure to submit 8.05(3)
subsequent information after conference 10.06
– where to send 8.05(6)
Changes in Method of Accounting or Accounting Period
– applicable sections of Rev. Proc. 2019–1 for changes in method of accounting 9
– applicable sections of Rev. Proc. 2019–1 for accounting period Appendix G
– automatic change request procedures 9.01, 9.22, Appendix G
– identical changes in method of accounting 9.15, 15.07, Appendix A
– user fees Appendix A
Checklist Required 7.01(19), Appendix C
– offered 10.02
after conference of right 10.05
application of § 6110 7.01(12)(e)
– requesting a conference 7.02(6)
– scheduling 10.01, 10.02
application of § 7805(b) 11.11(2), 13.02(2)
pre-submission conferences 10.07
telephone conferences 10.08
– Associate office 1.01(2)
– closing agreement 2.02
– determination letter 2.03
– Director 1.01(3)
– Field office 1.01(4)
– taxpayer 1.01(5)
– information letter 2.04
– letter ruling 2.01
– Service 1.01(1)
Determinations Under § 999(d) 5.04
Discussions Not Binding on Service
– at pre-submission conference 10.07(4)
– informal opinion expressed 8.04
– oral advice to taxpayers 2.05(2)
Employee Plans and Exempt Organizations
– jurisdiction of Commissioner, Tax Exempt and Government Entities Division 4.02
– user fees 4.02
Estate Tax Matters
– issuance of determination letters 12.02, 12.05
– issuance of letter rulings 5.06
under § 2032A(c) 5.07
Expedited Handling of Letter Ruling and Determination Letter Requests 7.02(4)
– to schedule conference 10.01
– to submit additional information 8.05(2)
Fax Transmission
– to receive letter ruling 7.02(5)
– to receive request for additional information 7.02(5)
– letter ruling requests must not be submitted by fax 7.04(1)(c)
Hand Delivery of Letter Ruling Requests 7.04(1)
No-Rule Areas 6
Oral Advice to Taxpayers 2.05
– form for letter ruling request 7.01(16)(a)
– form for submission of additional information 8.05(4)
– required with draft letter ruling 8.07
– signature requirements 7.01(16)(b)
– when to attach a copy to return 7.05(2)
estate tax matters 5.06
– when to notify Associate office 7.05
– Form 2848 7.01(15), 7.02(2)
original sent to the taxpayer 7.02(2)
copy sent to a representative 7.02(2)
copies sent to multiple representatives 7.02(2)
no copy sent to representatives 7.02(2)
– signature requirements 7.01(15)
Public Disclosure of Information Letters 2.04
Public Inspection Under § 6110 7.01(12)
– signature requirements 7.01(12)(c)
– compliance with Treasury Department Circular No. 230 7.01(14)
– power of attorney required 7.01(15)
– requirements 7.01(14)
authorized representatives 7.01(14)(a)
authorized based on relationship 7.01(14)(b)
return preparer 7.01(14)(c)
foreign representative 7.01(14)(d)
Retroactive Revocation or Modification
– of determination letter 13
request to limit retroactive effect 13.02
– of letter ruling 11.05 - 11.10
Revenue Rulings
– effect on a letter ruling 11.04
– request to limit retroactive effect 11.11
Sample of a Letter Ruling Request 7.01(18), Appendix B
Section 301.9100 Relief 5.03
Section 367 Rulings 5.05
Status of Letter Ruling and Determination Letter Requests 7.07
Substantially Identical Letter Rulings 15.07(2), Appendix A
Tax Exempt and Government Entities
– schedule of user fees Appendix A
– user fee requirements 15
to reopen case 8.05(3)
Where to Send
– determination letter request 7.04
– letter ruling request 7.04, 9.05
additional information 8.05(6), 9.08(6)
hand delivery 7.04(1)
Withdrawal of Letter Ruling and Determination Letter Requests 7.08
SCHEDULE OF USER FEES
NOTE: Payment must be in U.S. dollars and made through www.pay.gov. See section 15.09.
(A) FEE SCHEDULE
USER FEE FOR REQUESTS RECEIVED PRIOR TO FEBRUARY 2, 2019
USER FEE FOR REQUESTS RECEIVED AFTER FEBRUARY 1, 2019
(1) User fee for a request for a determination letter from a Director. The user fee for each determination letter request governed by Rev. Proc. 2019–1, this revenue procedure. $275 $275
(2) User fee for a request for an advance pricing agreement or a renewal of an advance pricing agreement. See section 3.05 of Rev. Proc. 2015–41, 2015–35 I.R.B. 263. See section 3.05 of Rev. Proc. 2015–41, 2015–35 I.R.B. 263.
(3) User fee for a request for a letter ruling or closing agreement. Except for the user fees for advance pricing agreements and renewals, the reduced fees provided in paragraph (A)(4) of this appendix, the user fees provided in paragraph (A)(5) of this appendix, and the exemptions provided in section 15.04 of this revenue procedure, the user fee for each request for a letter ruling or closing agreement under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), or the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) is as follows:
(a) Accounting periods
(i) Form 1128, Application to Adopt, Change, or Retain a Tax Year, (except as provided in paragraph (A)(4)(a) of this appendix) $5,800 $6,200
(ii) Requests made on Part II of Form 2553, Election by a Small Business Corporation, to use a fiscal year based on a business purpose (except as provided in paragraph (A)(4)(a) of this appendix) $5,800 $6,200
(iii) Letter ruling requests for extensions of time to file Form 1128, Application to Adopt, Change, or Retain a Tax Year, Form 8716, Election To Have a Tax Year Other Than a Required Tax Year, or Part II of Form 2553 under § 301.9100–3 (except as provided in paragraph (A)(4)(a) of this appendix) $5,400 $6,500
(b) Changes in Methods of Accounting
(i) Non-automatic Form 3115, Application for Change in Accounting Method (except as provided in paragraph (A)(4)(a) or (b), or (5)(b) of this appendix) $9,500 $10,800
(ii) Letter ruling requests for extensions of time to file Form 3115, Application for Change in Accounting Method, under § 301.9100–3 (except as provided in paragraph (A)(4)(a) or (b), or (5)(c) of this appendix) $10,000 $11,800
No user fee is required if the change in accounting period or method of accounting is permitted to be made pursuant to a published automatic change request procedure. See section 9.22 and Appendix G of Rev. Proc. 2019–1, this revenue procedure, for the list of automatic change request procedures published and/or in effect as of December 31, 2018.
(c) (i) Letter ruling request for relief under § 301.9100–3 (except as provided in paragraph (A)(4)(a) or (b), or (5)(a) of this appendix) $10,000 $10,900
(ii) All other letter ruling requests (including accounting period and method of accounting requests other than those properly submitted on Form 1128, Application to Adopt, Change, or Retain a Tax Year, Part II of Form 2553, Election by a Small Business Corporation, or Form 3115, Application for Change in Accounting Method) (except as provided in paragraph (A)(4)(a) or (b), or (5)(a) of this appendix) $28,300 $30,000
(d) Requests for closing agreements on a proposed transaction or on a completed transaction before a return for the transaction has been filed in which a letter ruling on that transaction is not requested or issued (except as provided in paragraph (A)(4)(a) or (b), and in paragraph (A)(5), of this appendix) $28,300 $30,000
(e) A request for a Foreign Insurance Excise Tax Waiver Agreement $8,000 $8,000
NOTE: A taxpayer who receives relief under § 301.9100–3 (for example, an extension of time to file Form 3115, Application for Change in Accounting Method) will be charged a separate user fee for the letter ruling request on the underlying issue (for example, the accounting period or method of accounting application).
(4) Reduced user fee for a request for a letter ruling, method or period change, or closing agreement. A reduced user fee for a request involving a personal, exempt organization, governmental entity, or business tax issue is provided in the following situations if the person provides the certification described in paragraph (B)(1) of this appendix:
(a) Request involves a tax issue from a person with gross income (as determined under paragraphs (B)(2), (3), (4), and (5) of this appendix) of less than $250,000 $2,400 $2,800
(b) Request involves a tax issue from a person with gross income (as determined under paragraphs (B)(2), (3), (4), and (5) of this appendix) of less than $1 million and $250,000 or more. $7,600 $7,600
(5) User fee for substantially identical letter ruling requests or closing agreements, identical changes in method of accounting, or plans from issuing authorities under § 25(c)(2)(B). If the requirements of section 15.07 of Rev. Proc. 2019–1, this revenue procedure, are satisfied, the user fee for the following situations is as follows:
(a) Substantially identical letter rulings and closing agreements requested (other than changes in methods of accounting requested on Form 3115) $2,700 $3,000
Requests for substantially identical letter rulings or closing agreements for multiple entities with a common member or sponsor, or for multiple members of a common entity, or for parties engaged together in the same transaction affecting all requesting taxpayers, for each additional letter ruling request after the $30,000 fee or reduced fee, as applicable, has been paid for the first letter ruling request. These requests may include, but are not limited to, requests for substantially identical letter rulings for two or more identical trusts, multiple beneficiaries of a trust, a trust divided into identical subtrusts, spouses making split gifts, or series funds within a single trust or series organization.
NOTE: Each entity or member that is entitled to the user fee under paragraph (A)(5)(a) of this appendix, that receives relief under § 301.9100–3 (for example, an extension of time to file an election) will be charged a separate user fee for the letter ruling request on the underlying issue.
NOTE: The fee charged for the first letter ruling is the highest fee applicable to any of the entities.
NOTE: Where the requests for the letter rulings are submitted by a private foundation described in § 509 and one or more disqualified persons described in § 4946, the fee charged for the first letter ruling to a disqualified person is the highest fee applicable to any of the taxpayers.
(b) Identical change in method of accounting requested on a single Form 3115, Application for Change in Accounting Method, as provided in section 15.07(4). Fee for each additional applicant seeking the identical change in method of accounting on the same Form 3115 after the $10,800 fee or reduced fee, as applicable, has been paid for the first applicant. $200 $230
(c) Substantially identical plans under § 25(c)(2)(B) $1,500 $1,500
Situations where an issuing authority under § 25 submits substantially identical plans for administering the 95-percent requirement of § 143(d)(1) following the submission of an initial plan that was approved.
(d) Extension of time requested to file Form 3115, Application for Change in Accounting Method, for an identical change in method of accounting as provided in section 15.07(4). Fee for each additional or each additional applicant seeking the identical extension of time under § 301.9100–3 to file a single Form 3115 for the identical change in method of accounting after the $11,800 fee or reduced fee, as applicable, has been paid for the first applicant. $200 $230
NOTE: When an extension of time to file Form 3115, Application for Change in Accounting Method, is granted under § 301.9100–3 for multiple applicants, a separate user fee will be charged for the change in method of accounting application, Form 3115.
(6) User fee for information letter requests. $0 $0
(7) User fee for pre-filing agreements. $174,000 $174,000
(8) Tax treaty limitation of benefits. See Rev. Proc. 2015–40, 2015–35 I.R.B. 236 for procedures for requesting competent authority assistance under tax treaties. $27,500 $27,500
(9) Statement of Value. See Rev. Proc. 96–15 for procedures for requesting a statement of value.
(A) User fee for a case with 1–3 items $6,500 $6,500
(B) Cost per each additional item beyond 3 $300 $300
(B) PROCEDURAL MATTERS
(1) Required certification. A person seeking a reduced user fee under paragraph (A)(4) of this Appendix must provide the following certification in order to obtain the reduced user fee:
(a) If a person is seeking a reduced user fee under paragraph (A)(4)(a) of this appendix, the person must certify in the request that his, her, or its gross income, as defined under paragraphs (B)(2), (3), (4), and (5) of this appendix, as applicable, is less than $250,000 as reported on their last federal income tax return (as amended) filed for a full (12 months) taxable year ending before the date the request is filed.
(b) If a person is seeking a reduced user fee under paragraph (A)(4)(b) of this appendix, the person must certify in the request that his, her, or its gross income, as defined under paragraphs (B)(2), (3), (4), and (5) of this appendix, as applicable, is less than $1 million and more than $250,000 as reported on their last federal income tax return (as amended) filed for a full (12 months) taxable year ending before the date the request is filed.
The certification must be attached as part of the ruling request.
(2) Gross income for a request involving a personal tax issue. For purposes of the reduced user fees provided in paragraphs (A)(4)(a) and (b) of this Appendix of—
(a) U.S. citizens and resident alien individuals, domestic trusts, and domestic estates, “gross income” is equal to “total income” as reported on their last federal income tax return (as amended) filed for a full (12 months) taxable year ending before the date the request is filed, plus any interest income not subject to tax under § 103 (interest on state and local bonds) for that period. “Total income” is a line item on Federal tax returns. For example, if the 2014 Form 1040, U.S. Individual Income Tax Return, is the most recent 12-month taxable year return filed by a U.S. citizen, “total income” on the Form 1040 is the amount entered on line 22.
In the case of a request for a letter ruling or closing agreement from a domestic estate or trust that, at the time the request is filed, has not filed a Federal income tax return for a full taxable year, the reduced user fee in paragraph (A)(4)(a) of this Appendix will apply if the decedent’s or (in the case of an individual grantor) the grantor’s total income as reported on the last Federal income tax return filed for a full taxable year ending before the date of death or the date of the transfer, taking into account any additions required to be made to total income described in paragraph (B)(2)(a), is less than $250,000 (or less than $1,000,000 for the paragraph (A)(4)(b) fee to apply). In this case, the executor or administrator of the decedent’s estate or the grantor must provide the certification required under paragraph (B)(1) of this appendix.
(b) Nonresident alien individuals, foreign trusts, and foreign estates, “gross income” is equal to “total effectively connected income” as reported on their last Federal income tax return (as amended) filed for a full (12 months) taxable year ending before the date the request is filed, plus any income for the period from United States or foreign sources that is not taxable by the United States, whether by reason of § 103, an income tax treaty, § 871(h) (regarding portfolio interest), or otherwise, plus the total amount of any fixed or determinable annual or periodical income from United States sources, the United States tax liability for which is satisfied by withholding at the source. “Total effectively connected income” is a line item on Federal tax returns. For example, if the 2014 Form 1040NR, U.S. Nonresident Alien Income Tax Return, is the most recent 12-month taxable year return filed by a nonresident alien individual, “total effectively connected income” on the Form 1040NR is the amount entered on line 23.
In the case of a request for a letter ruling or closing agreement from a foreign estate or trust that, at the time the request is filed, has not filed a Federal income tax return for a full taxable year, the reduced user fee in paragraph (A)(4)(a) of this Appendix will apply if the decedent’s or (in the case of an individual grantor) the grantor’s total income or total effectively connected income, as relevant, as reported on the last Federal income tax return filed for a full taxable year ending before the date of death or the date of the transfer, taking into account any additions required to be made to total income or total effectively connected income described respectively in paragraph (B)(2)(a) of this Appendix or in this paragraph (B)(2)(b), is less than $250,000 (or less than $1,000,000 for the paragraph (A)(4)(b) fee to apply). In this case, the executor or administrator of the decedent’s estate or the grantor must provide the certification required under paragraph (B)(1) of this Appendix.
(3) Gross income for a request involving a business-related tax issue. For purposes of the reduced user fees provided in paragraphs (A)(4)(a) and (b) of this Appendix of—
(a) U.S. citizens and resident alien individuals, domestic trusts, and domestic estates, “gross income” is equal to gross income as defined under paragraph (B)(2)(a) of this Appendix, plus “cost of goods sold” as reported on the same Federal income tax return.
(b) Nonresident alien individuals, foreign trusts, and foreign estates, “gross income” is equal to gross income as defined under paragraph (B)(2)(b) of this Appendix, plus “cost of goods sold” as reported on the same Federal income tax return.
(c) Partnerships with a Form 1065 filing requirement and corporations (foreign and domestic), “gross income” is equal to “total income” as reported on their last Federal tax return (as amended) filed for a full (12 months) taxable year ending before the date the request is filed, plus “cost of goods sold” as reported on the same Federal tax return, plus any interest income not subject to tax under § 103 (interest on state and local bonds) for that period. Partnerships with a Form 1065 filing requirement should also include “gross rents” reported on Form 8825 at line 2, as well as the income amounts reported on Schedule K Form 1065 at lines 3a, 5, 6a, 7, 8, 9a, 10, and 11 from the same Federal tax return described in the preceding sentence to calculate “gross income” for the purpose of applying the reduced user fee in paragraph (A)(4) of this Appendix. S Corporations with a Form 1120S filing requirement should also include “gross rents” reported on Form 8825 at line 2, as well as the income amounts reported on Schedule K Form 1120S at lines 3a, 4, 5a, 6, 7, 8a, 9, and 10 from the same Federal tax return described in the first sentence of this paragraph to calculate “gross income” for the purpose of applying the reduced user fee in paragraph (A)(4) of this Appendix. If a partnership or S Corporation is not required to file or a C corporation is not subject to tax, “total income” and “cost of goods sold” are the amounts that the partnership or corporation would have reported on the Federal tax return if the partnership or S Corporation had been required to file or the C corporation had been subject to tax.
“Cost of goods sold” and “total income” are line items on Federal tax returns. For example, if the 2015 Form 1065, U.S. Return of Partnership Income, is the most recent 12-month taxable year return filed by a partnership, “cost of goods sold” and “total income” on the Form 1065 are the amounts entered on lines 2 and 8, respectively; if the 2015 Form 1120, U.S. Corporation Income Tax Return, is the most recent 12-month taxable year return filed by a domestic corporation, “cost of goods sold” and “total income” on the Form 1120 are the amounts entered on lines 2 and 11, respectively; and if the 2015 Form 1120S, U.S. Income Tax Return for an S Corporation, is the most recent 12-month taxable year return filed by an S corporation, “cost of goods sold” and “total income” on the Form 1120S are the amounts entered on lines 2 and 6, respectively.
If, at the time the request is filed, a partnership or corporation subject to tax has not filed a Federal tax return for a full taxable year, the reduced user fee in paragraph (A)(4)(a) or (b) of this Appendix will apply if, in the aggregate, the partners’ or the shareholders’ gross income (as defined in paragraph (B)(3)(a), (b), or (c), of this Appendix, as applicable) is less than $250,000 for purposes of paragraph (A)(4)(a) or $1 million for purposes of paragraph (A)(4)(b) for the last full (12 months) taxable year ending before the date the request is filed. In this case, the partners or the shareholders must provide the certification required under paragraph (B)(1) of this Appendix.
(4) Gross income for a request involving an exempt organization or governmental entity. For purposes of the reduced user fees provided in paragraphs (A)(4)(a) and (b) of this Appendix of—
(a) Organizations exempt from income tax under “Subchapter F-Exempt Organizations” of the Code, “gross income” is equal to the amount of gross receipts for the last full (12 months) taxable year ending before the date the request for a letter ruling or closing agreement is filed.
(b) State, local, and Indian tribal government entities, “gross income” is equal to the annual operating revenue of the government requesting the ruling for its last fiscal year ending before the date of the ruling request. The annual operating revenue is to be determined at the government level and not at the level of the government entity or agency making the request.
(5) Special rules for determining gross income. For purposes of paragraphs (B)(2), (3) and (4) of this Appendix, the following rules apply for determining gross income.
(a) Gross income of individuals, trusts, and estates.
(1) In the case of a request from a married individual, the gross incomes (as defined in paragraph (B)(2) or (3) of this Appendix, as applicable) of the applicant and the applicant’s spouse must be combined. This rule does not apply to an individual: (i) who is legally separated from his or her spouse and (ii) who did not file a joint income tax return; and
(2) If there are two or more applicants filing the request, the gross incomes (as defined in paragraph (B)(2) or (3) of this Appendix, as applicable) of the applicants must be combined.
(b) Gross income of domestic partnerships and corporations.
(1) In the case of a request from a domestic C corporation, the gross income (as defined in paragraph (B)(3) of this Appendix) of (i) all members of the applicant’s controlled group (as defined in § 1563(a)), and (ii) any taxpayer who is involved in the transaction on which the letter ruling or closing agreement is requested, must be combined; and
(2) In the case of a request from a domestic partnership, the gross income (as defined in paragraph (B)(3) of this Appendix) of (i) the partnership, and (ii) any partner who owns, directly or indirectly, 50 percent or more of the capital interest or profits interest in the partnership, must be combined.
(3) In the case of a request from an S corporation, the gross income (as defined in paragraph (B)(3) of this Appendix) of (i) the S corporation, and (ii) any shareholder who owns 50 percent or more of the S corporation, must be combined.
(c) Gross income of exempt organizations. If there are two or more organizations exempt from income tax under Subchapter F filing the request, the gross receipts (as defined in paragraph (B)(4)(a) of this Appendix) of the applicants must be combined.
(6) When gross income depends on a favorable ruling. If a taxpayer’s qualification for a reduced user fee under paragraphs (A)(4)(a) and (b) of this Appendix depends on the receipt of a favorable ruling, the taxpayer must pay the higher fee with the request and cannot assume that the Service will rule favorably. If a favorable ruling is issued, and as a result of the ruling the taxpayer’s gross income is reduced such that the taxpayer would qualify for a reduced user fee, the amount that the taxpayer paid in excess of the reduced user fee will be returned to the taxpayer. See section 15.09.
To assist you in preparing a letter ruling request, the Service is providing this sample format. You are not required to use this sample format. If your request is not identical or similar to the sample format, the different format will not defer consideration of your request.
(Insert the date of request)
Insert either: Associate Chief Counsel (Insert one of the following: Corporate; Financial Institutions and Products; Income Tax and Accounting; International; Passthroughs and Special Industries; Procedure and Administration; or Employee Benefits, Exempt Organizations, and Employment taxes)
Dear Sir or Madam:
(Insert the name of the taxpayer) requests a ruling on the proper treatment of (insert the subject matter of the letter ruling request) under section (insert the number) of the Internal Revenue Code.
[If the taxpayer is requesting expedited handling, a statement to that effect must be attached to, or contained in, the letter ruling request. The statement must explain the need for expedited handling. See section 7.02(4) of Rev. Proc. 2019–1, this revenue procedure. Hereafter, all references are to Rev. Proc. 2019–1 unless otherwise noted.]
A. STATEMENT OF FACTS
1. Taxpayer Information
[Provide the statements required by sections 7.01(1)(a) and (b).]
2. Description of Taxpayer’s Business Operations
[Provide the statement required by section 7.01(1)(c).]
3. Facts Relating to Transaction
[The ruling request must contain a complete statement of the facts relating to the transaction that is the subject of the letter ruling request. This statement must include a detailed description of the transaction, including material facts in any accompanying documents, and the business reasons for the transaction. See sections 7.01(1)(d), 7.01(1)(e), and 7.01(2).]
B. RULING REQUESTED
[The ruling request should contain a concise statement of the ruling requested by the taxpayer. The Service prefers that the language of the requested ruling be exactly the same as the language the taxpayer wishes to receive.]
C. STATEMENT OF LAW
[The ruling request must contain a statement of the law in support of the taxpayer’s views or conclusion and identify any pending legislation that may affect the proposed transaction. The taxpayer also is strongly encouraged to identify and discuss any authorities believed to be contrary to the position advanced in the ruling request. See sections 7.01(6), 7.01(10), 7.01(10), and 7.01(11).]
D. ANALYSIS
[The ruling request must contain a discussion of the facts and an analysis of the law. The taxpayer also is strongly encouraged to identify and discuss any authorities believed to be contrary to the position advanced in the ruling request. See sections 7.01(3), 7.01(6), 7.01(9), 7.01(10), and 7.01(11).]
[The ruling request should contain a statement of the taxpayer’s conclusion on the ruling requested.]
F. PROCEDURAL MATTERS
1. Revenue Procedure 2019–1 Statements
a. [Provide the statement required by section 7.01(4) regarding whether any return of the taxpayer, a related taxpayer within the meaning of § 267 or of a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504 which would be affected by the requested letter ruling or determination letter, is currently under examination, before Appeals, or before a Federal court, or was previously under examination, before Appeals, or before a Federal court.]
b. [Provide the statement required by section 7.01(5)(a) regarding whether the Service previously ruled on the same or similar issue for the taxpayer, a related taxpayer, or a predecessor. Please further note that if a reduced user fee is being submitted, a certification of eligibility for the reduced fee must be included with the ruling request.]
c. [Provide the statement required by section 7.01(5)(b) regarding whether the taxpayer, a related taxpayer, a predecessor, or any representatives previously submitted a request (including an application for change in method of accounting) involving the same or similar issue but withdrew the request before a letter ruling or determination letter was issued.]
d. [Provide the statement required by section 7.01(5)(c) regarding whether the taxpayer, a related taxpayer, or a predecessor previously submitted a request (including an application for change in method of accounting) involving the same or a similar issue that is currently pending with the Service.]
e. [Provide the statement required by section 7.01(5)(d) regarding whether, at the same time as this request, the taxpayer or a related taxpayer is presently submitting another request (including an application for change in method of accounting) involving the same or similar issue to the Service.]
f. [Provide the statement required by section 7.01(5)(e) regarding whether the taxpayer or a related taxpayer had, or has scheduled, a pre-submission conference involving the same or a similar issue.]
g. [If the letter ruling request involves the interpretation of a substantive provision of an income or estate tax treaty, provide the statement required by section 7.01(6) regarding whether the tax authority of the treaty jurisdiction has issued a ruling on the same or similar issue for the taxpayer, a related taxpayer, or a predecessor; whether the same or similar issue is being examined, or has been settled, by the tax authority of the treaty jurisdiction or is otherwise the subject of a closing agreement in that jurisdiction; and whether the same or similar issue is being considered by the competent authority of the treaty jurisdiction.]
h. [If the letter ruling request involves a transaction between a taxpayer and a related party and either the taxpayer or the related party is located in a foreign country, provide the statement required by section 7.01(7) regarding whether this letter ruling potentially relates to any one of these categories (include all that apply): Preferential Regime; Transfer Pricing; Downward Adjustment; Treaty Permanent Establishment; Related Party Conduit.
i. [Provide the statement required by section 7.01(9) regarding whether the law in connection with the letter ruling request is uncertain and whether the issue is adequately addressed by relevant authorities.]
j. [If the taxpayer determines that there are no contrary authorities, a statement in the request to this effect should be included. See section 7.01(10).]
k. [If the taxpayer wants to have a conference on the issues involved in the letter ruling request, the ruling request should contain a statement to that effect. See section 7.02(6).]
l. [If the taxpayer is requesting a copy of any document related to the letter ruling request to be sent by facsimile (fax) transmission, the ruling request should contain a statement to that effect. See section 7.02(5).]
m. [If the taxpayer is requesting separate letter rulings on multiple issues, the letter ruling request should contain a statement to that effect. See section 7.02(1).]
n. [If the taxpayer is seeking to obtain the user fee provided in paragraph (A)(5)(a) of Appendix A for substantially identical letter rulings, the letter ruling request must contain the statements required by section 15.07.]
a. [The ruling request should state: “The deletion statement and checklist required by Rev. Proc. 2019–1 are enclosed.” See sections 7.01(12) and 7.01(19).]
b. [The ruling request should state: “The required user fee of $ (Insert the amount of the fee) has been paid through www.pay.gov” See section 15.09 and Appendix A.]
c. [If the taxpayer’s authorized representative is to sign the letter ruling request or is to appear before the Service in connection with the request, the ruling request should state: “A Power of Attorney is enclosed.” See sections 7.01(14), 7.01(15), and 7.02(2).]
(Insert the name of the taxpayer or the taxpayer’s authorized representative)
Typed or printed name of person signing request
DECLARATION: [See section 7.01(16).]
Under penalties of perjury, I declare that I have examined this request, including accompanying documents, and, to the best of my knowledge and belief, the request contains all the relevant facts relating to the request, and such facts are true, correct, and complete.
(Insert the name of the taxpayer)
Signature Title Date
(must be signed by taxpayer, not by taxpayer’s representative, see section 7.01(16)(b) of this revenue procedure)
Typed or printed name of
person signing declaration
[If the taxpayer is a corporation that is a member of an affiliated group filing consolidated returns, the above declaration must also be signed and dated by an officer of the common parent of the group. See section 7.01(16).]
CHECKLIST IS YOUR LETTER RULING REQUEST COMPLETE?
The Service will be able to respond more quickly to your letter ruling request if it is carefully prepared and complete. Use this checklist to ensure that your request is in order. Complete the four items of information requested before the checklist. Answer each question by circling “Yes,” “No,” or “N/A.” When a question contains a place for a page number, insert the page number (or numbers) of the request that gives the information called for by a “Yes” answer to a question. Sign and date the checklist (as taxpayer or authorized representative) and place it on top of your request.
If you are an authorized representative submitting a request for a taxpayer, you must include a completed checklist with the request or the request will either be returned to you or substantive consideration of it will be deferred until a completed checklist is submitted. If you are a taxpayer preparing your own request without professional assistance, an incomplete checklist will not cause the return of your request or defer substantive consideration of your request. You should still complete as much of the checklist as possible and submit it with your request.
TAXPAYER’S NAME
TAXPAYER’S I.D. NO.
ATTORNEY/P.O.A.
PRIMARY CODE SECTION
CIRCLE ONE
Yes No 1. Does your request involve an issue under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), or the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes)? See section 3 of Rev. Proc. 2019–1, this revenue procedure. For issues under the jurisdiction of other offices, see section 4 of Rev. Proc. 2019–1. (Hereafter, all references are to Rev. Proc. 2019–1 unless otherwise noted.)
Yes No 2. Have you read Rev. Proc. 2019–1, Rev. Proc. 2019–3, and Rev. Proc. 2019–7, this bulletin, to see if part or all of the request involves a matter on which letter rulings are not issued or are ordinarily not issued?
Yes No N/A 3. If your request involves a matter on which letter rulings are not ordinarily issued, have you given compelling reasons to justify the issuance of a letter ruling? Before preparing your request, you may want to call the branch in the Office of Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions and Products), the Office of Associate Chief Counsel (Income Tax and Accounting), the Office of Associate Chief Counsel (International), the Office of Associate Chief Counsel (Passthroughs and Special Industries), the Office of Associate Chief Counsel (Procedure and Administration), or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) responsible for substantive interpretations of the principal Internal Revenue Code section on which you are seeking a letter ruling to discuss the likelihood of an exception. For matters under the jurisdiction of—
(a) the Office of Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions and Products), the Office of Associate Chief Counsel (Income Tax and Accounting), the Office of Associate Chief Counsel (Passthroughs and Special Industries), the Office of the Associate Chief Counsel (Procedure and Administration), or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), the appropriate branch to call may be obtained by calling (202) 317-5221 (not a toll-free call);
(b) the Office of the Associate Chief Counsel (International), the appropriate branch to call may be obtained by calling (202) 317-3800 (not a toll-free call).
Yes No N/A Page __ 4. If the request involves a retirement plan qualification matter under § 401(a), § 409, or § 4975(e)(7), have you demonstrated that the request satisfies section 4.02(12) of Rev. Proc. 2019–3, this Bulletin, for a ruling?
Yes No N/A Page __ 5. transaction was completed? See section 5.01.
Yes No 6. Are you requesting the letter ruling on a hypothetical situation or question? See section 6.12.
Yes No 7. Are you requesting the letter ruling on alternative plans of a proposed transaction? See section 6.12.
Yes No 8. Are you requesting the letter ruling for only part of an integrated transaction?
Yes No Page __ 9. Are you requesting a letter ruling under the jurisdiction _of Associate Chief Counsel (Corporate) on a significant issue (within the meaning of section 3.01(55) of Rev. Proc. 2019–3, this Bulletin) with respect to a transaction described in § 332, § 351, § 355, or § 1036 or a reorganization within the meaning of § 368? See section 6.03(2).
Yes No 10. Are you requesting the letter ruling for a business, trade, industrial association, or similar group concerning the application of tax law to its members? See section 6.05.
Yes No 11. Are you requesting the letter ruling for a foreign government or its political subdivision? See section 6.07.
Yes No Page __ 12. Have you included a complete statement of all the facts relevant to the transaction? See section 7.01(1).
Yes No N/A 13. Have you submitted with the request true copies of all wills, deeds, and other documents relevant to the transaction, and labeled and attached them in alphabetical sequence? See section 7.01(2).
Yes No N/A 14. Have you submitted with the request a copy of all applicable foreign laws, and certified English translations of documents that are in a language other than English or of foreign laws in cases where English is not the official language of the foreign country involved? See section 7.01(2).
Yes No 15. Have you included an analysis of facts and their bearing on the issues? Have you included, rather than merely incorporated by reference, all material facts from the documents in the request? See section 7.01(3).
Yes No Page __ 16. Have you included the required statement regarding whether any return of the taxpayer (or any return of a related taxpayer within the meaning of § 267 or of a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504) who would be affected by the requested letter ruling or determination letter is currently or was previously under examination, before Appeals, or before a Federal court? See section 7.01(4).
Yes No Page __ 17. Have you included the required statement regarding whether the Service previously ruled on the same or similar issue for the taxpayer, a related taxpayer, or a predecessor? See section 7.01(5)(a).
Yes No Page __ 18. Have you included the required statement regarding whether the taxpayer, a related taxpayer, a predecessor, or any representatives previously submitted a request (including an application for change in method of accounting) involving the same or similar issue but withdrew the request before the letter ruling or determination letter was issued? See section 7.01(5)(b).
Yes No Page __ 19. Have you included the required statement regarding whether the taxpayer, a related taxpayer, or a predecessor previously submitted a request (including an application for change in method of accounting) involving the same or similar issue that is currently pending with the Service? See section 7.01(5)(c).
Yes No Page __ 20. Have you included the required statement regarding whether, at the same time as this request, the taxpayer or a related taxpayer is presently submitting another request (including an application for change in method of accounting) involving the same or similar issue to the Service? See section 7.01(5)(d).
Yes No Page __ 21. Have you included the required statement regarding whether the taxpayer or a related taxpayer had, or has scheduled, a pre-submission conference involving the same or a similar issue? See section 7.01(5)(e).
Yes No N/A Page __ 22. If your request involves the interpretation of a substantive provision of an income or estate tax treaty, have you included the required statement regarding whether the tax authority of the treaty jurisdiction has issued a ruling on the same or similar issue for the taxpayer, a related taxpayer, or a predecessor; whether the same or similar issue is being examined, or has been settled, by the tax authority of the treaty jurisdiction or is otherwise the subject of a closing agreement in that jurisdiction; and whether the same or similar issue is being considered by the competent authority of the treaty jurisdiction? See section 7.01(6).
Yes No N/A Page __ 23. If your request involves a transaction between a taxpayer and a related party and either the taxpayer or the related party is located in a foreign country, have you included the required statement regarding whether the letter ruling relates to any one of these categories (include all that apply: Preferential Regime; Transfer Pricing; Downward Adjustment; Treaty Permanent Establishment; Related Party Conduit? See section 7.01(7).
Yes No N/A Page __ 24. If your request is for recognition of Indian tribal government status or status as a political subdivision of an Indian tribal government, does your request contain a letter from the Bureau of Indian Affairs regarding the tribe’s status? See section 7.01(9), which states that taxpayers are encouraged to submit this letter with the request and provides the address for the Bureau of Indian Affairs.
Yes No Page __ 25. Have you included the required statement of relevant authorities in support of your views? See section 7.01(10).
Yes No Page __ 26. Have you included the required statement regarding whether the law in connection with the request is uncertain and whether the issue is adequately addressed by relevant authorities? See section 7.01(9).
Yes No Pages __ 27. Does your request discuss the implications of any legislation, tax treaties, court decisions, regulations, notices, revenue rulings, or revenue procedures that you determined to be contrary to the position advanced? See section 7.01(10), which states that taxpayers are encouraged to inform the Service of such authorities.
Yes No N/A Page __ 28. If you determined that there are no contrary authorities, have you included a statement to this effect in your request? See section 7.01(10).
Yes No N/A Page __ 29. Have you included in your request a statement identifying any pending legislation that may affect the proposed transaction? See section 7.01(11).
Yes No 30. Have you included the deletion statement required by § 6110 and placed it on the top of the letter ruling request as required by section 7.01(12)(b)?
Yes No Page __ 32. Have you (or your authorized representative) signed and dated the request? See section 7.01(13).
Yes No N/A 32. If the request is signed by your representative or if your representative will appear before the Service in connection with the request, is the request accompanied by a properly prepared and signed power of attorney with the signatory’s name typed or printed? See section 7.01(15).
Yes No Page __ 33. Have you signed, dated, and included the penalties of perjury statement in the format required by section 7.01(16)?
Yes No N/A 34. Are you submitting your request in duplicate if necessary? See section 7.01(17).
Yes No N/A Page __ 35. If you are requesting separate letter rulings on different issues involving one factual situation, have you included a statement to that effect in each request? See section 7.02(1).
Yes No N/A 36. If you want copies of the letter ruling sent to a representative, does the power of attorney contain a statement to that effect? See section 7.02(2).
Yes No N/A 37. If you do not want a copy of the letter ruling to be sent to any representative, does the power of attorney contain a statement to that effect? See section 7.02(2).
Yes No N/A 38. If you are making a two-part letter ruling request, have you included a summary statement of the facts you believe to be controlling? See section 7.02(3).
Yes No N/A Page __ 39. If you want your letter ruling request to be processed ahead of the regular order or by a specific date, have you requested expedited handling in the manner required by section 7.02(4) and stated a compelling need for such action in the request? See section 7.02(4) of this revenue procedure.
Yes No N/A Page __ 40. If you are requesting a copy of any document related to the letter ruling request to be sent by facsimile (fax) transmission, have you included a statement to that effect? See section 7.02(5).
Yes No N/A Page __ 41. If you want to have a conference on the issues involved in the request, have you included a request for conference in the letter ruling request? See section 7.02(6).
Yes No 42. Have you paid the correct user fee through www.pay.gov? See section 15 and Appendix A to determine the correct amount.
Yes No N/A Page __ 43. If your request involves a personal, exempt organization, governmental entity, or business-related tax issue and you qualify for the reduced user fee because your gross income is less than $250,000, have you included the required certification? See paragraphs (A)(4)(a) and (B)(1) of Appendix A.
Yes No N/A Page __ 44. If your request involves a personal, exempt organization, governmental entity, or business-related tax issue and you qualify for the reduced user fee because your gross income is less than $1 million, have you included the required certification? See paragraphs (A)(4)(b) and (B)(1) of Appendix A.
Yes No N/A Page __ 45. If you qualify for the user fee for substantially identical letter rulings, have you included the required information? See section 15.07(2) and paragraph (A)(5)(a) of Appendix A.
Yes No N/A Page __ 46. If you qualify for the user fee for a § 301.9100 request to extend the time for filing an identical change in method of accounting on a single Form 3115, Application for Change in Accounting Method, have you included the required information? See section 15.07(4) and paragraph (A)(5)(d) of Appendix A.
Yes No N/A 47. If your request is covered by any of the checklists, guideline revenue procedures, notices, safe harbor revenue procedures, or other special requirements listed in Appendix G, have you complied with all of the requirements of the applicable revenue procedure or notice?
Rev. Proc. ____ ____ ____ List other applicable revenue procedures or notices, including checklists, used or relied upon in the preparation of this letter ruling request (Cumulative Bulletin or Internal Revenue Bulletin citation not required).
Yes No N/A Page __ 48. If you are requesting relief under § 7805(b) (regarding retroactive effect), have you complied with all of the requirements in section 11.11?
Yes No N/A Page __ 49. If you are requesting relief under § 301.9100 for a late entity classification election, have you included a statement that complies with section 4.04 of Rev. Proc. 2009–41, 2009–39 I.R.B. 439? See section 5.03(5) of this revenue procedure.
Yes No N/A Page __ 50. If you are requesting relief under § 301.9100, and your request involves a year that is currently under examination or with appeals, have you included the required notification, which also provides the name and telephone number of the examining agent or appeals officer? See section 7.01(4) of this revenue procedure.
Yes No 51. If you are requesting relief under § 301.9100, have you included the affidavit(s) and declaration(s) required by § 301.9100–3(e)? See § 5.03(1) of this revenue procedure.
Yes No N/A 52. If you are requesting relief under § 301.9100–3, and the period of limitations on assessment under § 6501(a) will expire for any year affected by the requested relief before the anticipated receipt of a letter ruling, have you secured consent under § 6501(c)(4) to extend the period of limitations on assessment for the year(s) at issue? See § 5.03(2) of this revenue procedure.
Yes No 53. Have you addressed your request to the attention of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), or the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), as appropriate? The mailing address is:
The package should be marked: RULING REQUEST SUBMISSION. Improperly addressed requests may be delayed (sometimes for over a week) in reaching CC:PA:LPD:DRU for initial processing.
Signature Title or Authority Date
person signing checklist
APPENDIX D
ADDITIONAL CHECKLIST FOR GOVERNMENT PICK-UP PLAN RULING REQUESTS
In order to assist Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) in processing a ruling request involving government pick-up plans, in addition to the items in Appendix C please check the following list.
Yes No N/A Page ___ 1. Is the plan qualified under § 401(a) of the Code? (Evidence of qualification or representation that the plan is qualified.)
Yes No N/A Page ___ 2. Is the organization that established the plan a State or political subdivision thereof, or any agency or instrumentality of the foregoing? An example of this would be a representation that the organization that has established the plan is a political subdivision or municipality of the State.
Yes No N/A Page ___ 3. Is there specific information regarding who are the eligible participants?
Yes No N/A Page ___ 4. Are the contributions that are the subject of the ruling request mandatory employee contributions? These contributions must be for a specified dollar amount or a specific percentage of the participant’s compensation and the dollar amount or percentage of compensation cannot be subject to change.
Yes No N/A Page ___ 5. Does the plan provide that the participants do not have the election to opt in and/or out of the plan?
Yes No N/A Page ___ 6. Are copies of the enacting legislation providing that the contributions although designated as employee contributions are being paid by the employer in lieu of contributions by the employee included?
Yes No N/A Page ___ 7. Are copies of the specific enabling authorization that provides the employee must not have the option of choosing to receive the contributed amounts directly instead of having them paid by the employer to the plan included? For example, a resolution, ordinance, plan provision, or collective bargaining agreement could specify this information.
APPENDIX E
ADDITIONAL CHECKLIST FOR CHURCH PLAN RULING REQUESTS
In order to assist Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) in processing a church plan ruling request, in addition to the items in Appendix C, please check the following list.
Yes No N/A Page ___ 1. Is there specific information showing that the submission is on behalf of a plan established by a named church or convention or association of churches? The information must show how the sponsoring organization, if not a church or convention or association of churches, is controlled by, or associated with, the named church or convention or association of churches. For example, the board of directors of the sponsoring organization may be made up of members of the named church, or the sponsoring organization might be listed in the church’s official directory of related organizations whose mission is to further the objectives of the church. In order to be considered associated with a church or convention or association of churches, the organization must share common religious bonds and convictions with that church or convention or association of churches.
Yes No N/A Page ___ 2. Is there specific information showing that the organization that has established the plan is a tax-exempt organization as described in § 501 of the Code?
Yes No N/A Page ___ 3. Is there a representation that the plan for which the ruling is being requested is qualified under § 401(a) of the Code or meets the requirements of § 403(b) of the Code?
Yes No N/A Page ___ 4. Does the ruling request clearly state who are the eligible participants and the name of the employer of these eligible participants?
Yes No N/A Page ___ 5. Is there a representation that none of the eligible participants are or can be considered employed in connection with one or more unrelated trades or businesses within the meaning of § 513 of the Code?
Yes No N/A Page ___ 6. Is there a representation that all of the eligible participants are or will be employed by the named church or convention or association of churches, and will not include employees of for-profit entities? An example of an eligible employee includes a duly ordained, commissioned, or licensed minister of a church in the exercise of his or her ministry.
Yes No N/A Page ___ 7. Is there specific information showing an existing plan committee whose principal purpose or function is the administration or funding of the plan? This committee must be controlled by or associated with the named church or convention or association of churches.
Yes No N/A Page ___ 8. Is the composition of the committee stated?
Yes No N/A Page ___ 9. Did the plan sponsor provide a written notice to interested persons that a letter ruling under § 414(e) of the Code on behalf of a church plan will be submitted to the IRS? (see Rev. Proc. 2011–44).
Yes No N/A Page ___ 10. Does the ruling request include a copy of the notice?
Yes No N/A Page ___ 11. Is there a representation as to whether an election has ever been made under § 1.410(d) –1 of the Federal Income Tax Regulations to apply certain provisions of the Code and ERISA to the plan?
APPENDIX F
LIST OF SMALL BUSINESS/SELF-EMPLOYED OPERATING DIVISION (SB/SE) OFFICES TO WHICH TO SEND REQUESTS FOR DETERMINATION LETTERS
SB/SE and W&I taxpayers should send requests for determination letters under this Rev. Proc. 2019–1 to the appropriate SB/SE office listed below. Both the request and its envelope should be marked “DETERMINATION LETTER REQUEST.”
Requests for determination letters regarding income tax (including requests from international taxpayers) should be sent to:
SB/SE Exam-Field, Director
Office of Technical Services
SE:S:E:FE:TS
24000 Avila Road
Requests for determination letters regarding estate and gift tax should be sent to:
Director SB/SE Exam, Specialty Policy
SE:S:E:HQ:SEP
c/o Staff Assistant-Specialty Examination Policy
1301 Clay Street—Stop 1080
EMPLOYMENT TAXES
Requests for determination letters regarding employment tax (except for requests for determination of worker status made on Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding, which should be sent to the address in the Form instructions) should be sent to:
Oakland, CA 94612–5217
EXCISE TAXES
Requests for determination letters regarding excise taxes should be sent to:
APPENDIX G
CHECKLISTS, GUIDELINE REVENUE PROCEDURES, NOTICES, SAFE HARBOR REVENUE PROCEDURES, AND AUTOMATIC CHANGE REVENUE PROCEDURES
Specific revenue procedures and notices supplement the general instructions for requests explained in section 7 of this revenue procedure and apply to requests for letter rulings or determination letters regarding the Code sections and matters listed in this section.
Checklists, guideline revenue procedures, and notices .01 For requests relating to the following Code sections and subject matters, refer to the following checklists, guideline revenue procedures, and notices.
CODE OR REGULATION SECTION REVENUE PROCEDURE AND NOTICE
103, 141 – 150, 1394, 1400L(d), 1400N(a), 1400U–1, 1400U–3, 7478, and 7871 Issuance of state or local obligations Rev. Proc. 96–16, 1996–1 C.B. 630 (for a reviewable ruling under § 7478 and a nonreviewable ruling); Rev. Proc. 88–31, 1988–1 C.B. 832 (for approval of areas of chronic economic distress); and Rev. Proc. 82–26, 1982–1 C.B. 476 (for “on behalf of” and similar issuers). For approval of areas of chronic economic distress, Rev. Proc. 88–31 explains how this request for approval must be submitted to the Assistant Secretary for Housing/Federal Housing Commissioner of the Department of Housing and Urban Development.
1.166–2(d)(3) Uniform express determination letter for making election Rev. Proc. 92–84, 1992–2 C.B. 489.
Subchapter C-Corporate Distributions, Adjustments, Transfers, and Reorganizations Rev. Proc. 77–37, 1977–2 C.B. 568, as modified by Rev. Proc. 89–30, 1989–1 C.B. 895, and as amplified by Rev. Proc. 77–41, 1977–2 C.B. 574, Rev. Proc. 83–81, 1983–2 C.B. 598 (See also Rev. Proc. 2019–3, this bulletin, Rev. Proc. 84–42, 1984–1 C.B. 521 (superseded, in part, as to no-rule areas by Rev. Proc. 2019–3, Rev. Proc. 86–42, 1986–2 C.B. 722, Rev. Proc. 89–50, 1989–2 C.B. 631, and Rev. Proc. 2017–52, 2017–41 I.R.B. 283 (relating to Transactional Rulings for Covered Transactions), and Rev. Proc. 2018–53, 2018–43 I.R.B. 667. But see section 3.01(55) of Rev. Proc. 2019–3, which states that the Service will not issue a letter ruling as to whether a transaction constitutes a reorganization within the meaning of § 368 (except as provided in section 6.03(2)(b) of this revenue procedure). However, the Service will issue a letter ruling addressing significant issues (within the meaning of section 3.01(55) of Rev. Proc. 2019–3) presented in a reorganization within the meaning of § 368. See section 6.03(2) of this revenue procedure. In addition, the Service will issue a Transactional ruling for a Covered Transaction, as described in Rev. Proc. 2017–52.
301 Nonapplicability on sales of stock of employer to defined contribution plan Rev. Proc. 87–22, 1987–1 C.B. 718.
302, 311 Checklist questionnaire Rev. Proc. 86–18, 1986–1 C.B. 551; and Rev. Proc. 77–41, 1977–2 C.B. 574.
302(b)(4) Checklist questionnaire Rev. Proc. 81–42, 1981–2 C.B. 611.
311 Checklist questionnaire Rev. Proc. 86–16, 1986–1 C.B. 546.
332 Checklist questionnaire See section 3.01 of Rev. Proc. 2019–3, this Bulletin, which states that the Service will not issue a letter ruling on whether a corporate distribution qualifies for nonrecognition treatment under § 332. However, the Service will issue a letter ruling addressing significant issues (within the meaning of section 3.01 of Rev. Proc. 2019–3) presented in a transaction described in § 332. The information and representations described in Rev. Proc. 90–52, 1990–2 C.B. 626, should be included in a letter ruling request only to the extent that they relate to the significant issues with respect to which the letter ruling is requested. See section 6.03(4).
338 Extension of time to make elections Rev. Proc. 2003–33, 2003–1 C.B. 803, provides guidance as to how an automatic extension of time under § 301.9100–3 of the Treasury Regulations may be obtained to file elections under § 338. This revenue procedure also informs taxpayers who do not qualify for the automatic extension of the information necessary to obtain a letter ruling.
351 Checklist questionnaire See section 3.01 of Rev. Proc. 2019–3, this Bulletin, which states that the Service will not issue a letter ruling on whether certain transfers to controlled corporations qualify for nonrecognition treatment under § 351. However, the Service will issue a letter ruling addressing significant issues (within the meaning of section 3.01 of Rev. Proc. 2019–3) presented in a transaction described in § 351. The information and representations described in Rev. Proc. 83–59, 1983–2 C.B. 575, should be included in a letter ruling request only to the extent that they relate to the significant issues with respect to which the letter ruling is requested. See section 6.03(4).
355 Checklist questionnaire Rev. Proc. 2017–52, 2017–41 I.R.B. 283, and Rev. Proc. 2018–53, 2018–43 I.R.B. 667. See also section 6.03(2) of this revenue procedure.
368(a)(1)(E) Checklist questionnaire See section 3.01 of Rev. Proc. 2019–3, this Bulletin, which states that the Service will not issue a letter ruling as to whether a transaction constitutes a reorganization, including a recapitalization within the meaning of § 368(a)(1)(E) (or a transaction that qualifies under § 1036). However, the Service will issue a letter ruling addressing significant issues (within the meaning of section 3.01 of Rev. Proc. 2019–3) presented in a transaction described in § 368(a)(1)(E) (or in a transaction described in § 1036). The information and representations described in Rev. Proc. 81–60, 1981–2 C.B. 680, should be included in a letter ruling request only to the extent that they relate to the significant issues. See section 6.03(4).
412, 4971(b) Additional tax (on failure to meet minimum funding standards) Rev. Proc. 81–44, 1981–2 C.B. 618, provides guidance for requesting a waiver of the 100 percent tax imposed under § 4971(b) on a pension plan that fails to meet the minimum funding standards of § 412.
412(c) Minimum funding standards Rev. Proc. 2004–15, 2004–1 C.B. 490, provides guidance for requesting a waiver of the minimum funding standards.
412(c)(7)(B) Minimum funding standards - restrictions on plan amendments Rev. Proc. 79–62, 1979–2 C.B. 576 provides guidance for requesting a determination that a plan amendment is reasonable and provides for only de minimis increases in plan liabilities in accordance with former § 412(f)(2)(A) (now § 412(c)(7)(B)(i)).
412(d)(2) Minimum funding standards - certain retroactive plan amendments Rev. Proc. 94–42, 1994–1 C.B. 717, as modified by Rev. Proc. 2019–4 sets forth procedures under which a plan sponsor may file notice with and obtain approval for a retroactive amendment described in § 412(d)(2) (formerly § 412(c)(8)) and § 302(d)(2) of the Employee Retirement Income Security Act of 1974 (ERISA) that reduces prior accrued benefits.
414(e) Church plans Rev. Proc. 2011–44, 2011–39 I.R.B. 445 provides supplemental procedures for requesting a ruling relating to church plans under section 414(e). This revenue procedure provides that plan participants and other interested persons must receive a notice when a letter ruling is requested and a copy of the notice must be submitted as part of the ruling request. It also provides procedures for the Service to receive and consider comments about the ruling request from interested persons. See Appendix E.
414(r) Qualified separate lines of business – administrative scrutiny Rev. Proc. 93–41, 1993–2 C.B. 536, sets forth procedures relating to the issuance of an administrative scrutiny determination, which is a determination by the Service as to whether a separate line of business satisfies the requirement of administrative scrutiny, within the meaning of § 1.414(r) –6, for the testing year.
461(h) Alternative method for the inclusion of common improvement costs in basis Rev. Proc. 92–29, 1992–1 C.B. 748.
482 Advance pricing agreements Rev. Proc. 2015–40, 2015–35 I.R.B. 236, and Rev. Proc. 2015–41, 2015–35 I.R.B. 263.
521 Appeal procedure with regard to adverse determination letters and revocation or modification of exemption letter rulings and determination letters Rev. Proc. 2019–5, this Bulletin.
817(h) Closing agreement for inadvertent failures of variable contracts Rev. Proc. 2008–41, 2008–2 C.B. 155.
860 Self Determination of Deficiency Dividend Rev. Proc. 2009–28, 2009–20 I.R.B. 1011.
877, 2107, and 2501(a)(3) Individuals who lose U.S. citizenship or cease to be taxed as long-term U.S. residents with a principal purpose to avoid U.S. taxes Notice 97–19, 1997–1 C.B. 394, as modified by Notice 98–34, 1998–2 C.B. 29, and as obsoleted in part by Notice 2005–36, 2005–1 C.B. 1007.
1362(b)(5) and 1362(f) Relief for late S corporation and related elections under certain circumstances Rev. Proc. 2013–30, 2013–36 I.R.B. 173.
1362(b)(5) and 301.7701–3 Automatic extensions of time for late S corporation election and late corporate entity classification Rev. Proc. 2013–30, 2013–36 I.R.B. 173.
1.1502–13(e)(3) Consent to treat intercompany transactions on a separate entity basis and revocation of this consent Rev. Proc. 2009–31, 2009–27 I.R.B. 107.
1.1502–75(b) Consent to Be Included in a Consolidated Income Tax Return Rev. Proc. 2014–24, 2014–13 I.R.B. 879, provides a determination that certain subsidiary corporations are treated as if they had filed a Form 1122, Authorization and Consent of Subsidiary Corporation To Be Included in a Consolidated Income Tax Return, even though they failed to do so. This revenue procedure also informs taxpayers who do not qualify for the automatic determination of the procedure for requesting such determination.
1.1502–76(a)(1) Consent to file a consolidated return where member(s) of the affiliated group use a 52–53 week taxable year Rev. Proc. 89–56, 1989–2 C.B. 643, as modified by Rev. Proc. 2006–21, 2006–1 C.B. 1050.
1504(a)(3)(A) and (B) Waiver of application of § 1504(a)(3)(A) for certain corporations Rev. Proc. 2002–32, 2002–1 C.B. 959, as modified by Rev. Proc. 2006–21, 2006–1 C.B. 1050.
1552 Consent to elect or change method of allocating affiliated group’s consolidated Federal income tax liability Rev. Proc. 90–39, 1990–2 C.B. 365, as clarified by Rev. Proc. 90–39A, 1990–2 C.B. 367, and as modified by Rev. Proc. 2006–21, 2006–1 C.B. 1050.
2642 Allocations of generation-skipping transfer tax exemption Rev. Proc. 2004–46, 2004–2 C.B. 142, provides an alternative method for requesting relief to make a late allocation of the generation-skipping transfer tax exemption. This revenue procedure also informs taxpayers who are denied relief or who are outside the scope of the revenue procedure of the information necessary for obtaining a letter ruling.
2652(a)(3) Reverse qualified terminable interest property elections Rev. Proc. 2004–47, 2004–2, C.B. 169, provides an alternative method for certain taxpayers to obtain an extension of time to make a late reverse qualified terminable interest property election under § 2652(a)(3). This revenue procedure also informs taxpayers who are denied relief or who are outside the scope of the revenue procedure of the information necessary to obtain a letter ruling.
4980B Failure to satisfy continuation coverage requirements of group health plans Rev. Proc. 87–28, 1987–1 C.B. 770 (treating references to former § 162(k) as if they were references to § 4980B).
7701 Relief for a late initial classification election for a newly formed entity Rev. Proc. 2009–41, 2009–39 I.R.B. 439.
7701(a)(40) and 7871(d) Indian tribal governments and subdivision of Indian tribal governments Rev. Proc. 84–37, 1984–1 C.B. 513, as modified by Rev. Proc. 86–17, 1986–1 C.B. 550, and this revenue procedure, (provides guidelines for obtaining letter rulings recognizing Indian tribal government or tribal government subdivision status; also provides for inclusion in list of federally recognized Indian tribes published annually by the Department of the Interior, Bureau of Indian Affairs, or in list of recognized subdivisions of Indian tribal governments in revised versions of Rev. Proc. 84–36, 1984–1 C.B. 510, as modified and made permanent by Rev. Proc. 86–17).
301.7701–2(a) Classification of undivided fractional interests in rental real estate Rev. Proc. 2002–22, 2002–1 C.B. 733 (specifies the conditions under which the Service will consider a letter ruling request that an undivided fractional interest in rental real property (other than a mineral property as defined in § 614) is not an interest in a business entity).
301.7701–3 Automatic extensions of time for late S corporation election and late corporate entity classification Rev. Proc. 2013–30, 2013–36 I.R.B. 173.
301.9100–3 Extension of time to make entity classification election Rev. Proc. 2009–41, 2009–39 I.R.B. 439.
7702 Closing agreement for failure to account for charges for qualified additional benefits Rev. Proc. 2010–26, 2010–30 I.R.B. 91.
7702 Closing agreement for failed life insurance contracts Rev. Proc. 2008–40, 2008–2 C.B. 151.
7702A Closing agreement for inadvertent non-egregious failure to comply with modified endowment contract rules Rev. Proc. 2008–39, 2008–2 C.B. 143.
7704(g) Revocation of election Notice 98–3, 1998–1 C.B. 333.
SUBJECT MATTERS REVENUE PROCEDURE
Accounting periods; changes in period Rev. Proc. 2002–39, 2002–1 C.B. 1046, as clarified and modified by Notice 2002–72, 2002–2 C.B. 843, as modified by Rev. Proc. 2003–34, 2003–1 C.B. 856, and modified by Rev. Proc. 2003–79, 2003–2 C.B. 1036; and this revenue procedure, for which sections 1, 2.01, 2.02, 2.05, 3.03, 5.02, 6.03, 6.05, 6.07, 6.11, 7.01(1), 7.01(2), 7.01(3), 7.01(4), 7.01(5), 7.01(6), 7.01(9), 7.01(10), 7.01(11), 7.01(14), 7.01(15), 7.01(16), 7.02(2), 7.02(4), 7.02(5), 7.02(6), 7.04, 7.05, 7.06, 7.08, 8.01, 8.03, 8.04, 8.05, 8.06, 10, 11, 15, 17, 18, Appendix A, and Appendix G are applicable.
Classification of liquidating trusts Rev. Proc. 82–58, 1982–2 C.B. 847, as modified and amplified by Rev. Proc. 94-45, 1994–2 C.B. 684, and as amplified by Rev. Proc. 91–15, 1991–1 C.B. 484 (checklist questionnaire), as modified and amplified by Rev. Proc. 94–45.
Earnings and profits determinations Rev. Proc. 75–17, 1975–1 C.B. 677; this revenue procedure, sections 2.05, 3.03, 7, 8, and 10.05; and Rev. Proc. 2019–3, this Bulletin, section 3.01.
Estate, gift, and generation-skipping transfer tax issues Rev. Proc. 91–14, 1991–1 C.B. 482 (checklist questionnaire).
Intercompany transactions; election not to defer gain or loss Rev. Proc. 2009–31, 2009–27 I.R.B. 107.
Leveraged leasing Rev. Proc. 2001–28, 2001–1 C.B. 1156, and Rev. Proc. 2001–29, 2001–1 C.B. 1160.
Rate orders; regulatory agency; normalization A letter ruling request that involves a question of whether a rate order that is proposed or issued by a regulatory agency will meet the normalization requirements of § 168(f)(2) (pre-Tax Reform Act of 1986, § 168(e)(3)) and former §§ 46(f) and 167(l) ordinarily will not be considered unless the taxpayer states in the letter ruling request whether—
(1) the regulatory authority responsible for establishing or approving the taxpayer’s rates has reviewed the request and believes that the request is adequate and complete; and
(2) the taxpayer will permit the regulatory authority to participate in any Associate office conference concerning the request.
If the taxpayer or the regulatory authority informs a consumer advocate of the request for a letter ruling and the advocate wishes to communicate with the Service regarding the request, any such communication should be sent to: Internal Revenue Service, Associate Chief Counsel (Procedure and Administration), Attn: CC:PA:LPD:DRU, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044 (or, if a private delivery service is used: Internal Revenue Service, Associate Chief Counsel (Procedure and Administration), Attn: CC:PA:LPD:DRU, Room 5336, 1111 Constitution Ave., NW, Washington, DC 20224). These communications will be treated as third party contacts for purposes of § 6110.
Unfunded deferred compensation Rev. Proc. 71–19, 1971–1 C.B. 698, as amplified by Rev. Proc. 92–65, 1992–2 C.B. 428. See Rev. Proc. 92–64, 1992–2 C.B. 422, as modified by Notice 2000–56, 2000–2 C.B. 393, for the model trust for use in Rabbi Trust Arrangements.
Safe harbor revenue procedures .02 For requests relating to the following Code sections and subject matters, refer to the following safe harbor revenue procedures.
CODE OR REGULATION SECTION REVENUE PROCEDURE
23 and 36C Adoption credit for foreign adoptions Rev. Proc. 2010–31, 2010–40 I.R.B. 413.
103 and 141–150 Issuance of state or local obligations Rev. Proc. 2017–13, 2017–6 I.R.B. 787 (management contracts); and Rev. Proc. 2007–47, 2007–2 C.B. 108 (research agreements).
61 Utility Cost Recovery Securitization Transactions Rev. Proc. 2005–62, 2005–2 C.B. 507.
137 Exclusion for Employer Reimbursements Rev. Proc. 2010–31, 2010–40 I.R.B. 413.
162 Restaurant Small Wares Costs Rev. Proc. 2002–12, 2002–1 C.B. 374.
165 Losses from corrosive drywall Rev. Proc. 2010–36, 2010–42 I.R.B. 439.
165 Theft losses from fraudulent investment arrangements Rev. Proc. 2009–20, 2009–14 I.R.B. 749; Rev. Proc. 2011–58, 2011–50 I.R.B. 849 (modifies Rev. Proc. 2009–20).
167 and 168 Primary use of certain cable network assets described in asset class 48.42 of Rev. Proc. 87–56, 1987–2 C.B. 674 Section 9 of Rev. Proc. 2015–12, 2015–2 I.R.B. 266.
168 Depreciation of original and replacement tires for certain vehicles Rev. Proc. 2002–27, 2002–1 C.B. 802.
168 Depreciation of fiber optic node and trunk line of a cable system operator Section 8 of Rev. Proc. 2015–12, 2015–2 I.R.B. 266.
168 Recovery periods of certain tangible assets used by wireless telecommunication carriers Rev. Proc. 2011–22, 2011–18 I.R.B. 737
263, 471 Treatment of rotable spare parts as inventory or depreciable property Rev. Proc. 2007–48, 2007–2 C.B. 110
263 Safe harbor methods for track structure expenditures Rev. Proc. 2002–65, 2002–2 C.B. 700; Rev. Proc. 2001–46, 2001–2 C.B. 263.
263 Determination whether expenditures to maintain, replace or improve wireline network assets must be capitalized Rev. Proc. 2011–27, 2011–18 I.R.B. 740.
263 Determination whether expenditures to maintain, replace or improve wireless network assets must be capitalized Rev. Proc. 2011–28, 2011–18 I.R.B. 743.
263 Allocating success-based fees paid in business acquisitions or reorganizations Rev. Proc. 2011–29, 2011–18 I.R.B. 746.
263 Electric trade and distribution property assets Rev. Proc. 2011–43, 2011–37 I.R.B. 326.
263A Safe harbor methods for certain motor vehicle dealerships Rev. Proc. 2010–44, 2010–49 I.R.B. 811.
280A Safe harbor method to determine the amount of deductible expenses attributable to certain business use of a residence Rev. Proc. 2013–13, 2013–6 I.R.B. 478.
280B Certain structural modifications to a building not treated as a demolition Rev. Proc. 95–27, 1995–1 C.B. 704.
446 Film producer’s treatment of certain creative property costs Rev. Proc. 2004–36, 2004–1 C.B. 1063.
446 Bank’s treatment of uncollected interest Rev. Proc. 2007–33, 2007–1 C.B. 1289.
448 Nonaccrual-experience method - book safe harbor method Rev. Proc. 2011–46, 2011–42 I.R.B. 518.
451 Safe harbor for capital cost reduction payments Rev. Proc. 2002–36, 2002–1 C.B. 993
451 Treatment of gift cards issued to customers in exchange for returned merchandise Rev. Proc. 2011–17, 2011–5 I.R.B. 441.
451 Safe harbor for certain minors’ trusts established under the Indian Gaming Regulatory Act (U.S.C. §§ 2701–2721) Rev. Proc. 2011–56, 2011–49 I.R.B. 834.
461 Safe harbor method for payroll tax liabilities for compensation Rev. Proc. 2008–25, 2008–1 C.B. 686.
471 Estimating inventory shrinkage Rev. Proc. 98–29, 1998–1 C.B. 857.
471 Valuation of automobile dealer vehicle parts inventory Rev. Proc. 2002–17, 2002–1 C.B. 676.
471 Valuation of remanufactured cores Rev. Proc. 2003–20, 2003–1 C.B. 445.
471 Valuation of heavy equipment dealer parts inventory Rev. Proc. 2006–14, 2006–1 C.B. 350.
471 Rolling-average method of accounting for inventories Rev. Proc. 2008–43, 2008–2 C.B. 186.
475 Eligible positions Rev. Proc. 2007–41, 2007–1 C.B. 1492.
584(a) Qualification of a proposed common trust fund plan Rev. Proc. 92–51, 1992–1 C.B. 988.
642(c)(5) Qualification of trusts as pooled income funds Rev. Proc. 88–53, 1988–2 C.B. 712.
664 Charitable remainder trusts Rev. Proc. 2005–24, 2005–1 C.B. 909, as modified by Notice 2006–15, 2006–1 C.B. 501.
664(d)(1) Qualification of trusts as charitable remainder annuity trusts Rev. Proc. 2003–53, 2003–2 C.B. 230; Rev. Proc. 2003–54, 2003–2 C.B. 236; Rev. Proc. 2003–55, 2003–2 C.B. 242; Rev. Proc. 2003–56, 2003–2 C.B. 249; Rev. Proc. 2003–57, 2003–2 C.B. 257; Rev. Proc. 2003–58, 2003–2 C.B. 262; Rev. Proc. 2003–59, 2003–2 C.B. 268; Rev. Proc. 2003–60, 2003–2 C.B. 274.
664(d)(2) and (3) Qualification of trusts as charitable remainder unitrusts Rev. Proc. 2005–52, 2005–2 C.B. 326; Rev. Proc. 2005–53, 2005–2 C.B. 339; Rev. Proc. 2005–54, 2005–2 C.B. 353; Rev. Proc. 2005–55, 2005–2 C.B. 367; Rev. Proc. 2005–56, 2005–2 C.B. 383; Rev. Proc. 2005–57, 2005–2 C.B. 392; Rev. Proc. 2005–58, 2005–2 C.B. 402; Rev. Proc. 2005–59, 2005–2 C.B. 412.
832 Insurance company premium acquisition expenses Rev. Proc. 2002–46, 2002–2 C.B. 105.
856(c) Certain loans treated as real estate assets Rev. Proc. 2003–65, 2003–2 C.B. 336.
1031(a) Qualification as a qualified exchange accommodation arrangement Rev. Proc. 2000–37, 2000–2 C.B. 308, as modified by Rev. Proc. 2004–51, 2004–2 C.B. 294.
1031 Safe harbor with respect to exchanges of residential real property Rev. Proc. 2008–16, 2008–1 C.B. 547.
1031 Safe harbor for reporting gain or loss on failed exchanges Rev. Proc. 2010–14, 2010–12 I.R.B. 456.
1272(a)(6) Proportional method of accounting for original issue discount on pools of credit card receivables Rev. Proc. 2013–26, 2013–22 I.R.B. 1160.
1286 Determination of reasonable compensation under mortgage servicing contracts Rev. Proc. 91–50, 1991–2 C.B. 778.
1362(f) Automatic inadvertent termination relief to certain corporations Rev. Proc. 2013–30, 2013–36 I.R.B. 173.
2056A Qualified Domestic Trust Rev. Proc. 96–54, 1996–2 C.B. 386.
2702(a)(3)(A) and 25.2702–5(c) Qualified Personal Residence Trust Rev. Proc. 2003–42, 2003–1 C.B. 993.
4051(a)(2) Imposition of tax on heavy trucks and trailers sold at retail Rev. Proc. 2005–19, 2005–1 C.B. 832.
1.7704–2(d) New business activity of existing partnership is closely related to pre-existing business Rev. Proc. 92–101, 1992–2 C.B. 579.
Certain rent-to-own contracts treated as leases Rev. Proc. 95–38, 1995–2 C.B. 397.
Automatic change in accounting period revenue procedures
.03 For requests for an automatic change in accounting period, refer to the following automatic change revenue procedures.
Rev. Proc. 2006–45, 2006–2 C.B. 851, as clarified and modified by Rev. Proc. 2007–64, 2007–2 C.B. 818 (certain corporations); Rev. Proc. 2006–46, 2006–2 C.B. 859 (certain partnerships, subchapter S corporations, personal service corporations, and trusts); and Rev. Proc. 2003–62, 2003–2 C.B. 299 (individuals seeking a calendar year);
The Commissioner’s consent to an otherwise qualifying automatic change in accounting period is granted only if the taxpayer timely complies with the applicable automatic change revenue procedure.
SECTION 1. PURPOSE AND AUTHORITY 108
.01 Description of purpose 108
.02 Updated annually 108
SECTION 2. DEFINITIONS 108
.01 Operating division 108
.02 Director 108
.03 Appeals officer 109
.04 Taxpayer 109
.05 Associate office 109
.06 Field office 109
.07 Field counsel 109
SECTION 3. THE NATURE OF TECHNICAL ADVICE 109
.01 When advice furnished 109
.02 TAM may be requested even if previous TAM on same matter was issued 109
.03 Taxpayer participation 109
.04 Areas of mandatory technical advice on employee plans matters 110
.05 Basis for requests by Exempt Organizations Rulings & Agreements 110
SECTION 4. TYPES OF ISSUES NOT SUBJECT TO THIS PROCEDURE 110
.01 Alcohol, tobacco, and firearms taxes 110
.02 Employment status determinations 110
.03 Issues under § 301.9100 110
.04 Frivolous issues 110
.05 Issues in a docketed case 110
.06 Collection issues 111
.07 Request for relief under § 7805(b) relating to matters handled by TE/GE 111
SECTION 5. INITIATING A REQUEST FOR TECHNICAL ADVICE 111
.01 Initiating a request for technical advice 111
.02 Taxpayer may request referral for technical advice 111
.03 Appeal of field office denial of TAM referral request 111
.04 The decision of the Director, the LB&I Territory Manager, or the Tax Exempt Bonds Manager, Field Operations may be reviewed but not appealed 112
SECTION 6. PRE-SUBMISSION CONFERENCES 112
.01 Purpose 112
.02 Pre-submission conferences are mandatory 112
.03 Actions before a pre-submission conference 112
.04 Initiating a pre-submission conference 113
.05 Manner of transmitting pre-submission materials 113
.06 Scheduling the pre-submission conference 113
.07 Pre-submission conferences may be conducted in person 114
.08 Pre-submission conference may not be taped 114
.09 Discussion of substantive issues is not binding on the Service 114
.10 New issues may be raised at pre-submission conference 114
.11 Power of attorney 114
SECTION 7. SUBMITTING THE REQUEST FOR TECHNICAL ADVICE 114
.01 Memorandum of issues, facts, law, and arguments 114
.02 Transaction involving multiple taxpayers 115
.03 Foreign laws and documents: submission of relevant foreign laws and documents in the official language and in English 115
.04 Statement regarding interpretation of relevant income tax or estate tax treaty 115
.05 Statement recommending information to be deleted from public inspection 116
.06 Preparation of the memorandum; resolution of disagreements 116
.07 Transmittal Form 4463, Request for Technical Advice 117
.08 All supporting and additional documents 117
.09 Number of copies of request to be submitted 118
SECTION 8. INITIAL PROCESSING OF THE REQUEST FOR TECHNICAL ADVICE BY THE ASSOCIATE OFFICE 118
.01 Assignment and initial review by Associate office attorney 118
.02 Other forms of guidance 118
.03 Initial acknowledgment and processing 118
.04 Deficiencies in request leading to return 118
.05 Initial discussion 119
.06 If additional information requested 119
.07 Taxpayer request for extension of time to submit additional information 119
.08 Where to send additional information 119
.09 Tentative conclusions 119
SECTION 9. TAXPAYER CONFERENCES 120
.01 Notification of conference 120
.02 Scheduling conference 120
.03 Taxpayer may request extensions 120
.04 One conference of right 120
.05 Additional conferences may be offered 120
.06 Additional information submitted after the conference 121
.07 Normally conducted in person 121
.08 Service makes only tentative recommendations 121
.09 Conference may not be taped 121
SECTION 10. PREPARATION OF THE TECHNICAL ADVICE 121
.01 Reply consists of two parts 121
.02 Status of a request 122
.03 Opportunity for field counsel review 122
.04 Copy of preliminary TAM to field office and field counsel 122
.05 Routing of reply 122
.06 Copy of final TAM to field counsel and Division Counsel 122
.07 Reconsideration 122
.08 Discussing contents with the taxpayer 122
.09 Section 6110 122
.10 TAM takes effect when taxpayer receives a copy 123
.11 Taxpayer may protest deletions not made 123
.12 Public inspection in civil fraud or criminal investigation cases 123
SECTION 11. WITHDRAWAL OF REQUESTS FOR TECHNICAL ADVICE 123
.01 Taxpayer notified 123
.02 Acknowledgment of withdrawal 124
.03 Associate office may decide not to provide a TAM 124
.04 Associate office may provide views 124
SECTION 12. USE OF THE TECHNICAL ADVICE 124
.01 Service generally applies advice in processing taxpayer’s case 124
SECTION 13. RETROACTIVITY AND RELIANCE 124
.01 Usually applies retroactively 124
.02 Revocation or modification of an earlier letter ruling or TAM 124
.03 Continuing action or series of actions 125
.04 Other taxpayers 125
SECTION 14. HOW MAY RETROACTIVE EFFECT BE LIMITED? 125
.01 Request for relief under § 7805(b) 125
.02 Form of request for relief—in general 125
.03 Form of request for relief—continuing transaction before examination of return 126
.04 Taxpayer’s right to a conference 126
.05 Reconsideration of request for relief under § 7805(b) 126
SECTION 15. SIGNIFICANT CHANGES MADE TO REV. PROC. 2018–2 126
SECTION 16. EFFECT ON OTHER DOCUMENTS 126
SECTION 17. EFFECTIVE DATE 126
DRAFTING INFORMATION 126
SECTION 1. PURPOSE AND AUTHORITY
Description of purpose
.01 Technical advice. This revenue procedure explains when and how an Associate office provides technical advice, conveyed in a technical advice memorandum (TAM). It also explains the rights that a taxpayer has when a field office requests a TAM regarding a tax matter. Rev. Proc. 2018–2 is superseded.
.02 This revenue procedure is updated annually as the second revenue procedure of the year, but it may be modified, amplified, or clarified during the year.
SECTION 2. DEFINITIONS
Operating division
.01 The term “operating division” means (1) the Large Business & International Division (LB&I); (2) the Small Business/Self-Employed Division (SB/SE); (3) the Wage and Investment Division (W&I); and (4) the Tax Exempt and Government Entities Division (TE/GE).
.02 The term “Director” means (1) the Director, Field Operations (LB&I) for the taxpayer’s practice area; (2) a Territory Manager, Field Compliance (SB/SE); (3) the Director, Return Integrity & Compliance Services (W&I); (4) the Director, International Compliance, Strategy and Policy; (5) the Director, Employee Plans Examinations; (6) the Director, Employee Plans Rulings & Agreements; (7) the Director, Exempt Organizations Examinations; (8) the Director, Exempt Organizations Rulings & Agreements; (9) the Director, Indian Tribal Governments and Tax Exempt Bonds; (10) the Appeals Area Director; (11) the Appeals Director, Technical Guidance; (12) the Appeals Director, International Operations; or (13) any official to whom the authority normally exercised by a Director has properly been delegated.
Appeals officer
.03 The term “Appeals officer” means the Appeals officer assigned to the taxpayer’s case and can include an Appeals Team Case Leader or settlement officer.
.04 The term “taxpayer” means any person subject to any provision of the Internal Revenue Code, including an issuer of obligations the interest on which is excluded from gross income under § 103, and issuers of other bonds that provide a tax subsidy.
Associate office
.05 The term “Associate office” means (1) the Office of Associate Chief Counsel (Corporate); (2) the Office of Associate Chief Counsel (Financial Institutions and Products); (3) the Office of Associate Chief Counsel (Income Tax and Accounting); (4) the Office of Associate Chief Counsel (International); (5) the Office of Associate Chief Counsel (Passthroughs and Special Industries); (6) the Office of Associate Chief Counsel (Procedure and Administration); or (7) the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).
.06 The term “field office” means personnel in any examination or Appeals office. For qualified retirement plan and exempt organizations matters, the term “field office” also means personnel in any Rulings & Agreements office.
Field counsel
.07 The term “field counsel” means any attorney assigned to the Division Counsel for an operating division who is not a member of Division Counsel Headquarters.
SECTION 3. THE NATURE OF TECHNICAL ADVICE
When advice furnished
.01 Technical advice is advice furnished by an Associate office in a memorandum that responds to any request, submitted under this revenue procedure, for assistance on any technical or procedural question that develops during any proceeding before the Internal Revenue Service (Service). The field office may request a TAM when the application of the law to the facts involved is unclear. The question must be on the interpretation and proper application of any legal authority, including legislation, tax treaties, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements to a specific set of facts that concerns the treatment of an item in a tax period under examination or in Appeals. A TAM may not be requested for prospective or hypothetical transactions (except for certain TAMs in connection with a taxpayer’s request for a determination letter on a matter within the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, pursuant to Rev. Proc. 2019–4 or 2019–5). Proceedings before the Service include: (1) the examination of a taxpayer’s return; (2) the consideration of a taxpayer’s claim for credit or refund; (3) any matter under examination or in Appeals pertaining to tax-exempt bonds, tax credit bonds, or mortgage credit certificates; and (4) any other matter involving a specific taxpayer under the jurisdiction of a Director. Technical advice does not include any oral legal advice or any written legal advice furnished to the field office that is not submitted and processed under this revenue procedure.
TAM may be requested even if previous TAM on same matter was issued
.02 The field office may request a TAM on an issue in any tax period, even if a TAM was requested and furnished for the same or similar issue for another tax period. The field office may also request a TAM on an issue even if Appeals disposed of the same or similar issue for another tax period of the same taxpayer.
Taxpayer participation
.03 Taxpayers will be afforded an opportunity to participate in the technical advice process. Taxpayer participation is preferred but not required in order to process a TAM. A taxpayer’s failure to participate in stages identified as “material,” however, will constitute waiver of the taxpayer’s right to the taxpayer conference described in section 9.
Under no circumstances will a taxpayer be treated as having waived its right to see the issued TAM or having waived its rights regarding disclosure and deletions described in section 10.
Areas of mandatory technical advice on employee plans matters
.04 Regarding qualified retirement plan matters, a request for a TAM is required in cases concerning plans for which the Service is proposing to issue a revocation letter because of certain fiduciary actions that violate the exclusive benefit rule of § 401(a) of the Code and are subject to Part 4 of Subtitle B of Title I of the Employee Retirement Income Security Act of 1974, Pub. L. No. 93–406, 1974–3 C.B. 1, 43 as amended (ERISA).
Basis for requests by Exempt Organizations Rulings & Agreements
.05 The circumstances in which Exempt Organizations Determinations should seek technical advice in the course of processing applications for tax exemption are described in Rev. Proc. 2019–5, this Bulletin, section 3.03. Technical advice may also be requested by Exempt Organizations Determinations in connection with requests for determination letters where no pending application for tax exemption is involved. A request for a TAM is not required if the Director, Exempt Organizations Examinations proposes to revoke or modify a letter recognizing tax-exempt status issued by the Service.
SECTION 4. TYPES OF ISSUES NOT SUBJECT TO THIS PROCEDURE
Alcohol, tobacco, and firearms taxes
.01 The procedures for obtaining technical advice that apply to Federal alcohol, tobacco, and firearms taxes under subtitle E of the Code are under the jurisdiction of the Alcohol and Tobacco Tax and Trade Bureau of the Department of the Treasury.
Employment status determinations
.02 Employment status determination letters issued pursuant to section 12.04 of Rev. Proc. 2019–1, of this Bulletin, are not subject to technical advice procedures.
Issues under § 301.9100
.03 A request for an extension of time for making an election or other application for relief under § 301.9100–3 of the Procedure and Administration Regulations is not submitted as a request for technical advice. Instead, the request must be submitted as a request for a letter ruling, even if submitted after the examination of the taxpayer’s return has begun or after the issues in the return are being considered in Appeals or a federal court. Therefore, a request under § 301.9100 should be submitted under Rev. Proc. 2019–1, of this Bulletin, and the payment of the applicable user fee is determined under Appendix A of Rev. Proc. 2019–1. However, a request under § 301.9100 related to recharacterization of a Roth IRA should be submitted under Rev. Proc. 2019–4 of this Bulletin. Requests for relief pertaining to exemption application matters involving §§ 505(c) and 508 are considered in the determination letter process under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. See Revenue Procedure 2019–5, this Bulletin.
Frivolous issues
.04 Associate offices will not issue a TAM on frivolous issues. The field office will deny a taxpayer’s request that it consider requesting technical advice if the taxpayer’s request involves frivolous issues. For purposes of this revenue procedure, a “frivolous issue” is one without basis in fact or law or one that asserts a position that courts have held frivolous or groundless. Examples of frivolous or groundless issues may be found in Service publications and other guidance (including, but not limited to, section 6.10 of Rev. Proc. 2019–1, Notice 2010–33, and Exhibit 25.25.10–1, Frivolous Arguments).
Issues in a docketed case
.05 Associate offices will not issue technical advice on an issue if the same issue of the same taxpayer (or of a related taxpayer within the meaning of § 267 or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504) is in a docketed case for any taxable year. If a case is docketed for an estate tax issue of a taxpayer while a request for technical advice on the same issue of the same taxpayer is pending, the Associate office may issue the TAM only if the appropriate Appeals officer and field counsel agree, by memorandum, to the issuance of the TAM.
Collection issues
.06 The Associate Chief Counsel (Procedure and Administration) will not issue technical advice on matters arising under the Internal Revenue Code and related statutes and regulations that involve the collection of taxes (including interest and penalties). With respect to such matters, the Associate Chief Counsel (Procedure and Administration) may issue alternative forms of advice.
Request for relief under § 7805(b) relating to matters handled by TE/GE
.07 Requests for relief under § 7805(b) relating to the revocation or modification of determination letters or letter rulings issued by TE/GE are handled in accordance with the procedures in sections 23 and 29 of Rev. Proc. 2019–4, and section 12 of Rev. Proc. 2019–5, this Bulletin.
SECTION 5. INITIATING A REQUEST FOR TECHNICAL ADVICE
Initiating a request for technical advice
.01 Because technical advice is issued to assist field offices, it is the field office that determines whether to request it. In determining whether to request technical advice, the field office should consider whether other forms of guidance, e.g., published guidance, generic advice, or some other form of advice, would be more appropriate. Additionally, before requesting technical advice, the field office must request assistance and a recommendation from field counsel. If the field office disagrees with field counsel’s recommendation, the field office must seek reconciliation with field counsel through their respective supervisors. A field office’s request for technical advice must be approved in writing by a Director. If technical advice is requested from the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) for a case with either an unagreed prohibited transaction, as defined in § 4975(c)(1) and ERISA § 406(a), or a violation of the exclusive benefit rule of § 401(a)(2) or ERISA § 404(a)(1)(A), a Form 6212–B must be submitted to the Department of Labor prior to submitting the request for technical advice.
Taxpayer may request referral for technical advice
.02 While a case is under the jurisdiction of a Director, a taxpayer may request that the field office refer an issue to the Associate office for technical advice. The taxpayer’s request may be oral or written and should be directed to the field office. If the field office decides that a taxpayer’s request for referral of an issue to the Associate office for a TAM is unwarranted, the field office will notify the taxpayer. A taxpayer’s request for referral of an issue for technical advice will not be denied merely because the Associate office has already provided legal advice other than a TAM to the field office on the matter.
Appeal of field office denial of TAM referral request
.03 The taxpayer may appeal the field office’s denial of the taxpayer’s request for referral by submitting to the field office, within 30 calendar days after notification that the request was denied, a written statement of the reasons why the matter should be referred to the Associate office. The statement should include a description of all pertinent facts (including any facts in dispute); a statement of the issue that the taxpayer would like to have addressed; a discussion of any relevant legal authority, including legislation, tax treaties, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements; and an explanation of the taxpayer’s position and the need for technical advice. Any extensions of the 30-day period must be requested in writing and must be approved by the Director, the LB&I Territory Manager, or the Tax Exempt Bonds Manager, Field Operations. Decisions on any extensions by the Director, the LB&I Territory Manager, or in the case of Tax Exempt Bonds, the Manager, Field Operations, are final and may not be appealed.
Upon receipt, the field office will refer the taxpayer’s written statement, along with the field office’s statement of why the issue should not be referred to the Associate office for technical advice, to the Director, the LB&I Territory Manager, or in the case of Tax Exempt Bonds, the Manager, Field Operations, for decision. The Director, the LB&I Territory Manager, or in the case of Tax Exempt Bonds, the Manager, Field Operations, will determine whether the issue should be referred for technical advice on the basis of the statements of the field office and the taxpayer. No conference will be held with the taxpayer or the taxpayer’s representative. If the Director, the LB&I Territory Manager, or in the case of Tax Exempt Bonds, the Manager, Field Operations, determines that a TAM is not warranted, the taxpayer will be informed in writing of the proposed denial of the request and the reasons for the denial (unless doing so would prejudice the Government’s interests).
The decision of the Director, the LB&I Territory Manager, or the Tax Exempt Bonds Manager, Field Operations may be reviewed but not appealed
.04 The taxpayer may not appeal the decision of the Director, the LB&I Territory Manager, or in the case of Tax Exempt Bonds, the Manager, Field Operations, not to request a TAM. If the taxpayer does not agree with the proposed denial, all data on the issue for which a TAM has been sought, including the taxpayer’s written request and statements, will be submitted for review to the Director, LB&I; the Director, Examination, SB/SE; the Director, Specialty Tax, SB/SE; the Director, Return Integrity & Compliance Services, W&I; the Director, Indian Tribal Governments and Tax Exempt Bonds; the Appeals Director, Policy Planning Quality & Analysis; or the Commissioner, Tax Exempt and Government Entities Division (who will review the proposed denial through the Director, Employee Plans; the Director, Exempt Organizations; or, if appropriate, the Appeals Director, Policy Planning Quality & Analysis). Review of the proposed denial will be based solely on the written record. No conference will be held with the taxpayer or the taxpayer’s representative. The person responsible for review may consult with the Associate office, if appropriate, and will notify the field office whether the proposed denial of the taxpayer’s request is approved or denied within 45 days of receiving all information. The field office will then notify the taxpayer. While the matter is under review, the field office will suspend any final decision on the issue (except when the delay would prejudice the Government’s interests). If the request for technical advice has been denied because the issue is frivolous as described in section 4.04 of this revenue procedure, this review process is not available.
SECTION 6. PRE-SUBMISSION CONFERENCES
.01 A pre-submission conference helps the field office, field counsel, the taxpayer, and the Associate office agree on the appropriate scope of the request for technical advice and the factual information and documents that must be included in the request. A pre-submission conference is not an alternative procedure for addressing the merits of the substantive positions advanced by the field office or by the taxpayer. During the pre-submission conference, the parties should discuss the framing of the issues and the background information and documents that should be included in the formal submission of the request for technical advice.
Pre-submission conferences are mandatory
.02 Pre-submission conferences are mandatory because they promote expeditious processing of requests for technical advice. If a request for technical advice is submitted without first holding a pre-submission conference, the Associate office will return the request for advice. Pre-submission conferences include the taxpayer and representatives from the field office, field counsel, and the Associate office. Requests for technical advice can proceed, however, even if a taxpayer declines to participate in a pre-submission conference.
Actions before a pre-submission conference
.03 Before requesting a pre-submission conference, the field office and the taxpayer must exchange proposed statements of the pertinent facts and issues. The proposed statements should include any facts in dispute, the issues that the parties intend to discuss, any legal analysis and supporting authorities, and any other background information that the parties believe would facilitate the Associate office’s understanding of the issues to be discussed during the conference. Prior to the scheduled pre-submission conference, the field office and the taxpayer must submit to the Associate office their respective statements of pertinent facts and issues. The legal analysis provided in the parties’ statements should be sufficient to enable the Associate office to be reasonably informed about the subject matter. Failure of the taxpayer to provide a statement of pertinent issues and facts shall not be allowed to unduly delay the scheduling of the pre-submission conference. If it is not provided within a reasonable period of time, the conference may be scheduled without the taxpayer’s statements.
The field office or the taxpayer must ensure that the Associate office receives a copy of any required power of attorney. Form 2848, Power of Attorney and Declaration of Representative, should be used.
Pre-submission materials include the field office and taxpayer’s statements (discussed above) and any required power of attorney for the taxpayer. The assigned Associate office must receive the pre-submission materials at least 10 business days before the conference is to be held.
Initiating a pre-submission conference
.04 A request for a pre-submission conference must be submitted in writing by the field office, with the assistance of field counsel. The request should identify the Associate office expected to have jurisdiction over the request for a TAM and should include a brief explanation of the primary issue so that an assignment within the appropriate Associate office can be made. If the request is submitted by Appeals, field counsel assignments will be subject to the ex parte rules set forth in section 1001(a)(4) of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, and Rev. Proc. 2012–18, 2012–10 I.R.B. 455. If the request involves an issue under the office of the Director, Abusive Transactions Examination, SB/SE, the field office and field counsel should coordinate with SB/SE Division Counsel headquarters. If the request involves an issue under the Office of Tax Shelter Analysis (OTSA), LB&I, then the field office and field counsel should coordinate with LB&I Division Counsel headquarters. If the request is from Appeals and involves a coordinated issue or emerging issue under Appeals Technical Guidance or International Operations or Appeals Coordinated Issue (ACI) Program, the Appeals officer must coordinate with the Appeals Technical Guidance or International Operations Technical Specialist.
Manner of transmitting pre-submission materials
.05 The request for a pre-submission conference and pre-submission materials should be electronically transmitted by field counsel to the Technical Services Support Branch (TSS4510). TSS4510 will ensure delivery of the pre-submission materials to the appropriate Associate office. The TSS4510 email box cannot accept encrypted mail.
If documents are not electronically available, or if documents cannot reasonably be transmitted electronically, the request for a pre-submission conference and pre-submission materials may be sent by fax to TSS4510 at 855-592-8976 or by express mail or private delivery service to the following address to avoid any delays in regular mail:
Attn: CC:PA:LPD:TSS, Room 5336
1111 Constitution Avenue, NW
Scheduling the pre-submission conference
.06 After the pre-submission materials have been received, the Associate office responsible for conducting the pre-submission conference will contact the taxpayer, the field office, and field counsel to arrange a mutually convenient time for the parties to participate in the conference. The conference generally should be held within 15, but not more than 30, calendar days after the field office is contacted.
Pre-submission conferences may be conducted in person
.07 Although pre-submission conferences are generally conducted by telephone, the parties may choose to conduct the conference in person.
Pre-submission conference may not be taped
.08 No tape, stenographic, or other verbatim recording of a conference may be made by any party.
Discussion of substantive issues is not binding on the Service
.09 Any discussion of substantive issues at a pre-submission conference is advisory only, is not binding on the Service in general or on the Office of Chief Counsel in particular, and cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
New issues may be raised at pre-submission conference
.10 During the pre-submission conference, the Associate office may raise new issues in addition to those submitted by the field office and the taxpayer.
.11 Form 2848, Power of Attorney and Declaration of Representative, should be used to provide the representative’s authority (Part I of Form 2848, Power of Attorney) and the representative’s qualification (Part II of Form 2848, Declaration of Representative). The name of the person signing Part I of Form 2848 should also be typed or printed on this form. A stamped or electronic signature is not permitted. An original, a copy, or fax of the power of attorney is acceptable so long as its authenticity is not reasonably disputed.
The taxpayer’s authorized representative, as described in section 7.01(13) of Rev. Proc. 2019–1, whether or not enrolled, must comply with Treasury Department Circular No. 230, which provides the rules for practice before the Service. In situations where the Service believes that the taxpayer’s representative is not in compliance with Circular 230, the Service will bring the matter to the attention of the Office of Professional Responsibility.
SECTION 7. SUBMITTING THE REQUEST FOR TECHNICAL ADVICE
Memorandum of issues, facts, law, and arguments
.01 The field office submits the request for technical advice. Every request for technical advice must include a memorandum that describes the facts, issues, applicable law, and arguments supporting the taxpayer’s position on the issues and the field office’s position on the issues. The field office will prepare this statement with the assistance of field counsel. The memorandum must include a statement of all the facts and the issues. If the taxpayer and the field office disagree about ultimate findings of fact or about the relevance of facts, all of the facts should be included with an explanation that highlights the areas of disagreement. The memorandum must include an explanation of the taxpayer’s position, discussing any relevant legal authority, including legislation, tax treaties, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements supporting the taxpayer’s position. The memorandum must also include a similar explanation of the field office’s position. Both the field office and the taxpayer should comment on any relevant legal authority contrary to their respective positions. If either party determines that there are no authorities contrary to its position, that statement should be noted in the memorandum.
When the field office initiates a request for technical advice, the field office should notify the taxpayer that it is requesting technical advice and provide the taxpayer with a copy of the arguments supporting the field office’s position. The taxpayer has 10 calendar days to state, in writing, any factual disagreement. The field office will make every effort to reach agreement on the facts and specific points at issue. The taxpayer is encouraged to submit a written statement with an explanation of the taxpayer’s position, including a discussion of any relevant legal authority.
Transaction involving multiple taxpayers
.02 If the subject matter of the request involves a transaction among multiple taxpayers, the field office may submit a request for a single TAM, but only if each taxpayer agrees to participate in the process, including the furnishing of Forms 8821, Tax Information Authorization, or other written disclosure consent, as appropriate.
Foreign laws and documents: submission of relevant foreign laws and documents in the official language and in English
.03 If applicable, the request for technical advice must include a copy of the relevant parts of all foreign laws, including statutes, regulations, administrative pronouncements, and any other relevant legal authority. The documents submitted must be in the official language of the country involved and must be copied from an official publication of the foreign government or another widely available and generally accepted publication. If English is not the official language of the country involved, the submission must also include a copy of an English language version of the relevant parts of all foreign laws. This translation must be: (i) from an official publication of the foreign government or another widely available, generally accepted publication; or (ii) a certified English translation submitted in accordance with paragraph (2) of this section 7.03. The taxpayer or the field office must identify the title and date of publication, including updates, of any widely available and generally accepted publication used as a source for the relevant parts of the foreign law. The taxpayer and the field office must inform the Associate office of the implications of any authority believed to interpret the foreign law, such as pending legislation, treaties, court decisions, notices, and administrative decisions.
(1) If the interpretation of a foreign law or foreign document is a material component of the request for technical advice, the Associate office, at its discretion, may refuse to provide a TAM. The interpretation of a foreign law or foreign document means making a judgment about the import or effect of the foreign law or document that goes beyond its plain meaning. This section applies whether or not the field office and the taxpayer dispute the interpretation of a foreign law or foreign document.
(2) If applicable, a request for technical advice must include an accurate and complete certified English translation of the relevant parts of all contracts, wills, deeds, agreements, instruments, trust documents, proposed disclaimers, and other documents pertinent to the request that are in a language other than English. If the taxpayer or the field office chooses to submit certified English translations of foreign laws, those translations must be based on an official publication of the foreign government or another widely available and generally accepted publication. In either case, the translation must be that of a qualified translator and must be attested to by the translator. The attestation must contain: (i) a statement that the translation submitted is a true and accurate translation of the foreign language document or law; (ii) a statement as to the attestant’s qualifications as a translator and as to that attestant’s qualifications and knowledge regarding tax matters or foreign law if the law is not a tax law; and (iii) the attestant’s name and address.
Statement regarding interpretation of relevant income tax or estate tax treaty
.04 A request for technical advice involving the interpretation of a substantive provision of a relevant income tax or estate tax treaty must include a written statement addressing whether: (1) the tax authority of the treaty jurisdiction has issued a ruling on the same or similar issue for the taxpayer, a related taxpayer (within the meaning of § 267 or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504 (related taxpayer)), or any predecessor; (2) the same or similar issue for the taxpayer, a related taxpayer, or any predecessor, is being examined, or has been settled, by the tax authority of the treaty jurisdiction or is otherwise the subject of a closing agreement in that jurisdiction; and (3) the same or similar issue for the taxpayer, a related taxpayer, or any predecessor, is being considered by the competent authority of the treaty jurisdiction.
Statement recommending information to be deleted from public inspection
.05 Except as provided below, every request for technical advice must separately include a statement of proposed deletions from public inspection (deletion statement). The text of TAMs and background file documents are open to public inspection under § 6110(a). The Service deletes certain information from the text before it is made available to the public in order to protect the privacy of taxpayers. To help the Service make the necessary deletions, the taxpayer must provide a deletion statement indicating the deletions desired. A taxpayer who wants only names, addresses, and identifying numbers deleted should state this in the deletion statement. A taxpayer who wants more information deleted must provide a copy of the TAM request and supporting documents on which the taxpayer has placed brackets around the material to be deleted plus a deletion statement indicating the statutory basis under § 6110(c) for each proposed deletion. The deletion statement is not to be included in the memorandum described in section 7.01 of this revenue procedure. Instead, the deletion statement is to be made in a separate document that is signed and dated by the taxpayer or the taxpayer’s authorized representative. A stamped signature or faxed signature is not permitted. If the deletion statement is not submitted, the taxpayer will be notified and advised by the field office that the deletion statement is required and that failure to provide a deletion statement will be interpreted by the field office, field counsel, and Associate office to mean that the taxpayer only wants names, addresses, and identifying numbers deleted. If the deletion statement is not received within 10 calendar days after the notification, the field office will notify the Associate office that the taxpayer has not provided a deletion statement and will advise the Associate office of any information in addition to names, addresses, and identifying numbers, that should be deleted pursuant to § 6110(c). The taxpayer should follow this same process to propose deletions from any additional information submitted after the initial request for a TAM. An additional deletion statement is not required with each submission of additional information if the taxpayer’s initial deletion statement requests that only names, addresses, and identifying numbers are to be deleted and the taxpayer wants only the same information deleted from the additional information. The above deletion statement requirements do not apply to the extent that the TAM is open to public inspection under § 6104. Section 6104(a)(1)(A) generally provides that if an organization described in § 501(c) or § 501(d) is exempt from taxation under § 501(a) or a political organization is exempt from taxation under § 527, the application for exemption under § 501(a) that the organization filed or the notice of status filed by a political organization pursuant to § 527(i) is open for public inspection as prescribed by regulations. Generally, § 6104(a)(1)(B) provides that: (1) an application filed with respect to the qualification of a pension, profit-sharing, or stock bonus plan under § 401(a) or § 403(a) or an individual retirement arrangement under § 408(a) or § 408(b) will be open to public inspection pursuant to regulations, as will (2) any application filed for an exemption from tax under § 501(a) of an organization forming part of a plan or account described above, (3) any papers submitted in support of an application referred to in (1) or (2) above, and (4) any letter or other document issued by the Internal Revenue Service and dealing with the qualification referred to in (1) or the exemption from tax referred to in (2).
Preparation of the memorandum; resolution of disagreements
.06 The field office prepares the memorandum described in section 7.01 of this revenue procedure with the assistance of field counsel and sends it to the taxpayer by mail or fax transmission. The taxpayer then will have 10 calendar days from the date of mailing or fax transmission to respond by providing a written statement specifying any disagreement on the facts and issues. A taxpayer who needs more than 10 calendar days must submit a written request for an extension of time, subject to the approval of the field office. The field office will make a determination on the request for extension as soon as reasonably possible. The request for extension will be considered denied unless the field office informs the taxpayer otherwise. The decision of the field office on whether to approve an extension, and the length of any extension granted, is final and may not be appealed. After the taxpayer’s response is received by the field office, the parties will have 10 calendar days to resolve remaining disagreements. If all disagreements about the statement of facts and issues are resolved, then the field office will prepare a single statement of those agreed facts and issues.
If disagreements continue, both the taxpayer’s set of facts and issues and the field’s set of facts and issues will be forwarded to the Associate office. The field office, with the assistance of field counsel, will prepare a memorandum for the Associate office highlighting the material factual differences, and provide a copy to the taxpayer for review. The taxpayer may respond in writing to the memorandum highlighting material factual differences. The field office may revise the memorandum described in section 7.01 of this revenue procedure in response to the taxpayer’s comments. This memorandum will be forwarded with the initial request for technical advice.
The taxpayer’s statement of facts and issues must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request for technical advice, and such facts are true, correct, and complete.” This declaration must be signed in accordance with the requirements in section 7.01(15)(b) of Rev. Proc. 2019–1. The field office must submit this declaration with the initial request for technical advice. If no agreement regarding the facts is reached, the Associate office may rely on the facts presented by the field office.
The field office will offer the taxpayer an opportunity to participate in the development of the request for technical advice. If the taxpayer participates in the process, the field office will continue to offer the taxpayer the opportunity to participate. If the taxpayer does not participate in a material stage of the process after being offered an opportunity, the Associate office will nonetheless process the request, and the taxpayer will have waived the right to participate in the development and issuance of the TAM, including the right to the taxpayer conference described in section 9. A taxpayer’s failure to participate in the development of the memorandum described in section 7.01 of this revenue procedure will be considered a failure to participate in a material stage of the TAM process.
Transmittal Form 4463, Request for Technical Advice
.07 The field counsel with whom the TAM request was coordinated must use Form 4463, Request for Technical Advice Memorandum, for submitting a request for a TAM through TSS4510 to the Associate office. While the field office is responsible for preparing Form 4463, field counsel must submit the Form 4463 for a TAM request to the TSS4510 email address. To the extent feasible, the accompanying documents should also be submitted to the TSS4510 email address, followed by hard copies upon the request of the assigned Associate office.
All supporting and additional documents
.08 Field counsel should send additional or supporting documents that are not available in electronic form by fax to TSS4510 at 855-592-8976 or by express mail or private delivery service to the following address to avoid any delays in regular mail:
Whenever possible, all documents should contain the case number and name of the Associate office attorney assigned to the pre-submission conference for the TAM request.
The field office must indicate on the Form 4463 the proper mailing address of the Director to whom the Associate office should mail a copy of its reply to the TAM request under section 10.06 of this revenue procedure.
.09 The field office must submit one paper copy of the request for a TAM to the address in section 7.08 of this revenue procedure. If the TAM relates to a SB/SE, W&I, or TE/GE taxpayer, the field office must send one paper copy to the Division Counsel of the operating division that has jurisdiction over the taxpayer’s tax return. If the TAM relates to a LB&I taxpayer, an electronic copy (no paper copy to follow) to “&LB&I HQ” email address should be sent. If the request is from an Appeals office, the field office must advise Appeals Policy Planning Quality & Analysis that a request has been submitted. The field office will send a copy of the TAM request to *AP TAM Coordinator by encrypted e-mail.
SECTION 8. INITIAL PROCESSING OF THE REQUEST FOR TECHNICAL ADVICE BY THE ASSOCIATE OFFICE
Assignment and initial review by Associate office attorney
.01 After a request for technical advice has been received by the appropriate Associate office, it will be assigned to an Associate office attorney and reviewer. The Associate office attorney determines whether the request meets all procedural requirements of sections 4, 5, 6, and 7 of this revenue procedure and whether it raises issues that may be appropriately addressed in a TAM. Unless otherwise indicated, all references in this section to the Associate office or Associate office attorney are to the Associate office and attorney with primary responsibility for the TAM request.
Other forms of guidance
.02 If the assigned reviewer in the Associate office determines that guidance other than a TAM should be provided, the reviewer will immediately notify the Associate Chief Counsel. This other form of guidance may be published guidance, generic advice, or case-specific advice. Although the reviewer should make this determination as soon as possible, it may be made at any time during the processing of the request for technical advice. To make this determination, the reviewer should consider whether the issue has a broad application to similarly situated taxpayers or a practice area and whether resolution of the issue is important to a clear understanding of the tax laws. The Associate Chief Counsel, after consultation with Division Counsel Headquarters and the Operating Division, will decide whether to provide the TAM or issue guidance in another form. The Associate Chief Counsel may decide to provide the TAM as well as another type of guidance, if doing so would promote sound tax administration.
Initial acknowledgment and processing
.03 Upon receipt of a request for technical advice, the Associate office attorney who is assigned as the primary attorney on the request should immediately contact the field office. The purpose of this contact is only to acknowledge receipt of the request.
Deficiencies in request leading to return
.04 Within 7 calendar days after assignment, the Associate office attorney will contact the field office and field counsel to discuss any deficiencies in the request and will work with the field office and field counsel to correct them.
If only minor procedural deficiencies exist, the Associate office attorney will request the additional information without returning the case. If the deficiencies cannot be corrected over the next 7 calendar days, the request will be closed and returned to the field office. The request may be resubmitted when the deficiencies are corrected. If substantial additional information is required to resolve an issue or if major procedural problems cannot be resolved, the Associate office attorney will inform the field office and field counsel that the request for technical advice will be returned. If a request is returned, the field office should promptly notify the taxpayer of that decision and the reasons for the decision.
Initial discussion
.05 Within 21 calendar days of receipt, the Associate office attorney should contact the field office to discuss any procedural and substantive issues in the request. The Associate office attorney should also inform the field office about any matters referred to another Associate office for assistance and provide points of contact.
If additional information requested
.06 If additional information is needed, the Associate office attorney will obtain that information from the taxpayer, the field office, or the Director in the most expeditious manner possible. Any additional information requested from the taxpayer by the Associate office must be submitted by letter, accompanied by a penalties of perjury statement that conforms with the penalties of perjury statement set forth in section 7.06 of this revenue procedure, within 10 calendar days after the request for information is made. To facilitate prompt action, the Associate office and taxpayers are encouraged to exchange information by fax or express mail service whenever feasible. A taxpayer’s failure to submit the additional information requested is considered a failure to participate in a material stage of the TAM process and results in a waiver of the right to the taxpayer conference discussed in section 9.
To facilitate prompt action on TAM requests, the Associate office may request any additional information from the taxpayer by fax.
The Associate office attorney will take certain precautions to protect confidential information. For example, the Associate office attorney will use a cover sheet that identifies the intended recipient of the fax and the number of pages transmitted, that does not identify the taxpayer by name or tax identifying number and that contains a statement prohibiting unauthorized disclosure of the document if a recipient of the faxed document is not the intended recipient of the fax. The cover sheet will be faxed in an order in which it is the first page covering the faxed document.
Taxpayer request for extension of time to submit additional information
.07 A taxpayer’s request for an extension of time to submit additional information must be made in writing and received by the Associate office within the 10-day period. It must provide compelling facts and circumstances to justify an extension. Only an Associate Chief Counsel may determine whether to grant or deny the request for an extension. Except in rare and unusual circumstances, the Associate office will not agree to an extension of more than 10 calendar days beyond the end of the 10-day period. There is no right to appeal the denial of a request for an extension.
Where to send additional information
.08 Any additional information submitted by the taxpayer should be sent to the attention of the assigned Associate office attorney. Generally, only the original of the additional information is necessary. In appropriate cases, however, the Associate office may request additional copies of the information. In all cases, the taxpayer must also send a copy of the additional information to the field office and field counsel for comment.
Any comments by the field office or field counsel must be furnished within an agreed period of time to the Associate office with primary responsibility for the TAM request. If there are no comments, the Associate office attorney should be notified promptly.
Tentative conclusions
.09 The Associate office attorney will inform the field office and field counsel when all necessary substantive and procedural information has been received. If possible, the Associate office attorney will provide a tentative conclusion. If no tentative conclusion can be reached, the Associate office attorney is encouraged to discuss the underlying complexities with the field office and field counsel. Because the Associate office attorney’s tentative conclusion may change during the preparation and review of the TAM, the tentative conclusion is not considered final. If the tentative conclusion is changed, the Associate office attorney will inform the field office and field counsel. Neither the Associate office, nor the field office or the field counsel, should discuss the tentative conclusion and its underlying rationale with the taxpayer or the taxpayer’s representative until the Associate office is ready to provide a TAM that agrees with the taxpayer’s position or is ready to hold an adverse conference. To afford taxpayers an appropriate opportunity to prepare and present their position at a taxpayer conference, however, the taxpayer or the taxpayer’s representative is to be told (by the Associate office attorney) the tentative conclusion when scheduling the taxpayer conference. Field counsel should be notified of, and given the opportunity to participate in, the notification to the taxpayer of the tentative conclusions and scheduling of the taxpayer conference.
SECTION 9. TAXPAYER CONFERENCES
Notification of conference
.01 If the Associate office proposes to provide a TAM that will be adverse to the taxpayer, and if the taxpayer has not waived its right to a taxpayer conference, the taxpayer will be informed of the time and place of the conference.
Scheduling conference
.02 The taxpayer conference for a TAM must occur within 10 calendar days after the taxpayer is informed that an adverse TAM is proposed. The Associate office will notify the field office and field counsel of the scheduled taxpayer conference and will offer the field office and field counsel the opportunity to participate in the conference.
Taxpayer may request extensions
.03 Only an Associate Chief Counsel may approve an extension of the 10-day period for holding a conference. Although extensions are granted in appropriate circumstances at the discretion of the Associate Chief Counsel, taxpayers should not expect extensions to be routinely granted. The taxpayer must submit a request for an extension in writing to the Associate office, and must immediately notify the field office and field counsel of the request. The request must contain a detailed justification for the extension and must be submitted sufficiently before the end of the 10-day period to allow the Associate Chief Counsel to consider, and either approve or deny, the request before the end of the 10-day period. If unusual circumstances near the end of the 10-day period make a timely written request impracticable, the taxpayer may orally inform the assigned Associate office attorney or reviewer before the end of the 10-day period about the need for an extension and then promptly submit the written request. The Associate office attorney will inform the taxpayer by telephone of the approval or denial of a requested extension. There is no right to appeal the denial of a request for extension.
One conference of right
.04 In general, a taxpayer who has not waived the right to a taxpayer conference is entitled by right to only one conference with the Associate office. The conference is normally held at the branch level. A person who has authority to sign the transmittal memorandum in his or her own name, or on behalf of the branch chief, will participate. When more than one branch of an Associate office has taken an adverse position on issues in the request or when the position ultimately adopted by one branch will affect another branch’s determination, a representative from each branch with authority to sign in his or her own name, or for the branch chief, will participate in the conference. The conference is the taxpayer conference for each subject discussed.
Additional conferences may be offered
.05 After the taxpayer conference, the Service will offer the taxpayer an additional conference only if an adverse holding is proposed on a new issue or on the same issue but on grounds different from those discussed at the first conference. If a tentative position is changed at a higher level with a result less favorable to the taxpayer, the taxpayer has no right to another conference if the grounds or arguments on which the change is based were discussed at the taxpayer conference. The limitation on the number of conferences to which a taxpayer is entitled does not prevent the Associate office from inviting a taxpayer to participate in additional conferences if that office determines that additional conferences would be useful. These additional conferences are not to be offered routinely following an adverse decision.
Additional information submitted after the conference
.06 In order to ensure that the taxpayer conference is productive, the taxpayer should make a reasonable effort to supply all information, documents, and arguments in writing well before the conference.
Sometimes, however, it becomes apparent that new information may be helpful in resolving issues discussed at the conference. If the Associate office and the taxpayer agree that such information would be helpful, all such materials must be submitted and received within 10 calendar days after the conference. Any extension of the 10-day period must be requested by the taxpayer in writing and must be approved by the branch chief of the Associate office attorney. Extensions will not be routinely granted. Taxpayers have no right to submit additional materials after the conference, and are discouraged from providing additional copies or versions of materials already submitted. If the additional information is not received from the taxpayer within 10 calendar days plus any extensions granted by the branch chief, the TAM will be issued on the basis of the existing record.
The taxpayer must also send a copy of the additional information to the field office and field counsel for comment. If the additional information has a significant impact on the facts in the request, the Associate office will ask the field office and field counsel for comments, both of which will respond within the agreed upon period of time. If there are no comments, the Associate office attorney will be promptly notified.
Normally conducted in person
.07 Conferences under this section are generally conducted in person, but may be conducted by telephone.
Service makes only tentative recommendations
.08 At the end of the taxpayer conference, no commitment will be made about the conclusion that the Service will finally adopt for any issue, including the outcome of a request for relief under § 7805(b).
Conference may not be taped
.09 No tape, stenographic, or other verbatim recording of a taxpayer conference may be made by any party.
SECTION 10. PREPARATION OF THE TECHNICAL ADVICE
Reply consists of two parts
.01 The Associate office attorney prepares replies to requests for technical advice in two parts. Each part identifies the taxpayer by name, address, identification number, and tax period(s) involved. The first part of the reply is a transmittal memorandum (Form M–6000). The second part is the TAM, which contains: (1) a statement of the issues; (2) the conclusions of the Associate office; (3) a statement of the facts pertinent to the issues; (4) a statement of the relevant legal authority, including legislation, tax treaties, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements; and (5) a discussion of the rationale supporting the conclusions reached by the Associate office. The conclusions give direct answers, whenever possible, to the specific issues raised by the field office. The Associate office is not bound by the issues as submitted by the taxpayer or by the field office and may reframe the issues to be answered in a TAM after consultation with the field office and field counsel. The discussion of the issues in a TAM will be in sufficient detail so that the field or Appeals officials will understand the reasoning underlying the conclusion.
Status of a request
.02 The taxpayer or the taxpayer’s authorized representative may obtain information on the status of the request by contacting the field office that requested the advice. The Associate office attorney or reviewer assigned to the TAM request will give frequent status updates to the field office and field counsel.
Opportunity for field counsel review
.03 The Associate office attorney will inform field counsel regarding the Associate office’s final conclusions before a draft of the TAM is sent to the field office. Field counsel will be offered a reasonable opportunity to review and informally discuss these conclusions with the Associate office before the final TAM is sent to the field office.
Copy of preliminary TAM to field office and field counsel
.04 After field counsel is given a reasonable opportunity to review the Associate office’s final conclusions, the Associate office attorney will provide a draft of the proposed final version of the TAM to the field office and field counsel. If the field office or field counsel disagrees with the proposed final conclusions, normal reconciliation and reconsideration procedures will be followed to resolve the disagreement.
Routing of reply
.05 A TAM is generally addressed to the field office that requested it. In the case of issues arising within the jurisdiction of the Director, Indian Tribal Governments and Tax Exempt Bonds; the Director, Employee Plans or Exempt Organizations Examinations; or the Director, Employee Plans or Exempt Organizations Rulings & Agreements, the TAM is addressed to the appropriate Director with a copy sent to the field office and the field counsel attorney. A copy of a TAM requested by LB&I should be mailed simultaneously to the appropriate Practice Area Director. A copy of a TAM requested by Appeals should be addressed to the appropriate field office, and an electronic copy sent by encrypted e-mail to *AP TAM Coordinator.
Copy of final TAM to field counsel and Division Counsel
.06 The Associate office will provide a copy of the final TAM to the individual field counsel attorney who assisted the field office in submitting the request and to that attorney’s Associate Area Counsel or other manager, as appropriate. The Associate office also will provide a copy of the final TAM to the Division Counsel for the operating division from which the request originated or that has jurisdiction over the particular matter in the TAM. The TAM may be transmitted electronically if it is in .pdf format, or may be sent by mail or fax transmission.
.07 Requests for reconsideration may be submitted by the field office, or in the case of bonds under the jurisdiction of the Director of Indian Tribal Governments and Tax Exempt Bonds, by that Director after the Associate office has provided a final copy of the TAM to field counsel and Division Counsel. Requests for reconsideration must describe with specificity the errors in the analysis and conclusions. Requests should focus on points that the TAM overlooked or misconstrued rather than simply re-argue points raised in the initial request. The Associate office will give priority consideration to the request and should act on the request as expeditiously as possible. The Associate office may request further submissions from the field office and field counsel or the taxpayer, but the parties should otherwise make no additional submissions. If a request for reconsideration fails to follow the procedures set forth in this section of this revenue procedure, or the request fails to raise issues or arguments different from those asserted in the initial request for technical advice, the Associate office may return the request for reconsideration without ruling on the request for reconsideration.
Discussing contents with the taxpayer
.08 The Associate office will not discuss the specific contents of the TAM with the taxpayer until after the field office has provided a copy of the TAM to the taxpayer.
.09 Before the TAM is issued, the Associate office will inform the taxpayer in writing of the material likely to appear in the TAM that the taxpayer proposed for deletion but that the Associate office has determined should not be deleted. If so informed, the taxpayer may submit within 10 calendar days any further information or arguments supporting the taxpayer’s proposed deletions. The Associate office will attempt to resolve all disagreements about proposed deletions before the TAM is issued. The taxpayer does not have the right to a conference to resolve any disagreements about material to be deleted from the text of the TAM. For TAMs subject to § 6110, accompanying the TAM is a notice under § 6110(f)(1) of intention to disclose a TAM, including a copy of the version proposed to be open to public inspection and notations of third party communications under § 6110(d). If the transmittal memorandum associated with the TAM provides information not in the TAM, or if the case is returned for further development without issuance of the TAM, the transmittal memorandum may be Chief Counsel Advice, as defined in § 6110(i)(1), subject to public inspection under § 6110. These procedures do not apply to TAMs to the extent that § 6104 applies. See section 7.05 of this revenue procedure and § 6110(l)(1).
TAM takes effect when taxpayer receives a copy
.10 After a TAM is sent to the field office (or, for Tax Exempt Bonds, Employee Plans, and Exempt Organizations, to the Director), the field office or Director adopts and issues the TAM within the meaning of Treas. Reg. § 301.6110–2(h). Then the field office or Director provides the taxpayer a copy of the TAM, the notice of intention to disclose under § 6110(f)(1), as applicable, and a copy of the version proposed to be open to public inspection, which includes notations of third party communications under § 6110(d), as applicable. If a request for technical advice pertains to more than one taxpayer, and the requirements of section 7.02 of this revenue procedure have been met, the field office or Director will provide each taxpayer with a copy of the TAM and will notify the Associate office when this occurs. The requirement to provide a taxpayer a copy of the TAM does not apply to a TAM involving civil fraud or a criminal investigation, or to a TAM involving a jeopardy or termination assessment. See section 10.12 of this revenue procedure.
Taxpayer may protest deletions not made
.11 Generally, the Associate office considers only the deletion of material that the taxpayer has proposed for deletion or other deletions as required under § 6110(c) before the TAM is sent to the field office or Director. After receiving the notice of intention to disclose under § 6110(f)(1), the taxpayer may protest the disclosure of certain information in it by submitting a written statement in accordance with the notice of intention to disclose under § 6110(f)(1) (Notice 438, Notice of Intention to Disclose).
Public inspection in civil fraud or criminal investigation cases
.12 The provisions of this revenue procedure about referring issues upon the taxpayer’s request, telling the taxpayer about the referral of issues, giving the taxpayer a copy of the arguments submitted, submitting proposed deletions, granting conferences in the Associate office, or providing a copy of the TAM to the taxpayer do not apply to a TAM described in § 6110(g)(5)(A), which involves any matter that is the subject of a civil fraud or criminal investigation, or that involves a jeopardy or termination assessment. In these cases, after all proceedings in the investigations or assessments are complete, the taxpayer receives a copy of the TAM with the notice of intention to disclose under § 6110(f)(1). The taxpayer may protest the disclosure of certain information in the TAM by submitting a written statement in accordance with the Notice of Intention to Disclose (Notice 438).
SECTION 11. WITHDRAWAL OF REQUESTS FOR TECHNICAL ADVICE
Taxpayer notified
.01 Once a request for a TAM has been sent to the Associate office, only a Director may withdraw the request, and this must be done before the responding transmittal memorandum for the TAM is signed. To withdraw the request, the Director must first notify the taxpayer of the intent to withdraw unless: (1) the period of limitation on assessment is about to expire and the taxpayer has declined to give written consent to extend the period; or (2) the notification would be prejudicial to the best interests of the Government. If the taxpayer does not agree that the request should be withdrawn and wishes to request review of the decision, the procedures in section 5.04 of this revenue procedure for review must be followed.
Acknowledgment of withdrawal
.02 Acknowledgment of the withdrawal of a request submitted by a Director should be sent to the appropriate Director, with a copy to the TAM coordinator. For a withdrawal of a request submitted by Appeals, send an electronic copy by encrypted e-mail to *AP TAM Coordinator.
Associate office may decide not to provide a TAM
.03 If the Associate office determines that a TAM will not be provided, it may return the request for technical advice unanswered. This determination must be made on the basis of sound tax administration and must be approved by the Associate Chief Counsel. The decision not to provide a TAM should be an infrequent occurrence and be made only after consultation with field counsel and the requesting field office. If field counsel disagrees with this determination, they may request reconsideration through existing reconciliation procedures.
Associate office may provide views
.04 If a request for technical advice is withdrawn or an Associate office decides not to provide a TAM, the Associate office may address the substantive issues through other published guidance. The Associate office may also address the substantive issues through legal advice, either generic or case-specific. The decision to address the issues through these other forms of guidance will be based on the general standards for issuing those types of guidance.
SECTION 12. USE OF THE TECHNICAL ADVICE
Service generally applies advice in processing the taxpayer’s case
.01 After a TAM is issued, the field office must process the taxpayer’s case on the basis of the conclusions in the TAM. In the case of a TAM unfavorable to the taxpayer, the Appeals Area Director may decide to settle the issue under existing settlement authority. Appeals, however, will not settle an issue contrary to a TAM if it concerns an organization’s exempt status or private foundation classification, or if it concerns an employee plan’s status or qualification. Thus, if the TAM received by the field office concerns an organization’s exempt status, private foundation classification, or a plan’s status or qualification, the organization or plan has no right to appeal those specific issues with the Appeals Office. Appeals may submit a proposed disposition of the issue contrary to a TAM as a request for a new TAM. If a TAM provides conclusions involving a § 103 obligation and the issuer of this obligation, the field office must apply the conclusions to the issuer and any holder of the obligation, unless a field office separately initiates a request for a TAM on behalf of the holder for the same issue addressed in the TAM involving the issuer, and the Associate office issues a TAM involving that issue and that holder.
SECTION 13. RETROACTIVITY AND RELIANCE
Usually applies retroactively
.01 The holdings in a TAM are applied retroactively, whether they are initial holdings or they are later holdings that modify or revoke holdings in a prior TAM. The Associate Chief Counsel with jurisdiction over the TAM, however, may exercise the discretionary authority under § 7805(b) to limit the retroactive effect of any holding. This authority is exercised in rare and unusual circumstances.
Revocation or modification of an earlier letter ruling or TAM
.02 A TAM may be used to seek revocation or modification of an earlier TAM or revocation or modification of a private letter ruling (PLR). See Rev. Proc. 2019–1, section 11.03 et seq. with respect to revocation or modification of PLRs. Generally, a TAM that revokes or modifies a letter ruling or an earlier TAM will not be applied retroactively if: (1) the applicable law has not changed; (2) the taxpayer directly involved in the letter ruling or earlier TAM relied in good faith on it; and (3) revocation or modification would be detrimental to the taxpayer. The new TAM will be applied retroactively to the taxpayer whose tax liability was directly involved in the letter ruling or TAM if: (1) controlling facts have been misstated or omitted; or (2) the facts at the time of the transaction are materially different from the controlling facts on which the letter ruling or earlier TAM was based. If a letter ruling or a TAM is modified or revoked with retroactive effect, the notice to the taxpayer, except in fraud cases, should set forth the grounds on which the modification or revocation is being made and the reason why the modification or revocation is being applied retroactively.
Continuing action or series of actions
.03 If an issue addressed in the TAM relates to a continuing action or a series of actions, it is generally applied until it is withdrawn or until the conclusion is modified or revoked by a final decision in favor of the taxpayer with respect to that issue, the enactment of legislation, the ratification of a tax treaty, a decision of the United States Supreme Court, or the issuance of temporary regulations, final regulations, a revenue ruling, or other statement published in the Internal Revenue Bulletin. Publication of a notice of proposed rulemaking does not affect the application of a TAM. If a new holding in a TAM is less favorable to the taxpayer than the holding in an earlier TAM, the new holding is generally not applied to the tax period when the taxpayer relied on the earlier holding. It will be applied to that tax period, however, if material facts on which the earlier TAM was based have changed.
Other taxpayers
.04 Under § 6110(k)(3), a taxpayer may not rely on a TAM issued by the Service for another taxpayer. In addition, retroactive or non-retroactive treatment to one member of a practice area directly involved in a letter ruling or TAM does not extend to another member of that same practice area, and retroactive or non-retroactive treatment to one client of a tax practitioner does not extend to another client of that same practitioner. The tax liability of each employee covered by a letter ruling or TAM relating to a pension plan of an employer is directly involved in the letter ruling or TAM.
SECTION 14. HOW MAY RETROACTIVE EFFECT BE LIMITED?
Request for relief under § 7805(b)
.01 A taxpayer with respect to whom a TAM is issued, or for whom a TAM request is pending, may request that the appropriate Associate Chief Counsel limit the retroactive effect of any holding in the TAM or of any subsequent modification or revocation of the TAM. For a pending request for technical advice, the taxpayer should make the request for relief under § 7805(b) as part of the initial request for advice. The Associate office will consider a request for relief under § 7805(b) made at a later time if the Director determines that there is justification for the delay in the making of the request. The Director’s determination that the delayed request for § 7805 is not justified cannot be appealed. Requests for relief under § 7805(b) relating to the revocation or modification of determination letters and letter rulings issued by TE/GE are handled under the procedures in sections 23 and 29 of Rev. Proc. 2019–4, and section 12 of Rev. Proc. 2019–5, this Bulletin.
Form of request for relief – in general
.02 During the course of an examination of a taxpayer’s return by the field office or during consideration of the taxpayer’s return by the Appeals Area Director, a taxpayer’s request to limit retroactivity must be made in the form of a request for a TAM. This includes recommendations by a Director that an earlier letter ruling or TAM be modified or revoked. The request must meet the general requirements of a request for technical advice. It must also: (1) state that it is being made under § 7805(b); (2) state the relief sought; (3) explain the reasons and arguments in support of the relief sought; and (4) include any documents bearing on the request. The taxpayer’s request must be submitted to the Director, who should then forward the request to the Associate office for consideration. If taxpayer submits a request for relief after the initial TAM request, the taxpayer must provide justification for having delayed the request. Requests for relief under § 7805(b) relating to the revocation or modification of determination letters and letter rulings issued by TE/GE are handled under the procedures in sections 23 and 29 of Rev. Proc. 2019–4, and section 12 of Rev. Proc. 2019–5, this Bulletin.
Form of request for relief – continuing transaction before examination of return
.03 A request for relief under § 7805(b) must be made in the form of a request for a letter ruling if: (1) a TAM addressing a continuing transaction is modified or revoked by later published guidance; and (2) the request for relief is submitted before an examination has begun covering the tax period(s) for which relief is sought. The requirements for a letter ruling request are given in Rev. Proc. 2019–1 (this Bulletin).
Taxpayer’s right to a conference
.04 When a request for a TAM concerns only the application of § 7805(b), the taxpayer has the right to a conference with the Associate office in accordance with the provisions of section 9 of this revenue procedure. If the request for application of § 7805(b) is included in the request for a TAM on the substantive issues or is made before the taxpayer conference on the substantive issues, the § 7805(b) issues will be discussed at the taxpayer’s one conference of right. If the request for the application of § 7805(b) is made as part of a pending TAM request after a taxpayer conference has been held on the substantive issues and the Director determines that there is justification for having delayed the request, then the taxpayer will have the right to a taxpayer conference concerning the application of § 7805(b), with the conference limited to discussion of this issue only.
Reconsideration of request for relief under § 7805(b)
.05 When a TAM grants a taxpayer relief under § 7805(b), the Director may not request reconsideration of the § 7805(b) issue unless the Director determines there has been a misstatement or omission of controlling facts by the taxpayer in its request for § 7805(b) relief.
SECTION 15. SIGNIFICANT CHANGES MADE TO REV. PROC. 2018–2
All references to Associate Chief Counsel (Tax Exempt and Government Entities) have been revised to read “Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes)”. All references to “Appeals Policy” have been revised to read “Appeals Policy Planning Quality & Analysis”.
Section 3.04 has been amended to delete the mandatory TAM requirement in qualified retirement plan matters in cases concerning proposed adverse letters or proposed revocation letters on collectively bargained plans.
Section 14.02 has been amended to clarify that requests for relief under § 7805(b) relating to the revocation or modification of determination letters and letter rulings issued by TE/GE are handled under the procedures in sections 23 and 29 of Rev. Proc. 2019–4, and section 12 of Rev. Proc. 2019–5.
SECTION 16. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2018–2, 2018–1 I.R.B. 106, is superseded.
SECTION 17. EFFECTIVE DATE
This revenue procedure is effective January 2, 2019.
The principal author of this revenue procedure is Marshall T. French of the Office of Associate Chief Counsel (Procedure and Administration). For further information regarding this revenue procedure for matters under the jurisdiction of:
(1) the Associate Chief Counsel (Corporate), contact Ken Cohen at (202) 317-7700 or Jean Broderick at (202) 317-6848 (not a toll-free call);
(2) the Associate Chief Counsel (Financial Institutions and Products), contact K. Scott Brown at (202) 317-4423 (not a toll-free call);
(3) the Associate Chief Counsel (Income Tax and Accounting), contact R. Matthew Kelley at (202) 317-7002 (not a toll-free call);
(4) the Associate Chief Counsel (Passthroughs and Special Industries), contact Anthony McQuillen at (202) 317-6850 (not a toll-free call);
(5) the Associate Chief Counsel (Procedure and Administration), contact Jennifer Auchterlonie at (202) 317-3400 (not a toll-free call);
(6) the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), contact Michael B. Blumenfeld at (202) 317-6000 (not a toll-free call);
(7) the Associate Chief Counsel (International), contact Nancy Galib at (202) 317-3800 (not a toll-free call);
(8) the Commissioner (Large Business & International Division), contact Shirley S. Lee at (202) 317-3152 (not a toll-free call);
(9) the Commissioner (Small Business/Self-Employed Division), contact Charles Hall at (240) 613-6353 (not a toll-free call);
(10) the Commissioner (Wage and Investment Division), contact Geoffrey Gerbore at (631) 977-3210 (not a toll-free call); or
(11) the Office of Appeals, contact Mark K. Wesner at (602) 636-9571 (not a toll-free call).
– initial processing of TAM request 8.06
– taxpayer request for extension of time to send 8.07
– where to send 8.08
– after taxpayer conference 06
– proposed deletions under § 6110 7.05, 10.09
Appeal of decision to seek or not seek TAM 5.03
–The decision of the Director, the LB&I Territory Manager, or the Tax Exempt Bonds Manager, Field Operations may be reviewed but not appealed 5.04
Civil fraud or criminal investigation cases 10.12
– offered 6, 9, 14.04
– after taxpayer conference 9.05
– scheduling 6.06, 9.02
request to limit retroactivity 14.04
telephone conferences 6.07, 9.07
– Appeals officer 2.03
– Director 2.02
– field office 2.06
– field counsel 2.07
– frivolous issue 4.04
– taxpayer 2.04
– technical advice 1.01
Discussions with Taxpayers
– contents of TAM 10.08
– substantive issues at pre-submission conference 6.09
– tentative conclusion in TAM 8.09
– application of § 6104 7.05
– mandatory technical advice on employee plans matters 3.04
– requests by Exempt Organizations Rulings & Agreements 3.05
– request for relief under § 7805(b) for matters handled by TE/GE 4.07
– to appeal decision not to request a TAM 5.03
– to disagree with statement of facts in technical advice request 7.06
– to schedule conference 9.03
– to submit additional information requested by Associate office in initial processing of TAM 8.07
– to submit additional information after conference 9.06
Foreign laws and documents 7.03
Issues Eligible for TAMs 3
Issues Not Eligible for TAMs 4
– form 7.06
– required when no factual agreement 7.06
– required with additional information 8.06
Power of Attorney 6.11
Pre-submission Conferences 6
Public Inspection Under § 6110
– deletion statement required 7.05
– exception when § 6104 applies 7.05
– notice of intention to disclose 10.09
– protesting deletions not made 10.11
Responsibility for Requesting Advice 5.01
Retroactive Effect
– request to limit retroactivity 14.01
– format of request 14.02, 14.03
– right to conference 14.04
Status of TAM 10.02
Taxpayer Participation 3.03
– consequences of failure to participate in material stage 7.06, 8.06
What to Include in the Request for Advice
– Memorandum of issues, facts, law, and arguments 7.01
– Statement proposing information to be deleted from public
inspection 7.05
– Transmittal Form 4463 7.07
– Number of copies 7.09
– information required prior to pre-submission conference 6.05
– request for referral for a TAM 5.02
Withdrawal of TAM Requests 11
SECTION 1. PURPOSE AND NATURE OF CHANGES 130
SECTION 2. BACKGROUND AND SCOPE 130
SECTION 3. AREAS IN WHICH RULINGS WILL NOT BE ISSUED 131
SECTION 4. AREAS IN WHICH RULINGS WILL NOT ORDINARILY BE ISSUED 138
SECTION 5. AREAS UNDER STUDY IN WHICH RULINGS WILL NOT BE ISSUED 143
SECTION 6. AREAS COVERED BY AUTOMATIC APPROVAL PROCEDURES 144
SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES 145
SECTION 8. EFFECTIVE DATE 145
SECTION 9. PAPERWORK REDUCTION ACT 145
SECTION 1. PURPOSE AND NATURE OF CHANGES
.01 The purpose of this revenue procedure is to update Rev. Proc. 2018–3, 2018–1 I.R.B. 130, by providing a revised list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) (EEE) relating to issues on which the Internal Revenue Service (the “Service”) will not issue letter rulings or determination letters. For a list of areas under the jurisdiction of the Associate Chief Counsel (International) relating to international issues on which the Service will not issue letter rulings or determination letters, see Rev. Proc. 2019–7, this Bulletin. For a list of areas under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division relating to issues, exempt organizations, plans, or plan amendments on which the Service will and will not issue letter rulings or determination letters, see Rev. Proc. 2019–4 and Rev. Proc. 2019–5, this Bulletin.
.02 Changes.
(1) Section 3.01(7), regarding § 61, has been added.
(2) Section 3.01(31), regarding § 162, has been added.
(3) Section 3.01(33), regarding §§ 165, 381, and 1502, has been clarified and paragraph (ii) has been added.
(4) Section 3.01(85), regarding § 643(f), has been added.
(5) Section 3.01(125), regarding § 6050P, has been added.
(6) Section 4.01(46), regarding § 1031(f), has been modified.
(7) Old sections 5.01(15) and 5.01(16), regarding § 6050P, have been moved to sections 3.01(126) and 3.01(127).
(8) References to Associate Chief Counsel (Tax Exempt and Government Entities) (TEGE) have been changed to Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) (EEE) throughout the revenue procedure to reflect the Office’s name change.
SECTION 2. BACKGROUND, SCOPE OF APPLICATION, AND NO-RULE ISSUES PART OF INTEGRATED TRANSACTION
.01 Background.
Whenever appropriate in the interest of sound tax administration, it is the policy of the Service to answer inquiries of individuals and organizations regarding their status for tax purposes and the tax effects of their acts or transactions, prior to the filing of returns or reports that are required by the revenue laws. In employee plans matters described in section 5.15 of Rev. Proc. 2019–1, this Bulletin, the Associate Chief Counsel (EEE) may issue letter rulings after the filing of returns or reports that are required by the revenue laws.
There are, however, certain areas in which, because of the inherently factual nature of the problems involved, or for other reasons, the Service will not issue rulings or determination letters. These areas are set forth in four sections of this revenue procedure. Section 3 reflects those areas in which rulings or determination letters will not be issued. Section 4 sets forth those areas in which rulings or determination letters will not ordinarily be issued. “Not ordinarily” means that unique and compelling reasons must be demonstrated to justify the issuance of a ruling or determination letter. Section 5 sets forth those areas in which the Service is temporarily not issuing rulings or determination letters because those matters are under study. Finally, section 6 of this revenue procedure lists specific areas in which the Service will not ordinarily issue rulings because the Service has provided automatic approval procedures for these matters.
See Rev. Proc. 2019–1, this Bulletin, particularly section 6 captioned “Under What Circumstances Does The Service Not Issue Letter Rulings Or Determination Letters?” for general instructions and other situations in which the Service will not or ordinarily will not issue letter rulings or determination letters.
With respect to the items listed, revenue rulings or revenue procedures may be published in the Internal Revenue Bulletin from time to time to provide general guidelines regarding the position of the Service.
Additions or deletions to this revenue procedure as well as restatements of items listed will be made by modification of this revenue procedure. Changes will be published as they occur throughout the year and will be incorporated annually in a new revenue procedure published as the third revenue procedure of the year. These lists should not be considered all-inclusive because the Service may decline to issue a letter ruling or a determination letter when appropriate in the interest of sound tax administration (including due to resource constraints) or on other grounds whenever warranted by the facts or circumstances of a particular case. Decisions not to rule on individual cases (as contrasted with those that present significant pattern issues) are not reported in this revenue procedure and will not be added to subsequent revisions.
If the Service determines that it is not in the interest of sound tax administration to issue a letter ruling or determination letter due to resource constraints, it will adopt a consistent approach with respect to taxpayers that request a ruling on the same issue. The Service will also consider adding the issue to the no rule list at the first opportunity. See section 6.02 of Rev. Proc. 2019–1, this Bulletin.
.02 Scope of Application.
This revenue procedure does not preclude the submission of requests for technical advice to the National Office from other offices of the Service.
.03 No-Rule Issues Part of Integrated Transaction.
If it is impossible for the Service to determine the tax consequences of an integrated transaction without knowing the resolution of an issue on which the Service will not issue rulings or determination letters under this revenue procedure involving a part of the transaction or a related transaction, the taxpayer must state in the request to the best of the taxpayer’s knowledge and belief the tax consequences of the no-rule issue. The Service’s ruling or determination letter will state that the Service did not consider, and no opinion is expressed upon, that issue. In appropriate cases the Service may decline to issue rulings or determination letters on such integrated transactions due to the relevance of the no-rule issue, despite the taxpayer’s representation. See also section 4.02(2) of this revenue procedure.
SECTION 3. AREAS IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT BE ISSUED
.01 Specific Questions and Problems.
(1) Section 42.—Low-Income Housing Credit.—Whether under § 42(j)(4)(E) a casualty loss has been restored by reconstruction or replacement within a reasonable period of time. The Service may issue a determination letter in this case. See section 12 of Rev. Proc. 2019–1, this Bulletin.
(2) Section 45.—Electricity Produced from Certain Renewable Resources, Etc.—The allocation by a partnership of the § 45 credit, the validity of the partnership, or whether any taxpayer is a valid partner in the partnership.
(3) Section 45.—Electricity Produced from Certain Renewable Resources, Etc.—Whether the taxpayer meets the requirements of § 45 or Notice 2010–54, 2010–40 I.R.B. 403, for refined coal.
(4) Sections 45 and 48.—Electricity Produced from Certain Renewable Resources, Etc.; Energy Credit.—The application of the beginning of construction requirement under § 45(d) and § 48(a)(5).
(5) Section 47.—Rehabilitation Credit.—The allocation by a partnership of the § 47 rehabilitation credit, the validity of the partnership, or whether any taxpayer is a valid partner in the partnership.
(6) Section 48.—See section 3.01(4), above.
(7) Section 61.—Gross Income Defined.—Whether an amount is not included in a taxpayer’s gross income under section 61 because the taxpayer receives the amount subject to an unconditional obligation to repay the amount.
(8) Section 61.—Gross Income Defined.—Whether amounts voluntarily deferred by a taxpayer under a deferred-compensation plan maintained by an organization described in § 501 (other than an eligible plan maintained by an eligible employer pursuant to the provisions of § 457(b)) are currently includible in the taxpayer’s gross income.
(9) Section 61.—Gross Income Defined.—Whether a split-dollar life insurance arrangement is “materially modified” within the meaning of § 1.61–22(j)(2) of the Income Tax Regulations. (Also §§ 83, 301, 1401, 2501, 3121, 3231, 3306, 3401, and 7872.)
(10) Sections 61, 451, and 1001.—Gross Income Defined; General Rule for Taxable Year of Inclusion; Determination of Amount of and Recognition of Gain or Loss.—Whether, under authorization by an appropriate state agency to recover certain costs pursuant to state specified cost recovery legislations, any investor-owned utility company realizes income upon: (i) the creation of an intangible property right; (ii) the transfer of that intangible property right; or (iii) the securitization of the intangible property right.
(11) Section 79.—Group-Term Life Insurance Purchased for Employees.—Whether a group insurance plan for 10 or more employees qualifies as group-term insurance, if the amount of insurance is not computed under a formula that would meet the requirements of § 1.79–1(c)(2)(ii) of the Income Tax Regulations had the group consisted of fewer than 10 employees.
(12) Section 83.—Property Transferred in Connection with Performance of Services.—Whether a restriction constitutes a substantial risk of forfeiture, if the employee is a controlling shareholder. Also, whether a transfer has occurred, if the amount paid for the property involves a nonrecourse obligation.
(13) Section 83.—Property Transferred in Connection with Performance of Services.—Which corporation is entitled to the deduction under § 83(h) in cases in which a corporation undergoes a corporate division, if the facts are not similar to those described in Rev. Rul. 2002–1, 2002–1 C.B. 268.
(14) Section 101.—Certain Death Benefits.—Whether there has been a transfer for value for purposes of § 101(a) in situations involving a grantor and a trust when (i) substantially all of the trust corpus consists or will consist of insurance policies on the life of the grantor or the grantor’s spouse, (ii) the trustee or any other person has a power to apply the trust’s income or corpus to the payment of premiums on policies of insurance on the life of the grantor or the grantor’s spouse, (iii) the trustee or any other person has a power to use the trust’s assets to make loans to the grantor’s estate or to purchase assets from the grantor’s estate, and (iv) there is a right or power in any person that would cause the grantor to be treated as the owner of all or a portion of the trust under §§ 673 to 677.
(15) Sections 101, 761, and 7701.—Certain Death Benefits; Terms Defined; Definitions.—Whether, in connection with the transfer of a life insurance policy to an unincorporated organization, (i) the organization will be treated as a partnership under §§ 761 and 7701, or (ii) the transfer of the life insurance policy to the organization will be exempt from the transfer for value rules of § 101, when substantially all of the organization’s assets consist or will consist of life insurance policies on the lives of the members.
(16) Section 102.—Gifts and Inheritances.—Whether a transfer is a gift within the meaning of § 102(a).
(17) Section 105(h).—Amount Paid to Highly Compensated Individuals Under a Discriminatory Self-Insured Medical Expense Reimbursement Plan.—Whether a self-insured medical reimbursement plan satisfies the requirements of § 105(h) for a plan year.
(18) Section 107.—Rental Value of Parsonages.—Whether amounts distributed to a retired minister from a pension or annuity plan should be excludible from the minister’s gross income as a parsonage allowance under § 107.
(19) Section 107.—Rental Value of Parsonages.—Whether an individual is a “minister of the gospel” for Federal tax purposes. (Also §§ 1402(a)(8), (c)(4), and (e), 3121(b)(8)(A), and 3401(a)(9).)
(20) Section 115.—Income of States, Municipalities, Etc.—The results of transactions pursuant to a plan or arrangement created by state statute a primary objective of which is to enable participants to pay for the costs of a post-secondary education for themselves or a designated beneficiary, including: (i) whether the plan or arrangement, itself, is an entity separate from a state and, if so, how the plan or arrangement is treated for Federal tax purposes; and (ii) whether any contract under the plan or arrangement is a debt instrument and, if so, how interest or original issue discount attributable to the contract is treated for Federal tax purposes. (Also §§ 61, 163, 1275, 2501, and 7701.)
(21) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s compensation claims is excluded from gross income under § 115.
(22) Section 115.—Income of States, Municipalities, Etc.—Whether some, but not all, income of an entity is from the exercise of an essential government function in order to be excluded from gross income under § 115.
(23) Section 115.—Income of States, Municipalities, Etc.—Whether income accruing to a trust, or other entity, relating to or associated with a qualified retirement plan described in § 401(a) is excluded from gross income under § 115.
(24) Section 117.—Qualified Scholarships.—Whether amounts paid to research fellows and research associates are scholarships or fellowships excluded from wages for FICA tax purposes.
(25) Section 117.—Qualified Scholarships.—Whether an employer-related scholarship or fellowship grant is excludible from the employee’s gross income, if there is no intermediary private foundation distributing the grants, as described in Rev. Proc. 76–47, 1976–2 C.B. 670.
(26) Section 118.—Contributions to the Capital of a Corporation.—Whether a transfer of an intertie as defined in section III. B. 2. of Notice 2016–36, 2016–25 I.R.B. 1029, meets all of the requirements under the safe harbor provided by Notice 2016–36.
(27) Section 119.—Meals or Lodging Furnished for the Convenience of the Employer.—Whether the value of meals or lodging is excludible from gross income by an employee who is a controlling shareholder of the employer.
(28) Section 121.—Exclusion of Gain from Sale of Principal Residence.—Whether property qualifies as the taxpayer’s principal residence.
(29) Section 125.—Cafeteria Plans.—Whether amounts used to provide group-term life insurance under § 79, accident and health benefits under §§ 105 and 106, and dependent care assistance programs under § 129 are includible in the gross income of participants and considered “wages” for purposes of §§ 3401, 3121, and 3306 when the benefits are offered through a cafeteria plan.
(30) Section 162.—Trade or Business Expenses.—Whether compensation is reasonable in amount.
(31) Section 162.—Trade or Business Expenses.—Whether a taxpayer is engaged in a trade or business. This area does not include a request for a ruling that relies on a representation from a taxpayer that the taxpayer is or is not engaged in a trade or business, or a request for a ruling that relies on factual information provided by the taxpayer evidencing the active conduct of a trade or business (for example, a request that relies on the taxpayer’s active conduct of a trade or business as evidenced by financial statements provided by the taxpayer).
(32) Section 163.—Interest.—The income tax consequences of transactions involving “shared appreciation mortgage” (SAM) loans in which a taxpayer, borrowing money to purchase real property, pays a fixed rate of interest on the mortgage loan below the prevailing market rate and will also pay the lender a percentage of the appreciation in value of the real property upon termination of the mortgage. This applies to all SAM arrangements in which the loan proceeds are used for commercial or business activities, or to finance a personal residence, if the facts are not similar to those described in Rev. Rul. 83–51, 1983–1 C.B. 48. (Also §§ 61, 451, 461, 856, 1001, and 7701.)
(33) Sections 165, 381, and 1502.—Losses; Carryovers in Certain Corporate Acquisitions; Regulations.—In determining whether a loss for worthless securities is subject to § 165(g)(3), (i) whether the source of any gross receipts may be determined by reference to the source of gross receipts of a counter party to an intercompany transaction, as defined in § 1.1502–13(b)(1) (e.g., an intercompany distribution to which § 1.1502–13(f)(2) applies), other than an intercompany transaction to which § 381(a) applies, and (ii) in an intercompany transaction to which § 381(a) applies, whether the acquiring corporation takes into account historic gross receipts of the distributor or transferor corporation, if the intercompany transaction is part of a plan to claim a deduction for worthless securities under § 165(g)(3).
(34) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether a charitable contribution deduction under § 170 is allowed for a transfer of an interest in a limited partnership or a limited liability company taxed as a partnership to an organization described in § 170(c).
(35) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether a taxpayer who advances funds to a charitable organization and receives therefor a promissory note may deduct as contributions, in one taxable year or in each of several years, amounts forgiven by the taxpayer in each of several years by endorsement on the note.
(36) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether an organization is or continues to be described in § 170(b)(1)(A) (other than clause (v)) or § 170(c)(2) – (5), including, for example, whether changes in an organization’s activities or operations will affect or jeopardize the organization’s status as an organization described in those sections. The Associate Chief Counsel (EEE) will rule, however, on specific legal questions related to §§ 170(b)(1)(A) or 170(c) that are not otherwise described in this revenue procedure. See Rev. Proc. 2019–5, this Bulletin, for the procedures for obtaining determination letters on public charity status under § 170.
(37) Section 181.—Treatment of Certain Qualified Film and Television Productions.—The determination under § 1.181–1(a)(1) and (2) as to who is the owner of a qualified film or television production.
(38) Section 199.—Income Attributable to Domestic Production Activities.—The determination under § 1.199–3(f)(1) as to who is the taxpayer that has the benefits and burdens of ownership under Federal income tax principles of any qualifying production property (as defined in § 1.199–3(j)(1)), qualified film (as defined in § 1.199–3(k)), or utilities (as defined in § 1.199–3(l)) during the period in which a qualifying activity under § 199 occurs.
(39) Section 213.—Medical, Dental, Etc., Expenses.—Whether a capital expenditure for an item that is ordinarily used for personal, living, or family purposes, such as a swimming pool, has as its primary purpose the medical care of the taxpayer or the taxpayer’s spouse or dependent, or is related directly to such medical care.
(40) Section 216.—Deduction of Taxes, Interest, and Business Depreciation by Cooperative Housing Corporation Tenant-Stockholder.—Whether a unit constitutes an “apartment in a building” under § 216(b)(1)(B).
(41) Section 264.—Certain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(d)(1) applies.
(42) Section 264(c)(1).—Contracts Treated as Single Premium Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 years from the date on which the contract is purchased. Also, whether an amount deposited is in payment of a “substantial number” of future premiums on such a contract.
(43) Sections 267, 304, 331, 332, 351, and 1502.—Losses, Expenses, and Interest with Respect to Transactions Between Related Taxpayers; Redemption Through Use of Related Corporations; Gain or Loss to Shareholders in Corporate Liquidations; Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Regulations.—The treatment of transactions in which stock of a corporation is transferred with a plan or intention that the corporation be liquidated in a transaction intended to qualify under § 331.
(44) Section 269.—Acquisitions Made to Evade or Avoid Income Tax.—Whether an acquisition is within the meaning of § 269.
(45) Section 274.—Disallowance of Certain Entertainment, Etc., Expenses.—Whether a taxpayer who is traveling away from home on business may, in lieu of substantiating the actual cost of meals, deduct a fixed per-day amount for meal expenses that differs from the amount authorized by the revenue procedure providing optional rules for substantiating the amount of travel expenses for the period in which the expense was paid or incurred.
(46) Section 302.—Distributions in Redemption of Stock.—Whether § 302(b) applies when the consideration given in redemption by a corporation consists entirely or partly of its notes payable, and the shareholder’s stock is held in escrow or as security for payment of the notes with the possibility that the stock may or will be returned to the shareholder in the future, upon the happening of specific defaults by the corporation.
(47) Section 302.—Distributions in Redemption of Stock.—Whether § 302(b) applies when the consideration given in redemption by a corporation in exchange for a shareholder’s stock consists entirely or partly of the corporation’s promise to pay an amount based on, or contingent on, future earnings of the corporation, when the promise to pay is contingent on working capital being maintained at a certain level, or any other similar contingency.
(48) Section 302.—Distributions in Redemption of Stock.—Whether § 302(b) applies to a redemption of stock, if, after the redemption, the distributing corporation uses property that is owned by the shareholder from whom the stock is redeemed and the payments by the corporation for the use of the property are dependent upon the corporation’s future earnings or are subordinate to the claims of the corporation’s general creditors. Payments for the use of property will not be considered to be dependent upon future earnings merely because they are based on a fixed percentage of receipts or sales.
(49) Section 302.—Distributions in Redemption of Stock.—Whether the acquisition or disposition of stock described in § 302(c)(2)(B) has, or does not have, as one of its principal purposes the avoidance of Federal income taxes within the meaning of that section, unless the facts and circumstances are materially identical to those set forth in Rev. Rul. 85–19, 1985–1 C.B. 94; Rev. Rul. 79–67, 1979–1 C.B. 128; Rev. Rul. 77–293, 1977–2 C.B. 91; Rev. Rul. 57–387, 1957–2 C.B. 225; Rev. Rul. 56–584, 1956–2 C.B. 179; or Rev. Rul. 56–556, 1956–2 C.B. 177.
(50) Section 302(b)(4) and (e).—Redemption from Noncorporate Shareholder in Partial Liquidation; Partial Liquidation Defined.—The amount of working capital attributable to a business or portion of a business terminated that may be distributed in partial liquidation.
(51) Section 304.—See section 3.01(43), above.
(52) Section 312.—Effect on Earnings and Profits.—The determination of the amount of earnings and profits of a corporation.
(53) Sections 331, 453, and 1239.—Gain or Loss to Shareholders in Corporate Liquidations; Installment Method; Gain from Sale of Depreciable Property Between Certain Related Taxpayers.—The tax effects of a transaction in which there is a transfer of property by a corporation to a partnership or other noncorporate entity (or the transfer of stock to such entity followed by a liquidation of the corporation) when more than a nominal amount of the stock of such corporation and the capital or beneficial interests in the purchasing entity (that is, more than 20 percent in value) is owned by the same persons, and the consideration to be received by the selling corporation or the selling shareholders includes an installment obligation of the purchasing entity.
(55) Sections 332, 351, 368, and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; Stock for Stock of Same Corporation.—Whether a transaction qualifies under § 332, 351, or 1036 for nonrecognition treatment or whether it constitutes a corporate reorganization within the meaning of § 368, except a transaction intended to qualify under §§ 368(a)(1)(D) and 355, and whether various tax consequences (such as nonrecognition and basis) result from the application of that section. The Service will instead rule only on significant issues presented in a transaction described in § 332, 351, 368, or 1036. Additionally, the Service will rule on one or more significant issues under the Code sections that address the tax consequences (such as nonrecognition and basis) that result from the qualification of a transaction under § 332, 351, 368, or 1036. See section 6.03(2) of Rev. Proc. 2019–1, this Bulletin.
SIGNIFICANT ISSUE: A significant issue is a germane and specific issue of law, provided that a ruling on the issue would not be a comfort ruling, as defined in section 6.11 of Rev. Proc. 2019–1, or the conclusion in such a ruling otherwise would not be essentially free from doubt. An issue is germane if resolution of the issue is necessary to determine an element of the tax treatment of the transaction. An issue is specific if it is the narrowest articulation of the germane issue. A change of circumstances arising after a transaction ordinarily does not present a significant issue with respect to the transaction.
OBTAINING A LETTER RULING: To obtain a letter ruling on a significant issue presented in a transaction, the taxpayer in its letter ruling request must comply with all the requirements set forth in section 6.03(2) of Rev. Proc. 2019–1, as well as Rev. Proc. 2019–1, in general.
(57) Section 351.—See sections 3.01(43) and (55), above.
(58) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the distribution of the stock of a controlled corporation is being carried out for one or more corporate business purposes, whether the transaction is used principally as a device, and whether the distribution and an acquisition are part of a plan under § 355(e). Notwithstanding the preceding sentence, the Service: (i) will issue a letter ruling with respect to a significant issue under § 1.355–2(b) pertaining to the corporate business purpose requirement, provided that the issue is a legal issue and is not inherently factual in nature, (ii) will issue a letter ruling with respect to a significant issue under § 355(a)(1)(B) and § 1.355–2(d) pertaining to device, provided that the issue is a legal issue and is not inherently factual in nature, and (iii) may issue a ruling regarding the effect of redemptions under § 355(e) pending the issuance of temporary or final regulations regarding redemptions under § 355(e) if an adverse ruling on such question would result in there being a direct or indirect acquisition by one or more persons of stock representing a 50-percent or greater interest in the distributing corporation or the controlled corporation that is part of a plan under § 355(e).
(59) Section 358.—Basis to Distributees.—The acceptability of an estimation procedure or the acceptability of a specific sampling procedure to determine the basis of stock acquired by an acquiring corporation in a reorganization described in § 368(a)(1)(B).
(62) Section 403(b).—Taxability of Beneficiary Under Annuity Purchased by Section 501(c)(3) Organization or Public School.—Whether the form of a plan satisfies the requirements of § 403(b) as provided in Rev. Proc. 2019–4, this Bulletin.
(63) Section 409A.—Inclusion in Gross Income of Deferred Compensation Under Nonqualified Deferred Compensation Plans.—The income tax consequences of establishing, operating, or participating in a nonqualified deferred compensation plan within the meaning of § 1.409A–1(a); whether a plan is described in § 1.409A–1(a)(3)(iv) or (v); whether a plan is a bona fide vacation leave, sick leave, or compensatory time plan described in § 1.409A–1(a)(5); and whether a plan provides for the deferral of compensation under § 1.409A–1(b).
(64) Section 411(d)(3).—Termination or Partial Termination; Discontinuance of Contributions.—Whether there has been a partial termination of an employee plan. The Service may issue a determination letter involving the partial termination of an employee plan. See Rev. Proc. 2019–4, this Bulletin.
(65) Section 414(d).—Governmental Plan.—Whether a plan is a governmental plan under § 414(d).
(66) Section 419(e).—Welfare Benefit Fund.—Whether a captive insurance arrangement through which an employer provides health insurance to current or retired employees is a welfare benefit fund.
(67) Section 424.—Definitions and Special Rules.—Whether the substitution of a new Incentive Stock Option (ISO) for an old ISO, or the assumption of an old ISO, by an employer by reason of a corporate transaction constitutes a modification which results in the issuance of a new option by reason of failing to satisfy the spread test requirement of § 424(a)(1) or the ratio test requirement of § 1.425–1(a)(4). The Service will continue to rule on the issue of whether the new ISO or the assumption of the old ISO gives the employee additional benefits not present under the old option within the meaning of § 424(a)(2).
(68) Section 451.—General Rule for Taxable Year of Inclusion.—The tax consequences of a nonqualified unfunded deferred-compensation arrangement with respect to a controlling shareholder-employee eligible to participate in the arrangement.
(69) Section 451.—General Rule for Taxable Year of Inclusion.—The tax consequences of nonqualified unfunded deferred-compensation arrangements in which the arrangements fail to meet the requirements of Rev. Proc. 92–65, 1992–2 C.B. 428, and Rev. Proc. 71–19, 1971–1 C.B. 698.
(70) Sections 451 and 457.—General Rule for Taxable Year of Inclusion; Nonqualified Deferred Compensation Plans of State and Local Governments and Tax-Exempt Organizations.—The tax consequences to unidentified independent contractors in nonqualified unfunded deferred compensation plans. This applies to plans established under § 451 by employers in the private sector and to plans of state and local governments and tax-exempt organizations under § 457. However, a ruling with respect to a specific independent contractor’s participation in such a plan may be issued.
(74) Section 457A.—Nonqualified Deferred Compensation from Certain Tax Indifferent Parties.—The income tax consequences of establishing, operating, or participating in a nonqualified deferred compensation plan within the meaning of § 457A(d)(3).
(75) Section 501.—Exemption from Tax on Corporations, Certain Trusts, Etc.—Whether an organization is or continues to be exempt from taxation under § 501(a) as an organization described in §§ 501(c) or 501(d), including, for example, whether changes in an organization’s activities or operations will affect or jeopardize the organization’s exempt status. The Associate Chief Counsel (EEE) will rule, however, on specific legal questions related to §§ 501(c) or 501(d) that are not otherwise described in this revenue procedure. For example, although the Associate Chief Counsel (EEE) would not rule on whether a change in a § 501(c)(3) organization’s activities would jeopardize the organization’s exempt status, the Associate Chief Counsel (EEE) would (subject to the limitations described in this revenue procedure) rule on whether such new activities would further an exempt purpose described in § 501(c)(3). See Rev. Proc. 2019–5, this Bulletin, for the procedures for issuing determination letters on tax-exempt status under § 501.
(76) Sections 501, 511, 512, 513, and 514.—Exemption from Tax on Corporations, Certain Trusts, Etc.; Imposition of Tax on Unrelated Business Income of Charitable, Etc., Organizations; Unrelated Business Taxable Income; Unrelated Trade or Business; Unrelated Debt-Financed Income.—Whether a joint venture between a tax-exempt organization and a for-profit organization affects an organization’s exempt status, furthers an exempt purpose, or results in unrelated business income.
(77) Sections 507, 664, 4941, and 4945.—Termination of Private Foundation Status; Charitable Remainder Trusts; Taxes on Self-Dealing; Taxes on Taxable Expenditures.—Issues pertaining to the tax consequences of the termination of a charitable remainder trust (as defined in § 664) before the end of the trust term as defined in the trust’s governing instrument in a transaction in which the trust beneficiaries receive their actuarial shares of the value of the trust assets.
(78) Section 509.—Private Foundation Defined.—Whether an organization is or continues to be described in § 509(a) including, for example, whether changes in an organization’s activities or operations will affect or jeopardize the organization’s status as a public charity described in § 509(a)(1) – (4). The Associate Chief Counsel (EEE) will rule, however, on specific legal questions related to § 509(a) that are not otherwise described in this revenue procedure. See Rev. Proc. 2019–5, this Bulletin, for the procedures for obtaining determination letters on public charity status under § 509.
(79) Sections 511, 512, 513, and 514.—Imposition of Tax on Unrelated Business Income of Charitable, Etc., Organizations; Unrelated Business Taxable Income; Unrelated Trade or Business; Unrelated Debt-Financed Income.—Whether unrelated business income tax issues arise when charitable lead trust assets are invested with charitable organizations.
(80) Sections 511, 512, 513, and 514.—See section 3.01(76), above.
(81) Section 529.—Qualified Tuition Programs.—Whether a state-run tuition program qualifies under § 529.
(82) Sections 542, 543, and 544.—Definition of Personal Holding Company; Personal Holding Company Income; Rules for Determining Stock Ownership.—Whether the application of § 544(a) causes a corporation to meet the stock ownership requirements under § 542(a)(2), § 543(a)(4), § 543(a)(6), or § 543(a)(7).
(83) Section 641.—Imposition of Tax.—Whether the period of administration or settlement of an estate or a trust (other than a trust described in § 664) is reasonable or unduly prolonged.
(84) Section 642(c).—Deduction for Amounts Paid or Permanently Set Aside for a Charitable Purpose.—Allowance of an unlimited deduction for amounts set aside by a trust or estate for charitable purposes when there is a possibility that the corpus of the trust or estate may be invaded.
(85) Section 643(f).—Treatment of multiple trusts.—Whether two or more trusts shall be treated as one trust for purposes of subchapter J of chapter 1.
(86) Section 664.—Charitable Remainder Trusts.—Whether the settlement of a charitable remainder trust upon the termination of the noncharitable interest is made within a reasonable period of time.
(88) Section 671.—Trust Income, Deductions, and Credits Attributable to Grantors and Others as Substantial Owners.—Whether the grantor will be considered the owner of any portion of a trust when (i) substantially all of the trust corpus consists or will consist of insurance policies on the life of the grantor or the grantor’s spouse, (ii) the trustee or any other person has a power to apply the trust’s income or corpus to the payment of premiums on policies of insurance on the life of the grantor or the grantor’s spouse, (iii) the trustee or any other person has a power to use the trust’s assets to make loans to the grantor’s estate or to purchase assets from the grantor’s estate, and (iv) there is a right or power in any person that would cause the grantor to be treated as the owner of all or a portion of the trust under §§ 673 to 677.
(89) Section 704(b).—Determination of Distributive Share.—Whether the allocation to a partner under the partnership agreement of income, gain, loss, deduction, or credit (or an item thereof) has substantial economic effect or is in accordance with the partner’s interest in the partnership.
(90) Section 761.—Terms Defined.—Matters relating to the validity of a partnership or whether a person is a partner in a partnership.
(92) Section 856.—Definition of Real Estate Investment Trust.—Whether a corporation whose stock is “paired” with or “stapled” to stock of another corporation will qualify as a real estate investment trust under § 856, if the activities of the corporations are integrated.
(93) Section 1001.—Determination of Amount of and Recognition of Gain or Loss.—Whether the termination of a charitable remainder trust before the end of the trust term as defined in the trust’s governing instrument, in a transaction in which the trust beneficiaries receive their actuarial shares of the value of the trust assets, is treated as a sale or other disposition by the beneficiaries of their interests in the trust.
(94) Section 1001.—See section 3.01(10), above.
(95) Section 1033.—Involuntary Conversions.—Whether the replacement or proposed replacement of compulsorily or involuntarily converted property does or does not qualify under § 1033(a), if the taxpayer has already filed a Federal tax return for the first taxable year in which any of the gain was realized from the converted property. The Service may issue a determination letter in this case. See section 12.01 of Rev. Proc. 2019–1, this Bulletin.
(97) Section 1221.—Capital Asset Defined.—Whether specialty stock allocated to an investment account by a registered specialist on a national securities exchange is a capital asset.
(98) Section 1221.—Capital Asset Defined.—Whether the termination of a charitable remainder trust before the end of the trust term as defined in the trust’s governing instrument, in a transaction in which the trust beneficiaries receive their actuarial shares of the value of the trust assets, is treated as a sale or exchange of a capital asset by the beneficiaries.
(100) Section 1361.—S Corporation Defined.—Whether a state law limited partnership electing under § 301.7701–3 to be classified as an association taxable as a corporation has more than one class of stock for purposes of § 1361(b)(1)(D). The Service will treat any request for a ruling on whether a state law limited partnership is eligible to elect S corporation status as a request for a ruling on whether the partnership complies with § 1361(b)(1)(D).
(101) Section 1502.—Regulations.—If a member of an affiliated group fails to file Form 1122 or fails to join in the making of a consolidated return due to a mistake of law or fact, or inadvertence, whether such member will be treated as if it had filed a Form 1122. The Service may issue a determination letter in this case. See section 12.01 of Rev. Proc. 2019–1, this Bulletin. But see also section 6.07 of this revenue procedure.
(102) Section 1502.—See sections 3.01(33) and (43), above.
(103) Section 1551.—Disallowance of the Benefits of the Graduated Corporate Rates and Accumulated Earnings Credit.—Whether a transfer is within § 1551.
(104) Section 2031.—Definition of Gross Estate.—Actuarial factors for valuing interests in the prospective gross estate of a living person.
(105) Section 2055.—Transfers for Public, Charitable, and Religious Uses.—Whether a charitable contribution deduction under § 2055 is allowed for the transfer of an interest in a limited partnership or a limited liability company taxed as a partnership to an organization described in § 2055(a).
(106) Section 2512.—Valuation of Gifts.—Actuarial factors for valuing prospective or hypothetical gifts of a donor.
(107) Section 2522.—Charitable and Similar Gifts.—Whether a charitable contribution deduction under § 2522 is allowable for a transfer of an interest in a limited partnership or a limited liability company taxed as a partnership to an organization described in § 2522(a).
(108) Section 2601.—Tax Imposed.—Whether a trust exempt from generation-skipping transfer (GST) tax under § 26.2601–1(b)(1), (2), or (3) of the Generation-Skipping Transfer Tax Regulations will retain its GST exempt status when there is a modification of a trust, change in the administration of a trust, or a distribution from a trust in a factual scenario that is similar to a factual scenario set forth in one or more of the examples contained in § 26.2601–1(b)(4)(i)(E).
(109) Sections 3121, 3306, and 3401.—Definitions.—For purposes of determining prospective employment status, whether an individual will be an employee or an independent contractor. A ruling with regard to prior employment status may be issued.
(110) Sections 3121, 3306, and 3401.—Definitions.—Who is the employer of an “employee-owner” as defined in § 269A(b)(2).
(111) Sections 3121, 3306, and 3401.—Definitions.—For purposes of determining employment classification pursuant to the filing of Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding, whether a worker is a bona fide partner and, therefore, not an employee of the business.
(112) Section 4052(f)(1).—Certain Repairs and Modifications Not Treated as Manufacture.—Whether a chassis repaired or modified using a “glider kit” is treated as manufactured or produced if the cost of the repairs or modifications does not exceed 75 percent of the retail price of a comparable new chassis.
(113) Section 4191.—Medical Devices.—Whether a device (as defined in section 201(h) of the Federal Food, Drug, and Cosmetic Act) intended for humans is not a “taxable medical device” within the meaning of § 4191(b)(1) due to the application of the exemption provided in § 4191(b)(2) for eyeglasses, contact lenses, hearing aids, and any other medical device determined by the Secretary to be of a type which is generally purchased by the general public at retail for individual use.
(114) Section 4216(b).—Constructive Sale Price.—Whether a particular methodology for determining the tax base is allowable under the constructive sale price rules.
(115) Sections 4375, 4376, and 4377.—Health Insurance; Self-Insured Health Plans; Definitions and Special Rules.—Whether an arrangement is a specified health insurance policy or an applicable self-insured health plan that is subject to the fee applicable to such arrangements.
(116) Sections 4940 and 4942.—Excise Tax Based on Investment Income; Taxes on Failure to Distribute Income.—Whether an organization is or continues to be an “operating foundation” described in § 4942(j)(3) or an “exempt operating foundation” described in § 4940(d)(2), including, for example, whether changes in an organization’s activities or operations will affect or jeopardize the organization’s status as an operating foundation or exempt operating foundation. The Associate Chief Counsel (EEE) will rule, however, on specific legal questions related to §§ 4940(d)(2) or 4942(j)(3) that are not otherwise described in this revenue procedure. See Rev. Proc. 2019–5, this Bulletin, for the procedures for obtaining determination letters on foundation status under §§ 4940 and 4942.
(117) Section 4941.—Taxes on Self-Dealing.—Whether transactions during the administration of an estate or trust meet the requirements of the exception to § 4941 set forth in § 53.4941(d)–1(b)(3) of the Private Foundation Excise Tax Regulations, in cases in which a disqualified person issues a promissory note in exchange for property of an estate or trust.
(118) Section 4941.—See section 3.01(77), above.
(119) Section 4942.—See section 3.01(116), above.
(121) Section 4958.—Taxes on Excess Benefit Transactions.—Whether a compensation or property transaction satisfies the rebuttable presumption that the transaction is not an excess benefit transaction as described in § 53.4958–6 of the Excess Benefit Transactions Excise Tax Regulations.
(122) Section 4975(d).—Exemptions.—Whether the renewal, extension, or refinancing of an exempt loan satisfies the requirements of § 4975(d)(3). Also, whether the pre-payment of employee stock ownership plan (ESOP) loans satisfies the requirements of § 4975(d)(3) other than with respect to plan termination.
(123) Section 4980B.—Failure to Satisfy Continuation Coverage Requirements of Group Health Plans.—Whether an action is “gross misconduct” within the meaning of § 4980B(f)(3)(B). (See section 3.05 of Rev. Proc. 87–28, 1987–1 C.B. 770, 771.)
(124) Section 4980H.—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b).
(125) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discharge that include as grounds for the request a dispute regarding the underlying liability.
(126) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Whether amounts reduced pursuant to the terms of a debt instrument are reportable under § 6050P and the regulations.
(127) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Whether amounts discharged in a nonlending transaction are reportable under § 6050P and the regulations.
(128) Section 6166.—Extension of Time for Payment of Estate Tax Where Estate Consists Largely of Interest in Closely Held Business.—Requests involving § 6166 if there is no decedent.
(129) Section 6901.—Transferred Assets.—Whether a taxpayer is liable for tax as a transferee.
(130) Section 7216.—Disclosure or Use of Information by Preparers of Returns.—Whether a criminal penalty is applicable for any disclosure or use of information by preparers of returns.
(131) Section 7701.—Definitions.—The classification of an instrument that has certain voting and liquidation rights in an issuing corporation but whose dividend rights are determined by reference to the earnings of a segregated portion of the issuing corporation’s assets, including assets held by a subsidiary.
(132) Section 7701.—Definitions.—The classification for Federal tax purposes of a fideicomiso or other land trust created under local law, applying the principles of Rev. Rul. 2013–14, 2013–26 I.R.B. 1267, or Rev. Rul. 92–105, 1992–2 C.B. 204.
(134) Section 7704.—Certain Publicly Traded Partnerships Treated as Corporations.—Whether interests in a partnership that are not traded on an established securities market (within the meaning of § 7704(b) and § 1.7704–1(b) of the Procedure and Administration Regulations) are readily tradable on a secondary market or the substantial equivalent thereof under § 1.7704–1(c)(1). This specifically includes, but is not limited to, whether an investment fund or portfolio supporting variable contract arrangements of life insurance companies is a publicly traded partnership.
(135) Section 9815.—Additional Market Reforms.—Whether an insured group health plan satisfies the requirements of § 2716 of the Public Health Service Act, Prohibition on Discrimination in Favor of Highly Compensated Individuals, as incorporated into the Code by § 9815.
.02 General Areas.
(1) Whether the economic substance doctrine is relevant to any transaction or whether any transaction complies with the requirements of § 7701(o).
(2) The results of transactions that lack a bona fide business purpose or have as their principal purpose the reduction of Federal taxes.
(3) A matter upon which a court decision adverse to the Government has been handed down and the question of following the decision or litigating further has not yet been resolved.
(4) A matter involving alternate plans of proposed transactions or involving hypothetical situations.
(5) Whether under Subtitle F (Procedure and Administration) reasonable cause, due diligence, good faith, clear and convincing evidence, or other similar terms that require a factual determination exist.
(6) A matter involving the regulations governing practice before the Service under 31 CFR Part 10 (reprinted as Treasury Department Circular No. 230).
(7) Whether a proposed transaction would subject the taxpayer to a criminal penalty.
(8) Whether a completed transaction can be rescinded for Federal income tax purposes.
(9) The income tax (including unrelated business income tax) or excise tax consequences of the contribution of stock options to, or their subsequent exercise from, plans described in Part 1 of Subchapter D of Chapter 1 of Subtitle A of the Code.
(10) Questions that the Service determines, in its discretion, should not be answered in the general interests of sound tax administration, including due to resource constraints.
(11) Any frivolous issue, as that term is defined in section 6.10 of Rev. Proc. 2019–1, this Bulletin.
(12) A request that does not comply with the provisions of Rev. Proc. 2019–1, this Bulletin.
SECTION 4. AREAS IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT ORDINARILY BE ISSUED
(1) Sections 38, 39, 46, and 48.—General Business Credit; Carryback and Carryforward of Unused Credits; Amount of Credit; Energy Credit.—Application of these sections if the formal ownership of property is in a party other than the taxpayer, except when title is held merely as security.
(2) Section 61.—Gross Income Defined.—Determination as to who is the true owner of property in cases involving the sale of securities, or participation interests therein, if the purchaser has the contractual right to cause the securities, or participation interests therein, to be purchased by either the seller or a third party.
(3) Sections 61 and 163.—Gross Income Defined; Interest.—Determinations as to who is the true owner of property or the true borrower of money in cases in which the formal ownership of the property, or the liability for the indebtedness, is in another party.
(4) Section 62(c).—Certain Arrangements Not Treated as Reimbursement Arrangements.—Whether amounts related to a salary reduction and paid under a purported reimbursement or other expense allowance arrangement will be treated as paid under an “accountable plan” in accordance with § 1.62–2(c)(2).
(5) Sections 83 and 451.—Property Transferred in Connection with Performance of Services; General Rule for Taxable Year of Inclusion.—When compensation is realized by a person who, in connection with the performance of services, is granted a nonstatutory option without a readily ascertainable fair market value to purchase stock at a price that is less than the fair market value of the stock on the date the option is granted.
(6) Sections 101 and 7702.—Certain Death Benefits; Life Insurance Contract Defined.—Whether amounts received under an arrangement with an entity that is not regulated as an insurance company may be treated as received under a “life insurance contract” within the meaning of §§ 101(a) and 7702.
(7) Section 103.—Interest on State and Local Bonds.—Whether the interest on state or local bonds will be excludible from gross income under § 103(a), if the proceeds of issues of bonds (other than advance refunding issues) are placed in escrow or otherwise not expended for a governmental purpose for an extended period of time even though the proceeds are invested at a yield that will not exceed the yield on the state or local bonds prior to their expenditure.
(8) Section 103.—Interest on State and Local Bonds.—Whether a state or local governmental obligation that does not meet the criteria of section 5 of Rev. Proc. 89–5, 1989–1 C.B. 774, is an “arbitrage bond” within the meaning of former § 103(c)(2) solely by reason of the investment of the bond proceeds in acquired nonpurpose obligations at a materially higher yield more than 3 years after issuance of the bonds or 5 years after issuance of the bonds in the case of construction issues described in former § 1.103–13(a)(2)(ii)(E) or § 1.148–2(e)(2)(ii).
(9) Section 141.—Private Activity Bond; Qualified Bond.—Whether state or local bonds will meet the “private business use test” and the “private security or payment test” under § 141(b)(1) and (2) in situations in which the proceeds are used to finance certain output facilities and, pursuant to a contract to take, or take or pay for, a nongovernmental person purchases 30 percent or more of the actual output of the facility but 10 percent or less of the available output of the facility as defined in § 1.141–7(b)(1). In similar situations, the Service will not ordinarily issue rulings or determination letters concerning questions arising under paragraphs (3), (4), and (5) of § 141(b).
(10) Sections 142 and 144(a).—Exempt Facility Bond; Qualified Small Issue Bond.—Whether an issue of private activity bonds meets the requirements of § 142 or § 144(a), if the sum of—
(i) the portion of the proceeds used to finance a facility in which an owner (or related person) or a lessee (or a related person) is a user of the facility both after the bonds are issued and at any time before the bonds were issued, and
(ii) the portion used to pay issuance costs and nonqualified costs equals more than 5 percent of the net proceeds, as defined in § 150(a)(3).
(11) Section 148.—Arbitrage.—Whether amounts received as proceeds from the sale of municipal bond financed property and pledged to the payment of debt service or pledged as collateral for the municipal bond issue are sinking fund proceeds within the meaning of former § 1.103–13(g) (issued under former § 103(c)) or replaced proceeds described in § 148(a)(2) (or former § 103(c)(2)(B)).
(12) Sections 162 and 262.—Trade or Business Expenses; Personal, Living, and Family Expenses.—Whether expenses are nondeductible commuting expenses, except for situations governed by Rev. Rul. 99–7, 1999–1 C.B. 361.
(13) Section 162(m).—Certain Excessive Employee Remuneration.—Whether the deduction limit under § 162(m) applies to compensation attributable to services performed for a related partnership.
(14) Section 163.—See section 4.01(3), above.
(15) Section 165.—Losses.—Whether stock in a corporation has been abandoned.
(16) Section 167.—Depreciation.
(i) Useful lives of assets.
(ii) Depreciation rates.
(iii) Salvage value of assets.
(17) Sections 167 and 168.—Depreciation; Accelerated Cost Recovery System.—Application of those sections in which the formal ownership of property is in a party other than the taxpayer except when title is held merely as security.
(18) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable contribution deduction under § 170(f)(2)(A).
(19) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one or two measuring lives qualifies for a charitable deduction under § 170(f)(2)(A).
(20) Section 170.—Charitable, Etc., Contributions and Gifts.—Whether a taxpayer who transfers property to a charitable organization and thereafter leases back all or a portion of the transferred property may deduct the fair market value of the property transferred and leased back as a charitable contribution.
(21) Section 216.—Deduction of Taxes, Interest, and Business Depreciation by Cooperative Housing Corporation Tenant-Stockholder.—If a cooperative housing corporation (CHC), as defined in § 216(b)(1), transfers an interest in real property to a corporation (not a CHC) in exchange for stock or securities of the transferee corporation, which engages in commercial activity with respect to the real property interest transferred, whether (i) the income of the transferee corporation derived from the commercial activity and (ii) any cash or property (attributable to the real property interest transferred) distributed by the transferee corporation to the CHC will be considered as gross income of the CHC for the purpose of determining whether 80 percent or more of the gross income of the CHC is derived from tenant-stockholders within the meaning of § 216(b)(1)(D).
(23) Section 265(a)(2).—Interest.—Whether indebtedness is incurred or continued to purchase or carry obligations the interest on which is wholly exempt from the taxes imposed by Subtitle A.
(24) Section 302.—Distributions in Redemption of Stock.—The tax effect of the redemption of stock for notes, when the payments on the notes are to be made over a period in excess of 15 years from the date of issuance of such notes.
(25) Section 302(b)(4) and (e).—Redemption from Noncorporate Shareholder in Partial Liquidation; Partial Liquidation Defined.—Whether a distribution will qualify as a distribution in partial liquidation under § 302(b)(4) and (e)(1)(A), unless it results in a 20 percent or greater reduction in (i) gross revenue, (ii) net fair market value of assets, and (iii) employees. (Partial liquidations that qualify as § 302(e)(2) business terminations are not subject to this provision.)
(26) Section 306.—Dispositions of Certain Stock.—Whether the distribution, disposition, or redemption of “section 306 stock” in a closely held corporation is in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes within the meaning of § 306(b)(4).
(27) Sections 331 and 346(a).—Gain or Loss to Shareholders in Corporate Liquidations; Complete Liquidation.—The tax effect of the liquidation of a corporation by a series of distributions, when the distributions in liquidation are to be made over a period in excess of 3 years from the adoption of the plan of liquidation.
(28) Section 351.—Transfer to Corporation Controlled by Transferor.—Whether § 351 applies to the transfer of an interest in real property by a cooperative housing corporation (as described in § 216(b)(1)) to a corporation in exchange for stock or securities of the transferee corporation, if the transferee engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acquired control of a controlled corporation as a result of the distributing corporation transferring cash or other liquid or inactive assets to the controlled corporation in a transaction in which gain or loss was not recognized as a result of the transfer meeting the requirements of § 351(a) or § 368(a)(1)(D).
(30) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Any issue relating to the qualification, under § 355 and related provisions, of a distribution, or another distribution which is part of the same plan or series of related transactions, if, immediately after any such distribution, the fair market value of the gross assets of the trade(s) or business(es) on which the distributing corporation or the controlled corporation relies to satisfy the active trade or business requirement of § 355(b) is less than five percent of the fair market value of the total gross assets of such corporation.
For purposes of determining the fair market value of the total gross assets of such corporation and of the gross assets of such trade(s) or business(es), (i) all members of a separate affiliated group, within the meaning of § 355(b)(3)(B), are treated as one corporation; and (ii) if the distributing corporation or the controlled corporation relies on an active trade or business of a partnership for purposes of § 355(b), such corporation is treated as owning its ratable share of the gross assets of the partnership.
This section 4.01(30) does not apply if (i) all the stock of the controlled corporation that is distributed in the distribution is distributed to one or more members of the affiliated group, as defined in § 243(b)(2)(A), of which the distributing corporation is a member; and (ii) such distribution is not part of a plan or series of related transactions pursuant to which stock of any corporation will be distributed outside such affiliated group in a distribution described in this section 4.01(30) or section 5.01(3) of this revenue procedure.
(31) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Any issue under § 355(e) other than whether a distribution and an acquisition are part of a plan (i.e., any non-plan issue). Notwithstanding the preceding sentence, the Service generally will rule on a non-plan issue or issues (e.g., whether a corporation constitutes a predecessor of distributing) if an adverse ruling on such non-plan issue or issues would result in there being a direct or indirect acquisition by one or more persons of stock representing a 50-percent or greater interest in the distributing corporation or the controlled corporation that is part of a plan under § 355(e).
(32) Section 441(i).—Taxable Year of Personal Service Corporations.—Whether the principal activity of the taxpayer during the testing period for the taxable year is the performance of personal services within the meaning of § 1.441–3(c)(1)(iii).
(33) Section 448(d)(2)(A).—Limitation on Use of Cash Method of Accounting; Qualified Personal Service Corporation.—Whether 95 percent or more of the time spent by employees of the corporation, serving in their capacity as such, is devoted to the performance of services within the meaning of § 1.448–1T(e)(4)(i).
(34) Section 451.—General Rule for Taxable Year of Inclusion.—The tax consequences of a nonqualified deferred compensation arrangement using a grantor trust if the trust fails to meet the requirements of Rev. Proc. 92–64, 1992–2 C.B. 422.
(35) Section 451.—General Rule for Taxable Year of Inclusion.—The income tax consequences as a result of being a beneficiary of a trust that an Indian tribe (as defined in 25 U.S.C. § 2703(5)) establishes to receive and invest per capita payments for its members under the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701 through 2721).
(37) Section 584.—Common Trust Funds.—Whether a common trust fund plan meets the requirements of § 584. (For § 584 plan drafting guidance, see Rev. Proc. 92–51, 1992–1 C.B. 988.)
(38) Section 642.—Special Rules for Credits and Deductions.—Whether a pooled income fund satisfies the requirements described in § 642(c)(5).
(39) Section 664.—Charitable Remainder Trusts.—Whether a charitable remainder trust that provides for annuity or unitrust payments for one or two measuring lives or for annuity or unitrust payments for a term of years satisfies the requirements described in § 664.
(40) Section 664.—Charitable Remainder Trusts.—Whether a trust that will calculate the unitrust amount under § 664(d)(3) qualifies as a § 664 charitable remainder trust when a grantor, a trustee, a beneficiary, or a person related or subordinate to a grantor, a trustee, or a beneficiary can control the timing of the trust’s receipt of trust income from a partnership or a deferred annuity contract to take advantage of the difference between trust income under § 643(b) and income for Federal income tax purposes for the benefit of the unitrust recipient.
(41) Sections 671 to 679.—Grantors and Others Treated as Substantial Owners.—In a nonqualified, unfunded deferred compensation arrangement described in Rev. Proc. 92–64, 1992–2 C.B. 422, the tax consequences of the use of a trust, other than the model trust described in that revenue procedure.
(42) Sections 671 to 679.—Grantors and Others Treated as Substantial Owners.—Whether an Indian tribe (as defined in 25 U.S.C. § 2703(5)) that establishes a trust to receive and invest per capita payments for its members under the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701–2721) is the grantor and owner of the trust.
(43) Section 678.—Person Other than Grantor Treated as Substantial Owner.— Whether a person will be treated as the owner of any portion of a trust over which that person has a power to withdraw the trust property (or had such power prior to a release or modification, but retains other powers which would cause that person to be the owner of the trust under § 671 if the person were the grantor), other than a power which would constitute a general power of appointment within the meaning of § 2041, if the trust purchases the property from that person with a note and the value of the assets with which the trust was funded by the grantor is nominal compared to the value of the property purchased.
(44) Section 851.—Definition of Regulated Investment Company.—Any issue relating to the treatment of a corporation as a regulated investment company under § 851 and related provisions that requires a determination whether a financial instrument or position is a security as defined in the Investment Company Act of 1940.
(45) Section 856.—Definition of Real Estate Investment Trust.—Whether an outdoor advertising display constitutes real property for purposes of § 856. However, if the real estate investment trust has made an election under § 1.1033(g)–1(b), the Service may rule on whether an asset that is not within the scope of the election, but is related to the outdoor advertising display, constitutes real property for purposes of § 856.
(46) Section 1031(f).—Special Rules for Exchanges Between Related Persons.—Except in the case of (i) a transaction involving an exchange of undivided interests in different properties that results in each taxpayer holding either the entire interest in a single property or a larger undivided interest in any of the properties or (ii) a disposition of property in a nonrecognition transaction in which the taxpayer or the related party receives no cash or other property that results in gain recognition, whether an exchange described in § 1031(f) involving related parties, or a subsequent disposition of property involved in the exchange, has as one of its principal purposes the avoidance of Federal income tax, or is part of a transaction (or series of transactions) structured to avoid the purposes of § 1031(f).
(47) Section 1362.—Election; Revocation; Termination.—All situations in which the Service has provided an automatic approval procedure or administrative procedure for an S corporation to obtain relief for late S corporation, qualified subchapter S subsidiary, qualified subchapter S trust, or electing small business trust elections. See Rev. Proc. 2013–30, 2013–36 I.R.B. 173. (For instructions on how to seek this relief, see the preceding revenue procedure.)
(48) Section 1502.—Regulations.—Whether a parent cooperative housing corporation (as defined in § 216(b)(1)) will be permitted to file a consolidated income tax return with its transferee subsidiary, if the transferee engages in commercial activity with respect to the real property interest transferred to it by the parent.
(49) Sections 2035, 2036, 2037, 2038, and 2042.—Adjustments for Certain Gifts Made Within Three Years of Decedent’s Death; Transfers with Retained Life Estate; Transfers Taking Effect at Death; Revocable Transfers; Proceeds of Life Insurance.—Whether trust assets are includible in a trust beneficiary’s gross estate under § 2035, 2036, 2037, 2038, or 2042 if the beneficiary sells property (including insurance policies) to the trust or dies within 3 years of selling such property to the trust, and (i) the beneficiary has a power to withdraw the trust property (or had such power prior to a release or modification, but retains other powers which would cause that person to be the owner if the person were the grantor), other than a power which would constitute a general power of appointment within the meaning of § 2041, (ii) the trust purchases the property with a note, and (iii) the value of the assets with which the trust was funded by the grantor is nominal compared to the value of the property purchased.
(50) Section 2055.—Transfers for Public, Charitable, and Religious Uses.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2055(e)(2)(A).
(51) Section 2055.—Transfers for Public, Charitable, and Religious Uses.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one or two measuring lives or a term of years qualifies for a charitable deduction under § 2055(e)(2)(A).
(52) Section 2501.—Imposition of Tax.—Whether the sale of property (including insurance policies) to a trust by a trust beneficiary will be treated as a gift for purposes of § 2501 if (i) the beneficiary has a power to withdraw the trust property (or had such power prior to a release or modification, but retains other powers which would cause that person to be the owner if the person were the grantor), other than a power which would constitute a general power of appointment within the meaning of § 2041, (ii) the trust purchases the property with a note, and (iii) the value of the assets with which the trust was funded by the grantor is nominal compared to the value of the property purchased.
(53) Section 2503.—Taxable Gifts.—Whether the transfer of property to a trust will be a gift of a present interest in property when (i) the trust corpus consists or will consist substantially of insurance policies on the life of the grantor or the grantor’s spouse, (ii) the trustee or any other person has a power to apply the trust’s income or corpus to the payment of premiums on policies of insurance on the life of the grantor or the grantor’s spouse, (iii) the trustee or any other person has a power to use the trust’s assets to make loans to the grantor’s estate or to purchase assets from the grantor’s estate, (iv) the trust beneficiaries have the power to withdraw, on demand, any additional transfers made to the trust, and (v) there is a right or power in any person that would cause the grantor to be treated as the owner of all or a portion of the trust under §§ 673 to 677.
(54) Section 2514.—Powers of Appointment.—If the beneficiaries of a trust permit a power of withdrawal to lapse, whether § 2514(e) will be applicable to each beneficiary in regard to the power when (i) the trust corpus consists or will consist substantially of insurance policies on the life of the grantor or the grantor’s spouse, (ii) the trustee or any other person has a power to apply the trust’s income or corpus to the payment of premiums on policies of insurance on the life of the grantor or the grantor’s spouse, (iii) the trustee or any other person has a power to use the trust’s assets to make loans to the grantor’s estate or to purchase assets from the grantor’s estate, (iv) the trust beneficiaries have the power to withdraw, on demand, any additional transfers made to the trust, and (v) there is a right or power in any person that would cause the grantor to be treated as the owner of all or a portion of the trust under §§ 673 to 677.
(55) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(56) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one or two measuring lives or a term of years qualifies for a charitable deduction under § 2522(c)(2)(A).
(57) Section 2601.—Tax Imposed.—Whether a trust that is exempt from the application of the generation-skipping transfer tax because it was irrevocable on September 25, 1985, will lose its exempt status if the situs of the trust is changed from the United States to a situs outside of the United States.
(58) Section 2702.—Special Valuation Rules in Case of Transfers of Interests in Trusts.—Whether annuity interests are qualified annuity interests under § 2702 if the amount of the annuity payable annually is more than 50 percent of the initial net fair market value of the property transferred to the trust, or if the value of the remainder interest is less than 10 percent of the initial net fair market value of the property transferred to the trust. For purposes of the 10 percent test, the value of the remainder interest is the present value determined under § 7520 of the right to receive the trust corpus at the expiration of the term of the trust. The possibility that the grantor may die prior to the expiration of the specified term is not taken into account, nor is the value of any reversion retained by the grantor or the grantor’s estate.
(59) Section 2702.—Special Valuation Rules in Case of Transfers of Interests in Trusts.—Whether a trust with one term holder satisfies the requirements of § 2702(a)(3)(A) and § 25.2702–5(c) to be a qualified personal residence trust.
(60) Section 2702.—Special Valuation Rules in Case of Transfers of Interests in Trusts.—Whether the sale of property (including insurance policies) to a trust by a trust beneficiary is subject to § 2702 if (i) the beneficiary has a power to withdraw the trust property (or had such power prior to a release or modification, but retains other powers which would cause that person to be the owner if the person were the grantor), other than a power which would constitute a general power of appointment within the meaning of § 2041, (ii) the trust purchases the property with a note, and (iii) the value of the assets with which the trust was funded by the grantor is nominal compared to the value of the property purchased.
(61) Section 3121.—Definitions.—Determinations as to which of two entities, under common law rules applicable in determining the employer-employee relationship, is the employer, when one entity is treating the worker as an employee.
(62) Section 7702.—See section 4.01(6), above.
(1) Any matter in which the determination requested is primarily one of fact, e.g., market value of property, or whether an interest in a corporation is to be treated as stock or indebtedness. Although it is generally inappropriate for the Service to issue a letter ruling on whether an interest in a corporation is stock or indebtedness, there may be instances in which the Service may issue a letter ruling. For example, the Service may issue a letter ruling with respect to an instrument issued by a domestic corporation if (i) the taxpayer believes that the facts strongly support the classification of the instrument as stock and (ii) the taxpayer can demonstrate that there are unique and compelling reasons to justify the issuance of a letter ruling. Before preparing the letter ruling request, the taxpayer should call the Office of Associate Chief Counsel having jurisdiction for the matters on which the taxpayer is seeking a letter ruling to discuss whether the Service will consider issuing a letter ruling for a particular factual situation. To determine which Associate office has jurisdiction over a particular issue see section 3 of Rev. Proc. 2019–1, this Bulletin. For a list of telephone numbers for the different Associate offices, see section 10.07 of Rev. Proc. 2019–1.
(2) Situations in which the requested ruling deals with only part of an integrated transaction. Generally, a letter ruling will not be issued on only part of an integrated transaction. If, however, a part of a transaction falls under a no-rule area, a letter ruling on other parts of the transaction may be issued. Before preparing the letter ruling request, the taxpayer should call the Office of Associate Chief Counsel having jurisdiction for the matters on which the taxpayer is seeking a letter ruling to discuss whether a letter ruling will be issued on part of the transaction. To determine which Associate office has jurisdiction over a particular issue, see section 3 of Rev. Proc. 2019–1, this Bulletin. For a list of telephone numbers for the different Associate offices, see section 10.07 of Rev. Proc. 2019–1.
Notwithstanding the previous paragraph, in connection with transactions described in § 332, 351, 355, or 1036 and reorganizations within the meaning of § 368, the Associate Chief Counsel (Corporate) may issue a letter ruling on part of an integrated transaction if and to the extent that the transaction presents a significant issue (within the meaning of section 3.01(55)). See section 6.03(2) of Rev. Proc. 2019–1.
(3) Situations in which two or more items or sub-methods of accounting are interrelated. If two or more items or sub-methods of accounting are interrelated, ordinarily a letter ruling will not be issued on a change in accounting method involving only one of the items or sub-methods.
(4) The tax effect of any transaction to be consummated at some indefinite future time.
(5) Any matter dealing with the question of whether property is held primarily for sale to customers in the ordinary course of a trade or business.
(6) The tax effect of a transaction if any part of the transaction is involved in litigation among the parties affected by the transaction, except for transactions involving bankruptcy reorganizations.
(7) (a) Situations in which the taxpayer or a related party is domiciled or organized in a foreign jurisdiction with which the United States does not have an effective mechanism for obtaining tax information with respect to civil tax examinations and criminal tax investigations, which would preclude the Service from obtaining information located in such jurisdiction that is relevant to the analysis or examination of the tax issues involved in the ruling request.
(b) The provisions of subsection (a) above do not apply if the taxpayer or affected related party (i) consents to the disclosure of all relevant information requested by the Service in processing the ruling request or in the course of an examination in order to verify the accuracy of the representations made and to otherwise analyze or examine the tax issues involved in the ruling request, and (ii) waives all claims to protection of bank or commercial secrecy laws in the foreign jurisdiction with respect to the information requested by the Service. In the event the taxpayer’s or related party’s consent to disclose relevant information or to waive protection of bank or commercial secrecy is determined by the Service to be ineffective or of no force and effect, then the Service may retroactively rescind any ruling rendered in reliance on such consent.
(8) A matter involving the Federal tax consequences of any proposed Federal, state, local, municipal, or foreign legislation. The Service may provide general information in response to an inquiry. However, the Office of Associate Chief Counsel (EEE) may issue letter rulings regarding the effect of proposed state, local, or municipal legislation upon an eligible deferred compensation plan under § 457(b) provided that the letter ruling request relating to the plan complies with the other requirements of Rev. Proc. 2019–1, this Bulletin.
(9) Except with respect to a Covered Transaction within the meaning of section 2.03(1)(a) of Rev. Proc. 2017–52, 2017–41 I.R.B. 283, a letter ruling will not be issued with respect to an issue that is clearly and adequately addressed by statute, regulations, decision of a court, revenue rulings, revenue procedures, notices, or other authority published in the Internal Revenue Bulletin (Comfort Ruling). However, except with respect to issues under §§ 332, 351, 368, and 1036 and the tax consequences resulting from the application of such Code sections (see generally section 6.03(2) of Rev. Proc. 2019–1, this Bulletin), an Associate office may in its discretion issue a Comfort Ruling if the Associate office is otherwise ruling on another issue arising in the same transaction.
(10) Whether an amount received (in periodic payments or as a lump sum) in connection with a legal action or a settlement of a legal action is properly allocated (including an allocation of all payments to one category) to recovery of capital, compensatory damages, punitive damages, dividends, interest, back pay, etc., for Federal tax purposes.
(11) The treatment or effects of hook equity, including as a result of its issuance, ownership, or redemption. This section 4.02(11) ordinarily will not apply if (i) an interest’s status as hook equity is only transitory, such as in a triangular reorganization, or (ii) the treatment of the hook equity is not relevant to the treatment of the overall transaction and issue presented. For this purpose, “hook equity” means an ownership interest in a business entity (such as stock in a corporation) that is held by another business entity in which at least 50 percent of the interests (by vote or value) in such latter entity are held directly or indirectly by the former entity. However, if an entity directly or indirectly owns all of the equity interests in another entity, the equity interests in the latter entity are not hook equity.
(12) Whether a tax-qualified plan satisfies the requirements for qualification under §§ 401 through 420 and § 4975(e)(7). These matters are generally handled through the Employee Plans Determinations program as provided in Rev. Proc. 2019–4, this Bulletin, Rev. Proc. 2016–37, 2016–29 I.R.B. 136, and Rev. Proc. 2015–36, 2015–27 I.R.B. 20. Notwithstanding the preceding sentence, the Office of Associate Chief Counsel (EEE) may issue a ruling if (i) the taxpayer has demonstrated to the satisfaction of the Office of Associate Chief Counsel (EEE) that the qualification issue involved is unique and requires immediate guidance, (ii) as a practical matter, it is not likely that such issue will be addressed through the determination letter process, and (iii) the Office determines that it is in the interest of good tax administration to provide guidance to the taxpayer with respect to such qualification issue.
(13) Any issue that is being considered by the Pension Benefit Guaranty Corporation (PBGC) or the Department of Labor (DOL), and involves the same taxpayer, will be issued at the discretion of the Office of Associate Chief Counsel (EEE).
SECTION 5. AREAS UNDER STUDY IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT BE ISSUED UNTIL THE SERVICE RESOLVES THE ISSUE THROUGH PUBLICATION OF A REVENUE RULING, A REVENUE PROCEDURE, REGULATIONS, OR OTHERWISE
(1) Sections 302 and 304.—Distributions in Redemption of Stock; Redemptions Through Use of Related Corporations.—Treatment of basis in a § 302/304 redemption.
(2) Sections 351, 358, and 362.—Transfer to Corporation Controlled by Transferor; Basis to Distributees; Basis to Corporations.—The issues described as being under study in Rev. Rul. 2006–2, 2006–1 C.B. 261.
(3) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Any issue relating to the qualification, under § 355 and related provisions, of a distribution, or another distribution which is part of the same plan or series of related transactions, if, immediately after any such distribution, all of the following conditions exist: (i) the fair market value of the gross investment assets of the distributing corporation or the controlled corporation is two-thirds or more of the fair market value of its total gross assets; (ii) the fair market value of the gross assets of the trade(s) or business(es) on which the distributing corporation or the controlled corporation relies to satisfy the active trade or business requirement of § 355(b) is less than 10 percent of the fair market value of its gross investment assets; and (iii) the ratio of the fair market value of the gross investment assets to the fair market value of the gross assets other than the gross investment assets of the distributing corporation or the controlled corporation is three times or more of such ratio for the other corporation (i.e., the controlled corporation or the distributing corporation, respectively).
For purposes of determining the fair market value of the distributing corporation’s and the controlled corporation’s gross investment assets, gross assets other than gross investment assets, gross assets of the trade or business, and total gross assets, all members of such corporation’s separate affiliated group, within the meaning of § 355(b)(3)(B), are treated as one corporation. If the distributing corporation or the controlled corporation relies on an active trade or business of a partnership for purposes of § 355(b), then for purposes of determining the fair market value of the gross assets of the trade(s) or business(es) on which the distributing corporation or the controlled corporation relies to satisfy the active trade or business requirement of § 355(b), such corporation is treated as owning its ratable share of the gross assets of the partnership.
For purposes of this section 5.01(3), “investment assets” has the meaning given such term by § 355(g)(2)(B), except as follows: (i) in the case of stock or securities in a corporation any stock of which is traded on (or subject to the rules of) an established financial market within the meaning of § 1.1092(d)–1(b) (publicly traded stock), § 355(g)(2)(B)(iv) is applied by substituting “50-percent” for “20-percent;” (ii) except as provided in clause (iv) of this sentence, an interest in a publicly traded partnership (as defined in § 7704(b), regardless of whether such partnership is treated as a corporation pursuant to § 7704(a)) is treated in the same manner as publicly traded stock; (iii) except as provided in clause (iv) of this sentence, an interest in a partnership that is not a publicly traded partnership is treated in the same manner as stock which is not publicly traded stock; and (iv) in the case of an interest in a partnership (other than a publicly traded partnership treated as a corporation pursuant to § 7704(a)), the active trade or business of which is taken into account by the distributing corporation or the controlled corporation for purposes of § 355(b), or would be taken into account without regard to the five-year requirement of § 355(b)(2)(B), clauses (ii) and (iii) of this sentence do not apply.
The Service also will not rule on any issue relating to the qualification, under § 355 and related provisions, of a distribution if, as part of a plan or series of related transactions, investment assets are disposed of, or property, including property qualifying as an active trade or business within the meaning of § 355(b), is acquired with a principal purpose of avoiding this section 5.01(3). This section 5.01(3) does not apply if (i) all the stock of the controlled corporation that is distributed in the distribution is distributed to one or more members of the affiliated group, as defined in § 243(b)(2)(A), of which the distributing corporation is a member; and (ii) such distribution is not part of a plan or series of related transactions pursuant to which stock of any corporation will be distributed outside such affiliated group in a distribution described in this section 5.01(3) or in section 4.01(30) of this revenue procedure.
(4) Section 358.—See section 5.01(2), above.
(6) Section 613A.—Limitations on Percentage Depletion in Case of Oil and Gas Wells.—Whether the sale of oil or gas, or any product derived from oil or gas, is a bulk sale for purposes of § 613A(d)(2).
(7) Sections 661 and 662.—Deduction for Estates and Trusts Accumulating Income or Distributing Corpus; Inclusion of Amounts in Gross Income of Beneficiaries of Estates and Trusts Accumulating Income or Distributing Corpus.—Whether the distribution of property by a trustee from an irrevocable trust to another irrevocable trust (sometimes referred to as a “decanting”) resulting in a change in beneficial interests is a distribution for which a deduction is allowable under § 661 or which requires an amount to be included in the gross income of any person under § 662.
(8) Section 1014.—Basis of Property Acquired from a Decedent.—Whether the assets in a grantor trust receive a § 1014 basis adjustment at the death of the deemed owner of the trust for income tax purposes when those assets are not includible in the gross estate of that owner under chapter 11 of subtitle B of the Internal Revenue Code.
(9) Section 2036.—Transfers with Retained Life Estate.—Whether the corpus of a trust will be included in a grantor’s estate when the trustee of the trust is a private trust company owned partially or entirely by members of the grantor’s family.
(10) Section 2038.—Revocable Transfers.—Whether the corpus of a trust will be included in a grantor’s estate when the trustee of the trust is a private trust company owned partially or entirely by members of the grantor’s family.
(11) Section 2041.—Powers of Appointment.—Whether the corpus of a trust will be included in an individual’s estate when the trustee of the trust is a private trust company owned partially or entirely by members of the individual’s family.
(12) Section 2501.—Imposition of Tax.—Whether the distribution of property by a trustee from an irrevocable trust to another irrevocable trust (sometimes referred to as a “decanting”) resulting in a change in beneficial interests is a gift under § 2501.
(13) Sections 2601 and 2663.—Tax Imposed; Regulations.—Whether the distribution of property by a trustee from an irrevocable generation-skipping transfer tax (GST) exempt trust to another irrevocable trust (sometimes referred to as a “decanting”) resulting in a change in beneficial interests is the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612.
(14) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions from donor advised funds.
(15) Section 6109.l—Identifying Numbers.l—The proper assignment or retention of an employer identification number (EIN) in the case of a reorganization within the meaning of § 368(a)(1)(F) if the transferor corporation becomes disregarded as an entity separate from its owner under § 301.7701–3.
SECTION 6. AREAS COVERED BY AUTOMATIC APPROVAL PROCEDURES IN WHICH RULINGS WILL NOT ORDINARILY BE ISSUED
.01 Section 338.—Certain Stock Purchases Treated as Asset Acquisitions.—All requests for an extension of time under § 301.9100–3 within which to make an election under § 338(g) or (h)(10) where the Service has provided an administrative procedure to seek such an extension. See Rev. Proc. 2003–33, 2003–1 C.B. 803 (extension automatically granted to certain persons required to file Form 8023 to make a valid § 338 election that have not filed Form 8023 by its due date).
.02 Section 442.—Change of Annual Accounting Period.—All requests for a change in annual accounting period where the Service has provided an automatic change procedure for obtaining such a change in annual accounting period. See Rev. Proc. 2002–39, 2002–1 C.B. 1046 (general procedures for prior approval), as clarified and modified by Notice 2002–72, 2002–2 C.B. 843, and modified by Rev. Proc. 2003–34, 2003–1 C.B. 856, and Rev. Proc. 2018–17, 2018–9 I.R.B. 384; Rev. Proc. 2006–45, 2006–2 C.B. 851 (certain corporations), as clarified and modified by Rev. Proc. 2007–64, 2007–2 C.B. 818, and modified by Rev. Proc. 2018–17, 2018–9 I.R.B. 384; Rev. Proc. 2006–46, 2006–2 C.B. 859 (partnership, S corporation, personal service corporation, or trust); and Rev. Proc. 2003–62, 2003–2 C.B. 299 (individual seeking a calendar year).
.03 Section 446.—General Rule for Methods of Accounting.—Except as otherwise specifically provided in applicable procedures published in the Internal Revenue Bulletin, all requests for a change in method of accounting where the Service has provided an automatic change request procedure for obtaining such a change in method of accounting. See the automatic change request procedures listed in section 9.22 of Rev. Proc. 2019–1, this Bulletin.
.04 Section 461.—General Rule for Taxable Year of Deduction.—All requests for making or revoking an election under § 461 where the Service has provided an administrative procedure for making or revoking such an election under § 461. See Rev. Proc. 92–29, 1992–1 C.B. 748 (dealing with the use of an alternative method for including in basis the estimated cost of certain common improvements in a real estate development).
.05 Section 704(c).—Contributed Property.—Requests from Qualified Master Feeder Structures, as described in section 4.02 of Rev. Proc. 2001–36, 2001–1 C.B. 1326, for permission to aggregate built-in gains and losses from contributed qualified financial assets for purposes of making § 704(c) and reverse § 704(c) allocations.
.06 Section 1362.—Election; Revocation; Termination.—All situations in which an S corporation qualifies for automatic late S corporation relief under Rev. Proc. 2013–30, 2013–36 I.R.B. 173.
.07 Sections 1502, 1504, and 1552.—Regulations; Definitions; Earnings and Profits.—All requests for waivers or consents on consolidated return issues where the Service has provided an administrative procedure for obtaining such waivers or consents on consolidated return issues. See Rev. Proc. 2014–24, 2014–13 I.R.B. 879 (certain subsidiary members treated as if they filed a Form 1122 even though they failed to do so); Rev. Proc. 2002–32, 2002–1 C.B. 959, as modified by Rev. Proc. 2006–21, 2006–1 C.B. 1050 (certain corporations seeking reconsolidation within the 5-year period specified in § 1504(a)(3)(A)); Rev. Proc. 90–39, 1990–2 C.B. 365, as modified by Rev. Proc. 2006–21, and as clarified by Rev. Proc. 90–39A, 1990–2 C.B. 367 (certain affiliated groups of corporations seeking, for earnings and profits determinations, to make an election or a change in their method of allocating the group’s consolidated Federal income tax liability); and Rev. Proc. 89–56, 1989–2 C.B. 643, as modified by Rev. Proc. 2006–21 (certain affiliated groups of corporations seeking to file a consolidated return in which member(s) of the group use a 52–53 week taxable year).
.08 Section 2010(c)(5)(A).—Election Required.—All requests filed before the second anniversary of the decedent’s date of death for an extension of time under § 301.9100–3 to make an election under § 2010(c)(5)(A), where the Service has provided an administrative procedure to seek such an extension. See Rev. Proc. 2017–34, 2017–26 I.R.B. 1282 (procedure providing for an extension of time to certain taxpayers to make a “portability” election under § 2010(c)(5)(A)).
.09 Section 7701.—Definitions.—All requests for an extension of time under § 301.9100–3 within which to make an entity classification election under § 301.7701–3 where the Service has provided an administrative procedure to seek such an extension. See Rev. Proc. 2009–41, 2009–39 I.R.B. 439 (extension automatically granted to certain persons required to file Form 8832 to make a valid entity classification election that have not filed Form 8832 by its due date).
SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES
SECTION 8. EFFECTIVE DATE
SECTION 9. PAPERWORK REDUCTION ACT
and approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act (44 U.S.C. § 3507) under control number 1545-1522.
The collections of information in this revenue procedure are in sections 2.03 and 3.01(55).
This information is required to evaluate whether the request for a letter ruling or determination letter is not covered by the provisions of this revenue procedure. The collections of information are required to obtain a letter ruling or determination letter. The likely respondents are businesses or other for-profit institutions.
The estimated total annual reporting and/or recordkeeping burden of this revenue procedure, and Rev. Proc. 2019–1, this Bulletin is 316,020 hours.
The estimated annual burden per respondent/recordkeeper varies from 1 hour to 200 hours, depending on individual circumstances, with an estimated average burden of 80 hours. The estimated number of respondents and/or recordkeepers is 3,956.
Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. § 6103.
The principal author of this revenue procedure is Jean Broderick of the Office of Associate Chief Counsel (Corporate). For further information about this revenue procedure, please contact Ms. Broderick at (202) 317–6848 (not a toll-free call), or phone the Associate office contacts listed in section 10.07 of Rev. Proc. 2019–1, this Bulletin. See section 3 of Rev. Proc. 2019–1 to determine which Associate office has jurisdiction over a particular issue.
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 152
.01 Purpose of revenue procedure 152
.02 Organization of revenue procedure 152
.03 Other guidance affecting this revenue procedure 152
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4? 154
.01 In general 154
.02 Changes made to Revenue Procedure 2018–4 154
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 155
.02 Letter ruling 155
.03 Closing agreement 156
.04 Determination letter 156
.05 Opinion letter 156
.06 Oral advice 156
.07 Nonbank trustee approval letters 157
.08 Compliance statement 157
.09 Advisory letter 157
SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE? 158
SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES? 158
.01 Pre-approved plans 158
.02 Employee Plans Compliance Resolution System 159
.03 Chief Counsel 159
.04 Determination letters not issued for requests for minimum funding waivers 159
SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 159
.02 Certain information required in all requests 159
.03 Additional information required in certain circumstances 166
.04 Address to send the request 168
.05 Pending letter ruling requests 168
.06 When to attach letter ruling to return 168
.07 How to check on status of request 168
SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER? 169
.02 Notification of appropriate Service official 169
.03 Refunds of user fee 169
PART II. PROCEDURES FOR DETERMINATION LETTER REQUESTS
PART IIA. REQUESTING DETERMINATION LETTERS
SECTION 8. IN WHAT AREAS ARE DETERMINATION LETTERS ISSUED? 169
.01 Circumstances under which determination letters are issued 169
.02 Types of requests 170
.03 Areas in which determination letters will not be issued 171
.04 Determination letter applications 172
.05 Review of determination letters 172
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 172
.01 Scope of this section 172
.02 Scope of determination letters 172
.03 Design-based safe harbor 172
.04 Governmental plans under § 414(d) 172
.05 Church plans under § 414(e) 172
.06 Tax treatment of certain contributions under § 414(h) 173
.07 Other limits on scope of determination letter 173
.08 Leased employees 173
.09 Partial terminations 173
.10 Publication 794, Favorable Determination Letter 173
SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 173
.01 Scope 173
.02 Complete information required 174
.03 Complete copy of plan and trust instrument and applicable amendments required 174
.04 Separate application for each single § 414(l) plan 174
.05 Prior letters 174
.06 Plans involving mergers 174
.07 User fees 174
.08 Interested party notification and comment 175
.09 Contrary authority must be distinguished 175
.10 Employer/employee relationship 175
.11 Incomplete applications 175
.12 Effect of failure to disclose material fact 176
.13 Where to file requests 176
.14 Submission of related plans 176
.15 Withdrawal of requests 176
.16 Right to status conference 176
.17 How to request status conference 176
.18 Correct format required 177
SECTION 11.WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 177
.01 Requesting determination letters 177
.02 Elimination of remedial amendment cycle for individually designed plans 177
.03 Forms 177
.04 Application must include copy of plan and amendments 178
.05 Restatements required 178
.06 Section 414(x) combined plans 178
SECTION 12. WHEN MAY AN ADOPTER OF A MASTER AND PROTOTYPE OR VOLUME SUBMITTER PLAN SUBMIT A DETERMINATION LETTER APPLICATION? 178
.01 Eligibility to apply for a determination letter 178
.02 Reliance equivalent to determination letter 180
SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR VOLUME SUBMITTER PLANS? 180
.02 Determination letter for adoption of volume submitter plan 180
.03 Timing of determination letter applications for adopting employers of pre-approved plans 182
SECTION 14.WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS? 182
.02 Applicant must request letter for plan in the name of the controlling member 182
.04 Addition of employers 182
SECTION 15. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION UPON TERMINATION OR DISCONTINUANCE OF CONTRIBUTIONS, NOTICE OF MERGER, CONSOLIDATION, ETC.? 183
.03 Supplemental information 183
.04 Compliance with Title IV of ERISA 184
.05 Termination prior to time for amending for change in law 184
.06 Restatement not required for terminating plan 184
SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS? 184
.02 Required information 185
SECTION 17. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION OF LEASED EMPLOYEE STATUS? 185
.02 Employer must request the determination under § 414(n) 185
.04 Employer is responsible for determining continuing status under § 414(n) 186
.06 Required information for § 414(n) determination 186
SECTION 18. WHAT ARE THE PROCEDURES FOR REQUESTING SECTION 401(h) AND SECTION 420 DETERMINATION LETTERS? 187
.02 Required information for § 401(h) determination 187
.03 Required information for § 420 determination 187
PART IIB. INTERESTED PARTY NOTICE AND COMMENT
SECTION 19. WHAT RIGHTS TO NOTICE AND COMMENT DO INTERESTED PARTIES HAVE? 188
.01 Rights of interested parties 188
.02 Comments by interested parties 189
.03 Requests for DOL to submit comments 190
.04 Right to comment if DOL declines to comment 191
.05 Confidentiality of comments 191
.06 Availability of comments 191
.07 When comments are deemed made 191
SECTION 20. WHAT ARE THE GENERAL RULES FOR NOTICE TO INTERESTED PARTIES? 191
.01 Notice to interested parties 191
.02 Time when notice must be given 191
.03 Content of notice 192
.04 Procedures for making information available to interested parties 192
.05 Information to be available to interested parties 193
.06 Special rules if there are fewer than 26 participants 193
.07 Information described in § 6104(a)(1)(D) should not be included 193
.08 Availability of additional information to interested parties 193
.09 Availability of notice to interested parties 194
PART IIC. PROCESSING DETERMINATION LETTER REQUESTS
SECTION 21. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HANDLE DETERMINATION LETTER REQUESTS? 194
.02 Conferences 194
.03 Determination letter based solely on administrative record 194
.04 Notice of final determination 195
.05 Issuance of the notice of final determination 195
SECTION 22. WHAT ARE THE STEPS FOR EXHAUSTING ADMINISTRATIVE REMEDIES? 195
.02 Steps for exhausting administrative remedies 196
.03 Applicant’s request for § 7805(b) relief 196
.04 Interested parties 196
.05 Deemed exhaustion of administrative remedies 196
.06 Service must have reasonable time to act on appeal 196
.07 Service must have reasonable time to act on request for § 7805(b) relief 196
SECTION 23. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 197
.01 May be relied on subject to limitations 197
.02 Scope of reliance on determination letter 197
.03 Effect of subsequent publication of revenue ruling, etc. 197
.04 Effect of subsequent amendment by employer 197
.05 Revocation or modification of a determination letter 198
.06 Determination letter revoked or modified based on material change in facts applied retroactively 198
.07 Not otherwise generally revoked or modified retroactively 198
.08 Taxpayer may request that retroactive effect of revocation or modification be limited under § 7805(b) 198
PART III. PROCEDURES FOR LETTER RULING REQUESTS
PART IIIA. REQUESTING LETTER RULINGS
SECTION 24. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS ISSUE LETTER RULINGS? 199
.01 Scope limited to issues specified 199
.02 Generally not in employee plans qualification matters 200
.03 Request to Employee Plans Rulings and Agreements for extension of time for making an election or for other relief under § 301.9100–1 of the Procedure and Administration Regulations 200
.04 Issuance of a letter ruling before the issuance of a regulation or other published guidance 200
.05 Issues in prior return 201
.06 Generally not to business associations or groups 201
.07 Generally not to foreign governments 201
.08 Generally not on federal tax consequences of proposed legislation 201
SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE THE DISCRETION TO ISSUE LETTER RULINGS? 201
.01 Ordinarily not in certain areas because of factual nature of the problem 201
.02 No “comfort” letter rulings 202
.03 Not on alternative plans or hypothetical situations 202
.04 Ordinarily not on part of an integrated transaction 202
.05 Not on partial terminations of employee plans 202
.06 Law requires a letter ruling 202
.07 Issues under consideration by the PBGC or the DOL 202
.08 Domicile in a foreign jurisdiction 202
SECTION 26. WHAT IS THE PROCEDURE FOR REQUESTING A LETTER RULING FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 203
.01 General procedures for requesting a letter ruling 203
.02 Specific additional procedures apply to certain letter ruling requests 203
PART IIIB. PROCESSING LETTER RULING REQUESTS
SECTION 27. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HANDLE LETTER RULING REQUESTS? 203
.02 Is not bound by informal opinion expressed 203
.03 Will return any letter ruling request mistakenly sent to wrong address 203
.04 Tells taxpayer if request lacks essential information during initial contact 204
.05 Information must be submitted within 30 calendar days 204
.06 Requires prompt submission of additional information requested after initial contact 204
.07 Encourages use of fax 204
.08 Address to send additional information 204
.09 Number of copies of additional information to be submitted 204
.10 30-day or 21-day period may be extended if justified and approved 204
.11 Case closed if taxpayer does not submit additional information 205
.12 Near the completion of the ruling process, advises taxpayer of conclusions and, if Employee Plans Rulings and Agreements will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling request 205
.13 May request draft of proposed letter ruling near the completion of the ruling process 205
SECTION 28. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS SCHEDULE CONFERENCES WITH TAXPAYERS? 205
.01 Schedules a conference if requested by taxpayer 205
.02 Permits taxpayer one conference of right 206
.03 Disallows verbatim recording of conferences 206
.04 Makes tentative recommendations on substantive issues 206
.05 May offer additional conferences 206
.06 Requires written confirmation of information presented at conference 207
.07 May schedule a pre-submission conference 207
.08 Under limited circumstances, may schedule a conference to be held by telephone 207
SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE? 207
.01 Has same effect as a determination letter 207
.02 Will not apply to another taxpayer 208
.03 Will be used by the Service in examining the taxpayer’s return 208
.04 May be revoked or modified if found to be in error 208
.05 Letter ruling revoked or modified based on material change in facts applied retroactively 208
.07 Will not apply to a similar transaction in same year or any other year 209
.08 Retroactive effect of revocation or modification applied to a continuing action or series of actions 209
.09 May be retroactively revoked or modified if the transaction is completed without reliance on the letter ruling 209
.10 Taxpayer may request that retroactivity be limited 209
PART IV. USER FEES
SECTION 30. WHAT ARE THE USER FEE REQUIREMENTS FOR REQUESTING ADVICE FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 210
.01 Legislation authorizing user fees 210
.02 Requests to which user fees apply 210
.03 Requests and other actions that do not require the payment of a user fee. 210
.04 Exemptions from the user fee requirements 210
.05 User fees under EPCRS 211
.06 Requests involving multiple offices, fee categories, issues, transactions, or entities 211
.07 Method of payment 211
.08 Transmittal forms 212
.09 Effect of nonpayment or payment of incorrect amount 212
.10 Refunds of user fees 213
.11 Request for reconsideration of user fee 214
SECTION 31. WHAT ARE THE MAILING ADDRESSES FOR REQUESTING LETTER RULINGS, OPINION LETTERS, ADVISORY LETTERS, DETERMINATION LETTERS, AND VCP COMPLIANCE STATEMENTS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 215
.01 Letter rulings and opinion letters 215
.02 Determination letters 2016
.03 VCP compliance statements 217
SECTION 32. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS? 217
SECTION 34. PAPERWORK REDUCTION ACT 218
APPENDIX A-SCHEDULE OF USER FEES 219
.01 Letter ruling requests 219
.02 Opinion letters on prototype individual retirement accounts and/or annuities, SEPs, SIMPLE IRAs, SIMPLE IRA Plans, Roth IRAs and dual-purpose IRAs 219
.03 Opinion letters on master and prototype plans submitted pursuant to Rev. Proc. 2015–36 219
.04 Advisory letters on VS plans submitted pursuant to Rev. Proc. 2015–36 219
.05 Opinion letters on pre-approved plans submitted pursuant to Rev. Proc. 2017–41 219
.06 Determination letters 219
.07 Opinion letters on § 403(b) prototype plans 220
.08 Advisory letters on § 403(b) VS plans 220
.09 User fees for VCP submissions under EPCRS 220
APPENDIX B-SAMPLE NOTICE TO INTERESTED PARTIES 221
APPENDIX C-CHECKLIST FOR SECTION 401(h) AND SECTION 420 DETERMINATION LETTERS 223
APPENDIX D-SAMPLE FORMAT FOR A LETTER RULING REQUEST FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS 225
APPENDIX E-CHECKLIST FOR LETTER RULINGS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS 227
APPENDIX F-ADDITIONAL CHECKLIST FOR ROTH IRA RECHARACTERIZATION RULING REQUESTS 229
Purpose of revenue procedure
.01 This revenue procedure explains how the Internal Revenue Service provides advice to taxpayers on issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Rulings and Agreements Office (Employee Plans Rulings and Agreements). It also details the types of advice available to taxpayers, and the manner in which such advice is requested and provided.
Organization of revenue procedure
(1) Part I of this revenue procedure contains general information about the types of advice provided by Employee Plans Rulings and Agreements and the procedures that apply to both requests for determination letters and requests for private letter rulings. Part II contains procedures for determination letters for various types of plans and transactions. Part III contains procedures for private letter rulings within the jurisdiction of Employee Plans Rulings and Agreements. Part IV contains the rules for user fees that are required to be paid when requesting various types of advice.
(2) Employee Plans Rulings and Agreements will continue to issue letter rulings only on certain matters specified in section 24.01 of this revenue procedure. Rev. Proc. 2019–1, this Bulletin, sets forth procedures for obtaining letter rulings from the Office of Associate Chief Counsel, including letter rulings relating to qualified retirement plans and IRAs. Rev. Proc. 2019–2, this Bulletin, sets forth procedures for requesting technical advice from the Office of Associate Chief Counsel.
Other guidance affecting this revenue procedure
(1) Determination letter program
(a) Revenue Procedure 2016–37, 2016–29 I.R.B. 136, modified the determination letter program for qualified plans to eliminate, as of January 1, 2017, the five-year remedial amendment cycle system for individually designed plans set forth in Rev. Proc. 2007–44, 2007–2 C.B. 54, and to provide the circumstances under which a plan sponsor may submit a determination letter application to Employee Plans Rulings and Agreements. In addition, Rev. Proc. 2016–37 described a system of remedial amendment cycles that applies to qualified pre-approved master and prototype (M&P) and volume submitter (VS) plans and the deadlines to submit applications for opinion and advisory letters.
(b) Rev. Proc. 2018–19, 2018–14 I.R.B. 466 changes the user fee set forth in Appendix A of Rev. Proc. 2018–4, Schedule of User Fees, with respect to applications on Form 5310, Application for Determination for Terminating Plan.
(c) Notice 2018–24, 2018–17 I.R.B. 507, requests comments on the potential expansion of the scope of the determination letter program for individually designed plans during the 2019 calendar year, beyond provision of determination letters for initial qualification and qualification upon plan termination and provides that the Department of the Treasury and the IRS will issue guidance if they identify any additional types of plans for which plan sponsors may request determination letters during the 2019 calendar year.
(d) Each year a Required Amendments List is issued. The 2018 Required Amendments List, which establishes the end of the remedial amendment period for an individually designed plan with respect to changes in qualification requirements that appear on the list, is contained in Notice 2018–91, 2018–50 I.R.B. 985. No items have been included on the 2018 Required Amendments List.
(e) The 2017 Required Amendments List, which establishes the end of the remedial amendment period for an individually designed plan with respect to changes in qualification requirements that appear on the list, is contained in Notice 2017–72, 2017–52 I.R.B. 601.
(f) The 2015 Cumulative List, which applied to individually designed plans submitted for a determination letter during the 2017 calendar year (with the exception of terminating plans), is contained in Notice 2015–84, 2015–52 I.R.B. 880.
(g) Notice 2017–1, 2017– 2 I.R.B. 367, provides an exemption from the requirement to pay a user fee for certain requests to the Service for determination letters with respect to the qualified status of pension, profit-sharing, stock bonus, annuity, and employee stock ownership (ESOP) plans maintained by small employers.
(2) Pre-approved plan program
(a) Rev. Proc. 2015–36, 2015–27 I.R.B. 20, sets forth the procedures for obtaining opinion and advisory letters for qualified pre-approved M&P and VS plans submitted with respect to remedial amendment cycles prior to the third six-year remedial amendment cycle. Under Rev Proc. 2015–36, the second six-year remedial amendment cycle for defined contribution plans began on February 1, 2011, and ended on January 31, 2017 and the second six-year remedial amendment cycle for defined benefit plans began on February 1, 2013, and ends on January 31, 2019. Rev. Proc. 2015–36 continues to apply to certain opinion and advisory letter applications for defined contribution and defined benefit M&P and VS plans that may still be submitted with respect to cycles prior to the third six-year remedial amendment cycle. Defined benefit M&P and VS plans received opinion or advisory letters relating to the second six-year remedial amendment cycle in 2018. Adopting employers may adopt such plans and request determination letters, if eligible, during the two-year period that began on May 1, 2018 and will end on April 30, 2020. Thus, provisions relating to the M&P and VS programs described under Rev. Proc. 2015–36 that continue to apply to such pre-approved plans have been retained in this revenue procedure.
(b) Rev. Proc. 2017–41, 2017–29 I.R.B. 92, modifies the pre-approved program by eliminating the distinction between M&P and VS plans, liberalizing the types of plans eligible for pre-approved status and affording greater flexibility in the design. In addition Rev. Proc. 2017–41 sets forth the procedures for obtaining an opinion letter for qualified pre-approved plans submitted with respect to the third (and subsequent) six-year remedial amendment cycles. The third six-year remedial amendment cycle for defined contribution plans began on February 1, 2017, and ends on January 31, 2023. Under Rev. Proc. 2017–41, the on-cycle submission period for pre-approved plan providers to submit applications for opinion letters for defined contribution plans for the third six-year remedial amendment cycle began on October 2, 2017, and ended on October 1, 2018. The third six-year remedial amendment cycle for defined benefit plans will begin on February 1, 2019, and will end on January 31, 2025. The on-cycle submission period for pre-approved plan providers to submit applications for opinion letters for defined benefit plans for the third six-year remedial amendment cycle will be announced in future guidance.
(c) The 2017 Cumulative List, which will be used to submit opinion letter applications for pre-approved defined contribution plans during the third six-year remedial amendment cycle, is contained in Notice 2017–37, 2017–29 I.R.B. 89.
(d) Ann. 2018–5, 2018–13 I.R.B. 461, provides that the period for employer adoption of pre-approved defined benefit plans for the second six-year remedial amendment cycle will end on April 30, 2020. Ann. 2018–5 also provides that starting May 1, 2018, and ending April 30, 2020, the IRS will accept applications for individual determination letters from employers who adopt such plans and are otherwise eligible to submit a determination letter request. In addition, Ann. 2018–5 provides that the IRS will announce in future guidance a delayed beginning date for the third six-year remedial amendment cycle for pre-approved defined benefit plans.
(e) Rev. Proc. 2018–42, 2018–36 I.R.B. 424, modified Rev. Proc. 2017–41 to extend the deadline for submitting on-cycle applications for opinion letters for pre-approved defined contribution plans for the third six-year remedial amendment cycle from October 1, 2018, to December 31, 2018.
(3) Other guidance
(a) Rev. Proc. 2013–22, 2013–18 I.R.B. 985, as modified by Rev. Proc. 2014–28, 2014–16 I.R.B. 944, and Rev. Proc. 2015–22, 2015–11 I.R.B. 754, and clarified by Rev. Proc. 2017–18, 2017–5 I.R.B. 743, sets forth the procedures for obtaining opinion and advisory letters for § 403(b) prototype plans and VS plans.
(b) Rev. Proc. 2018–52, 2018–42 I.R.B. 611, sets forth the procedures for correcting qualification failures under the Employee Plans Compliance Resolution System (EPCRS).
.04 This revenue procedure is updated annually, but it may be modified, amplified or clarified during the year.
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4?
.01 This revenue procedure is a general update of Rev. Proc. 2018–4, 2018–1 I.R.B. 146, which sets forth general information about the types of advice provided by Employee Plans Rulings and Agreements; general procedures for letter ruling and determination letter requests; specific procedures for determination letter requests; and the user fees associated with advice requested from Employee Plans Rulings and Agreements. Procedures and user fees applicable to advice provided by the Commissioner, Tax Exempt and Government Entities, Exempt Organizations Office, are contained in Rev. Proc. 2019–5, this Bulletin.
Changes made to Revenue Procedure 2018–4
.02 In addition to minor non-substantive changes, including changes to dates, cross references, and citations to other revenue procedures, the following changes have been made:
(1) Section 4 is modified to reflect Employee Plans Rulings and Agreement’s current practice of considering voluntary requests for closing agreements to resolve certain income or excise tax issues that are ineligible for resolution under EPCRS.
(2) Section 6.03(4)(b) is deleted to clarify that letter ruling requests may not be submitted via facsimile transmission.
(3) Section 8.02 is modified to add new section 3, “Other Circumstances,” to provide a new category for which determination letters can be requested, and to renumber the following determination letter categories.
(4) Section 8.03(1) is modified to add § 414(b), (c) and (m) to the list of sections for which a determination is not made when a determination letter is issued in accordance with this revenue procedure.
(5) Section 9.03 is modified to clarify that in order for a plan to be reviewed for, and a determination letter relied upon with respect to, whether the terms of the plan satisfy one of the design-based safe harbors in §§ 1.401(a)(4)–2(b) and 1.401(a)(4)–3(b) of the regulations (relating to nondiscrimination in amount of contributions and benefits), the plan document must provide a definition of compensation that satisfies § 1.414(s)–1(c).
(6) Section 10.04 “Submission of reference list” is deleted and the remaining paragraphs in section 10 are renumbered.
(7) Section 10.11 is modified to reflect updated procedures with regard to the processing of incomplete applications.
(8) Section 24.03 is modified to provide that Employee Plans Rulings and Agreements will consider a request for an extension of time for making an election under § 301.9100–3 of the Procedure and Administration Regulations to recharacterize annual contributions made to a Roth IRA. Employee Plans Rulings and Agreements will also consider recharacterization requests under § 301.9100–3 that relate to a conversion or rollover contribution to a Roth IRA but only if the rollover or conversion was made prior to January 1, 2018.
(9) Section 24.03 is modified to clarify that SB/SE Exam will be notified if a request for an extension of time for making an election or other application for relief under § 301.9100–1 is submitted when the return is under examination.
(10) Section 30.03(4) is modified to delete the reference to change in accounting method.
(11) Section 30.07(2) is modified to provide that beginning April 1, 2019, VCP submissions and the applicable user fees must be made using www.pay.gov. Section 30.07(3) is modified to clarify that the payment of user fees for pre-approved plan submissions and letter ruling requests may not be made using www.pay.gov and that such requests must still be accompanied by a check in the amount of the applicable user fee.
(12) Section 30.08 is modified to clarify which forms must be submitted for VCP submissions made prior to April 1, 2019.
(13) The Office of Associate Chief Counsel (Tax Exempt and Government Entities) has been replaced with Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) throughout the document.
(14) Appendix A .03, .04, .07, and .08 are modified to delete certain types of submissions and user fees that are no longer applicable.
(15) Appendix A .06(1)(c) is modified to reflect that the user fee for Form 5310 will increase from $2,300 to $3,000 for submissions postmarked on or after July 1, 2019.
(16) Appendix E is modified to delete question 30 as not applicable.
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS?
.01 Employee Plans Rulings and Agreements provides advice in the form of letter rulings, closing agreements, compliance statements, determination letters, opinion letters, advisory letters, nonbank trustee approval letters, and oral advice.
.02 A “letter ruling” is a written statement issued to a taxpayer by Employee Plans Rulings and Agreements that interprets and applies the tax laws or any nontax laws applicable to employee plans to the taxpayer’s specific set of facts. Once issued, a letter ruling may be revoked or modified for any number of reasons, as described in section 29 of this revenue procedure, unless it is accompanied by a “closing agreement.”
.03 A “closing agreement” is a final agreement between the Service and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 of the Internal Revenue Code of 1986 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A closing agreement may be entered into if it is advantageous to have the matter permanently and conclusively closed, or if a taxpayer can show that there are good reasons for an agreement and that making the agreement will not prejudice the interests of the Government. In appropriate cases, taxpayers may be asked to enter into a closing agreement as a condition to the issuance of a letter ruling.
In appropriate cases, a closing agreement may be made with sponsors of M&P plans and practitioners of VS plans.
A closing agreement may also be entered into with respect to retirement plan failures corrected under EPCRS, as set forth in Rev. Proc. 2018–52.
.04 A “determination letter” is a written statement issued to a taxpayer by Employee Plans Rulings and Agreements that applies the principles and precedents previously announced to a specific set of facts. It is issued only if a determination can be made based on clearly established rules in the statute, a tax treaty, or the regulations, or based on a conclusion in a revenue ruling, opinion, or court decision that represents the position of the Service, and that specifically answers the questions presented. Employee Plans Rulings and Agreements issues determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans under §§ 401, 403(a), 409, and 4975(e)(7), and the status for exemption of any related trusts or custodial accounts under § 501(a).
Opinion letter
(1) For applications submitted with respect to cycles prior to the third six-year remedial amendment cycle, an “opinion letter” is a written statement issued by Employee Plans Rulings and Agreements to a sponsor or M&P mass submitter as to the acceptability of the form of an M&P plan under § 401(a), § 403(a), or both §§ 401(a) and 4975(e)(7) and, in the case of a master plan, the acceptability of the master trust under § 501(a). See Rev. Proc. 2015–36.
(2) For applications submitted with respect to the third (and subsequent) six-year remedial amendment cycles, an opinion letter is a written statement issued by Employee Plans Rulings and Agreements to a provider or mass submitter as to the qualification in form of a pre-approved plan under § 401, § 403(a), or both §§ 401 and 4975(e)(7). See Rev. Proc. 2017–41.
(3) An opinion letter will also be issued as to the acceptability of the form of a prototype plan under § 403(b). See Rev. Proc. 2013–22, as modified by Rev. Proc. 2014–28, and Rev. Proc. 2015–22, and clarified by Rev. Proc. 2017–18.
(4) An opinion letter will also be issued concerning the conformance of a prototype trust, custodial account, or individual annuity with the requirements of § 408(a), (b), (k), or, (p) or § 408A, as applicable. See Rev. Proc. 87–50, 1987–2 C.B. 647; Rev. Proc. 91–44, 1991–2 C.B. 733; Rev. Proc. 92–38, 1992–1 C.B. 859; Rev. Proc. 97–29, 1997–1 C.B. 698; Rev. Proc. 98–59, 1998–2 C.B. 729; Rev. Proc. 2002–10, 2002–1 C.B. 401, and Rev. Proc. 2010–48, 2010–50, I.R.B. 828 (pre-approved IRAs), as modified by Appendix A of this revenue procedure.
.06 Oral advice is advisory only, and is not binding on the Service.
(1) No oral rulings and no written rulings in response to oral requests.
The Service does not orally issue rulings or determinations, nor does it issue letter rulings or determination letters in response to oral requests from taxpayers. Service employees ordinarily will discuss with taxpayers or their representatives inquiries about whether the Service will rule on particular issues and about procedural matters regarding the submission of requests for letter rulings or determination letters.
(2) Discussion possible on substantive issues.
At the discretion of the Service and as time permits, Service employees may also discuss substantive issues with taxpayers or their representatives. Such a discussion will not bind the Service or the Office of Associate Chief Counsel, and it cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).
Service employees who are not directly involved in the examination, appeal, or litigation of particular substantive tax issues will not discuss those issues with taxpayers or their representatives unless the discussion is coordinated with Service employees who are directly involved in the matter. The taxpayer or the taxpayer’s representative ordinarily will be asked whether an oral request for advice or information relates to a matter pending before another office of the Service or before a Federal court.
If a tax issue is not under examination, in an Appeals Office, or in litigation, the tax issue may be discussed even though the issue is affected by a nontax issue pending in litigation.
Nonbank trustee approval letters
.07 A “nonbank trustee approval letter” is a letter ruling that determines that the applicant is qualified to act as a nonbank custodian pursuant to the requirements of § 1.408–2(e)(2) through (5) of the Income Tax Regulations with respect to plans qualified under § 401(a), accounts described in § 403(b)(7), individual retirement arrangements (IRAs) established under § 408(a), (b), or (h), Roth IRAs established under § 408A, Coverdell educational savings accounts established under § 530, Archer medical savings accounts established under § 220, or Health Savings Accounts established under § 223. An applicant requesting approval as a nonbank trustee must provide Employee Plans Rulings and Agreements with clear and convincing proof that the requirements of the regulations are met. If there is a requirement that the applicant feels is not applicable, the application must provide clear and convincing proof that such requirement is not germane to the manner in which the applicant will administer any trust or custodial account. See § 1.408–2(e)(6).
.08 A “compliance statement” is a binding written agreement between Employee Plans Rulings and Agreements and, generally, the plan sponsor with respect to certain failures of the retirement plan to meet the applicable qualification requirements identified by the plan sponsor in a voluntary submission under the Voluntary Correction Program (VCP) of EPCRS. The compliance statement addresses the failures identified in the VCP submission, the terms of correction, including any revision of administrative procedures, and the time period within which proposed corrections must be implemented. A compliance statement is conditioned on (i) there being no misstatement or omission of material fact in connection with the submission, and (ii) the implementation of the specific corrections and satisfaction of any other conditions in the compliance statement. See Rev. Proc. 2018–52.
Advisory letter
(1) An “advisory letter” is a written statement issued by Employee Plans Rulings and Agreements to a VS practitioner or VS mass submitter as to the acceptability of the form of a specimen plan and any related trust or custodial account under § 401(a) or § 403(a) for an application submitted with respect to cycles prior to the third six-year remedial amendment cycle. See Rev. Proc. 2015–36.
(2) An advisory letter is also issued as to the acceptability of the form of a specimen plan under § 403(b). See Rev. Proc. 2013–22, as modified by Rev. Proc. 2014–28 and Rev. Proc. 2015–22, and clarified by Rev. Proc. 2017–18.
SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE?
Taxpayers may request determination letters, letter rulings and closing agreements on issues within the jurisdiction of Employee Plans Rulings and Agreements under this revenue procedure.
Employee Plans Rulings and Agreements issues determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans under §§ 401, 403(a), 409, and 4975(e)(7), and the status for exemption of any related trusts or custodial accounts under § 501(a). See Rev. Proc. 2016–37, which contains a description of the determination letter program, including when to submit a request for a determination letter, for individually designed and pre-approved plans.
Employee Plans Rulings and Agreements issues letter rulings on the Code sections listed in section 24.01 of this revenue procedure, if appropriate in the interest of sound tax administration to answer written inquiries of individuals and organizations about their status for tax purposes and the tax effects of their acts or transactions.
Employee Plans Rulings and Agreements considers voluntary closing agreement requests to resolve certain income or excise tax issues (including, effective January 2, 2019, waiver under § 4980F(c)(4) of all or part of the excise tax imposed for failure to satisfy the notice requirements described in § 4980F(e)) that are ineligible for resolution under EPCRS. See www.irs.gov/retirement-plans/employee-plans-voluntary-closing-agreements.
Note that issues involving employee plans not listed in section 24.01 of this revenue procedure generally fall under the jurisdiction of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). See section 5.03 below and Rev. Proc. 2019–1, this Bulletin.
Pre-approved plans
(1) The procedures for obtaining opinion letters for M&P plans and any related trusts or custodial accounts under §§ 401(a), 403(a), and 501(a), and advisory letters for VS plans for applications submitted with respect to cycles prior to the third six-year remedial amendment cycle are contained in Rev. Proc. 2015–36.
(2) The procedures for obtaining opinion letters for pre-approved plans submitted with respect to the third (and subsequent) six-year remedial amendment cycles are contained in Rev. Proc. 2017–41.
(3) The procedures for obtaining opinion letters for prototype trusts, custodial accounts, or annuities under § 408(a), (b), (k), or (p), or § 408A, are contained in Rev. Proc. 87–50; Rev. Proc. 91–44; Rev. Proc. 92–38; Rev. Proc. 97–29; Rev. Proc. 98–59; Rev. Proc. 2002–10 and Rev. Proc. 2010–48, as modified by Appendix A of this revenue procedure.
(4) The procedures for obtaining opinion and advisory letters for prototype plans and VS plans under § 403(b) are contained in Rev. Proc. 2013–22, as modified by Rev. Proc. 2014–28 and Rev. Proc. 2015–22, and clarified by Rev. Proc. 2017–18.
Employee Plans Compliance Resolution System
.02 The procedures for obtaining compliance statements, etc., for certain failures of plans qualified under § 401(a), § 403(b) plans, SEPs, SIMPLEs, and § 457(b) plans under EPCRS are contained in Rev. Proc. 2018–52.
.03 The procedures for obtaining letter rulings, information letters, etc., on matters within the jurisdiction of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), or within the jurisdiction of other Offices of Associate Chief Counsel are contained in the following revenue procedures:
(1) Chief Counsel’s letter rulings, information letters, etc.: See Rev. Proc. 2019–1, this Bulletin.
(2) Technical Advice Requests: See Rev. Proc. 2019–2, this Bulletin.
(3) Chief Counsel’s no-rule positions: See Rev. Proc. 2019–3, this Bulletin.
Determination letters not issued for requests for minimum funding waivers
.04 The alternative of requesting a determination letter in conjunction with a waiver of the minimum funding standard as described in section 3.04 of Rev. Proc. 2004–15, 2004–1 C.B. 490, is no longer available. A request for a letter ruling on a waiver of the minimum funding standard is submitted to the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) and may no longer be submitted to Employee Plans Rulings and Agreements. See Rev. Proc. 2019–1, this Bulletin.
SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS?
.01 This section explains the general instructions for requesting letter rulings and determination letters on all matters within the jurisdiction of Employee Plans Rulings and Agreements. Requests for letter rulings and determination letters require the payment of the applicable user fee discussed in section 6.02(15), section 30, and Appendix A of this revenue procedure. Specific and additional instructions also apply to requests for letter rulings and determination letters on certain matters.
All requests must be submitted in English. All documents submitted in support of such requests must be in English, or accompanied by an English translation.
Certain information required in all requests
(1) Complete statement of facts and other information. Each request for a letter ruling or determination letter must contain a complete statement of all facts relating to the transaction. These facts include—
(a) names, addresses, telephone numbers, and taxpayer identification numbers of all interested parties (the term “all interested parties” does not mean all shareholders of a widely held corporation requesting a letter ruling relating to a reorganization, or all employees if a large number may be involved);
(b) a complete statement of the business reasons for the transaction; and
(c) a detailed description of the transaction.
The Service will usually not rule on only one step of a larger integrated transaction. See section 25.04 of this revenue procedure. However, if such a letter ruling is requested, the facts and circumstances relating to the entire transaction, including true copies of relevant documents, etc., must be submitted.
(2) Copies of all contracts, wills, deeds, agreements, instruments, plan documents, and other documents. All documents that are pertinent to the transaction (including contracts, wills, deeds, agreements, instruments, plan documents, trust documents, and proposed disclaimers) must be submitted with the request.
Original documents should not be submitted because they become part of the Service’s file and will not be returned to the taxpayer. Instead, true copies of all such documents should be submitted with the request. Each document, other than the request, should be labeled alphabetically and attached to the request in alphabetical order.
(3) Analysis of material facts. All material facts in documents must be included, rather than merely incorporated by reference, in the taxpayer’s initial request or in supplemental letters. These facts must be accompanied by an analysis of their bearing on the issue or issues, specifying the legal provisions that apply.
(4) Statement regarding whether same issue is in an earlier return. The request must state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, the same issue is in an earlier return of the taxpayer (or in a return for any year of a related taxpayer within the meaning of § 267 or of a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504 or of a predecessor of the taxpayer).
If the statement is affirmative, it must specify whether the issue—
(a) is being examined by the Service;
(b) has been examined and, if so, whether or not the statutory period of limitations has expired for either assessing tax or filing a claim for refund or credit of tax;
(c) has been examined and, if so, whether or not a closing agreement covering the issue or liability has been entered into by the Service;
(d) is being considered by an Appeals Office in connection with a return from an earlier period;
(e) has been considered by an Appeals Office in connection with a return from an earlier period and, if so, whether or not the statutory period of limitations has expired for either assessing tax or filing a claim for refund or credit of tax;
(f) has been considered by an Appeals Office in connection with a return from an earlier period and whether or not a closing agreement covering the issue or liability has been entered into by an Appeals Office;
(g) is pending in litigation in a case involving the taxpayer or a related taxpayer; or
(h) is being considered by the Pension Benefit Guaranty Corporation (PBGC) or the Department of Labor (DOL).
Same or similar issue previously submitted or currently pending
(5) Statement regarding whether same or similar issue was previously ruled on or requested, or is currently pending. The request must also state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives—
(a) Employee Plans Rulings and Agreements previously ruled on the same or a similar issue for the taxpayer (or a related taxpayer within the meaning of § 267, or a member of an affiliated group of which the taxpayer is also a member within the meaning of § 1504 or a predecessor);
(b) the taxpayer, a related taxpayer, or a predecessor previously submitted the same or a similar issue to Employee Plans Rulings and Agreements but withdrew the request before a letter ruling or determination letter was issued;
(c) the taxpayer, a related taxpayer, or a predecessor previously submitted a request involving the same or a similar issue that is currently pending with Employee Plans Rulings and Agreements or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes); or
(d) at the same time as this request, the taxpayer or a related taxpayer is presently submitting another request involving the same or a similar issue to Employee Plans Rulings and Agreements or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).
If the statement is affirmative for (a), (b), (c), or (d) of this section 6.02(5), the statement must give the date the request was submitted, the date the request was withdrawn or ruled on, if applicable, and other details of the consideration of the issue by Employee Plans Rulings and Agreements or the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).
(6) Statement of supporting authorities. If the taxpayer advocates a particular conclusion, an explanation of the grounds for that conclusion and the relevant authorities to support it must also be included. Even if not advocating a particular tax treatment of a proposed transaction, the taxpayer must still furnish views on the tax results of the proposed transaction and a statement of relevant authorities to support those views.
In all events, the request must include a statement of whether the law in connection with the request is uncertain and whether and how the issue is addressed by relevant authorities.
(7) Statement of contrary authorities. The taxpayer is also encouraged to inform Employee Plans Rulings and Agreements about, and discuss the implications of, any authority believed to be contrary to the conclusion requested, such as legislation (or pending legislation), tax treaties, court decisions, regulations, revenue rulings, revenue procedures, notices, or announcements. If the taxpayer determines that there are no contrary authorities, a statement in the request to this effect would be helpful. If the taxpayer does not furnish either contrary authorities or a statement that none exists, Employee Plans Rulings and Agreements, in complex cases or those presenting difficult or novel issues, may request submission of contrary authorities or a statement that none exists. Failure to comply with this request may result in Employee Plans Rulings and Agreements refusing to issue a letter ruling or determination letter.
Identifying and discussing contrary authorities generally will enable Employee Plans Rulings and Agreements personnel to understand the issue and relevant authorities more quickly. In that case, when Employee Plans Rulings and Agreements personnel receive the request, they will have before them the taxpayer’s thinking on the effect and applicability of contrary authorities. This information should make research easier and lead to earlier action by Employee Plans Rulings and Agreements. If the taxpayer does not disclose and distinguish significant contrary authorities, Employee Plans Rulings and Agreements may need to request additional information, which will delay action on the request and may result in the application being returned due to being an incomplete submission.
(8) Statement identifying pending legislation. At the time of filing the request, the taxpayer must identify any pending legislation that may affect the proposed transaction. In addition, if applicable legislation is introduced after the request is filed but before a letter ruling or determination letter is issued, the taxpayer must notify Employee Plans Rulings and Agreements.
Deletions statement required by § 6110
(9) Statement identifying information to be deleted from copy of letter ruling for public inspection. The text of private letter rulings is open to public inspection under § 6110. The Service makes deletions from the text before it is made available for inspection. To help the Service make the deletions required by § 6110(c), a request for a letter ruling must be accompanied by a statement indicating the deletions desired (“deletions statement”). If the deletions statement is not submitted with the request, a Service representative will tell the taxpayer that the request will be closed if the Service does not receive the deletions statement within 30 calendar days. See section 27.05 of this revenue procedure.
(a) Format of deletions statement. A taxpayer who wants only names, addresses, and identifying numbers to be deleted should state this in the deletions statement. If the taxpayer wants more information deleted, the deletions statement must be accompanied by a copy of the request and supporting documents on which the taxpayer should bracket the material to be deleted. The deletions statement must indicate the statutory basis under § 6110(c) for each proposed deletion.
If the taxpayer decides to ask for additional deletions before the letter ruling is issued, additional deletions statements may be submitted.
(b) Location of deletions statement. The deletions statement must not appear in the request, but instead must be made in a separate document and placed on top of the request for a letter ruling.
(c) Signature. The deletions statement must be signed and dated by the taxpayer or the taxpayer’s authorized representative. A stamped signature or signature by facsimile transmission (fax) is not permitted.
(d) Additional information. The taxpayer should follow the same procedures above to propose deletions from any additional information submitted after the initial request. An additional deletions statement, however, is not required with each submission of additional information if the taxpayer’s initial deletions statement requests that only names, addresses, and identifying numbers be deleted, and the taxpayer wants only the same information deleted from the additional information.
(e) Taxpayer may protest deletions not made. After receiving from the Service the notice under § 6110(f)(1) of intention to disclose the letter ruling (including a copy of the version proposed to be open to public inspection and notation of third-party communications under § 6110(d)), the taxpayer may protest the disclosure of certain information in the letter ruling. The taxpayer must send a written statement within 20 calendar days to the Service office indicated on the notice of intention to disclose. The statement must identify those deletions that the Service has not made and that the taxpayer believes should have been made. The taxpayer must also submit a copy of the version of the letter ruling and bracket the deletions proposed that have not been made by the Service. Generally, the Service will not consider deleting any material that the taxpayer did not propose to be deleted before the letter ruling was issued.
Within 20 calendar days after the Service receives the response to the notice under § 6110(f)(1), the Service will mail to the taxpayer its final administrative conclusion regarding the deletions to be made. The taxpayer does not have the right to a conference to resolve any disagreements concerning material to be deleted from the text of the letter ruling. However, these matters may be taken up at any conference that is otherwise scheduled regarding the request.
(f) Taxpayer may request delay of public inspection. After receiving the notice under § 6110(f)(1) of intention to disclose, but within 60 calendar days after the date of notice, the taxpayer may send a request for delay of public inspection under either § 6110(g)(3) or (4). The request for delay must be sent to the Service office indicated on the notice of intention to disclose. A request for delay under § 6110(g)(3) must contain the date on which it is expected that the underlying transaction will be completed. The request for delay under § 6110(g)(4) must contain a statement from which the Commissioner of Internal Revenue may determine that there are good reasons for the delay.
(g) Section 6110 does not apply to certain matters. Section 6110(I)(1) states that § 6110 disclosure provisions do not apply to any matter to which § 6104 applies. Therefore, letter rulings, determination letters, and related background file documents dealing with the following matters (covered by § 6104) are not subject to § 6110 disclosure provisions—
(i) An application for the qualification of a pension, profit-sharing or stock bonus plan, or an individual retirement account described in § 408 or § 408A, or any application for exemption under § 501(a) by an organization forming part of such a plan or an account;
(ii) Any document issued by the Service in which the qualification or exempt status of a plan or account is granted, denied, or revoked;
(iii) Any application filed and any document issued by the Service with respect to the qualification or status of pre-approved plans; and
(iv) The portion of any document issued by the Service with respect to the qualification or exempt status of a plan or account of a proposed transaction by such plan or account.
(10) Signature by taxpayer or authorized representative. The request for a letter ruling or determination letter must be signed and dated by the taxpayer or the taxpayer’s authorized representative. Neither a stamped signature nor a faxed signature is permitted.
(11) Authorized representatives. To sign the request or to appear before the Service in connection with the request, the representative must be one of the following:
(a) An attorney who is a member in good standing of the bar of the highest court of any state, possession, territory, commonwealth, or the District of Columbia and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as an attorney and current authorization to represent the taxpayer.
(b) A certified public accountant who is qualified to practice in any state, possession, territory, commonwealth, or the District of Columbia and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as a certified public accountant and current authorization to represent the taxpayer.
(c) An enrolled agent is a person, other than an attorney or certified public accountant that is currently enrolled to practice before the Service and is not currently under suspension or disbarment from practice before the Service, including a person enrolled to practice only for employee plans matters. He or she must file a written declaration with the Service showing current enrollment and authorization to represent the taxpayer. Either the enrollment number or the expiration date of the enrollment card must be included in the declaration. For the rules on who may practice before the Service, see Treasury Department Circular No. 230.
Enrolled actuary
(d) An enrolled actuary is a person enrolled as an actuary by the Joint Board for the Enrollment of Actuaries pursuant to 29 U.S.C. 1242 and qualified to practice in any state, possession, territory, commonwealth, or the District of Columbia and who is not currently under suspension or disbarment from practice before the Service. He or she must file a written declaration with the Service showing current qualification as an enrolled actuary and current authorization to represent the taxpayer. Practice as an enrolled actuary is limited to representation with respect to issues involving the following statutory provisions: §§ 401, 403(a), 404, 412, 413, 414, 419, 419A, 420, 4971, 4972, 4976, 4980, 6057, 6058, 6059, 6652(d), 6652(e), 6692, 7805(b), former § 405, and 29 U.S.C. 1083.
Enrolled retirement plan agent
(e) An enrolled retirement plan agent (ERPA) is an individual who is authorized to practice before the Service under the ERPA program. The ERPA program is established under Circular No. 230 of the U.S. Department of the Treasury and is administered by the Office of Professional Responsibility.
Practice as an ERPA is limited to representation with respect to issues involving the Employee Plans determination letter program, EPCRS, and the pre-approved programs. In addition, ERPAs are generally permitted to represent taxpayers with respect to Form 5300 series and Form 5500 filings, but not with respect to actuarial forms or schedules. For additional information on ERPAs, see §§ 10.4, 10.5, and 10.6 of Circular No. 230.
A person with a “Letter of Authorization”
(f) Any other person, including a foreign representative, who has received a “Letter of Authorization” from the Director, Office of Professional Responsibility under section 10.7(d) of Treasury Department Circular No. 230. A person may make a written request for a “Letter of Authorization” to: Office of Director, Office of Professional Responsibility, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC 20224. Section 10.7(d) of Circular No. 230 authorizes the Commissioner to allow an individual who is not otherwise eligible to practice before the Service to represent another person in a particular matter. For additional information, see section 6.02(12) below.
Employee, general partner, bona fide officer, administrator, trustee, etc.
(g) The above requirements do not apply to a regular full-time employee representing his or her employer, to a general partner representing his or her partnership, to a bona fide officer representing his or her corporation, association, or organized group, to a trustee, receiver, guardian, personal representative, administrator, or executor representing a trust, receivership, guardianship, or estate, or to an individual representing his or her immediate family. A preparer of a return (other than a person referred to in paragraph (a), (b), (c), (d), or (e) of this section 6.02(11)) who is not a full-time employee, a general partner, a bona fide officer, an administrator, a trustee, etc., or an individual representing his or her immediate family may not represent a taxpayer in connection with a letter ruling, determination letter, or technical advice request. See section 10.7(c) of Treasury Department Circular No. 230.
Foreign representative
(h) A foreign representative (other than a person referred to in paragraph (a), (b), (c), (d), or (e) of this section 6.02(11)) is not authorized to practice before the Service and, therefore, may not represent a taxpayer in a request for a letter ruling or a determination letter. In this situation, the nonresident alien or foreign entity must submit the request for a letter ruling or a determination letter on the individual’s or entity’s own behalf or through a person referred to in paragraph (a), (b), (c), (d), or (e) of this section 6.02(11).
(12) Power of attorney and declaration of representative. Any authorized representative, whether or not enrolled to practice, must also comply with the conference and practice requirements of the Statement of Procedural Rules (26 C.F.R. § 601.501–601.509), which provide the rules for representing a taxpayer before the Service. In addition, an unenrolled preparer must file a Form 8821, Tax Information Authorization, for certain limited employee plans matters.
Form 2848, Power of Attorney and Declaration of Representative, must be used to provide the representative’s authorization (Part I of Form 2848, Power of Attorney) and the representative’s qualification (Part II of Form 2848, Declaration of Representative). The name of the person signing Part I of Form 2848 should also be typed or printed on this form. A stamped signature is not permitted. An original, a copy, or a fax of the power of attorney is acceptable so long as its authenticity is not reasonably disputed. For additional information regarding the power of attorney form, see section 6.03(2) of this revenue procedure.
Compliance with Treasury Department Circular No. 230
(13) Compliance with Treasury Department Circular No. 230. The taxpayer’s authorized representative, whether or not enrolled, must comply with Treasury Department Circular No. 230, which provides the rules for practice before the Service. In those situations in which Employee Plans Rulings and Agreements believes that the taxpayer’s representative is not in compliance with Circular No. 230, Employee Plans Rulings and Agreements will bring the matter to the attention of the Director, Office of Professional Responsibility.
(a) Format of penalties of perjury statement. A request for a letter ruling or determination letter and any change in the request submitted at a later time must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this request, or this modification to the request, including accompanying documents, and, to the best of my knowledge and belief, the request or the modification contains all the relevant facts relating to the request, and such facts are true, correct, and complete.” See section 27.06 of this revenue procedure for the penalties of perjury statement applicable for submissions of additional information.
(b) Signature by taxpayer. The declaration must be signed and dated by the taxpayer, not the taxpayer’s representative. Neither a stamped signature nor a faxed signature is permitted.
The person who signs for a corporate taxpayer must be an officer of the corporate taxpayer who has personal knowledge of the facts, and whose duties are not limited to obtaining a letter ruling or determination letter from the Service. If the corporate taxpayer is a member of an affiliated group filing consolidated returns, a penalties of perjury statement must also be signed and submitted by an officer of the common parent of the group.
Applicable user fee
(15) Applicable user fee. Section 7528 of the Code requires taxpayers to pay user fees for requests for letter rulings, opinion letters, advisory letters, determination letters, and similar requests. Appendix A to this procedure contains the schedule of fees for each type of request under the jurisdiction of Employee Plans Rulings and Agreements. Section 30 of this revenue procedure provides guidance for administering the user fee requirements. If two or more taxpayers are parties to a transaction and each requests a letter ruling, each taxpayer must satisfy the rules herein and additional user fees may apply. See section 30.04 of this revenue procedure for exemptions from the user fee requirements.
(16) Number of copies of request to be submitted. Generally a taxpayer needs to submit only one copy of the request for a letter ruling or determination letter. If, however, more than one issue is presented in the letter ruling request, the taxpayer is encouraged to submit additional copies of the request.
Further, two copies of the request for a letter ruling or determination letter are required if—
(a) the taxpayer is requesting separate letter rulings or determination letters on different issues as described in section 6.03(1) of this revenue procedure;
(b) the taxpayer is requesting deletions other than names, addresses, and identifying numbers, as described in section 6.02(9) of this revenue procedure (one copy is the request for the letter ruling or determination letter and the second copy is the deleted version of such request); or
Sample of a letter ruling request
(17) Sample format for a letter ruling request. To assist a taxpayer or the taxpayer’s representative in preparing a letter ruling request, a sample format for a letter ruling request is provided in Appendix D. This format is not required to be used by the taxpayer or the taxpayer’s representative. If the letter ruling request is not identical or similar to the format in Appendix D, the different format will neither defer consideration of the letter ruling request nor be cause for returning the request to the taxpayer or taxpayer’s representative.
(18) Checklist for letter ruling requests. Employee Plans Rulings and Agreements will be able to respond more quickly to a taxpayer’s letter ruling request if it is carefully prepared and complete. The checklist in Appendix E of this revenue procedure is designed to assist taxpayers in preparing a request by reminding them of the essential information and documents to be furnished with the request. The checklist in Appendix E must be completed to the extent required by the instructions in the checklist, signed and dated by the taxpayer or the taxpayer’s representative, and placed on top of the letter ruling request. If the checklist in Appendix E is not received, Employee Plans Rulings and Agreements will ask the taxpayer or the taxpayer’s representative to submit the checklist, which may delay action on the letter ruling request. A photocopy of this checklist may be used.
Additional information required in certain circumstances
(1) To request a separate letter ruling for multiple issues in a single situation. If more than one issue is presented in a request for a letter ruling, Employee Plans Rulings and Agreements generally will issue a single letter ruling covering all the issues. However, if the taxpayer requests a separate letter ruling on any of the issues (because, for example, one letter ruling is needed sooner than another), Employee Plans Rulings and Agreements usually will comply with the request unless it is not feasible or not in the best interests of the Service to do so. A taxpayer who wants a separate letter ruling on multiple issues should make this clear in the request and submit two copies of the request. Additional checklists are solely for the specific issues designated.
In issuing each letter ruling, Employee Plans Rulings and Agreements will state that it has issued a separate letter ruling or that requests for other letter rulings are pending.
(2) Recipient of original letter ruling or determination letter. Employee Plans Rulings and Agreements will send the original of the letter ruling or determination letter to the taxpayer and a copy of the letter ruling or determination letter to the taxpayer’s representative. The letter ruling or determination letter is addressed to the taxpayer. A Form 2848, Power of Attorney and Declaration of Representative, must be used to provide the representative’s authorization except in certain employee plans matters. See section 6.02(12) of this revenue procedure.
To have a copy sent to taxpayer’s representative. A copy of the letter ruling or determination letter will be sent to any representative with a check in the box in the name and address block on Form 2848 to indicate the representative is to receive notices and communications. Copies of the letter ruling or determination letter, however, will be sent to no more than two representatives.
(3) To request expedited handling. Employee Plans Rulings and Agreements ordinarily processes requests for letter rulings and determination letters in order of the date received. Determination letter requests are not eligible for expedited handling. Expedited handling with respect to a letter ruling request means that the request is processed ahead of the regular order. Expedited handling is granted only in rare and unusual cases, both out of fairness to other taxpayers and because Employee Plans Rulings and Agreements seeks to process all requests as expeditiously as possible and to give appropriate deference to normal business exigencies in all cases not involving expedited handling.
A taxpayer who has a compelling need to have a letter ruling request processed ahead of the regular order may request expedited handling. This request must explain in detail the need for expedited handling. The request must be made in writing, preferably in a separate letter with, or soon after filing, the request for the letter ruling. If the request is not made in a separate letter, then the letter in which the letter ruling request is made should say, at the top of the first page: “Expedited Handling Is Requested. See page ___ of this letter.”
A request for expedited handling will not be forwarded to the appropriate group for action until the check or money order for the user fee in the correct amount is received.
Whether the request will be granted is within the discretion of Employee Plans Rulings and Agreements. Employee Plans Rulings and Agreements may grant a request if a factor outside a taxpayer’s control creates a real business need to obtain a letter ruling before a certain time in order to avoid serious business consequences. Examples include situations in which a court or governmental agency has imposed a specific deadline for the completion of a transaction, or a transaction must be completed expeditiously to avoid an imminent business emergency (such as the hostile takeover of a corporate taxpayer), provided that the taxpayer can demonstrate that the deadline or business emergency, and the need for expedited handling, resulted from circumstances that could not reasonably have been anticipated or controlled by the taxpayer. To qualify for expedited handling in such situations, the taxpayer must also demonstrate that the taxpayer submitted the request as promptly as possible after becoming aware of the deadline or emergency. The extent to which the letter ruling complies with all of the applicable requirements of this revenue procedure, and fully and clearly presents the issues, is a factor in determining whether expedited treatment will be granted. If Employee Plans Rulings and Agreements agrees to process a request out of order, it cannot give assurance that any letter ruling will be processed by the time requested. The scheduling of a closing date for a transaction or a meeting of the board of directors or shareholders of a corporation, without regard for the time it may take to obtain a letter ruling, will not be considered a sufficient reason to process a request ahead of its regular order. Also, the possible effect of fluctuation in the market price of stocks on a transaction will not be considered a sufficient reason to process a request out of order.
Because most requests for letter rulings cannot be processed ahead of their regular order, Employee Plans Rulings and Agreements urges all taxpayers to submit their requests well in advance of the contemplated transaction. In addition, in order to facilitate prompt action on letter ruling requests taxpayers are encouraged to ensure that their initial submissions comply with all of the requirements of this revenue procedure (including the requirements of other applicable guidelines set forth in sections 1.03 and 26.02 of this revenue procedure), and to provide promptly any additional information requested by Employee Plans Rulings and Agreements.
Facsimile transmission (fax)
(4) To receive a letter ruling by facsimile transmission (fax). A letter ruling ordinarily is not sent by fax. However, if the taxpayer requests, a copy of a letter ruling may be faxed to the taxpayer or the taxpayer’s authorized representative. A letter ruling, however, is not issued until the ruling is mailed. See § 301.6110–2(h).
A request to fax a copy of the letter ruling to the taxpayer or the taxpayer’s authorized representative must be made in writing, either as part of the original letter ruling request or prior to the approval of the letter ruling. The request must contain the fax number of the taxpayer or the taxpayer’s authorized representative to whom the letter ruling is to be faxed.
Employee Plans Rulings and Agreements will take certain precautions to protect confidential information. For example, Employee Plans Rulings and Agreements will use a cover sheet that identifies the intended recipient of the fax and the number of pages transmitted. The cover sheet, if possible, will not identify the specific taxpayer by name, and it will be the first page covering the letter ruling being faxed.
(5) To request a conference. A taxpayer who wants to have a conference on the issues involved in a request for a letter ruling should indicate this in writing when, or soon after, filing the request.
Address to send the request
The addresses for sending requests are provided in section 31 of this revenue procedure.
(1) Circumstances under which the taxpayer must notify Employee Plans Rulings and Agreements. The taxpayer must notify Employee Plans Rulings and Agreements if, after the letter ruling request is filed but before a letter ruling is issued, the taxpayer knows that—
(a) an examination of the issue or the identical issue on an earlier year’s return has been started by an Examinations office of the Service;
(b) the issue is being considered by the PBGC or the DOL; or
(c) legislation that may affect the transaction has been introduced (see section 6.02(8) of this revenue procedure).
(2) Taxpayer must notify Employee Plans Rulings and Agreements if return is filed and must attach request to return. If the taxpayer files a return before a letter ruling is received from Employee Plans Rulings and Agreements concerning the issue, the taxpayer must notify Employee Plans Rulings and Agreements that the return has been filed. The taxpayer must also attach a copy of the letter ruling request to the return to alert the Employee Plans Examinations office and thereby avoid premature Employee Plans Examinations office action on the issue.
When to attach letter ruling to return
.06 If, before filing a return, a taxpayer receives a letter ruling about any transaction that is relevant to the return, the taxpayer must attach a copy of the letter ruling to the return when it is filed.
How to check on status of request
.07 The taxpayer or the taxpayer’s authorized representative may obtain information regarding the status of a request by calling the person whose name and telephone number are shown on the acknowledgement of receipt of the request.
SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER?
.01 A taxpayer may withdraw a request for a letter ruling or determination letter at any time before the letter ruling or determination letter is signed by Employee Plans Rulings and Agreements. Correspondence and exhibits related to a request that is withdrawn or related to a letter ruling request or determination letter request for which Employee Plans Rulings and Agreements declines to issue a letter ruling or determination letter will not be returned to the taxpayer. See section 6.02(2) of this revenue procedure.
The processing of a request for a letter ruling or determination letter will not be suspended in Employee Plans Rulings and Agreements at the request of a taxpayer.
.02 If a taxpayer withdraws a request for a letter ruling, or if Employee Plans Rulings and Agreements declines to issue a letter ruling, Employee Plans Rulings and Agreements will notify the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return. Employee Plans Rulings and Agreements also may give the Service official its views on the issues in the request to consider in any later examination of the return. See section 10.15 of this revenue procedure regarding the withdrawal of a determination letter application.
.03 The user fee will not be returned for a letter ruling or determination letter request that is withdrawn. If Employee Plans Rulings and Agreements declines to issue a letter ruling on all of the issues in the request or declines to issue a determination letter, the user fee will be returned. If Employee Plans Rulings and Agreements, however, issues a letter ruling on some, but not all, of the issues, the user fee will not be returned.
SECTION 8. IN WHAT AREAS ARE DETERMINATION LETTERS ISSUED?
Circumstances under which determination letters are issued
.01 Employee Plans Rulings and Agreements issues determination letters in response to taxpayers’ written requests on completed transactions on matters within its jurisdiction.
Employee Plans Rulings and Agreements does not issue determination letters on the tax consequences of proposed transactions, except on the qualified status of employee plans under §§ 401, 403(a), 409, and 4975(e)(7), and the exempt status of any related trust under § 501.
Neither Employee Plans Rulings and Agreements nor any other office issues determination letters on plans under § 403(b). However, for information regarding the procedures for obtaining opinion and advisory letters for prototype plans and VS plans under § 403(b), see Rev. Proc. 2013–22, as modified by Rev. Proc. 2014–28 and Rev. Proc. 2015–22, and clarified by Rev. Proc. 2017–18.
Types of requests
.02 Determination letters may be requested on completed and proposed transactions as set forth in the table below:
REV. PROC. SECTION
1. Initial Qualification
a. Individually-designed plans (including collectively bargained plans) 5300 11
b. Pre-approved plans 5300 12
c. Employee Stock Ownership Plans (“ESOPs”) 5300, 5309 11
d. Multiple employer plans 5300 14
e. Group trusts 5316 16
f. § 414(x) combined plans 5300 11
a. In general 5310, 6088 15
b. Multiemployer plan covered by PBGC insurance 5300, 6088, Cover letter 15
Note: Form 5310–A, Notice of Plan Merger, Consolidation, Spinoff or Transfer of Plan Assets or Liabilities – Notice of Qualified Separate Lines of Business, generally must be filed not less than 30 days before the merger, consolidation or transfer of assets and liabilities. The filing of Form 5310–A will not result in the issuance of a determination letter.
3. Other Circumstances 5300 11
4. Volume Submitter Plans
Adoption of VS plans (if the employer has made modifications that are not extensive to the language of the approved specimen plan) 5307 13
5. M&P and Volume Submitter Plans
a. Adoption of VS multiple employer plan (if the controlling member has made modifications that are not extensive) 5300 12
b. Adoption of VS plan (if the employer has made extensive modifications) 5300 12
c. Adoption of M&P plan (if the employer has made any modifications) 5300 12
d. Adoption of M&P plan (if employer has modified plan to add overriding language to satisfy §§ 415 or 416) 5300 or 5307 12
e. Adoption of M&P or VS plan (if the employer requests a determination that the plan’s normal retirement age satisfies § 1.401(a)–1(b)(2)) 5300 12
Note: The types of requests listed in 4 and 5 above apply to determination letter requests submitted pursuant to Rev. Proc. 2015–36. The provisions of Rev. Proc. 2017–41 relating to the eligibility of adopting employers to submit determination letter requests during the third (and subsequent) six-year remedial amendment cycles will be set forth in future revisions to this revenue procedure.
6. Special Types of Requests
a. Leased employees (§ 414(n)) 5300, Cover letter 17
b. Partial termination 5300, Cover letter 9.09
c. Section 401(h) determination letters 5300, Cover letter 18
d. Section 420 determination letters including other matters under § 401(a) 5300, Cover letter, Checklist 18
e. Section 420 determination letters excluding other matters under § 401(a) Cover letter, Checklist 18
Areas in which determination letters will not be issued
.03 Determination letters issued in accordance with this revenue procedure do not include determinations involving the following:
(1) Issues involving §§ 72, 79, 105, 125, 127, 129, 402, 403 (other than 403(a)), 404, 409(l), 409(n), 412, 414(b), 414(c), 414(h)(2), 414(m), 415(m), 457, 511 through 515, and 4975 (other than 4975(e)(7));
(2) Plans or plan amendments for which automatic reliance is granted pursuant to section 19 of Rev. Proc. 2015–36, or section 7 of Rev. Proc. 2017–41;
(3) Plan amendments described below (these amendments will, to the extent provided, be deemed not to alter the qualified status of a plan under § 401(a)):
(a) An amendment solely to permit a trust forming part of a plan to participate in a pooled fund arrangement described in Rev. Rul. 81–100, 1981–1 C.B. 326, as clarified and modified by Rev. Rul. 2004–67, 2004–2 C.B. 28; Rev. Rul. 2011–1, 2011–2 I.R.B. 251; Notice 2012–6, 2012–3 I.R.B. 293, and Rev. Rul. 2014–24, 2014–37 I.R.B. 529;
(b) An amendment that merely adjusts the maximum limitations under § 415 to reflect annual cost-of-living increases under § 415(d), other than an amendment that adds an automatic cost-of-living adjustment provision to the plan; and
(c) An amendment solely to include language pursuant to § 403(c)(2) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA) concerning the reversion of employer contributions made as a result of mistake of fact;
(4) Determination letter requests with respect to plans that combine an ESOP (as defined in § 4975(e)(7)) with retiree medical benefit features described in § 401(h) (sometimes referred to as an HSOP):
(a) In general, determination letters will not be issued with respect to plans that combine an ESOP with another ESOP containing 401(h) features with respect to:
(i) whether the requirements of § 4975(e)(7) are satisfied;
(ii) whether the requirements of § 401(h) are satisfied; or
(iii) whether the combination of an ESOP with an ESOP that contains 401(h) features in a plan adversely affects its qualification under § 401(a);
(b) However, an arrangement will not be considered covered by section 8.03(4) of this revenue procedure if, under the provisions of the plan, the following conditions are satisfied:
(i) No individual accounts are maintained in the § 401(h) account (except as required by § 401(h)(6));
(ii) No employer securities are held in the § 401(h) account;
(iii) The § 401(h) account does not contain the proceeds (directly or otherwise) of an exempt loan as defined in § 54.4975–7(b)(1)(iii) of the Pension Excise Tax Regulations; and
(iv) The amount of actual contributions to provide § 401(h) benefits (when added to actual contributions for life insurance protection under the plan) does not exceed 25 percent of the sum of (1) the amount of cash contributions actually allocated to participants’ accounts in the plan, and (2) the amount of cash contributions used to repay principal with respect to the exempt loan, both determined on an aggregate basis since the inception of the § 401(h) arrangement; and
(5) Any issue if the same issue involving the same taxpayer or a related taxpayer is pending in a case in litigation or before an Appeals Office.
Determination letter applications
.04 The Service will accept applications for determination letters for plans seeking initial qualification and terminating plans any time during the year. See section 12 of Rev. Proc. 2016–37.
.05 Determination letters issued under this revenue procedure generally are not reviewed by any other office of the Service before they are issued. If a taxpayer believes that the conclusion reached in a determination letter is in error, the taxpayer may ask Employee Plans Rulings and Agreements to reconsider the matter or to request technical advice from the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) as described in Rev. Proc. 2019–2, this Bulletin.
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
Scope of this section
.01 This section delineates, generally, the scope of a determination letter issued by Employee Plans Rulings and Agreements. This section also identifies certain qualification requirements that are not considered by the Employee Plans Rulings and Agreements in its review of a plan and with respect to which determination letters do not provide reliance. This section applies to all determination letters, other than letters relating to the qualified status of group trusts; and certain letters relating solely to the requirements of § 420 (regarding the transfer of assets in a defined benefit plan to a health benefit account described in § 401(h)). For additional information pertaining to the scope of reliance on a determination letter, see section 23 of this revenue procedure.
Scope of determination letters
.02 In general, employee plans are reviewed by Employee Plans Rulings and Agreements for compliance with the form requirements (that is, those plan provisions that are required as a condition of qualification under § 401(a)). For terminating plans, the requirements are those that apply as of the date of termination. See Rev. Proc. 2016–37 for further details on the scope of Employee Plans Rulings and Agreements’ review of determination letter applications.
Design-based safe harbor
.03 Generally, a plan will not be reviewed for, and a determination letter may not be relied on with respect to, whether a plan satisfies the nondiscrimination requirements of § 401(a)(4), the minimum participation requirements of § 401(a)(26), or the minimum coverage requirements of § 410(b). However, if the applicant elects, and the plan document provides a definition of compensation that satisfies § 1.414(s)–1(c), a plan will be reviewed for, and a determination letter may be relied on with respect to, whether the terms of the plan satisfy one of the design-based safe harbors in §§ 1.401(a)(4)–2(b) and 1.401(a)(4)–3(b) of the regulations (relating to nondiscrimination in amount of contributions and benefits). A defined contribution plan will also be reviewed for, and a determination letter may be relied on with respect to, whether a plan’s terms satisfy the applicable requirements of §§ 401(k) and 401(m).
Governmental plans under § 414(d)
.04 A plan will not be reviewed for, and a determination letter does not constitute a ruling or determination as to, whether the plan is a governmental plan within the meaning of § 414(d). If a determination letter applicant represents on the application that the plan is a governmental plan within the meaning of § 414(d), the determination letter issued for the plan is predicated on that representation, and qualification is conditioned on the plan constituting a governmental plan within the meaning of § 414(d).
Church plans under § 414(e)
.05 A plan will not be reviewed for, and a determination letter does not constitute a ruling or determination as to, whether the plan is a church plan within the meaning of § 414(e). If a determination letter applicant represents on the application that the plan is a church plan within the meaning of § 414(e), the determination letter issued for the plan is predicated on that representation, and qualification is conditioned on the plan constituting a church plan within the meaning of § 414(e).
Tax treatment of certain contributions under § 414(h)
.06 A plan will not be reviewed for, and a determination letter does not constitute a ruling or determination as to, whether contributions to the plan satisfy § 414(h). A determination letter does not express an opinion on whether contributions made to a plan treated as a governmental plan defined in § 414(d) constitute employer contributions under § 414(h)(2).
Other limits on scope of determination letter
.07 A favorable determination letter does not provide reliance for purposes of §§ 404, 412, 430, 431, and 432 with respect to whether an interest rate (or any other actuarial assumption) is reasonable. A favorable determination letter does not constitute a determination with respect to whether any requirements of § 414(r), relating to whether an employer is operating qualified separate lines of business, are satisfied. A favorable determination letter does not constitute a determination with respect to the federal tax consequences of a lump sum risk-transferring program as described in Notice 2015–49, 2015–30 I.R.B. 79, except as explicitly provided in that notice.
.08 Applicants that are otherwise eligible to submit an application for a determination letter may elect that the letter include a determination as to whether leased employees are deemed employees of the employer under the meaning of § 414(n). See section 17 for procedures for requesting a leased employee determination.
Partial terminations
.09 Applicants may elect that a determination letter include a determination as to whether a partial termination has occurred with respect to the plan, and if so, its impact on plan qualification. An applicant may file a determination letter application on a Form 5300 and elect a determination regarding a partial termination, whether or not the plan is otherwise eligible to be submitted for a determination letter pursuant to sections 11.01 or 12.01 of this revenue procedure. However, if the plan is not otherwise eligible to be submitted for a determination letter, as provided in sections 11.01 or 12.01 of this revenue procedure, the scope of the determination letter issued with respect to the plan will be limited solely to the request regarding whether a partial termination has occurred.
Publication 794, Favorable Determination Letter
.10 Publication 794, Favorable Determination Letter, contains other information regarding the scope of a determination letter, including the requirement that all information submitted with the application be retained as a condition of reliance. In addition, the specific terms of each letter may further define its scope and the extent to which it may be relied upon. Publication 794 can also be found at http://www.irs.gov/Forms-&-Pubs.
SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS?
.01 Section 6 of this revenue procedure and this section 10 contain procedures that are generally applicable to all determination letter requests. Additional procedures for specific types of requests are contained in sections 11 through 18 of this revenue procedure.
Complete information required
.02 An applicant requesting a determination letter must file the material required by this revenue procedure with Employee Plans Rulings and Agreements Determinations Office (EP Determinations) at the address provided in section 31 of this revenue procedure. The filing of the application, when accompanied by all information and documents required by this revenue procedure, will generally serve to provide EP Determinations with the information required to make the requested determination. However, in making the determination, EP Determinations may require the submission of additional information. If an application is determined by EP Determinations to be procedurally or technically deficient, EP Determinations may decline to process the application and an applicant may be required to resubmit the entire application and pay a new user fee in order to request a determination letter. See section 10.11 of this revenue procedure for additional information. Information submitted to EP Determinations in connection with an application for determination may be subject to public inspection to the extent provided by § 6104. The applicant must include EPCRS documentation for any closing agreement or compliance statement. This includes applicable attachments or model schedules and copies of corrective amendments.
Complete copy of plan and trust instrument and applicable amendments required
.03 In addition to a copy of the plan and trust documents and other material required by the application, the determination letter application must also include a copy of all signed and dated plan amendments (including interim amendments, if applicable) adopted or effective subsequent to the most recent determination letter issued with respect to the plan (other than amendments adopted on behalf of the employer that adopted a VS plan by the practitioner that sponsors the employer’s VS plan) even if these amendments are dated earlier than a previous determination letter issued with respect to the plan. The application must also include the completed Procedural Requirements Checklist that is set forth in Forms 5300, 5307, 5310, and 5316.
Separate application for each single § 414(l) plan
.04 A separate application is required for each single plan within the meaning of § 414(l). This requirement does not pertain to applications regarding the qualified status of group trusts.
Prior letters
.05 If the plan (other than a plan submitting an application for initial determination) has received a favorable determination letter in the past, the application must include a copy of the latest determination letter. If a prior determination letter is not available, an explanation must be included with the application, and the employer must include a copy of the prior plan or adoption agreement, and the opinion or advisory letter, if applicable. The application also must include all amendments necessary to verify that the plan was amended timely.
Plans involving mergers
.06 If the submitted plan is the result of a merger of two or more plans, the applicant must include a copy of the prior determination letter for each of the plans that were combined to result in the merged plan. If a prior determination letter is not available for any such plan involved in a merger, an explanation must be included with the application, and the applicant must include a copy of the prior plan document or adoption agreement, and the opinion or advisory letter for the plan, if applicable. The application also must include all amendments necessary to verify that each plan was amended timely. Additionally, for each plan involved in a merger the applicant must provide all signed and dated plan amendments (including interim amendments, if applicable) adopted or effective subsequent to the most recent determination letter issued with respect to the plan.
.07 The appropriate user fee, if applicable, must be paid according to the procedures in section 30 of this revenue procedure. Form 8717, User Fee for Employee Plan Determination Letter Request, must accompany each determination letter request. In addition, if the user fee for a determination letter request is paid through www.pay.gov, a copy of the payment confirmation must be submitted along with Form 8717. If the criteria for the user fee exemption are met in accordance with Notice 2017–1, 2017–2 I.R.B. 367, the certification on Form 8717 must be signed. Stamped signatures are not acceptable.
Interested party notification and comment
.08 Before filing an application, the applicant requesting a determination letter must satisfy the requirements of section 3001(a) of ERISA, and § 7476(b)(2) of the Code and the regulations thereunder, which provide that an applicant requesting a determination letter on the qualified status of certain retirement plans must notify interested parties of such application. The general rules with respect to notifying interested parties of requests for determination letters relating to the qualification of plans involving §§ 401 and 403(a) are set out below in sections 19 and 20 of this revenue procedure.
Contrary authority must be distinguished
.09 If the application for determination involves an issue with respect to which contrary authorities exist, failure to disclose or distinguish such contrary authorities will result in requests for additional information or the determination that the application is not complete and cannot be processed.
Employer/employee relationship
.10 EP Determinations does not make determinations regarding the existence of an employer-employee relationship as part of its determination on the qualification of a plan, but relies on the applicant’s representations or assumptions, stated or implicit, regarding the existence of such a relationship. Taxpayers are reminded, however, that they may file Form SS–8, Determination of Worker Status for Purposes of Federal Employment Taxes and Income Tax Withholding, with the Service to determine the employment status of the individuals involved prior to filing an application for a determination letter on the qualified status of the plan. See section 12.04 of Rev. Proc. 2019–1.
Incomplete applications
.11 This section provides procedures for processing incomplete applications.
(1) Procedural Completeness. Upon receipt, an application will be reviewed to determine if it is procedurally complete. In order for an application to be procedurally complete, the application must include all of the information and documents required by this revenue procedure, including but not limited to the Form 5300 series application and the Procedural Requirements Checklist. See section 10.03 of this revenue procedure.
(2) Procedurally or Technically Deficient Determination Letter Applications – Individually Designed Plans. EP Determinations may request the submission of additional information for a procedurally or technically deficient application.
(a) If EP Determinations needs additional information to process the application, the applicant will be sent an information request with a 21-day response date.
(b) If the applicant’s response to such information request is not timely or complete, a letter will be sent to the applicant, giving an additional 30-day period in which to respond.
(c) If a complete response is not received by the response deadline set forth in the letter referenced in section 10.11(2)(b) of this revenue procedure, the case will be closed. The application will not be returned and any user fee submitted with respect to the application will not be refunded.
(3) Procedurally or Technically Deficient Determination Letter Applications – Pre-approved Plans. EP Determinations may request the submission of additional information for a procedurally or technically deficient application submitted by an adopter of an M&P or VS plan.
(a) If an application submitted by an adopter of an M&P or VS plan is procedurally deficient, EP Determinations will send the applicant a letter identifying the missing information. The applicant will have 21 days from the date of the letter to submit the missing information identified. If the missing information is not sent (postmarked) within 21 days of EP Determinations’ letter, the case will be closed. The application will not be returned, and any user fee with respect to the application will not be refunded.
(b) If a determination letter application for an adopter of an M&P or VS plan is closed pursuant to section 10.11(3)(a) of this revenue procedure, the applicant must resubmit the entire application, including a new user fee (if applicable), by the end of the plan sponsor’s remedial amendment cycle, unless a later date is specified in EP Determinations’ letter.
Effect of failure to disclose material fact
.12 EP Determinations may determine, based on the application form, the extent of review of the plan document. A failure to disclose a material fact or misrepresentation of a material fact on the application adversely affects the reliance that would otherwise be obtained through issuance by EP Determinations of a favorable determination letter. Similarly, failure to accurately provide any of the information called for on any form required by this revenue procedure may result in no reliance on the determination letter.
Where to file requests
.13 Requests for determination letters are to be addressed to EP Determinations at the address provided in section 31 of this revenue procedure.
Determination letter applications will not be accepted via fax.
Submission of related plans
.14 If applications for two or more plans of the same employer are submitted together, each application should include a cover letter that identifies the name of the employer and the plan numbers and employer identification numbers of all the related plans submitted together. EP Determinations will determine whether these applications will be worked simultaneously.
Withdrawal of requests
.15 The applicant’s request for a determination letter may be withdrawn by a written request at any time prior to the issuance of a final adverse determination letter. If an appeal to a proposed adverse determination letter is filed, a request for a determination letter may be withdrawn at any time prior to the forwarding of the proposed adverse action to the Chief, Appeals Office. In the case of a withdrawal, the Service will not issue a determination of any type. A failure to issue a determination letter as a result of a withdrawal will not be considered a failure of the Secretary or his delegate to make a determination within the meaning of § 7476. However, the Service may consider the information submitted in connection with the withdrawn request in a subsequent examination. Generally, the user fee will not be refunded if the application is withdrawn, however the applicant may submit a subsequent request for a determination letter pursuant to section 11 of this revenue procedure. The application must be accompanied with the appropriate user fee in accordance with section 30 of this revenue procedure. Any such application will be treated as an initial request.
Right to status conference
.16 An applicant for a determination letter has the right to a have a conference with the Director, EP Rulings and Agreements concerning the status of the application if the application has been pending at least 270 days. The status conference may be by phone or in person, as mutually agreed upon. During the conference, any issues relevant to the processing of the application may be addressed, but the conference will not involve substantive discussion of technical issues. No tape, stenographic, or other verbatim recording of a status conference may be made by any party. Subsequent status conferences may also be requested if at least 90 days have passed since the last preceding status conference.
How to request status conference
.17 A request for a status conference with the Director, EP Rulings and Agreements is to be made in writing and is to be sent to the specialist assigned to review the application or, if the applicant does not know who is reviewing the application, to the Director, EP Rulings and Agreements at the address provided in section 31 of this revenue procedure.
Correct format required
.18 Documents submitted should not be stapled or bound. The use of quickly removable clips or rubber bands is acceptable. The application form should be prepared using Courier 10 point font. Documents which must be unstapled or unbound may suffer data loss or may not scan properly, which impacts efficiency and delays processing of the application.
SECTION 11. WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS?
Requesting determination letters
.01 This section 11 contains the procedures for requesting determination letters for individually designed plans. Determination letters will be issued with respect to individually designed plans solely in the following circumstances:
(1) Initial qualification. See Rev. Proc. 2016–37, section 4.03(1), for a description of which plans may be submitted on a Form 5300, Application for Determination for Employee Benefit Plan, for initial qualification.
(2) Plan termination. See section 15 of this revenue procedure for additional procedures for requesting determination upon plan termination.
(3) Certain other circumstances as may be set forth in guidance published in the Internal Revenue Bulletin.
Elimination of Remedial Amendment Cycle for Individually Designed Plans
.02 Effective January 1, 2017, the staggered five-year remedial amendment cycle system for individually designed plans set forth in Rev. Proc. 2007–44 was eliminated. As of that date, EP Determinations no longer accepted determination letter applications based on the five-year remedial amendment cycle system.
.03 A determination letter request for the items listed in section 11.01 is made by filing the appropriate form according to the instructions to the form and any prevailing revenue procedures, notices, and announcements.
(1) Form 5300, Application for Determination for Employee Benefit Plan, including a copy of the Procedural Requirements Checklist included therein, must be filed to request a determination letter for an individually designed plan, including a collectively bargained plan. See section 12.01 for circumstances under which an adopting employer that has modified an M&P or VS plan may submit a determination letter request. In accordance with Rev. Proc. 2016–37, section 4.03(1), an employer may submit a plan for initial plan qualification on a Form 5300 as long as a favorable determination letter has never been issued with respect to the plan. Employers submitting requests on behalf of individually designed plans should file the most recent version of the Form 5300.
(2) Form 5309, Application for Determination of Employee Stock Ownership Plan, must be filed as an attachment with a Form 5300 in order to request a determination whether the plan is an ESOP under § 409 or § 4975(e)(7).
(3) Form 5310, Application for Determination for Terminating Plan, including a copy of the Procedural Requirements Checklist included therein, must be filed to request a determination for a terminating plan. Also, see section 15 of this revenue procedure for additional procedures pertaining to applications for determination upon plan termination.
(4) Form 8717, User Fee for Employee Plan Determination Letter Request (and the payment confirmation from www.pay.gov as described in section 10.07, if applicable) must be filed with the determination letter application. When completing the form, taxpayers should refer to the applicable Employee Plans user fees listed in Appendix A of this revenue procedure.
(5) Form 2848, Power of Attorney and Declaration of Representative.
(6) Form 8821, Tax Information Authorization.
Application must include copy of plan and amendments
.04 The application must include a copy of all signed and dated plan amendments (including interim amendments, if applicable) adopted or effective subsequent to the most recent determination letter issued with respect to the plan even if these amendments are dated earlier than a previous determination letter issued with respect to the plan. The application must also include a copy of the restated plan and trust instrument, if applicable. The application must also include the appropriate completed Procedural Requirements Checklist as set forth in Forms 5300, 5310, and 5316. If a plan did not receive a prior favorable determination letter, all plan documents and amendments must be submitted.
EP Determinations has the discretion to request copies of any other amendments during its review of a plan.
Restatements required
.05 If a sponsor of an individually designed plan has previously obtained a determination letter, the plan must be restated when it is submitted for a determination letter application, unless it is a terminating plan. Sponsors of terminating plans are encouraged, but not required, to submit a restatement when submitting a determination letter application. Plans submitted during 2019 must be restated for compliance with the 2017 Required Amendments List, Notice 2017–72, as well as any applicable prior Cumulative List.
Section 414(x) combined plans
.06 EP Determinations will consider § 414(x) in issuing determination letters for individually designed plans that consist of a defined benefit plan and a qualified cash or deferred arrangement (subject to the eligibility requirements in section 11.01 of this revenue procedure). A § 414(x) plan sponsor must submit two Forms 5300 and two applicable user fees.
SECTION 12. WHEN MAY AN ADOPTER OF A MASTER AND PROTOTYPE OR VOLUME SUBMITTER PLAN SUBMIT A DETERMINATION LETTER APPLICATION?
Eligibility to apply for a determination letter
.01 Rev. Proc. 2015–36 describes the procedures for requesting opinion letters and advisory letters on M&P and VS plans for applications submitted with respect to cycles prior to the third six-year remedial amendment cycle. This section 12 generally provides guidance on the eligibility of an adopting employer of an M&P or VS plan that received an opinion or advisory letter, pursuant to Rev. Proc. 2015–36, to submit a determination letter application with regard to that plan. Rev. Proc. 2017–41 modified the pre-approved plan program and is applicable to providers of pre-approved plans that submit requests for opinion letters with respect to the third (and subsequent) six-year remedial amendment cycles. Guidance on the eligibility of an employer that adopts a pre-approved plan that has received an opinion letter for the third (and subsequent) six-year remedial amendment cycles to submit a determination letter application, and the procedures for a submission with regard to such pre-approved plan, will be set forth in future revisions to this revenue procedure.
(1) Except as provided in section 12.01(5)(a), an adopting employer of an M&P plan (whether standardized or nonstandardized) may not apply for a determination letter for the plan on Form 5307.
(2) An adopting employer of a VS plan may not apply for a determination letter for the plan on Form 5307 unless the employer has modified the terms of the pre-approved plan, the pre-approved plan is not a multiple employer plan and the modifications are not extensive. Section 13 of this revenue procedure describes the procedures for requesting determination letters on Form 5307 for a VS plan in situations in which the employer has not made extensive modifications to the language of the pre-approved specimen plan and the pre-approved plan is not a multiple employer plan.
(3) A controlling member of a VS multiple employer plan (eligible to receive a determination letter as described in section 14.02 of this revenue procedure) that makes modifications to a VS multiple employer plan in situations in which the modifications are not extensive, may apply for a determination letter on Form 5300 in the two-year window described in section 13.03 of this revenue procedure regardless of whether a prior favorable determination letter has been issued with respect to the plan.
(4) An adopting employer that makes:
(a) Extensive modifications to a VS plan, or
(b) Any modification to a M&P plan,
may submit a determination letter application for the plan for initial plan qualification only during the two-year window described in section 13.03 of this revenue procedure, using Form 5300, as long as a favorable determination letter has never been issued with respect to the plan. See section 20 of Revenue Procedure 2016–37 regarding the effect of employer modifications on the six-year remedial amendment cycle.
(5) Notwithstanding the preceding paragraph, an adopter of an M&P or VS plan that has made no modifications other than the modifications listed in section 12.01(5)(a) and (b) of this revenue procedure may submit an application for a determination letter on Form 5300 (or on Form 5307 in the case of an application submitted pursuant to 12.01(5)(a)) regardless of whether a prior favorable determination letter has been issued with respect to the plan. Such an application may only be submitted during the two-year window described in section 13.03 of this revenue procedure.
(a) The employer has modified the terms of the M&P plan by adding overriding language necessary to coordinate the application of the limitations of § 415 or the requirements of § 416 because the employer maintains multiple plans.
(b) The plan is a pension plan and the normal retirement age under the plan is lower than 62. In this case, a determination letter is required for reliance that the plan’s normal retirement age satisfies the requirements of § 1.401(a)–1(b)(2) of the regulations.
An employer that submits an application for a determination letter for an M&P or VS plan for one or more of the reasons described in section 12.01(5)(a) and (b) of this revenue procedure must identify the applicable reason or reasons in a cover letter to the application and include a copy of the VS or M&P opinion or advisory letter.
If an adopting employer submits an application for a determination letter for an M&P or VS plan pursuant to section 12.01(2), (3), (4), or (5), the plan will be reviewed on the basis of the Cumulative List that was used to review the underlying pre-approved plan.
(6) An adopting employer of a pre-approved plan that is eligible to submit a determination letter application on Form 5300 in accordance with section 12.01(3), (4), or (5) of this revenue procedure may also request a determination regarding leased employee status (see section 17.05 of this revenue procedure).
(7) An adopting employer of a pre-approved plan may request a determination regarding partial termination (see section 9.09 of this revenue procedure) at any time, using Form 5300, regardless of whether the employer is otherwise eligible to submit a determination letter application in accordance with section 12.01(3), (4), or (5) of this revenue procedure.
Reliance equivalent to determination letter
.02 If an employer can rely on a favorable opinion or advisory letter pursuant to section 19 of Rev. Proc. 2015–36, as modified by Rev. Proc. 2016–37, or section 7 of Rev. Proc. 2017–41, the opinion or advisory letter is equivalent to a favorable determination letter. For example, the favorable opinion or advisory letter is treated as a favorable determination letter for purposes of section 23 of this revenue procedure, regarding the effect of a determination letter. Rev. Proc. 2015–36 also describes the extent to which adopting employers of such plans may rely on favorable opinion or advisory letters without requesting individual determination letters.
SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR VOLUME SUBMITTER PLANS?
.01 This section contains procedures for requesting determination letters for adopting employers of VS plans, that received an advisory letter pursuant to Rev. Proc. 2015–36 for the second six-year remedial amendment cycle, in situations in which the employer has made modifications to the approved specimen plan that are not extensive.
Determination letter for adoption of volume submitter plan
.02 An application filed on Form 5307, Application for Determination for Adopters of Modified Volume Submitter Plans, must include any interim plan amendments unless the VS plan authorizes the practitioner to amend on behalf of the adopting employer. EP Determinations may, however, request evidence of adoption of interim amendments during the course of its review of a particular plan. With respect to determination letters for adopting employers of VS plans:
(1) An application for a determination letter for an employer’s adoption of a VS plan in situations in which the employer has made modifications to the language of the approved specimen plan that are not extensive must be sent to the address provided in section 31 of this revenue procedure. For VS plans involved in plan mergers, see section 10.06 of this revenue procedure.
(2) The application for a determination letter must include the following:
(a) Form 8717, User Fee for Employee Plan Determination Letter Request (and the payment confirmation from www.pay.gov as described in section 10.07 of this revenue procedure, if applicable);
(b) Form 5307, Application for Determination for Adopters of Modified Volume Submitter Plans, including a copy of the Procedural Requirements Checklist included therein;
(c) Form 2848, Power of Attorney and Declaration of Representative. If applicable, submit Form 8812, Tax Information Authorization;
(d) Form 8905, Certification of Intent to Adopt a Pre-approved Plan, executed before the end of the employer’s second 5-year remedial amendment cycle as determined under Part III of Rev. Proc. 2007–44, if applicable;
(e) A copy of the most recent advisory letter for the practitioner’s VS specimen plan;
(f) A complete copy of the plan and trust instrument and, if applicable, a copy of the completed adoption agreement;
(g) A written representation (signature optional) made by the VS practitioner that explains how the plan and trust instrument differ from the approved specimen plan, describing the location, nature, and effect of each deviation from the language of the approved specimen plan;
(h) A copy of the plan’s latest favorable determination letter, if applicable;
(i) Applications filed on Form 5307 for VS plans in situations in which the employer has made modifications that are not extensive to the language of the approved specimen plan, and the plan does not authorize the practitioner to amend on behalf of the adopting employer, must include any interim amendments that were adopted for qualification changes on the applicable Cumulative List used in reviewing and approving the underlying VS plan; and
(j) Any other information or material that may be required by EP Determinations.
(3) Deviations from the language of the approved specimen plan will be evaluated based on the extent and complexities of the changes. If the changes are determined to be extensive, EP Determinations will require the applicant to file Form 5300 and pay the higher user fee, if otherwise eligible to file. If the changes are too extensive to be compatible with the VS program, the adopting employer’s plan will not be eligible for the VS program. See section 20.03(5) of Rev. Proc. 2016–37.
(4) An employer will not be treated as having adopted a VS plan if the employer has signed or otherwise adopted the plan prior to the date on the VS specimen plan’s advisory letter. In this case, the determination letter application for the employer’s plan may not be filed on Form 5307 and will not be eligible for a reduced user fee. A determination letter application for a VS plan must be based on the approved VS specimen plan with any applicable modifications. See section 19.03 of Rev. Proc. 2015–36.
Timing of determination letter applications for adopting employers of pre-approved plans
.03 In accordance with section 14 of Rev. Proc. 2016–37, adopting employers of M&P and VS plans have a six-year remedial amendment cycle. The deadline for an adopting employer to adopt the approved M&P or VS plan closes with the two-year window at the end of the plan’s remedial amendment cycle. An adopting employer of a modified VS plan that desires to obtain a determination letter for reliance must submit the application within the two-year window, except for a request for a determination on partial termination pursuant to section 12.01(7). Applications (other than those pursuant to section 12.01(7)) submitted outside of the two-year window will be returned.
SECTION 14. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS?
.01 This section contains procedures for applications filed with respect to plans described in § 413(c). A plan is not described in § 413(c) if all the employers maintaining the plan are members of the same controlled group or affiliated service group under § 414(b), (c), or (m).
Applicant must request letter for plan in the name of the controlling member
.02 A determination letter applicant for a multiple employer plan that is otherwise eligible to apply for a determination letter must request a letter for the plan in the name of the controlling member (the employer who sponsors the multiple employer plan). An applicant requesting a letter for the plan submits one Form 5300 application for the plan in the name of the controlling member, either including or omitting the design-based safe harbor questions. A participating employer maintaining a multiple employer plan may not request its own determination letter but may rely on a favorable determination letter issued to the controlling member, except with respect to the requirements of §§ 401(a)(4), 401(a)(26), 401(l), 410(b), and 414(s), and, if the employer maintains or has ever maintained another plan, §§ 415 and 416.
.03 The application is to be sent to the address provided in section 31. See Appendix A, section .06(1)(d) and (e) for the applicable user fee.
Addition of employers
.04 The controlling member may continue to rely on its favorable determination letter after another employer commences participation in the controlling member’s multiple employer plan. An employer that commences participation in the multiple employer plan after a controlling member receives a favorable determination letter may rely on the determination letter of the controlling member.
SECTION 15. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION UPON TERMINATION OR DISCONTINUANCE OF CONTRIBUTIONS, NOTICE OF MERGER, CONSOLIDATION, ETC.?
.01 This section contains procedures for requesting determination letters involving plan termination or discontinuance of contributions. This section also contains procedures regarding required notices of merger, consolidation, or transfer of assets or liabilities.
.02 Required Forms
(1) Form 5310, Application for Determination for Terminating Plan, including a copy of the Procedural Requirements Checklist included therein, is filed by plans other than multiemployer plans covered by the insurance program of the PBGC.
(2) Form 5300, Application for Determination of Employee Benefit Plan, including a copy of the Procedural Requirements Checklist included therein, is filed in the case of a multiemployer plan covered by PBGC insurance.
(3) Form 6088, Distributable Benefits from Employee Pension Benefit Plans, is filed in addition to Form 5310 or 5300 by a sponsor or plan administrator of a defined benefit plan or an underfunded defined contribution plan that files an application for a determination letter regarding plan termination. For collectively bargained plans, a Form 6088 is required only if the plan benefits employees who are not collectively bargained employees within the meaning of § 1.410(b)–6(d). A separate Form 6088 is required for each employer employing such employees. See the instructions for Form 6088 for information required to be submitted along with the form, including a statement explaining how plan present values were determined.
(4) Form 5310–A, Notice of Plan Merger or Consolidation, Spinoff, or Transfer of Plan Assets or Liabilities – Notice of Qualified Separate Lines of Business, if required, generally must be filed not later than 30 days before a merger, consolidation, or transfer of assets and liabilities. The filing of Form 5310–A will not result in the issuance of a determination letter.
(5) Form 8717, User Fee for Employee Plan Determination Letter Request (and the payment confirmation from www.pay.gov as described in section 10.07 of this revenue procedure, if applicable).
(6) Form 2848, Power of Attorney and Declaration of Representative. If applicable, submit Form 8821, Tax Information Authorization.
(7) Schedule SB (Form 5500), Single-Employer Defined Benefit Plan Actuarial Information, for defined benefit plans.
.03 The application for a determination letter involving plan termination must also include any supplemental information or schedules required by the forms or form instructions. For example, the application must include copies of all records of actions taken to terminate the plan (such as a resolution of the board of directors) and a schedule providing certain information regarding employees who separated from vesting service with less than 100% vesting.
In cases involving the termination of plans that contain a § 401(h) feature, a cover letter must accompany the submission, and it must reference the § 401(h) feature to make clear that this feature is part of the termination application. The cover letter must specifically state the location of plan provisions that relate to the § 401(h) feature.
In the case of the termination of a multiemployer plan, there must be a cover letter accompanying the submission, which specifies that it is an application for a termination of a multiemployer plan.
Compliance with Title IV of ERISA
.04 In the case of plans subject to Title IV of ERISA, a favorable determination letter issued in connection with a plan’s termination is conditioned on approval that the termination is a valid termination under Title IV of ERISA. Notification by the PBGC that a plan may not be terminated will be treated as a material change of fact.
Termination prior to time for amending for change in law
.05 A plan that terminates after the effective date of a change in law, but prior to the date that amendments related to the change in law are otherwise required, must be amended to comply with the applicable provisions of law from the date on which such provisions become effective with respect to the plan. Because such a terminated plan would no longer be in existence by the required amendment date and therefore could not be amended on that date, such plan must be amended in connection with the plan termination to comply with those provisions of law that become effective with respect to the plan on or before the date of plan termination. Such amendments include any amendments made after the date of plan termination that were required in order to obtain a favorable determination letter. In addition, annuity contracts distributed from such terminated plans must meet all the applicable provisions of any change in law. See section 7 of Rev. Proc. 2016–37.
An application will be deemed to be filed in connection with plan termination if it is filed no later than the later of (i) one year after the effective date of the termination, or (ii) one year after the date on which the action terminating the plan is adopted. However, in no event may the application be filed later than twelve months from the date of distribution of substantially all plan assets in connection with the termination of the plan.
Restatement not required for terminating plan
.06 An applicant for a terminating plan is encouraged to submit a restatement when applying for a determination; however, a restatement for a terminating plan generally is not required.
SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS?
.01 This section provides special procedures for requesting a determination letter on the qualified status of a group trust under Rev. Rul. 81–100, as clarified and modified by Rev. Rul. 2004–67, Rev. Rul. 2011–1, Notice 2012–6, and Rev. Rul. 2014–24.
.02 A request for a determination letter on the status of a group trust is made by submitting a Form 5316, Application for Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of certain individual retirement accounts under § 408 to participate. Rev. Rul. 2011–1 extends the ability to participate in group trusts to custodial accounts under § 403(b)(7), retirement income accounts under § 403(b)(9), and governmental retiree benefit plans under § 401(a)(24). There are two model amendments in Rev. Rul. 2011–1. Amendment 1 is for a group trust that received a determination letter from EP Determinations prior to January 10, 2011, that the group trust satisfies Rev. Rul. 81–100, but that does not satisfy the separate account requirement of paragraph (6) of the holding of Rev. Rul. 2011–1. Amendment 2 is for a group trust that received a determination letter from EP Determinations prior to January 10, 2011, that the group trust satisfies Rev. Rul. 81–100, as modified by Rev. Rul. 2004–67, and that intends to permit custodial accounts under § 403(b)(7), retirement income accounts under § 403(b)(9), or § 401(a)(24) governmental retirement plans to participate in the group trust. Rev. Rul. 2014–24 extends the ability to participate in a group trust to certain retirement plans qualified only under the Código de Rentas Internas para un Nuevo Puerto Rico de la Ley Núm. 1 de 31 de enero de 2011 (“Puerto Rico Code”), and clarifies that assets held by certain separate accounts maintained by insurance companies may be invested in group trusts that satisfy Rev. Rul. 81–100.
(1) Form 8717, User Fee for Employee Plan Determination Letter Request (and the payment confirmation from www.pay.gov as described in section 10.07, if applicable).
(3) Form 5316, Application for Group or Pooled Trust Ruling, including a copy of the Procedural Requirements Checklist.
SECTION 17. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION OF LEASED EMPLOYEE STATUS?
.01 This section provides procedures for determination letter requests on whether an employee is a leased employee and is deemed to be an employee of the recipient employer for qualification purposes under § 414(n). For an individually designed plan, an applicant may file a determination letter request on whether an employee is a leased employee and is deemed to be an employee of the recipient employer for qualification purposes under § 414(n) only if the plan is otherwise eligible to be submitted for a determination letter pursuant to section 11.01 of this revenue procedure.
Employer must request the determination under § 414(n)
.02 Generally, a determination letter will indicate whether an employee is a leased employee and is deemed to be an employee of the recipient employer under § 414(n) only if the employer requests such determination and submits with the determination letter application the information specified in section 17.06 of this revenue procedure.
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Restrepo Director Dies in Libya
IVAW mourns the passing of Tim Hetherington, photojournalist and co-director of the Oscar nominated documentary film Restrepo. We had the honor of meeting Tim in New York City at a joint screening of another Oscar nominated...
There's No Quick Fix for Veterans
Huffington Post, There's No Quick Fixes for Veterans April 13, 2011. By Maggie Martin "It has been nearly five years since I left the Army and still my time in the service is fresh in my mind. I think about my...
"Kill Team" in Afghanistan
March 27, 2011 / By Mark Boal Rolling Stone reports, "How U.S. soldiers in Afghanistan murdered innocent civilians and mutilated their corpses – and how their officers failed to stop them." http://www.rollingstone....
Repost from Truthout Friday 25 March 2011 by: David Bacon, t r u t h o u t | News Analysis The war in Iraq is supposedly over. The US administration says the occupation, which began on March 20 eight years ago, is ending...
Malalai Joya National Tour
(Reposted from Afghan Women's Mission) Malalai Joya, the acclaimed Afghan activist and author of A Woman Among Warlords with Derrick O’Keefe, will tour the United States this Spring to call attention to the on-going...
Iraq/Wisconson Labor Solidarity: Two Statements
In the wake of the threat posed to what remain of labor rights in Wisconsin, and the public’s powerful response, two Iraqi labor leaders, Hassan Jum’a and Faleh Abood, penned solidarity statements in late February on... | 2023-14/0000/en_head.json.gz/1328 | {"url": "https://www.ivaw.org/blog/iraqis-take-streets-call-real-democracy?page=14", "partition": "head_middle", "language": "en", "source_domain": "www.ivaw.org", "date_download": "2023-03-20T09:12:10Z", "digest": "sha1:UZXLI43MZRJC6C3ZMBI3EZ5M5R27IHDN"} | {"ccnet_length": [[0, 1488, 1488.0]], "ccnet_original_length": [[0, 1488, 17220.0]], "ccnet_nlines": [[0, 1488, 11.0]], "ccnet_original_nlines": [[0, 1488, 135.0]], "ccnet_language_score": [[0, 1488, 0.93]], "ccnet_perplexity": [[0, 1488, 312.0]], "ccnet_bucket": [[0, 1488, 0.0]], "rps_doc_curly_bracket": [[0, 1488, 0.0]], "rps_doc_ldnoobw_words": [[0, 1488, 0.0]], "rps_doc_lorem_ipsum": [[0, 1488, 0.0]], "rps_doc_stop_word_fraction": [[0, 1488, 0.30491803]], "rps_doc_ut1_blacklist": [[0, 1488, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1488, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1488, 0.01524132]], "rps_doc_frac_chars_top_3gram": [[0, 1488, 0.02201524]], "rps_doc_frac_chars_top_4gram": [[0, 1488, 0.0]], "rps_doc_frac_all_caps_words": [[0, 1488, 0.02622951]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1488, 0.54545455]], "rps_doc_frac_no_alph_words": [[0, 1488, 0.18360656]], "rps_doc_frac_unique_words": [[0, 1488, 0.68571429]], "rps_doc_mean_word_length": [[0, 1488, 4.82040816]], "rps_doc_symbol_to_word_ratio": [[0, 1488, 0.01967213]], "rps_doc_unigram_entropy": [[0, 1488, 4.88135991]], "rps_doc_word_count": [[0, 1488, 245.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 32, 0.0], [32, 259, 1.0], [259, 293, 0.0], [293, 506, 1.0], [506, 533, 0.0], [533, 751, 1.0], [751, 975, 1.0], [975, 1002, 0.0], [1002, 1221, 1.0], [1221, 1269, 0.0], [1269, 1488, 1.0]], "rps_lines_javascript_counts": [[0, 32, 0.0], [32, 259, 0.0], [259, 293, 0.0], [293, 506, 0.0], [506, 533, 0.0], [533, 751, 0.0], [751, 975, 0.0], [975, 1002, 0.0], [1002, 1221, 0.0], [1221, 1269, 0.0], [1269, 1488, 0.0]], "rps_lines_num_words": [[0, 32, 5.0], [32, 259, 36.0], [259, 293, 6.0], [293, 506, 41.0], [506, 533, 4.0], [533, 751, 31.0], [751, 975, 43.0], [975, 1002, 4.0], [1002, 1221, 34.0], [1221, 1269, 5.0], [1269, 1488, 36.0]], "rps_lines_numerical_chars_fraction": [[0, 32, 0.0], [32, 259, 0.0], [259, 293, 0.0], [293, 506, 0.02955665], [506, 533, 0.0], [533, 751, 0.03], [751, 975, 0.03755869], [975, 1002, 0.0], [1002, 1221, 0.0], [1221, 1269, 0.0], [1269, 1488, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 32, 0.0], [32, 259, 0.0], [259, 293, 0.0], [293, 506, 0.0], [506, 533, 0.0], [533, 751, 0.0], [751, 975, 0.0], [975, 1002, 0.0], [1002, 1221, 0.0], [1221, 1269, 0.0], [1269, 1488, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 32, 0.125], [32, 259, 0.06167401], [259, 293, 0.14705882], [293, 506, 0.07042254], [506, 533, 0.11111111], [533, 751, 0.04587156], [751, 975, 0.0625], [975, 1002, 0.14814815], [1002, 1221, 0.07762557], [1221, 1269, 0.125], [1269, 1488, 0.03652968]], "rps_doc_ml_palm_score": [[0, 1488, 0.00236708]], "rps_doc_ml_wikipedia_score": [[0, 1488, null]], "rps_doc_ml_wikiref_score": [[0, 1488, 0.73864746]], "rps_doc_books_importance": [[0, 1488, -97.84064152]], "rps_doc_openwebtext_importance": [[0, 1488, -8.60458705]], "rps_doc_wikipedia_importance": [[0, 1488, -37.88050366]], "rps_doc_num_sentences": [[0, 1488, 14.0]]} |
MPs meet with Headmaster at the REOPENED King Edmund School
Mark Francois, Member of Parliament for Rayleigh and Wickford, and Sir James Duddridge KCMG, Member of Parliament for Rochford and Southend East, met with Mr Osborn, the Headteacher of the recently reopened King Edmund School on Friday 27th January.
The King Edmund School was closed in November following the discovery of Asbestos within rubble on the site. Since the closure, both Members of Parliament have worked closely with the King Edmund School staff and the Department for Education to ensure the school was reopened safely as soon as possible, which subsequently occurred on Monday 23rd January.
During the meeting, Mr Osborn provided an update to the Members of Parliament on how the first week since the reopening has been for staff and pupils as they return to their classrooms.
Following the meeting, Mark said:
“Both my friend and neighbour, Sir James and I were involved in numerous virtual meetings with DfE officials, Cllr Tony Ball from Essex County Council and Schools Minister, Nick Gibb MP, to press for the asbestos to be cleared as soon as possible, so that the school could safely reopen for the benefit of pupils, parents and staff alike.
I am very pleased that this has now been successfully accomplished, after much work all round.”
Sir James added:
“I was pleased to hear that the reopening of the King Edmund School has been going well. It was reassuring to see that school attendance was high and pupils were keen to return to their classrooms to learn.
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Tricky for the Truth
Posted on March 9, 2019 by James Riley
“So give Your servant an understanding heart to judge
Your people to discern between good and evil.”
Solomon’s Methods..
A few years ago, I approached a friend of mine (let’s call him “Bill”) who was just about to retire from public school administration after 30 years in the field. He was planning to spend the first two months of his retirement in the Bahamas. His wife, “Jane,” had just recently retired from the social security administration, and between the two of them, I could tell they were more than comfortable. They owned two vacation homes, and–okay, I admit–I did look up Bill’s salary on one of those transparent government sites, and he was closing out his public life at $320,000 a year, salary and benefits.
I’m not coveting Bill’s life, believe me, because I have an enormous amount of respect for any civil servant who has the patience to calm down all the various, shrill constituencies you have to face in that profession, but Bill had just done something that really annoyed me. Bill’s a believer. We don’t go to church together, but a young friend of mine, “Jack,” had fallen on hard times, lost his wife, basically, to some weird cult, and had just been evicted from his home. He had this gloriously restored 1965 Mustang that was his pride and joy. He was going to have to sell that, and just about everything else he had, just to get a new start.
Well, Bill was never a big fan of Jack. Whenever they talked theology, Bill dropped the “heretic” card on him all the time. (I think Jack’s knowledge of scripture unnerved Bill; he was a young man who knew quite a bit about scripture and church history.) Jack wasn’t cocky, but he was confident in a way that Bill just couldn’t abide, so when things went bad for Jack, I could tell that Bill was taking some spiritual pleasure in the thing. That annoyed me, but not as much as the offer Bill made for Jack’s Mustang. This was a car that had won competitions. It had recently been appraised at $42,000.
Bill offered him $7,000 for it, and when Jack hesitated, Bill lowered the offer to $5,000.
Now you have to remember here that Jack was a broken man — utterly broken. His eyes were swollen. He confessed to us that he thought he was under God’s curse. He couldn’t believe how quickly his wife’s personality had changed, how she had become a different person entirely, and he just looked like the loneliest man on earth.
“$5,000?” Jack said. “Whatever. I’ll take it.”
“Oh, c’mon,” I said. “Bill. You can’t be serious.”
Bill actually put a hand on Jack’s shoulder. “Listen, Jack, sometimes we need a humbling.”
Piracy described as a Sunday School lesson. I went home that night furious. I vented to my wife for a while, but I tried to cool down. I saw Bill two weeks later. He was handing off the keys to his house to a temporary renter, pocketing a stack of one hundred dollar bills, and he was radiant at the thought of spending the summer in the Bahamas.
“Bill,” I said. “I have a problem. I was wondering if you have one of your district friends look into this for me. It’s not in your former jurisdiction, but you might know someone.”
I told him the story of two teachers in a neighboring district. The news had come to me through a friend of my wife who was fit to be tied.
“It’s hard to believe,” I began, “but there’s a young 4th grade teacher who is wheel chair bound. She had an accident last summer and she’s just getting back into teaching without the use of her legs. Well, it’s a really old building and she needs help getting into and out of her classroom until they get a few modifications made. This is the hard to believe part, but a little back-story: one of her colleagues has it in her head, that, prior to the accident, this young wheel-chair teacher had the hots for her husband. Everyone swears it’s not true, but she’s very attractive and so this is where you’ll get fighting mad.”
“What?” Bill asked.
“Her colleague was assigned to help her into and out of the classroom, and she’s extorting her for it.”
“Extorting her?”
“Twenty bucks a day.”
Bill’s eyes widened. “Are you F-ing kidding me? Do they even know what kind of MASSIVE lawsuit could be in the offing for that? Who was this? I want to know.”
I looked over at Jack’s beautiful black Mustang sitting in Bill’s garage.
“You,” I said.
Okay, so there is no “Bill” or “Jack.” I have no such friends. I tried to modernize the situation to illustrate the concept. The difference between the Bible and our version of it never stops surprising me. We see, over and over again, the people of God using outright trickery and deception in order to find out the truth about each other. They invent stories about unrelated people to keep the rebuked parties off guard. Nathan doesn’t confront the king directly. He tells a story of horrible cruelty and allows the king to do what we all do — wax angry at other peoples’ sins while we’re easy on our own. Solomon has to pretend as though he’s about to cut the baby in half — in order to find out its real mother. Joseph planted evidence in his brothers’ saddle bags, so as to find out, without doubt, if they had changed.
There is trickery in the Bible we probably should NOT emulate (Jacob fooling his father, for example), but there really does seem to be something called “a lie in pursuit of the truth.” Nathan, a prophet of God, fabricated a story about a man who owned a single lamb that was taken from him by a wealthy and selfish man. This lie convicted David and allowed him to understand his own sin. I believe there is also the fictional story, or parable, that is not literally true, but certainly not false either. Jesus tells dozens of them. They have this virtue, among others: no living person is specifically slandered by them, but all living persons, born with ears to hear, benefit from them.
Fictions, and sometimes outright lies, tell the truth — and, yet, how often, as believers do we allow ourselves this method of inquiry? We proceed — gentle as rattlesnakes and wise as idiot pigeons — as though people naturally tell the truth. They don’t, though, do they?
The Bible gives us tools, but most of the time we’re too “good” to use them.
Bible, David, Nathan, Solomon, Trickery
We Win A Battle — Now On To The War!
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Fuji Latex Posts April–December Business Results, Including Strong Sales for Condoms
on February 15, 2022 in Products
Fuji Latex Co. Ltd. (TYO:4199) has posted its business results for the first three quarters of fiscal 2021, revealing sales of 6.14 billion yen ($53.19 million), an operating profit of 647 million yen, an ordinary profit of 616 million yen and a net profit of 353 million yen. Looking at these figures on a per-segment basis, the company’s health care…
business results, fuji latex
Sumitomo Rubber to Launch Aftermarket EV Tire in China Starting April
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The 1884 "Exposure at Vienna": The (Re-)Debunking of a Notorious Medium
As I mentioned not long ago, the history of the Habsburg Empire is of particular interest to me, though I rarely have the opportunity to discuss it here. I learned the other day that a new book is going to be released last month on the death of Crown Prince Rudolf, the heir to the Austro-Hungarian throne, who committed suicide after murdering his teenage lover on a hunting trip in January of 1889. The reasons for his death have never been satisfactorily explained, and conspiracy theories surround the events at the hunting lodge of Mayerling. What cannot be denied, however, is that Rudolf’s death set in motion events that culminated in the outbreak of the First World War, because his absence left a weakness at the center of the monarchy and deprived it of its most important liberal voice.
Despite the morbid end to his brief life—he died three months short of his thirty-first birthday—and his penchant for escaping his loveless marriage through destructive affairs, there was much to commend him, and it is depressing to think of how history might have been different if, as was widely rumored, his father were to have abdicated in his favor in 1898, and liberal reforms prevented the instability of the Balkans from spilling over into Austria and spreading into the Great War. Many historians feel a Great War was inevitable, but Rudolf had favored an Austro-French alliance rather than an Austro-German one, and the shape of any war would likely have been very different. Unless the rumors about his syphilis were correct, in which case, maybe nothing would have been different by 1914.
At any rate, Rudolf was a liberal in a conservative country, and also a skeptic in a world of believers. Around 1880, a second wave of spiritualism burned through the courts of Europe, much as it had two decades earlier. This wave was just as silly, and it saw crowned heads gathering in gilded rooms to commune with the dead through the good offices of American mediums. In Austria, the spiritual (so to speak) leader of the spiritualist faction of the imperial family was the Empress Elizabeth, Rudolf’s mother, who was easily taken by any snake oil in her endless quest to cure her ennui. Rudolf became the leader of the anti-spiritualists, though at first not directly. As an Austrian Archduke and the heir to the throne, he wasn’t able to express himself publicly under his own name, so he had begun publishing news articles and editorials anonymously in a liberal newspaper. Continuing in that vein, in 1882 he published an anonymous pamphlet called Einige Worte über den Spiritismus (Some Words about Spiritualism) in which he viciously attacked all of the foolish pretensions of those who claimed to hold court with the dead.
I’m not sure exactly what it says about him that he became fascinated by exploring and debunking the paranormal only a few weeks after solemnizing his loveless dynastic marriage, but he had visited the pyramids of Egypt, married his wife, and the decided that the promises of spiritualism for a happy afterlife were so much hooey.
Rudolf in 1881.
While Rudolf’s arguments were no different than most attacks on Spiritualism, they were interesting because of who Rudolf was. In his efforts he was joined by his cousin, the Archduke John Salvator, who managed the neat trick of being more liberal than Rudolf, a worse womanizer, and almost as bizarre in his death. John Salvator conducted a torrid affair with a teenager named Mary Vetsera, and, having tired of her, basically arranged for his cousin Rudolf to start an affair with her. She was the girl Rudolf murdered. John Salvator claimed that he hated royal life after that, and he renounced his imperial titles so he could marry an American actress. They ran off together to South America, where he died in 1890 when the ship he sailed under the commoner name of John Orth sank. It took 21 years for him to be declared legally dead. But that was still in the future.
In 1884, he and Rudolf had great plans to deal a blow to the spiritualist nonsense infecting the older members of their family. John was 32 and Rudolf was 24, and possessed of the arrogance of youth, John believed that he would be able to deal a mortal blow to spiritualism if only he could expose a medium as a fraud.
At the time, a Chicago medium originally from Franco-German Alsace named Harry Bastian was making the rounds of Europe, using his command of English, French, and German to wow audiences with his ability to materialize the shades of the dead. He crowed about his access to the Austrian nobility. Rudolf and John developed a deep antipathy to Bastian because he claimed to call up the shades of the Habsburgs’ own ancestors and to take liberties in making them speak of the past. As the archdukes probably knew from their months of research into the séances of Bastian, disgruntled skeptics had tried exposing him as a fraud many times over. Bastian’s typical ploy was to say he needed to sleep in another room while the attendees clasped hands in a darkened room. This made fraud quite simple. In August 1874, for example, a woman attending a séance reached out to touch the “spirit” hand only to find it was attached to Bastian. On another occasion, while a spirit guitar floated overhead, an attendee turned on an electric light mid-séance only to find Bastian holding the guitar. In 1880, Stuart Cumberland, self-confessed fake medium, caught Bastian in an imposture in Bloomsbury, and reported, amusingly, that upon grabbing the “ghost,” it let out “more muffled profanity than I have heard in any one year” before breaking free and running back to hide the costume and resume Bastian’s “sleeping” pose. In cases like these, Bastian claimed that the spirits were acting through him while he was asleep, and his supporters agreed. Indeed, when some of the sitters tried to get local authorities to prosecute him for fraud, the charges were dismissed on the grounds that the sitters had violated Bastian’s rules. Surprisingly, the Crown Prince and Archduke succeeded where others had failed, though excuses would abound.
In 1882, Bastian supposedly entered retirement, claiming that his spiritual powers had waned, but this was a bit of an act. According to contemporary records, he was still performing séances through the middle of the year, five at a time! At John’s request, and through the offices of Austrian spiritualist leader Lazzaro, he agreed to host a series of séances at the Archduke’s palace apartments for members of the imperial family. The first two séances on January 17 and 30 proceeded as they always had, with Bastian performing a series of parlor tricks that he claimed represented spiritual powers. The first séance yielded nothing, and in the second a bell rang. But the third on February 11 (other sources say February 3) is when all hell broke loose. The scene unfolded while Bastian claimed to be sleeping in a small room while the others sat at a table in the dark. The Crown Prince and Archduke treated Bastian like a Scooby-Doo villain, and they actually prepared a Scooby-Doo-style trap for him.
The rest of the account appeared in the Vienna newspapers, and the account amused English and American correspondents enough that they translated the stories and sent them off to their home newspapers. Here is how the Daily News reported the story on February 13:
VIENNA, Tuesday night. Much amusement has been created here by an incident in which the Archduke John, the Crown Prince Rudolf, and a celebrated Spiritualistic medium, an American, named Bastian, took part. For many weeks the Spiritualists had tried to spread their views among the Vienna aristocracy, and scarcely a night passed in which seances were not held in some noble family. The Archduke John, desirous of understanding how even clever persons are deceived, invited Bastian to his palace. The Archduke and Prince Rudolf ordered some arrangements to be made privately, and when Bastian, who called the spirits in an adjoining room, made a tall figure in mourning appear before the awed spectators, the Crown Prince suddenly pulled a string which closed a secret door, and the spirit, who was no other than Bastian himself, tried to escape amid the laughter of the noble audience.
More specifically, the imperial pair rigged up a string so they could slam shut the door to Bastian’s sleeping-chamber while the “ghost” was walking among the guests. At a moment when a spirit dressed “half Roman, half knight, with bare head, draped in white, perfect in every way, and refulgent” appeared, the archdukes sprang the trap. With his means of egress cut off, they were able to grab the “ghost” and unmask him, just like in Scooby-Doo. Bastian reported threw a shrieking hissy fit until the archdukes were able to calm him down and assure him that they meant him no harm. A supporter, Dr. T. L. Nichols, later reported that Bastian was grievously offended by the accusation: “Greatly disgusted with the shabby and shameful treatment he had received, Mr. Bastian went to the railway station the same night, and took the train for London, where, I need not say, he was heartily welcomed by those who have known him long and well, and who know him to be an honest man, and a genuine and very remarkable medium.” Despite the testimony of those present that Bastian was captured in costume, a story grew up shortly thereafter that no costumes were found on Bastian’s person and therefore the “ghosts” were real entities that simply manifested through Bastian’s body.
Consider this from Nichols, writing a few months later.
Baron Hellenbach, a well-known savant of Vienna, published a volume of his observations of spiritual phenomena. Accounts, with many sensational exaggerations and misstatements, of the stupid escapade of two Austrian Princes, in destroying the conditions of what had been so far a successful seance, have been published all over the world. According to Baron Hellenbach, ten materialised forms had issued from the curtained recess used as a cabinet when the not too wise, and not too well mannered Crown Prince or Archduke—both boys— slammed a door and seized the medium, but failed to find one scrap of the apparatus which would have been necessary to manufacture the spirit-forms that had appeared to them.
The problem, in the eyes of believers, was that exposing the medium scared all the ghosts away!
Archduke John Salvatore wrote a book about the exposure of Bastian, supported by signed affidavits from all those in attendance. He outlined all of the crimes of spiritualism and implored the Austrian people to reject the fraud of mediums. No less that the Catholic Church attacked him for his efforts: The official papal newspaper, the Civilta Cattolica, conceded that Bastian might have been a fraud but nevertheless refused to endorse his conclusion that spiritualism was a fraud. Instead, they said, since the Fathers of the Church believed in spirits, and the afterlife is a doctrine of faith, it is wrong to declare that no commerce might occur between the living and the dead. This was a rather astonishing report from a Catholic paper, especially since Pius IX had condemned spiritualism.
Nevertheless, the “Exposure at Vienna,” as the incident became known, so thoroughly discredited Bastian that today the man once heralded as the world’s best and most famous medium is completely forgotten, a footnote and afterthought. Bastian continued giving private séances to true believers, who reported that his parlor tricks—voices, papier-mâché heads with cheesecloth bodies—thoroughly convinced them that ghosts were real, but he did not publicly display his talents for nobility. He became a watchword for fakery, and appeared as such in works by Rudolf Steiner, Arthur Conan Doyle, and others.
Now imagine how much good the Archdukes could have done if they had had the opportunity to expose Helena Blavatsky instead.
Charles Gaulke
I was peripherally aware of a bit of this, but I'd never seen the whole story before. Fascinating stuff! There are so many examples of spirit mediums being exposed as frauds, with more or less the same result (true believers making excuses or simply denying the debunking). What's always most interesting is how primitive the tricks were, cheese cloth, strings... Reading about it you can hardly believe anyone would be taken in, but of course, just like motivated believers denied their favourite medium had been debunked, they could make a "successful" seance much more impressive in the re-telling. We remember the psychic's hits and forget their misses, we recall seeing a trick we only heard described, and a man in a silly costume becomes a transparent and intangible ghost so easily in memory.
A favourite movie I refer to a lot when describing that exact principle to people is "The Illusionist," which ironically I now realize is a very skewed retelling of this very incident... I'll certainly include this context the next time I talk to someone about it.
"The Illusionist" sort of weaves this incident in with the Mayerling suicide. It's an interesting movie, but one that makes its fictional Crown Prince, modeled on Rudolf, into much more of a villain than the real man ever was.
Well, exactly... I'll still enjoy the movie knowing this, but I'll feel kind of bad about that aspect of it. I already felt like the title character was at least as much a villain as the Prince, though.
Could you recommend any further reading focused on Rudolf and/or the Archduke's skepticism? I suppose it's generally a sidenote in their histories, what with the War and all, but I'd love to look into it further.
I wish I knew more. I've read the couple of biographies of him that exist in English, and I'll be darned if I had even heard of this until I chanced upon it by accident in looking to see when the new book is coming out. I gather that there is more material in German, but unfortunately I am not fluent enough to read it. I also don't want to spend $100+ to buy a copy of his 40-page pamphlet on the supernatural. It would be an interesting artifact, but hardly worth the money if I can barely read it!
Titus pullo
Have u read about the andreas fellner trisl of the late 20s early 30s? It was the OJ trial of Vienna and very interesting given the politics of it
I hadn't heard this story before, but I loved the Scooby-Doo comparison.
I remember Harry Houdini had done the same with other alleged mediums, exposing their shenanigans after attending their séances.
It's nice to see that exposing frauds and the excuses of their supporters hasn't really changed much over time.
TheSmartestGuyInTheWorld
Fake News! Prince Rudolph and brother Archduke were clearly going out of their way to disparage spiritualism as just a way to "get Bastian!" Not fair to B and his amazing ghosts. Shame on those Habsburg losers! If they had been doing their job instead of attacking B then WWI would never have happened. The crooked media never mentioned that, did they? Could have made the Austro-Hungarian Empire Great Again! Rudolph and Archduke should have gone to jail. I bet they didn't even stand up during the Austrian national waltz. BIGTIME LOSERS!
There is something wrong here: “his father were to have abdicated in his favor 1898”.
“the world’s best and most famous medium”
The world’s most famous medium of the XIX century was Daniel Dunglas Home (1833-1886). His contemporary Madame Blavatsky (1831-1891) did not present herself as a medium after founding Theosophy in 1875, although she used similar tricks. She was exposed as a fraud during her lifetime. See Marion Meade: Madame Blavatsky, the Woman Behind the Myth, 1980.
Can I suggest a "Habsburgiana" tag for these posts? There are as many as there are of King Arthur.
I went ahead and added a tag for the Habsburgs. I hope this helps!
That's definitely more than King Arthur. 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Mr. David Baggett
Asst. Superintendent
10700 Yellow Jacket Blvd.
St. Martin, MS 39564
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Mr. David Baggett has been in education for 25 years. He worked for the Ocean Springs School District, Jackson County School District, and Starkville Oktibbeha School District before returning back to Jackson County to serve as Assistant Superintendent for the St. Martin Attendance Center.
He graduated from Ocean Springs High School in 1990 and attended college at Mississippi State. He has served in elementary, middle school, and high school as a teacher, coach, Assistant Principal, Principal, and Assistant Superintendent during his years of service. Mr. Baggett comes back home to Jackson County School District from Starkville, where he served as Assistant Superintendent for 4 years.
He is married to his wife, Cynthia and has 4 children.
Mr. Baggett believes we are all one family that works together to serve the betterment of our children. | 2023-14/0000/en_head.json.gz/1333 | {"url": "https://www.jcsd.ms/domain/78", "partition": "head_middle", "language": "en", "source_domain": "www.jcsd.ms", "date_download": "2023-03-20T08:50:51Z", "digest": "sha1:I4D6PIWXYQLLLTX7DH45RKQFBILJHZOZ"} | {"ccnet_length": [[0, 1042, 1042.0]], "ccnet_original_length": [[0, 1042, 12650.0]], "ccnet_nlines": [[0, 1042, 11.0]], "ccnet_original_nlines": [[0, 1042, 253.0]], "ccnet_language_score": [[0, 1042, 0.96]], "ccnet_perplexity": [[0, 1042, 191.2]], "ccnet_bucket": [[0, 1042, 0.0]], "rps_doc_curly_bracket": [[0, 1042, 0.0]], "rps_doc_ldnoobw_words": [[0, 1042, 0.0]], "rps_doc_lorem_ipsum": [[0, 1042, 0.0]], "rps_doc_stop_word_fraction": [[0, 1042, 0.24870466]], "rps_doc_ut1_blacklist": [[0, 1042, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1042, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1042, 0.03751465]], "rps_doc_frac_chars_top_3gram": [[0, 1042, 0.04220399]], "rps_doc_frac_chars_top_4gram": [[0, 1042, 0.05627198]], "rps_doc_frac_all_caps_words": [[0, 1042, 0.00518135]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1042, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1042, 0.19170984]], "rps_doc_frac_unique_words": [[0, 1042, 0.54716981]], "rps_doc_mean_word_length": [[0, 1042, 5.36477987]], "rps_doc_symbol_to_word_ratio": [[0, 1042, 0.0]], "rps_doc_unigram_entropy": [[0, 1042, 4.26779774]], "rps_doc_word_count": [[0, 1042, 159.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 54, 0.0], [54, 83, 0.0], [83, 101, 0.0], [101, 122, 0.0], [122, 148, 1.0], [148, 169, 0.0], [169, 191, 0.0], [191, 482, 1.0], [482, 884, 1.0], [884, 939, 1.0], [939, 1042, 1.0]], "rps_lines_javascript_counts": [[0, 54, 0.0], [54, 83, 0.0], [83, 101, 0.0], [101, 122, 0.0], [122, 148, 0.0], [148, 169, 0.0], [169, 191, 0.0], [191, 482, 0.0], [482, 884, 0.0], [884, 939, 0.0], [939, 1042, 0.0]], "rps_lines_num_words": [[0, 54, 7.0], [54, 83, 4.0], [83, 101, 3.0], [101, 122, 2.0], [122, 148, 4.0], [148, 169, 4.0], [169, 191, 1.0], [191, 482, 44.0], [482, 884, 61.0], [884, 939, 11.0], [939, 1042, 18.0]], "rps_lines_numerical_chars_fraction": [[0, 54, 0.0], [54, 83, 0.0], [83, 101, 0.0], [101, 122, 0.0], [122, 148, 0.20833333], [148, 169, 0.27777778], [169, 191, 0.0], [191, 482, 0.00704225], [482, 884, 0.01282051], [884, 939, 0.01923077], [939, 1042, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 54, 0.0], [54, 83, 0.0], [83, 101, 0.0], [101, 122, 0.0], [122, 148, 0.0], [148, 169, 0.0], [169, 191, 0.0], [191, 482, 0.0], [482, 884, 0.0], [884, 939, 0.0], [939, 1042, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 54, 0.12962963], [54, 83, 0.13793103], [83, 101, 0.16666667], [101, 122, 0.0952381], [122, 148, 0.11538462], [148, 169, 0.19047619], [169, 191, 0.09090909], [191, 482, 0.08247423], [482, 884, 0.05472637], [884, 939, 0.03636364], [939, 1042, 0.01941748]], "rps_doc_ml_palm_score": [[0, 1042, 0.00234193]], "rps_doc_ml_wikipedia_score": [[0, 1042, null]], "rps_doc_ml_wikiref_score": [[0, 1042, 0.1730994]], "rps_doc_books_importance": [[0, 1042, -9.06498166]], "rps_doc_openwebtext_importance": [[0, 1042, -1.98487926]], "rps_doc_wikipedia_importance": [[0, 1042, 22.37682893]], "rps_doc_num_sentences": [[0, 1042, 19.0]]} |
Featured News JCU Singapore awarded the EduTrust Star
Thu, 1 Jan 2015
JCU Singapore awarded the EduTrust Star
James Cook University’s Singapore campus has earned the distinction of being the first private education institution to attain an EduTrust Star quality mark from the Singapore Government.
The EduTrust Star is the highest level of quality assurance that can be awarded to a private education institution (PEI) by the Council for Private Education (CPE) under the EduTrust Certification Scheme (EduTrust).
JCU Singapore was awarded the EduTrust Star by the CPE on April 13, 2015.
Dr Dale Anderson, Deputy Vice-Chancellor and Head of Singapore Campus said that achieving EduTrust Star status has been a priority of JCU Singapore since this quality assurance scheme was introduced.
“Attaining EduTrust Star had been a long term aim of both JCU Singapore and its parent entity, James Cook University (JCU). The journey toward EduTrust Star has made our organisation a better place. Instilling the high operational standards required of an EduTrust Star institution has certainly benefited JCU Singapore and James Cook University in Australia has also benefited from observing this process,” Dr Anderson said.
“However, it’s our students who have benefited most from this award. All employees of JCU Singapore are mindful that they have to produce a high level of job performance in order to satisfy our main client group, the fee-paying students,” he added.
JCU Vice Chancellor and President, Professor Sandra Harding said achieving EduTrust Star status underscores the high level of commitment on the part of management and staff of JCU Singapore to strengthen the position of the institution as a leading provider of quality education.
“JCU has been committed to building a presence in Singapore since 2003 and sees JCU Singapore as an integral part of James Cook University - one university, two countries, three tropical locations (Singapore, Cairns and Townsville). The University considers the awarding of this quality mark as an important step to further broaden and deepen our commitment to Singapore,” Professor Harding said.
“We knew that attaining the EduTrust Star status was not going to be an easy undertaking. Despite the very stringent EduTrust Star requirements, our team in Singapore has managed to accomplish this remarkable feat,” she added.
There are currently three award types under EduTrust, namely EduTrust Star, EduTrust and EduTrust Provisional. EduTrust Star and EduTrust awards are valid for four years whereas EduTrust Provisional is valid for one year.
The EduTrust Star award is given to PEIs that have excelled in all key areas of management and the provision of quality education services. This mark is also a symbol of recognition for sustained efforts in organisational improvement.
Richard Davis, JCU Head of Media and Communications
(07) 4781 4822 / 0413 451 475
[email protected] | 2023-14/0000/en_head.json.gz/1334 | {"url": "https://www.jcu.edu.au/news/releases/2015/april/news-and-media111111111118", "partition": "head_middle", "language": "en", "source_domain": "www.jcu.edu.au", "date_download": "2023-03-20T09:51:05Z", "digest": "sha1:3PA65NRMBLBP5VUDK4WH4DGHPQNWTDTY"} | {"ccnet_length": [[0, 2930, 2930.0]], "ccnet_original_length": [[0, 2930, 10124.0]], "ccnet_nlines": [[0, 2930, 17.0]], "ccnet_original_nlines": [[0, 2930, 274.0]], "ccnet_language_score": [[0, 2930, 0.95]], "ccnet_perplexity": [[0, 2930, 326.0]], "ccnet_bucket": [[0, 2930, 0.0]], "rps_doc_curly_bracket": [[0, 2930, 0.0]], "rps_doc_ldnoobw_words": [[0, 2930, 0.0]], "rps_doc_lorem_ipsum": [[0, 2930, 0.0]], "rps_doc_stop_word_fraction": [[0, 2930, 0.34165067]], "rps_doc_ut1_blacklist": [[0, 2930, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2930, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2930, 0.02811079]], "rps_doc_frac_chars_dupe_6grams": [[0, 2930, 0.02811079]], "rps_doc_frac_chars_dupe_7grams": [[0, 2930, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2930, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2930, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2930, 0.07441091]], "rps_doc_frac_chars_top_3gram": [[0, 2930, 0.03720546]], "rps_doc_frac_chars_top_4gram": [[0, 2930, 0.027284]], "rps_doc_frac_all_caps_words": [[0, 2930, 0.03071017]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2930, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2930, 0.13435701]], "rps_doc_frac_unique_words": [[0, 2930, 0.46475771]], "rps_doc_mean_word_length": [[0, 2930, 5.32819383]], "rps_doc_symbol_to_word_ratio": [[0, 2930, 0.0]], "rps_doc_unigram_entropy": [[0, 2930, 4.82310386]], "rps_doc_word_count": [[0, 2930, 454.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 54, 0.0], [54, 70, 0.0], [70, 110, 0.0], [110, 298, 1.0], [298, 514, 1.0], [514, 588, 1.0], [588, 788, 1.0], [788, 1214, 1.0], [1214, 1463, 1.0], [1463, 1743, 1.0], [1743, 2140, 1.0], [2140, 2367, 1.0], [2367, 2589, 1.0], [2589, 2824, 1.0], [2824, 2876, 0.0], [2876, 2906, 0.0], [2906, 2930, 0.0]], "rps_lines_javascript_counts": [[0, 54, 0.0], [54, 70, 0.0], [70, 110, 0.0], [110, 298, 0.0], [298, 514, 0.0], [514, 588, 0.0], [588, 788, 0.0], [788, 1214, 0.0], [1214, 1463, 0.0], [1463, 1743, 0.0], [1743, 2140, 0.0], [2140, 2367, 0.0], [2367, 2589, 0.0], [2589, 2824, 0.0], [2824, 2876, 0.0], [2876, 2906, 0.0], [2906, 2930, 0.0]], "rps_lines_num_words": [[0, 54, 8.0], [54, 70, 4.0], [70, 110, 6.0], [110, 298, 27.0], [298, 514, 33.0], [514, 588, 14.0], [588, 788, 30.0], [788, 1214, 65.0], [1214, 1463, 42.0], [1463, 1743, 43.0], [1743, 2140, 60.0], [2140, 2367, 36.0], [2367, 2589, 33.0], [2589, 2824, 38.0], [2824, 2876, 8.0], [2876, 2906, 6.0], [2906, 2930, 1.0]], "rps_lines_numerical_chars_fraction": [[0, 54, 0.0], [54, 70, 0.35714286], [70, 110, 0.0], [110, 298, 0.0], [298, 514, 0.0], [514, 588, 0.08450704], [588, 788, 0.0], [788, 1214, 0.0], [1214, 1463, 0.0], [1463, 1743, 0.0], [1743, 2140, 0.01036269], [2140, 2367, 0.0], [2367, 2589, 0.0], [2589, 2824, 0.0], [2824, 2876, 0.0], [2876, 2906, 0.8], [2906, 2930, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 54, 0.0], [54, 70, 0.0], [70, 110, 0.0], [110, 298, 0.0], [298, 514, 0.0], [514, 588, 0.0], [588, 788, 0.0], [788, 1214, 0.0], [1214, 1463, 0.0], [1463, 1743, 0.0], [1743, 2140, 0.0], [2140, 2367, 0.0], [2367, 2589, 0.0], [2589, 2824, 0.0], [2824, 2876, 0.0], [2876, 2906, 0.0], [2906, 2930, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 54, 0.16666667], [54, 70, 0.125], [70, 110, 0.175], [110, 298, 0.04787234], [298, 514, 0.08796296], [514, 588, 0.14864865], [588, 788, 0.08], [788, 1214, 0.07511737], [1214, 1463, 0.02409639], [1463, 1743, 0.05714286], [1743, 2140, 0.04785894], [2140, 2367, 0.03964758], [2367, 2589, 0.08558559], [2589, 2824, 0.03404255], [2824, 2876, 0.15384615], [2876, 2906, 0.0], [2906, 2930, 0.0]], "rps_doc_ml_palm_score": [[0, 2930, 0.48510104]], "rps_doc_ml_wikipedia_score": [[0, 2930, null]], "rps_doc_ml_wikiref_score": [[0, 2930, 0.96485585]], "rps_doc_books_importance": [[0, 2930, -117.52719809]], "rps_doc_openwebtext_importance": [[0, 2930, 39.08507359]], "rps_doc_wikipedia_importance": [[0, 2930, 7.83363419]], "rps_doc_num_sentences": [[0, 2930, 22.0]]} |
Mania (Wilbushewitcz) Shochat
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Born on her father's estate in Belorussia, Mania Wilbushewitcz left home at a young age to work in her brother's factory in Minsk in order to learn about workers' living conditions and help them. She became associated with revolutionary circles and was arrested in the summer of 1899. While in prison, she met Zubatov, the chief of the Secret Police in Moscow. He suggested a workers' movement with his support, which would be loyal to the Czar. He convinced her to establish a Jewish workers' party which would be concerned with professional and economic matters and would abstain from politics.
Under his influence, she started to establish the Jewish Independent Labor Party in the summer of 1901. The strikes they declared were successful because secret police agents supported them. They were opposed by the Bund and other Jewish Socialist groups.
After the Kishinev pogrom, and with changes in government policies, the party dissolved in the summer of 1903. In 1904 her brother, Nahum, invited her to visit Eretz Yisrael. She traveled through the country for a year and concluded that collective agricultural settlement was an essential condition for the development of a Jewish country. In 1907, Mania went to Europe and the United States to study various communist settlements. Upon her return she sought a group of like-minded individuals, and became associated with the Bar Giora group led by Israel Shochat. Under her influence, the group settlement on a farm near Sejera (Ilaniyah) and tried setting up a collective farm in 1907-1908. This was the first attempt at collective settlement in Eretz Yisrael.
In 1908 she married Shochat and they were among the founders of HaShomer in 1909. When World War I began, the Turkish authorities exiled Mania and Israel Shochat to Boursa, Turkey. After attending the Poalei Zion convention in Stockholm, they returned to Eretz Yisrael in 1919 and joined the Ahdut HaAvodah party. In 1921, Mania Shochat was a member of the first Histadrut delegation to visit the United States. Her presence caused an uproar as Bundists and Communists recalled her previous collaboration with the Moscow Secret Police.
In the later years, Mania Shochat became active in Kibbutz Kfar Giladi and in Jewish-Arab cooperation. In 1948, she joined the Mapam party and settled in Tel Aviv, where she devoted herself to social work and writing.
Sources: The Pedagogic Center, The Department for Jewish Zionist Education, The Jewish Agency for Israel, (c) 1997, 1998, 1999, 2000, Director: Dr. Motti Friedman, Webmaster: Esther Carciente | 2023-14/0000/en_head.json.gz/1335 | {"url": "https://www.jewishvirtuallibrary.org/mania-wilbushewitcz-shochat", "partition": "head_middle", "language": "en", "source_domain": "www.jewishvirtuallibrary.org", "date_download": "2023-03-20T10:35:42Z", "digest": "sha1:6FNGJEQ2BVY4XIH3NYXWSGIZNEF7HZHW"} | {"ccnet_length": [[0, 2797, 2797.0]], "ccnet_original_length": [[0, 2797, 3665.0]], "ccnet_nlines": [[0, 2797, 16.0]], "ccnet_original_nlines": [[0, 2797, 42.0]], "ccnet_language_score": [[0, 2797, 0.97]], "ccnet_perplexity": [[0, 2797, 202.4]], "ccnet_bucket": [[0, 2797, 0.0]], "rps_doc_curly_bracket": [[0, 2797, 0.0]], "rps_doc_ldnoobw_words": [[0, 2797, 0.0]], "rps_doc_lorem_ipsum": [[0, 2797, 0.0]], "rps_doc_stop_word_fraction": [[0, 2797, 0.33524904]], "rps_doc_ut1_blacklist": [[0, 2797, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2797, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2797, 0.00875657]], "rps_doc_frac_chars_top_3gram": [[0, 2797, 0.01444834]], "rps_doc_frac_chars_top_4gram": [[0, 2797, 0.01707531]], "rps_doc_frac_all_caps_words": [[0, 2797, 0.00574713]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2797, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2797, 0.17049808]], "rps_doc_frac_unique_words": [[0, 2797, 0.55756208]], "rps_doc_mean_word_length": [[0, 2797, 5.15575621]], "rps_doc_symbol_to_word_ratio": [[0, 2797, 0.0]], "rps_doc_unigram_entropy": [[0, 2797, 5.000821]], "rps_doc_word_count": [[0, 2797, 443.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 30, 0.0], [30, 51, 0.0], [51, 72, 0.0], [72, 100, 0.0], [100, 122, 0.0], [122, 156, 0.0], [156, 171, 0.0], [171, 196, 0.0], [196, 214, 0.0], [214, 235, 0.0], [235, 832, 1.0], [832, 1088, 1.0], [1088, 1852, 1.0], [1852, 2388, 1.0], [2388, 2606, 1.0], [2606, 2797, 0.0]], "rps_lines_javascript_counts": [[0, 30, 0.0], [30, 51, 0.0], [51, 72, 0.0], [72, 100, 0.0], [100, 122, 0.0], [122, 156, 0.0], [156, 171, 0.0], [171, 196, 0.0], [196, 214, 0.0], [214, 235, 0.0], [235, 832, 0.0], [832, 1088, 0.0], [1088, 1852, 0.0], [1852, 2388, 0.0], [2388, 2606, 0.0], [2606, 2797, 0.0]], "rps_lines_num_words": [[0, 30, 3.0], [30, 51, 3.0], [51, 72, 3.0], [72, 100, 4.0], [100, 122, 3.0], [122, 156, 1.0], [156, 171, 2.0], [171, 196, 4.0], [196, 214, 2.0], [214, 235, 4.0], [235, 832, 100.0], [832, 1088, 40.0], [1088, 1852, 123.0], [1852, 2388, 87.0], [2388, 2606, 37.0], [2606, 2797, 27.0]], "rps_lines_numerical_chars_fraction": [[0, 30, 0.0], [30, 51, 0.0], [51, 72, 0.0], [72, 100, 0.0], [100, 122, 0.0], [122, 156, 0.0], [156, 171, 0.0], [171, 196, 0.0], [196, 214, 0.0], [214, 235, 0.1], [235, 832, 0.00687285], [832, 1088, 0.01593625], [1088, 1852, 0.02684564], [1852, 2388, 0.03041825], [2388, 2606, 0.01895735], [2606, 2797, 0.09039548]], "rps_lines_start_with_bulletpoint": [[0, 30, 0.0], [30, 51, 0.0], [51, 72, 0.0], [72, 100, 0.0], [100, 122, 0.0], [122, 156, 0.0], [156, 171, 0.0], [171, 196, 0.0], [196, 214, 0.0], [214, 235, 0.0], [235, 832, 0.0], [832, 1088, 0.0], [1088, 1852, 0.0], [1852, 2388, 0.0], [2388, 2606, 0.0], [2606, 2797, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 30, 0.1], [30, 51, 0.0952381], [51, 72, 0.0952381], [72, 100, 0.10714286], [100, 122, 0.09090909], [122, 156, 0.08823529], [156, 171, 0.13333333], [171, 196, 0.16], [196, 214, 0.11111111], [214, 235, 0.14285714], [235, 832, 0.02512563], [832, 1088, 0.0390625], [1088, 1852, 0.03141361], [1852, 2388, 0.06529851], [2388, 2606, 0.05504587], [2606, 2797, 0.10471204]], "rps_doc_ml_palm_score": [[0, 2797, 0.51212502]], "rps_doc_ml_wikipedia_score": [[0, 2797, null]], "rps_doc_ml_wikiref_score": [[0, 2797, 0.71327341]], "rps_doc_books_importance": [[0, 2797, -17.37446285]], "rps_doc_openwebtext_importance": [[0, 2797, 56.78504246]], "rps_doc_wikipedia_importance": [[0, 2797, 142.66575093]], "rps_doc_num_sentences": [[0, 2797, 26.0]]} |
Mariuchi Oregon Steel Tube (M.O.S.T.)
JH Kelly worked closely with Nucor Building Solutions to provide Mariuchi Oregon Steel Tube (M.O.S.T.) a new tube steel plant and warehouse in Portland, Oregon. JH Kelly performed the erection of a new 30,000 sf pre-engineered building, equipment setting, mechanical, piping, plumbing, and electrical scopes of work. | 2023-14/0000/en_head.json.gz/1336 | {"url": "https://www.jhkelly.com/projects/mariuchi-oregon-steel-tube/", "partition": "head_middle", "language": "en", "source_domain": "www.jhkelly.com", "date_download": "2023-03-20T09:39:53Z", "digest": "sha1:Q3C5WWQQOBVQEWZOEEDH3IVTHATINC46"} | {"ccnet_length": [[0, 354, 354.0]], "ccnet_original_length": [[0, 354, 3624.0]], "ccnet_nlines": [[0, 354, 2.0]], "ccnet_original_nlines": [[0, 354, 115.0]], "ccnet_language_score": [[0, 354, 0.92]], "ccnet_perplexity": [[0, 354, 302.0]], "ccnet_bucket": [[0, 354, 0.0]], "rps_doc_curly_bracket": [[0, 354, 0.0]], "rps_doc_ldnoobw_words": [[0, 354, 0.0]], "rps_doc_lorem_ipsum": [[0, 354, 0.0]], "rps_doc_stop_word_fraction": [[0, 354, 0.15]], "rps_doc_ut1_blacklist": [[0, 354, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 354, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 354, 0.19217082]], "rps_doc_frac_chars_dupe_6grams": [[0, 354, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 354, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 354, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 354, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 354, 0.09964413]], "rps_doc_frac_chars_top_3gram": [[0, 354, 0.13523132]], "rps_doc_frac_chars_top_4gram": [[0, 354, 0.16370107]], "rps_doc_frac_all_caps_words": [[0, 354, 0.125]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 354, 0.0]], "rps_doc_frac_no_alph_words": [[0, 354, 0.275]], "rps_doc_frac_unique_words": [[0, 354, 0.71153846]], "rps_doc_mean_word_length": [[0, 354, 5.40384615]], "rps_doc_symbol_to_word_ratio": [[0, 354, 0.0]], "rps_doc_unigram_entropy": [[0, 354, 3.52116372]], "rps_doc_word_count": [[0, 354, 52.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 38, 0.0], [38, 354, 1.0]], "rps_lines_javascript_counts": [[0, 38, 0.0], [38, 354, 0.0]], "rps_lines_num_words": [[0, 38, 5.0], [38, 354, 47.0]], "rps_lines_numerical_chars_fraction": [[0, 38, 0.0], [38, 354, 0.01666667]], "rps_lines_start_with_bulletpoint": [[0, 38, 0.0], [38, 354, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 38, 0.21052632], [38, 354, 0.06012658]], "rps_doc_ml_palm_score": [[0, 354, 0.00502658]], "rps_doc_ml_wikipedia_score": [[0, 354, null]], "rps_doc_ml_wikiref_score": [[0, 354, -1.67e-06]], "rps_doc_books_importance": [[0, 354, -33.43903008]], "rps_doc_openwebtext_importance": [[0, 354, -8.98942631]], "rps_doc_wikipedia_importance": [[0, 354, -3.71511151]], "rps_doc_num_sentences": [[0, 354, 10.0]]} |
CLARE, Rohese de
CLARE, Rohese de (b. 1055) - I31878
Maximum relationships to show: 1 2 3 4 5 6 7 8 9 10 | 2023-14/0000/en_head.json.gz/1337 | {"url": "https://www.josephsmithsr.com/relateform.php?primaryID=I31878&tree=josephsmithsr", "partition": "head_middle", "language": "en", "source_domain": "www.josephsmithsr.com", "date_download": "2023-03-20T10:01:33Z", "digest": "sha1:YDR6H3W3YSRBGIXOKPWOJHYWBYONTIPI"} | {"ccnet_length": [[0, 104, 104.0]], "ccnet_original_length": [[0, 104, 1604.0]], "ccnet_nlines": [[0, 104, 3.0]], "ccnet_original_nlines": [[0, 104, 64.0]], "ccnet_language_score": [[0, 104, 0.78]], "ccnet_perplexity": [[0, 104, 139.6]], "ccnet_bucket": [[0, 104, 0.0]], "rps_doc_curly_bracket": [[0, 104, 0.0]], "rps_doc_ldnoobw_words": [[0, 104, 0.0]], "rps_doc_lorem_ipsum": [[0, 104, 0.0]], "rps_doc_stop_word_fraction": [[0, 104, 0.06666667]], "rps_doc_ut1_blacklist": [[0, 104, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 104, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 104, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 104, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 104, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 104, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 104, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 104, 0.2972973]], "rps_doc_frac_chars_top_3gram": [[0, 104, 0.35135135]], "rps_doc_frac_chars_top_4gram": [[0, 104, 0.0]], "rps_doc_frac_all_caps_words": [[0, 104, 0.1]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 104, 0.0]], "rps_doc_frac_no_alph_words": [[0, 104, 0.6]], "rps_doc_frac_unique_words": [[0, 104, 0.86956522]], "rps_doc_mean_word_length": [[0, 104, 3.2173913]], "rps_doc_symbol_to_word_ratio": [[0, 104, 0.0]], "rps_doc_unigram_entropy": [[0, 104, 2.95467321]], "rps_doc_word_count": [[0, 104, 23.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 17, 0.0], [17, 53, 0.0], [53, 104, 0.0]], "rps_lines_javascript_counts": [[0, 17, 0.0], [17, 53, 0.0], [53, 104, 0.0]], "rps_lines_num_words": [[0, 17, 3.0], [17, 53, 6.0], [53, 104, 14.0]], "rps_lines_numerical_chars_fraction": [[0, 17, 0.0], [17, 53, 0.31034483], [53, 104, 0.22]], "rps_lines_start_with_bulletpoint": [[0, 17, 0.0], [17, 53, 0.0], [53, 104, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 17, 0.35294118], [17, 53, 0.19444444], [53, 104, 0.01960784]], "rps_doc_ml_palm_score": [[0, 104, 0.04506069]], "rps_doc_ml_wikipedia_score": [[0, 104, null]], "rps_doc_ml_wikiref_score": [[0, 104, -1.001e-05]], "rps_doc_books_importance": [[0, 104, -29.64181224]], "rps_doc_openwebtext_importance": [[0, 104, -12.59254564]], "rps_doc_wikipedia_importance": [[0, 104, -8.34005299]], "rps_doc_num_sentences": [[0, 104, 2.0]]} |
Feather symbolism: 15 Types of feathers and meanings
Leave a Comment / By Joyce J. Elliott / December 3, 2022 February 11, 2023
The feather as a symbol is a powerful one and, in fact, the image of it can sometimes help to unlock the secrets of your subconscious and stimulate your own psychic abilities. What does a feather symbolize?
The feather symbolism is related to spirituality and freedom, as they are often associated with angels or deities in religious texts. Their presence can be a reminder to live life freely and without fear. Feathers also symbolize purity, which can be a reminder to stay true to yourself.
Because of these beliefs, in many cultures around the world, feathers have been used for ceremonial purposes. Read on to learn more about the symbolism and true meaning of a feather.
What does a feather symbolize?
1. You’re protected
2. You have been honored
3. Price for your success
4. Spiritual connection
5. Bad luck is coming
Feather meaning chart
Native American feather meaning
What is the spiritual meaning of a feather?
Feather meaning in the Bible
When a feather appears an angel is near?
Types of feathers and meaning
1. Peacock feather
2. Blue jay feather
3. Crows feather
4. Eagle feather
5. Owl feather
6. Cardinal feather
7. Dove feather
8. Woodpecker feather
9. Vulture feather
10. Hawk feather
11. Swan feather
12. Ostrich feather
The meaning of feathers by color
1. Brown feather
2. Brown and white feather
3. White feather
4. Black and white feather
5. Black feather
6. Black and grey feather
7. Gray feather
8. Grey and white feather
9. Blue feather
10. Red feather
11. Yellow feather
12. Green feather
13. Orange feather
14. Purple feather
15. Pink feather
Feather dream symbolism
Feather totem
Feather omen
Feather tattoo symbolism
Is finding a feather good luck?
What does it mean when you find feathers around you?
A feather is a symbol of freedom, and it’s also a symbol of the power to soar. Feathers have been used as decorations and talismans since the beginning of time, and they’re still popular today.
In Native American culture, feathers are often used in headdresses and other decorations because they’re believed to have spiritual powers.
They believe that they help people connect with their gods or ancestors, which is why they are also used in ceremonial rituals.
Feathers are often used in fashion and accessories, such as hats and jewelry because they add a sense of elegance or beauty to any outfit.
So, what does a feather symbolize?
A feather symbolism denotes the power of the Universe and how we can be affected by it. It is also used as a symbol of inspiration, hope, and elegance, but it can also be seen as a representation of death.
In modern times, feathers have come to be seen as symbols of great things: dreams, aspirations, and wishes.
It’s said that when you dream about feathers, it means you’re going to have a new adventure in life or that you are ready for change.
Feathers symbolize protection and that you are being watched over. They are often associated with birds, which are considered to be messengers from the Divine.
If you see a feather in your dream means that you have been given a message from your guardian angel or some higher power.
Feathers are also associated with the element of air and therefore represent change and movement. This can be interpreted as a positive sign that your life is moving in the right direction, even if it looks scary or uncertain.
The symbolic meaning of the feather suggests that you have been honored by the Divine. Feathers are often associated with the power of flight, and this is a symbol of the ability to rise above all obstacles and challenges.
In Native American culture, they also represent the recognition and respect you have received from others. This may have come from personal achievements, such as graduating from school or winning a competition.
It could also come from your work, such as being promoted or receiving an award for your excellent performance. Feathers are also associated with creativity and imagination.
There are many different kinds of feathers, each with its own unique characteristics that contribute to the story of who you are as an individual.
In some cases, the feather symbolism suggests that you need to pay the price for your success. A feather can represent something you want or desire, but it also represents the effort you put in to obtain that thing.
The feather’s spiritual meaning could also imply that something is coming up in your life that requires a lot of hard work and dedication.
You may be working on something new or taking on a new project at work, school, or home. It could also signify that you have been working hard to achieve something recently and are now seeing the results of your efforts.
The feather is a symbol of honor and nobility, which can be attributed to its ability to fly high in the sky. It is often used as a metaphor for spiritually elevated beings, such as angels or deities.
Feathers are used in many traditional ceremonies and rituals worldwide, including Native American tribes who use them to represent a connection with the spirit world and nature.
In addition to these symbols, feathers can be used to represent spiritual growth or transformation. The process of molting is one that birds undergo every year when they grow new feathers.
This process represents rebirth and renewal in nature, which is why many people use feathers as symbols of hope in times of crisis.
Depending on the feather itself and the context you find it in, it can sometimes denote that bad fortune awaits. Feathers in a dark shade, for example, are typically associated with death and mourning.
They may also be a warning from the Universe that you need to change your ways and be more careful in your decisions. This is especially true when it comes to making investments or taking on new projects.
In addition to this association with bad luck, these feathers also symbolize sin and guilt in Western culture.
Here you can find a feather meaning chart, so you can easily see how to feather symbolism differs depending on the type of bird.
If you like this chart, please share it on your social media and/or website.
Feathers had always been a symbol of power and beauty for Native Americans.
They represent the connection between heaven and earth and can be seen as a metaphor for how humans should live: grounded in the physical world but also connected to something greater than themselves.
But the native American feather’s meaning can also relate to a symbol of truth and justice.
It represents how we should strive to live our lives in accordance with those ideals; it’s a reminder that your actions have consequences, so choose them wisely!
The feather symbolism also has spiritual significance, as it is thought to be connected to the sky and the heavens. This is why feathers are used in various religious ceremonies.
However, there are some exceptions when it comes to this symbolism. For instance, if you see an eagle feather on a person’s headdress or necklace, this means they are royalty or nobility within their tribe.
So, a lot of people are asking what is the spiritual meaning of a feather. Feathers have long been associated with spiritual ascension, and are often used to symbolize the journey from Earth to heaven.
They also have a connection to the wind, which is known as an elemental force in many cultures.
Feathers are often a symbol of strength and resilience. In this sense, they are used to symbolize the fact that even when things seem bleak and dark, there is always hope that things can turn around.
The ability to fly means you are free to go wherever you want, regardless of where you were before. Feathers may also suggest that you need to allow yourself more freedom in your life.
The feather meaning in the Bible represents a symbol of faith, hope, and knowledge. Feathers are often seen in art and decoration as symbols of the Holy Spirit, which is why it’s common to see feathers on Christian rosaries.
The Bible also uses several metaphors involving bird symbolism and feathers to describe the Holy Spirit.
The feather is also a symbol of lightness, freedom, and spirituality. It represents the ability to rise above your problems, like a bird soaring above the trees.
It can symbolize the acts of kindness you do for others, or it can represent your connection with God; the way that you feel when you’re in His presence.
The feather symbolism is also often used to represent how we commemorate those who have passed on by placing them on their gravesites.
This can be done as a way to honor them or simply because you want them to know that they are remembered. In Native American culture, feathers are used as part of ceremonies and rituals; they symbolize the connection between earth and sky.
They’re believed to connect us with our ancestors and spiritual guides who lived long before us.
Seeing a feather may be a sign of an angel nearby. This means that your guardian angels have been with you for a long time, and they are trying to get your attention.
They are sent to help us when we are in need. They can appear in many different forms, such as lights or feathers.
When you see an angel feather, it is a sign that someone close to you needs help, or it could be a sign from God that he needs your attention.
If you’re not sure whether your angel feather meaning is literal or figurative, try looking around for other signs of angels; you might notice rainbows more often than usual, for example.
Feathers can generally be categorized into two types: flight feathers and down feathers. Flight feathers are long and have a wide range of uses, such as flying or swimming.
Down feathers are soft and fluffy, making them ideal for nest building. The types of feathers and meanings depend on the species, their coloration, type, and shape.
For example, the black ostrich feather symbolizes power while peacock feathers represent beauty and majesty.
The peacock feather is a symbol of creativity and self-expression, which is why it’s often worn by artists, musicians, and anyone else who wants to show off their creative side.
It also represents confidence, pride, and beauty; all things that you can find within yourself if you’re willing to look for them!
Blue jay feathers are a symbol of protection and good fortune. This bird is the mascot of the United States Marine Corps, so it makes sense that this feather can be used for both protection and good luck in combat.
It’s also believed that these feathers have the power to heal wounds and cure disease, making them a symbol of healing and protection from illness.
The crow feather meaning is one of wisdom, which is often associated with messages from the spirit world.
This feather also represents the ability to see things from a different perspective. This can be helpful when you are trying to solve a problem or make a tough decision.
Eagle feathers are a symbol of power, courage, and knowledge. Native Americans often wore these feathers to symbolize their connection to the spirit world.
They believed that wearing them would help them to achieve a higher level of spirituality. The eagle feather is also used in many ceremonies and rituals within Native American culture.
They are symbols of wisdom and knowledge, which is why owl feathers are a popular choice for those who want to gain insight into something.
It can help you see things from a new perspective, so you can make better decisions in your life.
It’s also associated with introspection and meditation, so if you’re looking for ways to get closer to yourself and understand who you are, this feather is for you!
The cardinal feather meaning is a positive omen. It means that you will be rewarded for your hard work and be able to enjoy the fruits of your labor.
It is also a sign of success and wealth, so if you see it, you should take it as an indication that good things are on their way.
The dove feather is a powerful symbol of peace, hope, and love. It represents the return of innocence and goodness in the world.
This feather is often used to represent the Holy Spirit in many religions. It is also a symbol of purity and innocence. It is said, it can be used to protect one from evil spirits.
The woodpecker feather symbolism is a symbol of fertility, strength, and renewal. It represents the ability to keep going even when it seems like there’s no way out.
It can also be used to represent the ability to overcome seemingly impossible odds, like a woodpecker pecking at a tree.
This feather is a symbol of strength and power. It can also represent the idea that your own personal strength is what you need to achieve your goals.
It is said that finding one denotes the ability to see things from a higher perspective and see things as they really are. This feather is also a symbol of rebirth, as it can be used for new beginnings.
The feather of a hawk is a symbol of power, swiftness, and freedom. It represents the spirit and soul of the tribe and it is used for healing purposes.
It can also be used as an offering to the Great Spirit to ask for protection and safety. This feather is also used as an offering to spirits in order to receive blessings and good luck.
The swan feather symbolizes love and passion. The swan is a bird that is known for its grace, speed, and beauty.
When you see this feather in your dream, it means that you will attract a lover who has the same qualities as you.
The swan feather is also associated with romance, marriage, and fidelity.
Ostrich feathers are a symbol of strength, grace, and beauty. They’re also a symbol of flight, which is one of the most important aspects of life for someone who has recently lost a loved one.
These feathers represent the ability to move forward in life and overcome challenges with grace and determination.
They can also be used as a way to honor the memory of someone who has passed on, by displaying them in your home or other places where you want to remember them.
If you’re looking for the feather color meaning, there are a few things you need to keep in mind: First of all, feathers come in a wide range of colors. What’s more, each color has its own meaning and significance.
You can’t just assume that all red feathers mean the same thing or have the same significance. Second, birds use feathers to attract mates and to identify their species, so color is an important part of their identity.
So, what does the color of your bird’s feathers mean? We’ll go over the most common colors below:
The brown feather’s meaning and significance are that it can represent the earth, the earth’s elements, or a connection to the earth.
If you find one, it could mean that you have recently been thinking about your connection to nature or your affinity for it.
It could also mean that there is something you need to do in order to reconnect with nature.
Brown and white feathers are a sign of purity, innocence, and virtue. The color brown is associated with the earth, rocks, and the ground, while white represents purity, light, and peace.
These feathers may have spiritual significance for you. If so, they could mean that you need to reach out to your spirit guides or ancestors when making decisions about your future path.
A white feather is a sign of kindness and purity. It’s a message from the spirit world that you’re on the right path, and it can mean that you’re about to receive good news.
If you receive a white feather as a gift, it’s usually because they think highly of your character. This could be someone who is offering help, or someone who admires your work and wants to encourage you.
In Native American culture, black and white feathers are considered sacred. They were used in religious ceremonies and worn by tribal chiefs as a sign of authority.
The black/white feather meaning is often associated with freedom, peace, balance, spirituality, and wisdom.
The black feather symbolism can be interpreted in a variety of ways. In general, this color means that you are feeling a lot of internal darkness.
You might be feeling overwhelmed by your emotions or struggling with an addiction or negative thought pattern.
It could also mean that you are afraid to move forward in life, or that you need to be working on your self-love.
The black or grey feather is a symbol of the unknown. It represents something you don’t yet know, something that is currently hidden from view.
It generally means that there is much more to come in your life. Stay open to new experiences, and have faith that the best things are yet to come.
The grey feather represents the spirit that is hidden inside you, waiting to be revealed. When it emerges, it will bring with it a new way of being, and you’ll see things in a totally new light.
This feather is telling you that now is the time to let yourself be transformed by your own wisdom and truth so that you can embrace all aspects of who you are.
It’s not surprising that the grey and white feather meaning is connected to the idea of purity.
These feathers are almost always seen in religious iconography, and they represent truth and honesty. They’re also associated with the sun and light.
In Native American culture, they represent the balance between male and female energies. Many cultures use feathers in ceremonial headdresses or as part of their clothing.
Blue feathers are thought to represent truth, honesty, and clarity of thought. They’re also a symbol of freedom and the sky.
Blue is one of the most popular colors in art and fashion, so it’s no surprise that it’s been used as a symbol for so many different things.
These feathers are often given as gifts to new mothers because they’re said to bring peace and tranquility to any home.
Red is a passionate color, so red feathers can be a sign of intense love and passion in your life.
They may also be a sign that you have strong emotions about something, or that you need to take action on something.
You may be ready to take a leap of faith into a new relationship or begin an intimate friendship.
Yellow feather meanings are exceptional because yellow is the color of the Sun. It means that this feather is a symbol of warmth and creativity, as well as a reminder to be aware of your surroundings.
It’s also associated with new beginnings and fresh starts; something you’ll want to keep in mind if you’re trying to start something new!
The color of nature and life, green is a symbol of growth, renewal, and fertility. It’s also associated with money, success, and luck.
But while the significance of this color is mostly positive, it does have its downsides. For example, it can symbolize jealousy or envy over someone’s success or good fortune.
Orange is a warm color that represents creativity, vitality, and energy. It’s also the color of spring, which is the time of year when everything is new and growing.
Finding one of these feathers can be seen as a sign that your creativity is ready to take flight! In Native American culture, they are also thought to represent wisdom and understanding.
Purple is a color that symbolizes wisdom, royalty, and spirituality. It’s also the color of a creative mind, independence, and imagination.
Due to these qualities, purple feathers are often used for weddings and events that require an air of formality.
So, if you’re looking for a way to symbolize your wedding as something magical or special, these feathers are a great choice!
Pink feather symbolism represents hope, faith, and dreams. It is also associated with springtime, new beginnings, and love.
Pink feathers carry one of the most positive meanings associated with all the different colored feathers in the world.
These denote beauty and grace and can be used to attract someone you like, or just to let them know how much you care about them.
Feathers have long been a symbol of the soul and its ability to fly, so if you dream about them, you might be dreaming about your own ability to soar.
If you’re having trouble getting off the ground in real life, perhaps this vision is telling you that it’s time to take flight. Maybe you need to go on a vacation or try something new.
Or maybe you’re already soaring high, and now it’s time to find a new way to soar even higher! However, in some cases, a feather dream symbolism can also be a sign of deception.
If you find yourself in a situation where you are given feathers by someone who does not have your best interests at heart, then it could imply that you are being deceived by this person.
Feathers are symbolic of a lot of things, including the ability to rise above your current circumstances, the ability to fly and soar, and the ability to break free of things that hold you back.
The feather totem can also symbolize the ability to adapt and change as necessary. Feathers are lightweight yet strong, and they can be used for many different things.
They’re also soft and beautiful, which is why they’re often used in art.
When you dream about finding feathers, it’s likely because you feel like something is holding you back from reaching your full potential or living your best life.
Feathers are a powerful symbol of the soul, and the omen of a feather appearing to you can be interpreted in different ways.
First off, they represent the ability to soar above the earth, unhindered by worldly concerns.
They are also traditionally used in Native American rituals, where they are seen as a sign of wisdom and good luck.
In mythology, the feather omen has been associated with both good and evil.
The story of Icarus tells of how he fashioned wax wings made from feathers and flew too close to the sun, causing his wings to melt and him to plummet into the sea below.
This story warns us against becoming too prideful or arrogant; a lesson we should always keep in mind as we move through life.
Feathers can also be used as a charm or talisman against bad luck or ill fortune; if you find a feather on your path, consider it an omen that there is something good coming your way!
In most cases, feather tattoo symbolism relates to beauty and grace. Feathers represent freedom, flight, and the ability to soar above our problems.
Feather tattoos have been around for decades (feathers were used for war paint in ancient times) and are still popular today because they’re so versatile.
You can use them as a standalone piece or incorporate them into an existing tattoo design.
The feather symbolism is also used to represent wisdom and knowledge gained through experience; a good choice if you want to show your appreciation for life’s lessons!
Finally, tattoos including feathers are symbolic of the soul and its journey. They are often used to represent the spiritual journey of a person, as well as their connection with the Divine.
Yes, finding a feather represents the positive energy that is sent from above and from your own soul. It could be a blessing that helps you in your journey during this lifetime. If you are about to embark on an important journey, it could mean that you are being granted protection for the Divine.
Finding feathers all around you is like a friendly call from nature, letting you know that your presence is welcomed. It also could be a message from the Universe that you are destined for a special task!
In conclusion, the feather symbolism relates to a variety of qualities, from light-headedness to wisdom. In Native American cultures, it has been considered sacred for millennia.
While each bird type and feather include its own meaning and significance, one thing that is true across the board is that feathers are associated with freedom and Divine guidance.
You can take this knowledge and utilize it in your own life whenever you come across a feather.
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Location, Location, Location: The Buhl Mansion
“Steeped in history, built & maintained on love, the Buhl Mansion promises grand memories of a lifetime.” – The Buhl Mansion From the manicured gardens to the tented courtyard, it is no surprise that The Buhl Mansion is celebrated as one of America’s Top 10 Most Romantic Inns, listed on the National Register of Historic…. | 2023-14/0000/en_head.json.gz/1339 | {"url": "https://www.jpceventgroup.com/tag/buhl-mansion/", "partition": "head_middle", "language": "en", "source_domain": "www.jpceventgroup.com", "date_download": "2023-03-20T10:12:03Z", "digest": "sha1:7NZLQXZ2FZHDMWVSQATOAAUOHPWCWOUU"} | {"ccnet_length": [[0, 370, 370.0]], "ccnet_original_length": [[0, 370, 2222.0]], "ccnet_nlines": [[0, 370, 2.0]], "ccnet_original_nlines": [[0, 370, 63.0]], "ccnet_language_score": [[0, 370, 0.92]], "ccnet_perplexity": [[0, 370, 176.9]], "ccnet_bucket": [[0, 370, 0.0]], "rps_doc_curly_bracket": [[0, 370, 0.0]], "rps_doc_ldnoobw_words": [[0, 370, 0.0]], "rps_doc_lorem_ipsum": [[0, 370, 0.0]], "rps_doc_stop_word_fraction": [[0, 370, 0.2739726]], "rps_doc_ut1_blacklist": [[0, 370, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 370, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 370, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 370, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 370, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 370, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 370, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 370, 0.09333333]], "rps_doc_frac_chars_top_3gram": [[0, 370, 0.18666667]], "rps_doc_frac_chars_top_4gram": [[0, 370, 0.0]], "rps_doc_frac_all_caps_words": [[0, 370, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 370, 0.0]], "rps_doc_frac_no_alph_words": [[0, 370, 0.19178082]], "rps_doc_frac_unique_words": [[0, 370, 0.7]], "rps_doc_mean_word_length": [[0, 370, 5.0]], "rps_doc_symbol_to_word_ratio": [[0, 370, 0.01369863]], "rps_doc_unigram_entropy": [[0, 370, 3.52641142]], "rps_doc_word_count": [[0, 370, 60.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 47, 0.0], [47, 370, 1.0]], "rps_lines_javascript_counts": [[0, 47, 0.0], [47, 370, 0.0]], "rps_lines_num_words": [[0, 47, 6.0], [47, 370, 54.0]], "rps_lines_numerical_chars_fraction": [[0, 47, 0.0], [47, 370, 0.00634921]], "rps_lines_start_with_bulletpoint": [[0, 47, 0.0], [47, 370, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 47, 0.12765957], [47, 370, 0.05572755]], "rps_doc_ml_palm_score": [[0, 370, 0.00390267]], "rps_doc_ml_wikipedia_score": [[0, 370, null]], "rps_doc_ml_wikiref_score": [[0, 370, 0.01015323]], "rps_doc_books_importance": [[0, 370, -23.63842304]], "rps_doc_openwebtext_importance": [[0, 370, -0.57996138]], "rps_doc_wikipedia_importance": [[0, 370, -5.9725133]], "rps_doc_num_sentences": [[0, 370, 2.0]]} |
Tips on how to save money d...
Tips on how to save money during your Hong Kong Trip
Hong Kong bills itself as the center of 'east-meets-west'. It is governed by ethos of positive non-interference in public-private relationships and this has seen it grow into one of the richest regions in the world.
Hong Kong at one time or another has been under the reign of the Japanese, the British and today, under Chinese. It is one of the busiest business hubs in the world - easily rivalling Wall Street in New York.
As most a business students will tell you, where there is money, class follows and where there is class, you can expect to spend a small fortune. So what do you do if you are a traveller that is on a shoestring budget? Below are a few tips that can help you save cash while in Hong Kong.
Know the Budget Eateries
If you are on a tight budget, you are not alone. A lot of Hong Kong business people are too. You will notice that at every corner there is a snack-hole that has people lining up to take their light meals. Join them. There must be a reason why they have lined up while there is a restaurant next door. These eateries are locally known as dim sum and will serve you foods such as noodles, pork buns, egg tarts etc. Among the most famous dim sums include; Tim Ho Wan, Tai Cheong Bakery, ABC Kitchen and many more. With a budget of only HK$100, you can have food to your fill.
Substitute Night Clubs with Nature Walk
True, Hong Kong is a concrete jungle - but - about 60% of the city's land is preserved green. Among the popular trails include the Dragon’s Back Trail which leads all the way to Shek-O village where local beer lovers and bachelors spend their night before retiring to bed. Here you can have cheap noodle dishes as you listen to the locals chatting politics and business. Note that all the nature trails are free to use,
Visit Free Museums
All the museums in Hong Kong are free to visit. If you have a few hours, you can sample some of the best Chinese poetry and calligraphy at Hong Kong Museum of Art. If you are not into old stuff, then you can take a leisurely walk at the seaside promenade locally known as 'Avenue of the Stars'. Note that you are doing all this without spending a dime.
Stay at Chungking Mansions
So you got an early day tomorrow and want to retire early? Well, go downtown to the Chungking mansions and get a bed space. Oh...and before you retire, take a samosa or noodle dish at the ground floor. The rooms go for about HK$275.
Get Around Publicly
Hong Kong has some of the best well run public transport systems. From rail cars, buses, subway trains to ferries for crossing Kowloon, you will notice that the public transport system works like clockwork
Park Leftovers
Whenever you are in a restaurant and feel full after eating your meal halfway, ask the wait to pack it. If it goes to waste - it will be your loss.
Shop at the market
If you are staying in Hong Kong for long durations, cooking your own food might be cheaper. However, if you shop at ThreeSixty, you will quickly realize that this is not a city for the poor. Go to the market like the locals.
There are so many little things that you can do to sort out your money issues when in Hong Kong. You just need to think outside the box
By Kennedy Runo about Hong Kong
Start your trip to Hong Kong
Jubilee Travel will help you plan your trip to Hong Kong. | 2023-14/0000/en_head.json.gz/1340 | {"url": "https://www.jubileeonline.ca/tips-on-how-to-save-money-during-your-hong-kong-trip", "partition": "head_middle", "language": "en", "source_domain": "www.jubileeonline.ca", "date_download": "2023-03-20T09:31:34Z", "digest": "sha1:SOADJCASSHTUWWIQ7SBNI5RAPHU5UA65"} | {"ccnet_length": [[0, 3374, 3374.0]], "ccnet_original_length": [[0, 3374, 3937.0]], "ccnet_nlines": [[0, 3374, 23.0]], "ccnet_original_nlines": [[0, 3374, 54.0]], "ccnet_language_score": [[0, 3374, 0.96]], "ccnet_perplexity": [[0, 3374, 296.3]], "ccnet_bucket": [[0, 3374, 0.0]], "rps_doc_curly_bracket": [[0, 3374, 0.0]], "rps_doc_ldnoobw_words": [[0, 3374, 0.0]], "rps_doc_lorem_ipsum": [[0, 3374, 0.0]], "rps_doc_stop_word_fraction": [[0, 3374, 0.4598338]], "rps_doc_ut1_blacklist": [[0, 3374, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3374, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3374, 0.02862524]], 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Foreign, Commonwealth and Development Office Legalisation
Often when dealing with a legal issue abroad it will be necessary to get a document “legalised” for a specific legal purpose. This may sound like a rather complicated legal procedure but is actually quite a simple and easily understood process.
Legalising a document is required when it becomes necessary to prove to somebody overseas that the document being presented is genuine. This is because the people and/or legal body abroad have no other way of checking whether a document is genuine or whether the signature of a lawyer, solicitor, and/or notary is bona fide.
For documents which are signed by a lawyer, solicitor or Notary, the Foreign,Commonwealth and Development Office (FCDO) is certifying to the fact that the person is indeed genuine.
The FCDO therefore provide a service which is commonly known as “legalisation” which helps these documents be accepted overseas.
What actually happens is that the FCDO attach a stamp to the document being presented for legalisation, the stamp is commonly known as the “Apostille” which comes from the Hague Convention of 1961.
The Hague Convention specifies the modalities through which a document issued in one of the signatory countries can be certified for legal purposes in all the other signatory states. It is an international certification comparable to a Notarization in domestic law, and normally supplements a local notarization of the document
Obtaining this Apostille stamp only costs £30 per document and the Foreign and Commonwealth Office has now started a service whereby they will also send the duly legalised document on directly to the end destination abroad; although this additional service will incur an additional small fee dependent on the end destination.
You can check whether a document can be legalised, how to arrange this and how to pay by looking at the Foreign, Commonwealth and Development Office website
If you would like to know more about the legalisation of documents for use overseas then you can contact our overseas legal team at (insert link to our contacts page) who will be happy to talk you through the entire process.
Disclaimer – International legal issues are a complex area of law and this information is no substitute for independent legal advice on an individual basis taking into consideration your personal circumstances and legal requirements. This information is provided to provide general information only and was correct at the time of publishing. The legal position in relation to international transactions can change frequently and this page may not have been updated following any changes in the law. You should therefore not rely on this information and should seek legal advice in relation to your personal circumstances. | 2023-14/0000/en_head.json.gz/1341 | {"url": "https://www.judicaregroup.com/site/news/foreign-commonwealth-office-legalisation", "partition": "head_middle", "language": "en", "source_domain": "www.judicaregroup.com", "date_download": "2023-03-20T09:58:29Z", "digest": "sha1:43TIM3BEFG74UIZN4GLIBHDNOLKM2Z5F"} | {"ccnet_length": [[0, 2793, 2793.0]], "ccnet_original_length": [[0, 2793, 5879.0]], "ccnet_nlines": [[0, 2793, 11.0]], "ccnet_original_nlines": [[0, 2793, 108.0]], "ccnet_language_score": [[0, 2793, 0.94]], "ccnet_perplexity": [[0, 2793, 222.1]], "ccnet_bucket": [[0, 2793, 0.0]], "rps_doc_curly_bracket": [[0, 2793, 0.0]], "rps_doc_ldnoobw_words": [[0, 2793, 0.0]], "rps_doc_lorem_ipsum": [[0, 2793, 0.0]], "rps_doc_stop_word_fraction": [[0, 2793, 0.48148148]], "rps_doc_ut1_blacklist": [[0, 2793, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2793, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2793, 0.0336497]], "rps_doc_frac_chars_dupe_6grams": [[0, 2793, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2793, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2793, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2793, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2793, 0.01941329]], "rps_doc_frac_chars_top_3gram": [[0, 2793, 0.02588438]], "rps_doc_frac_chars_top_4gram": [[0, 2793, 0.02847282]], "rps_doc_frac_all_caps_words": [[0, 2793, 0.00617284]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2793, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2793, 0.08436214]], "rps_doc_frac_unique_words": [[0, 2793, 0.47640449]], "rps_doc_mean_word_length": [[0, 2793, 5.20898876]], "rps_doc_symbol_to_word_ratio": [[0, 2793, 0.0]], "rps_doc_unigram_entropy": [[0, 2793, 4.90496638]], "rps_doc_word_count": [[0, 2793, 445.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 58, 0.0], [58, 303, 1.0], [303, 628, 1.0], [628, 809, 1.0], [809, 938, 1.0], [938, 1136, 1.0], [1136, 1464, 0.0], [1464, 1790, 1.0], [1790, 1947, 0.0], [1947, 2172, 1.0], [2172, 2793, 1.0]], "rps_lines_javascript_counts": [[0, 58, 0.0], [58, 303, 0.0], [303, 628, 0.0], [628, 809, 0.0], [809, 938, 0.0], [938, 1136, 0.0], [1136, 1464, 0.0], [1464, 1790, 0.0], [1790, 1947, 0.0], [1947, 2172, 0.0], [2172, 2793, 0.0]], "rps_lines_num_words": [[0, 58, 6.0], [58, 303, 41.0], [303, 628, 54.0], [628, 809, 28.0], [809, 938, 19.0], [938, 1136, 33.0], [1136, 1464, 50.0], [1464, 1790, 51.0], [1790, 1947, 27.0], [1947, 2172, 41.0], [2172, 2793, 95.0]], "rps_lines_numerical_chars_fraction": [[0, 58, 0.0], [58, 303, 0.0], [303, 628, 0.0], [628, 809, 0.0], [809, 938, 0.0], [938, 1136, 0.02051282], [1136, 1464, 0.0], [1464, 1790, 0.00619195], [1790, 1947, 0.0], [1947, 2172, 0.0], [2172, 2793, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 58, 0.0], [58, 303, 0.0], [303, 628, 0.0], [628, 809, 0.0], [809, 938, 0.0], [938, 1136, 0.0], [1136, 1464, 0.0], [1464, 1790, 0.0], [1790, 1947, 0.0], [1947, 2172, 0.0], [2172, 2793, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 58, 0.0862069], [58, 303, 0.00816327], [303, 628, 0.00615385], [628, 809, 0.05524862], [809, 938, 0.03875969], [938, 1136, 0.04040404], [1136, 1464, 0.0152439], [1464, 1790, 0.01533742], [1790, 1947, 0.03184713], [1947, 2172, 0.00444444], [2172, 2793, 0.00805153]], "rps_doc_ml_palm_score": [[0, 2793, 0.48028749]], "rps_doc_ml_wikipedia_score": [[0, 2793, null]], "rps_doc_ml_wikiref_score": [[0, 2793, 0.37257916]], "rps_doc_books_importance": [[0, 2793, -108.78935346]], "rps_doc_openwebtext_importance": [[0, 2793, 9.67875063]], "rps_doc_wikipedia_importance": [[0, 2793, -95.3697434]], "rps_doc_num_sentences": [[0, 2793, 14.0]]} |
DRA: What the heck is it and do I have it?
If you are pregnant or have recently given birth, you've likely heard the term "DRA" mentioned once or twice. If you've never heard of DRA, that's ok -- that's what we're here for. I recently sat down with pelvic floor physiotherapist, Tesca Andrew-Wasylik, to chat about these three letters that so many post-partum women fear, without really knowing why.read more[...] | 2023-14/0000/en_head.json.gz/1342 | {"url": "https://www.kelsinwonderland.com/tag/pregnancy/", "partition": "head_middle", "language": "en", "source_domain": "www.kelsinwonderland.com", "date_download": "2023-03-20T10:48:04Z", "digest": "sha1:5R6RPIKPCLUSHBYIU6QQ4PXRJQIEOEWL"} | {"ccnet_length": [[0, 413, 413.0]], "ccnet_original_length": [[0, 413, 626.0]], "ccnet_nlines": [[0, 413, 2.0]], "ccnet_original_nlines": [[0, 413, 17.0]], "ccnet_language_score": [[0, 413, 0.97]], "ccnet_perplexity": [[0, 413, 334.5]], "ccnet_bucket": [[0, 413, 0.0]], "rps_doc_curly_bracket": [[0, 413, 0.0]], "rps_doc_ldnoobw_words": [[0, 413, 0.0]], "rps_doc_lorem_ipsum": [[0, 413, 0.0]], "rps_doc_stop_word_fraction": [[0, 413, 0.44444444]], "rps_doc_ut1_blacklist": [[0, 413, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 413, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 413, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 413, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 413, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 413, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 413, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 413, 0.0]], "rps_doc_frac_chars_top_3gram": [[0, 413, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 413, 0.0]], "rps_doc_frac_all_caps_words": [[0, 413, 0.05050505]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 413, 0.0]], "rps_doc_frac_no_alph_words": [[0, 413, 0.21212121]], "rps_doc_frac_unique_words": [[0, 413, 0.81428571]], "rps_doc_mean_word_length": [[0, 413, 4.52857143]], "rps_doc_symbol_to_word_ratio": [[0, 413, 0.01010101]], "rps_doc_unigram_entropy": [[0, 413, 3.9835656]], "rps_doc_word_count": [[0, 413, 70.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 43, 1.0], [43, 413, 0.0]], "rps_lines_javascript_counts": [[0, 43, 0.0], [43, 413, 0.0]], "rps_lines_num_words": [[0, 43, 11.0], [43, 413, 59.0]], "rps_lines_numerical_chars_fraction": [[0, 43, 0.0], [43, 413, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 43, 0.0], [43, 413, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 43, 0.11627907], [43, 413, 0.03243243]], "rps_doc_ml_palm_score": [[0, 413, 0.6826539]], "rps_doc_ml_wikipedia_score": [[0, 413, null]], "rps_doc_ml_wikiref_score": [[0, 413, 0.00091326]], "rps_doc_books_importance": [[0, 413, -1.01440581]], "rps_doc_openwebtext_importance": [[0, 413, -3.20830887]], "rps_doc_wikipedia_importance": [[0, 413, -57.27222417]], "rps_doc_num_sentences": [[0, 413, 5.0]]} |
Signs to Consider Wisdom Tooth Extractions
A Wisdom Tooth Extraction is often necessary in order to eliminate accompanying symptoms. Many individuals experience the eruption of their wisdom teeth and never notice the signs. However, there are also a lot of cases in which the wisdom teeth present noticeable symptoms that can be used to identify eruption. Teenagers and young adults should be aware of these signs as they may help indicate a need for a wisdom tooth extraction.
Wisdom tooth extraction signs
Outlined below are a few signs that indicate a need to consider wisdom tooth extraction. Keep reading to learn what to keep an eye out for!
Pain or discomfort
The number one sign that indicates a consideration for wisdom tooth extraction is pain or discomfort. When the wisdom teeth erupt, they often cause irritation because they are pushing the already-rooted teeth in different directions. This push can result in pain or discomfort. Pain may be felt in the upper or lower jaw, depending on the location of the eruption. Additionally, the back molars and gums may feel sore.
Swelling or inflammation
Wisdom teeth that erupt can cause swelling and inflammation in the gums, typically in the back of the mouth. It can be difficult to see that far back; however, most individuals can feel around with their finger or tongue to determine if the gums seem puffy or swollen. These symptoms can also lead to an infection in the gums, which makes it necessary to be evaluated for wisdom tooth extraction right away.
Another sign that a wisdom tooth extraction is worth considering is if the teeth start crowding. When the wisdom teeth erupt, they can push the other adult teeth into a crowded position. Crowding may not seem detrimental, but it actually is. When the teeth start to crowd, it can result in increased chances of tooth decay and gum disease. Teeth that are not evenly aligned are more difficult to clean as there are harder-to-access areas, thus resulting in a lack of oral hygiene, which can lead to infection development.
Oftentimes when the wisdom teeth begin to erupt, they can cause pressure in the oral cavity, typically in the back of the mouth. The upper and lower jaw, as well as back molars, usually experience the most amount of pressure. Pressure can be irritating and may lead to other symptoms, such as discomfort in the jaw. Any feelings of pressure should be taken to a general dentist who may recommend a wisdom tooth extraction.
Find out more about wisdom tooth extraction
There are a lot of signs that indicate a need to consider wisdom tooth extraction, going far and beyond the ones listed above. However, knowing what all of these signs are can be difficult, which is where a general dentist may be needed. A general dentist can perform an evaluation to help individuals determine whether or not wisdom tooth extraction is necessary. Reach out today to learn more or to get started with a consultation.
Request an appointment here: https://www.kevinjdailydds.com or call Kevin J Daily DDS at (831) 580-1141 for an appointment in our Santa Cruz office.
Check out what others are saying about our dental services on Yelp: Wisdom Teeth Extraction in Santa Cruz, CA.
How Long Is Recovery After A Wisdom Tooth Extraction?
Preparing for a wisdom tooth extraction? The procedure often sparks fear in patients because it does involve pulling teeth. However, it is important to know that modern-day technology has allowed for the evolution of better techniques, which reduce pain and recovery time. Nonetheless, it is still important to be familiar with the recovery time and…
When You Should Get A Wisdom Tooth Extraction
A wisdom tooth extraction is a procedure that not a lot of people look forward to. However, these procedures are done in order to avoid future complications such as pain, overcrowding or crookedness, which makes them worthwhile in the end. Wondering when to get a wisdom tooth extraction? There are some scenarios that may make…
A wisdom tooth extraction is often necessary in order to eliminate accompanying symptoms. Many individuals experience the eruption of their wisdom teeth and never notice the signs. However, there are also a lot of cases in which the wisdom teeth present noticeable symptoms that can be used to identify eruption. Teenagers and young adults should…
Wisdom Teeth Removal: What To Expect
As people grow older, the last set of molars called wisdom teeth start to develop. Due to them typically developing to the point of crowding other teeth, dentists often recommend wisdom teeth removal to avert complications. When wisdom teeth start to ache, most people visit the dentist to have it removed.Wisdom teeth removal is performed through… | 2023-14/0000/en_head.json.gz/1343 | {"url": "https://www.kevinjdailydds.com/blog/signs-to-consider-wisdom-tooth-extractions/", "partition": "head_middle", "language": "en", "source_domain": "www.kevinjdailydds.com", "date_download": "2023-03-20T09:46:37Z", "digest": "sha1:AXDIYKSFXNMJ72CXONNNUXVTGEJ4DLDF"} | {"ccnet_length": [[0, 4715, 4715.0]], "ccnet_original_length": [[0, 4715, 8744.0]], "ccnet_nlines": [[0, 4715, 21.0]], "ccnet_original_nlines": [[0, 4715, 162.0]], "ccnet_language_score": [[0, 4715, 0.94]], "ccnet_perplexity": [[0, 4715, 273.9]], "ccnet_bucket": [[0, 4715, 0.0]], "rps_doc_curly_bracket": [[0, 4715, 0.0]], "rps_doc_ldnoobw_words": [[0, 4715, 0.0]], "rps_doc_lorem_ipsum": [[0, 4715, 0.0]], "rps_doc_stop_word_fraction": [[0, 4715, 0.43502825]], "rps_doc_ut1_blacklist": [[0, 4715, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4715, 0.17438834]], "rps_doc_frac_chars_dupe_5grams": [[0, 4715, 0.25117126]], "rps_doc_frac_chars_dupe_6grams": [[0, 4715, 0.20301926]], "rps_doc_frac_chars_dupe_7grams": [[0, 4715, 0.18896408]], "rps_doc_frac_chars_dupe_8grams": [[0, 4715, 0.17438834]], "rps_doc_frac_chars_dupe_9grams": [[0, 4715, 0.17438834]], "rps_doc_frac_chars_top_2gram": [[0, 4715, 0.05153566]], "rps_doc_frac_chars_top_3gram": [[0, 4715, 0.09292035]], "rps_doc_frac_chars_top_4gram": [[0, 4715, 0.05726184]], "rps_doc_frac_all_caps_words": [[0, 4715, 0.01016949]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4715, 0.19047619]], "rps_doc_frac_no_alph_words": [[0, 4715, 0.10621469]], "rps_doc_frac_unique_words": [[0, 4715, 0.35159236]], "rps_doc_mean_word_length": [[0, 4715, 4.89426752]], "rps_doc_symbol_to_word_ratio": [[0, 4715, 0.00451977]], "rps_doc_unigram_entropy": [[0, 4715, 4.96191946]], "rps_doc_word_count": [[0, 4715, 785.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 43, 0.0], [43, 478, 1.0], [478, 508, 0.0], [508, 648, 1.0], [648, 667, 0.0], [667, 1086, 1.0], [1086, 1111, 0.0], [1111, 1519, 1.0], [1519, 2041, 1.0], [2041, 2464, 1.0], [2464, 2508, 0.0], [2508, 2942, 1.0], [2942, 3091, 1.0], [3091, 3202, 1.0], [3202, 3256, 1.0], [3256, 3607, 0.0], [3607, 3653, 0.0], [3653, 3982, 0.0], [3982, 4330, 0.0], [4330, 4367, 0.0], [4367, 4715, 0.0]], "rps_lines_javascript_counts": [[0, 43, 0.0], [43, 478, 0.0], [478, 508, 0.0], [508, 648, 0.0], [648, 667, 0.0], [667, 1086, 0.0], [1086, 1111, 0.0], [1111, 1519, 0.0], [1519, 2041, 0.0], [2041, 2464, 0.0], [2464, 2508, 0.0], [2508, 2942, 0.0], [2942, 3091, 0.0], [3091, 3202, 0.0], [3202, 3256, 0.0], [3256, 3607, 0.0], [3607, 3653, 0.0], [3653, 3982, 0.0], [3982, 4330, 0.0], [4330, 4367, 0.0], [4367, 4715, 0.0]], "rps_lines_num_words": [[0, 43, 6.0], [43, 478, 72.0], [478, 508, 4.0], [508, 648, 26.0], [648, 667, 3.0], [667, 1086, 69.0], [1086, 1111, 3.0], [1111, 1519, 72.0], [1519, 2041, 89.0], [2041, 2464, 74.0], [2464, 2508, 7.0], [2508, 2942, 75.0], [2942, 3091, 22.0], [3091, 3202, 19.0], [3202, 3256, 9.0], [3256, 3607, 55.0], [3607, 3653, 8.0], [3653, 3982, 55.0], [3982, 4330, 55.0], [4330, 4367, 6.0], [4367, 4715, 56.0]], "rps_lines_numerical_chars_fraction": [[0, 43, 0.0], [43, 478, 0.0], [478, 508, 0.0], [508, 648, 0.0], [648, 667, 0.0], [667, 1086, 0.0], [1086, 1111, 0.0], [1111, 1519, 0.0], [1519, 2041, 0.0], [2041, 2464, 0.0], [2464, 2508, 0.0], [2508, 2942, 0.0], [2942, 3091, 0.07246377], [3091, 3202, 0.0], [3202, 3256, 0.0], [3256, 3607, 0.0], [3607, 3653, 0.0], [3653, 3982, 0.0], [3982, 4330, 0.0], [4330, 4367, 0.0], [4367, 4715, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 43, 0.0], [43, 478, 0.0], [478, 508, 0.0], [508, 648, 0.0], [648, 667, 0.0], [667, 1086, 0.0], [1086, 1111, 0.0], [1111, 1519, 0.0], [1519, 2041, 0.0], [2041, 2464, 0.0], [2464, 2508, 0.0], [2508, 2942, 0.0], [2942, 3091, 0.0], [3091, 3202, 0.0], [3202, 3256, 0.0], [3256, 3607, 0.0], [3607, 3653, 0.0], [3653, 3982, 0.0], [3982, 4330, 0.0], [4330, 4367, 0.0], [4367, 4715, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 43, 0.11627907], [43, 478, 0.01609195], [478, 508, 0.03333333], [508, 648, 0.01428571], [648, 667, 0.05263158], [667, 1086, 0.01193317], [1086, 1111, 0.04], [1111, 1519, 0.00735294], [1519, 2041, 0.00957854], [2041, 2464, 0.00945626], [2464, 2508, 0.02272727], [2508, 2942, 0.00921659], [2942, 3091, 0.06040268], [3091, 3202, 0.08108108], [3202, 3256, 0.16666667], [3256, 3607, 0.01139601], [3607, 3653, 0.17391304], [3653, 3982, 0.01215805], [3982, 4330, 0.01149425], [4330, 4367, 0.16216216], [4367, 4715, 0.01149425]], "rps_doc_ml_palm_score": [[0, 4715, 0.41807127]], "rps_doc_ml_wikipedia_score": [[0, 4715, null]], "rps_doc_ml_wikiref_score": [[0, 4715, 0.03034538]], "rps_doc_books_importance": [[0, 4715, -139.10890998]], "rps_doc_openwebtext_importance": [[0, 4715, 40.40328187]], "rps_doc_wikipedia_importance": [[0, 4715, -99.57130513]], "rps_doc_num_sentences": [[0, 4715, 45.0]]} |
Home » Cross Defense — Entertainment, Social Media, and A Problem with The Chosen » Entertainment, Social Media, and A Problem with The Chosen
Entertainment, Social Media, and A Problem with The Chosen | 2023-14/0000/en_head.json.gz/1344 | {"url": "https://www.kfuo.org/2023/02/25/cross-defense-022523-entertainment-social-media-and-a-problem-with-the-chosen/fi_022523_cd_entertainment-social-media-and-a-problem-with-the-chosen/", "partition": "head_middle", "language": "en", "source_domain": "www.kfuo.org", "date_download": "2023-03-20T09:33:23Z", "digest": "sha1:SUB4QTCX7RXKCXX4RKHNIPGLRHDSSQGO"} | {"ccnet_length": [[0, 201, 201.0]], "ccnet_original_length": [[0, 201, 5779.0]], "ccnet_nlines": [[0, 201, 2.0]], "ccnet_original_nlines": [[0, 201, 247.0]], "ccnet_language_score": [[0, 201, 0.72]], "ccnet_perplexity": [[0, 201, 255.2]], "ccnet_bucket": [[0, 201, 0.0]], "rps_doc_curly_bracket": [[0, 201, 0.0]], "rps_doc_ldnoobw_words": [[0, 201, 0.0]], "rps_doc_lorem_ipsum": [[0, 201, 0.0]], "rps_doc_stop_word_fraction": [[0, 201, 0.15384615]], "rps_doc_ut1_blacklist": [[0, 201, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 201, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 201, 0.88343558]], "rps_doc_frac_chars_dupe_6grams": [[0, 201, 0.88343558]], "rps_doc_frac_chars_dupe_7grams": [[0, 201, 0.88343558]], "rps_doc_frac_chars_dupe_8grams": [[0, 201, 0.88343558]], "rps_doc_frac_chars_dupe_9grams": [[0, 201, 0.88343558]], "rps_doc_frac_chars_top_2gram": [[0, 201, 0.34969325]], "rps_doc_frac_chars_top_3gram": [[0, 201, 0.44171779]], "rps_doc_frac_chars_top_4gram": [[0, 201, 0.49693252]], "rps_doc_frac_all_caps_words": [[0, 201, 0.07692308]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 201, 0.0]], "rps_doc_frac_no_alph_words": [[0, 201, 0.23076923]], "rps_doc_frac_unique_words": [[0, 201, 0.42424242]], "rps_doc_mean_word_length": [[0, 201, 4.93939394]], "rps_doc_symbol_to_word_ratio": [[0, 201, 0.0]], "rps_doc_unigram_entropy": [[0, 201, 2.55563404]], "rps_doc_word_count": [[0, 201, 33.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 143, 0.0], [143, 201, 0.0]], "rps_lines_javascript_counts": [[0, 143, 0.0], [143, 201, 0.0]], "rps_lines_num_words": [[0, 143, 24.0], [143, 201, 9.0]], "rps_lines_numerical_chars_fraction": [[0, 143, 0.0], [143, 201, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 143, 0.0], [143, 201, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 143, 0.11888112], [143, 201, 0.12068966]], "rps_doc_ml_palm_score": [[0, 201, -1.001e-05]], "rps_doc_ml_wikipedia_score": [[0, 201, null]], "rps_doc_ml_wikiref_score": [[0, 201, -1.001e-05]], "rps_doc_books_importance": [[0, 201, -16.315251]], "rps_doc_openwebtext_importance": [[0, 201, -7.30376679]], "rps_doc_wikipedia_importance": [[0, 201, 0.61412513]], "rps_doc_num_sentences": [[0, 201, 1.0]]} |
Surprise Proposals
Party Events
Kim Hewitt Photography
McCain for President 2008
Art Page
bio_pic
To me the camera is key to learning about people and the stories they have to share. I noticed early on in my photography studies that when I had my camera in my hand people opened up to me. That openness is the inspiration that has driven my photography for the last 15 years.
I grew up in El Paso, Texas and upon graduating from UT Austin, in 1999, I moved to New York City. Just after Sept 11, 2001, the New York City Fire Department hired me as a staff photographer. For the next 2 years I used my camera to capture the moments and the stories of the firefighters of New York City. Surrounded by the personnel and the families of the FDNY, I listened to the stories of lost life.
From the fire department I was hired by the City Hall Mayor’s photo unit. After my experience at City Hall I went on to work in D.C. as a White House staff photographer. This journey took my photography skills to the next level. I refer to these years as my “photography boot camp".
After the White House I began a career in presidential campaigning. I have shot for five different presidential candidates and worked on many other political campaigns.
I now live in the best city on earth, New York City. I freelance with surprise proposals and pick up all event photo jobs that are offered to me! | 2023-14/0000/en_head.json.gz/1345 | {"url": "https://www.kimberleehewitt.com/bio", "partition": "head_middle", "language": "en", "source_domain": "www.kimberleehewitt.com", "date_download": "2023-03-20T08:40:32Z", "digest": "sha1:NTBJKVQSGHWCO4WMHQPCMBWBCAEE6LXT"} | {"ccnet_length": [[0, 1379, 1379.0]], "ccnet_original_length": [[0, 1379, 1610.0]], "ccnet_nlines": [[0, 1379, 11.0]], "ccnet_original_nlines": [[0, 1379, 27.0]], "ccnet_language_score": [[0, 1379, 0.98]], "ccnet_perplexity": [[0, 1379, 297.2]], "ccnet_bucket": [[0, 1379, 0.0]], "rps_doc_curly_bracket": [[0, 1379, 0.0]], "rps_doc_ldnoobw_words": [[0, 1379, 0.0]], "rps_doc_lorem_ipsum": [[0, 1379, 0.0]], "rps_doc_stop_word_fraction": [[0, 1379, 0.38515901]], "rps_doc_ut1_blacklist": [[0, 1379, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1379, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1379, 0.02547771]], "rps_doc_frac_chars_top_3gram": [[0, 1379, 0.0400364]], "rps_doc_frac_chars_top_4gram": [[0, 1379, 0.0]], "rps_doc_frac_all_caps_words": [[0, 1379, 0.06007067]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1379, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1379, 0.1130742]], "rps_doc_frac_unique_words": [[0, 1379, 0.53333333]], "rps_doc_mean_word_length": [[0, 1379, 4.30980392]], "rps_doc_symbol_to_word_ratio": [[0, 1379, 0.0]], "rps_doc_unigram_entropy": [[0, 1379, 4.52650947]], "rps_doc_word_count": [[0, 1379, 255.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 19, 0.0], [19, 32, 0.0], [32, 55, 0.0], [55, 81, 0.0], [81, 90, 0.0], [90, 98, 0.0], [98, 376, 1.0], [376, 782, 1.0], [782, 1065, 1.0], [1065, 1234, 1.0], [1234, 1379, 1.0]], "rps_lines_javascript_counts": [[0, 19, 0.0], [19, 32, 0.0], [32, 55, 0.0], [55, 81, 0.0], [81, 90, 0.0], [90, 98, 0.0], [98, 376, 0.0], [376, 782, 0.0], [782, 1065, 0.0], [1065, 1234, 0.0], [1234, 1379, 0.0]], "rps_lines_num_words": [[0, 19, 2.0], [19, 32, 2.0], [32, 55, 3.0], [55, 81, 4.0], [81, 90, 2.0], [90, 98, 1.0], [98, 376, 54.0], [376, 782, 79.0], [782, 1065, 53.0], [1065, 1234, 26.0], [1234, 1379, 29.0]], "rps_lines_numerical_chars_fraction": [[0, 19, 0.0], [19, 32, 0.0], [32, 55, 0.0], [55, 81, 0.16], [81, 90, 0.0], [90, 98, 0.0], [98, 376, 0.00729927], [376, 782, 0.0278481], [782, 1065, 0.0], [1065, 1234, 0.0], [1234, 1379, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 19, 0.0], [19, 32, 0.0], [32, 55, 0.0], [55, 81, 0.0], [81, 90, 0.0], [90, 98, 0.0], [98, 376, 0.0], [376, 782, 0.0], [782, 1065, 0.0], [1065, 1234, 0.0], [1234, 1379, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 19, 0.10526316], [19, 32, 0.15384615], [32, 55, 0.13043478], [55, 81, 0.11538462], [81, 90, 0.22222222], [90, 98, 0.0], [98, 376, 0.01438849], [376, 782, 0.07142857], [782, 1065, 0.05300353], [1065, 1234, 0.0295858], [1234, 1379, 0.03448276]], "rps_doc_ml_palm_score": [[0, 1379, 0.33809566]], "rps_doc_ml_wikipedia_score": [[0, 1379, null]], "rps_doc_ml_wikiref_score": [[0, 1379, 0.04073954]], "rps_doc_books_importance": [[0, 1379, -47.96812798]], "rps_doc_openwebtext_importance": [[0, 1379, 5.51224605]], "rps_doc_wikipedia_importance": [[0, 1379, -54.48794596]], "rps_doc_num_sentences": [[0, 1379, 17.0]]} |
Coffee: Drink to Your Health!
If you’re anything like me, you can’t function properly without your morning cup of coffee. Discovered more than 1,000 years ago by hungry goats roaming the hills of Ethiopia, it has become the number one source of antioxidants in the U.S. diet. Black tea, bananas, dry beans and corn round out the top five. Once a health pariah blamed for everything from stunted growth, to heart disease, to making you visit the bathroom more often, coffee is now making a comeback. Three new studies were published this year alone touting it’s health benefits. But can a latte a day really keep the doctor away? Here is some evidence that suggests the answer is, “Yes!”
It Might Decrease Exercise Pain
A study published in the April edition of the International Journal of Sport Nutrition and Exercise Metabolism says that coffee can dull the pain of athletic exertion.
University of Illinois kinesiology and community health professor Robert Motl, a former competitive cyclist, divided 25 fit, college-aged men into two groups – coffee drinkers and non coffee drinkers – and gave them 5 milligrams of caffeine or a placebo. 5 mg is the equivalent of two to three cups of coffee. One hour later, he put them through a high-intensity 30-minute workout on a stationary bike. Recording the subjects’ perceived muscle pain, along with their oxygen consumption, heart rate and work rate, Motl was surprised to discover that both the coffee drinkers and the non coffee drinkers experienced the same amount of pain reduction.
“Researchers speculate that it’s because caffeine works on the adenosine neuromodulatory system in the brain and spinal cord, which is heavily involved in pain processing,” said Cynthia Sass, a registered dietician board certified as a specialist in sports dietetics.
So, what does this mean for you the next time you hit the gym? Coffee lover or not, everyone might benefit from a little caffeine before a workout. Although more research needs to be done, Motl hopes that in the future the use of caffeine as a pain reducer might encourage people who would have quit exercising because of the pain to stick with their workouts.
It Might Help Your Memory
Your morning cup of java might help keep your memory sharp. A study done on lab mice bred to develop Alzheimer’s disease found that mice given caffeine in their daily drinking water performed better on memory and thinking tests than mice given just plain water. Thought to decrease inflammation in the brain, caffeine reduces the level of a protein found in plaque in the brains of people with Alzheimer’s disease.
“It’s not fully understood but the research suggests that levels of beta-amyloid proteins were reduced in mice who drank caffeine – beta-amyloid proteins collect into plaques in the brain and are seen in the brains of people with Alzheimer’s disease,” said Sass. “When the researchers gave caffeine to older mice with Alzheimer’s who already had high levels of beta-amyloid protein in their brains, the caffeine reduced the levels of beta-amyloid already present.”
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The mice were given 500 milligrams of caffeine in the study. “[In comparison], 8 ounces of fresh brewed coffee has 95 milligrams,” said Sass. “A 16 oz. Starbucks Caffe Latte has 150 milligrams, 1 oz. of espresso has 64 milligrams and 8 oz. black tea has 47 milligrams.” While 500 mg might look like a lot, it’s actually the equivalent of 2 1/2 Grandes a day at your local Starbucks. And while that’s a bit more coffee than most people have in the morning, it’s not an excessive amount.
The study, which appeared in the July 5 online edition of the Journal of Alzheimer’s Disease, was conducted over a two-month period and it’s not known whether or not the changes in the mice were permanent. Researchers plan to conduct more studies, including human trials, to see if caffeine can benefit people with early signs of Alzheimer’s.
It Might Lower Your Risk of Type 2 Diabetes
Several studies have suggested that people who drink coffee have a lower risk of developing type 2 diabetes than non coffee drinkers. In 2004, a Finnish study found that people who drank three or four cups of coffee a day reduced their risk of diabetes by 30 percent. And the more they drank, the more that percentage increased. Women who drank 10 or more cups a day reduced their risk by a whopping 79 percent! Men who drank more than six cups a day reduced their risk by more than 50 percent compared to men who didn’t drink coffee.
A study conducted by the Harvard School of Public Health, involving more than 125,000 men and women who were free of diabetes, cancer and cardiovascular disease, concurred with the Finnish study. Some 41,934 men and 84,276 women were tracked over a span of more than 12 years. They were given food questionnaires every two to four years that assessed both their regular and decaffeinated coffee intake. Both groups lowered their diabetes risk, with the men lowering their risk more than the women by 20 percent.
“This is good news for coffee drinkers, however, it doesn’t mean everyone should run out for a latte,” said Frank Hu, senior author of the study and an associate professor of nutrition and epidemiology at the Harvard School of Public Health. “We still don’t know exactly why coffee is beneficial for diabetes, and more research is clearly needed.”
Whatever the mystery ingredient is in coffee that reduces diabetes risk, that ingredient isn’t caffeine. While it is known to raise blood sugar and increase energy expenditure in the short-term, its long-term effects are still not well understood.
In 2008, Duke University researcher James D. Lane, Ph.D. discovered in a small, 10 patient study that caffeine can actually increase blood sugar levels in people who already have type 2 diabetes. Dr. Lane and his colleagues monitored the blood sugars of the diabetes patients after giving them 250 mg caffeine capsules at breakfast and lunch, equal to two cups of coffee, at each meal. The same people were given placebos on another day. The result? Blood sugar levels spiked by 8 percent on the days the patients were given the caffeine pills and their blood sugar spiked higher after every meal, including dinner, on those same days compared to the days they had no caffeine.
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So, what is a person to do if they have diabetes, or are at high risk, and want to enjoy their favorite morning cup of joe? Try decaf instead. Decaffeinated coffee might actually help people control their blood sugar and, although it’s effects are weaker than regular coffee, it is also beneficial.
It Might Improve Your Sex Drive
Ladies, listen up! Coffee might put you in the mood more often. Scientists from Southwestern University have found that caffeine increases libido in female rats. 108 rats given a moderate dose of caffeine 30 minutes before mating were quicker to return to their male counterparts for a second romp than uncaffeinated females. And they weren’t shy about it either. Instead of wandering about aimlessly on a caffeine buzz, the females specifically sought out the males, seemingly not to burn extra energy but to initiate sex, and weren’t interested in socializing with other female rats.
The Pharmacology, Biochemistry and Behaviour journal study says the effect was caused by caffeine stimulating the part of the brain that regulates arousal.
But before women everywhere start stocking up on Taster’s Choice to improve their sex life, not so fast! For the rats in the study, that dose of caffeine was their first. Researchers say that a similar effect is likely only in women who do not drink coffee regularly. Many women consume caffeine on a daily basis, whether it’s through coffee or soft drinks, and are unlikely to see any sexual enhancement. But women who drink caffeine once a week or less might.
While coffee might not be ready to replace chocolate and oysters as the next big aphrodisiac, researchers hope the study will help improve understanding about the relationship between the brain and sexual behavior, and might one day be used to help treat sexual dysfunction.
It Might Improve Your Breath
Surprise! Coffee can actually be good for your breath. Even the scientists who conducted the study at Tel Aviv University in Israel earlier this year were surprised. In findings presented to members of the International Society for Breath Odor Research in Germany, breath specialist Mel Rosenberg found an extract in coffee can inhibit the bacteria that lead to bad breath, making their presence neither felt nor smelt.
Rosenberg’s team took saliva and incubated it with different brands of coffee, thinking it would produce a terrible odor. Instead, it did the opposite. The real culprit behind the infamous “coffee breath?” Rosenberg says coffee has a dehydrating effect on the mouth and, when mixed with substances like milk, it can ferment and cause bad breath.
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Rosenberg, who also created the popular mouthwash Dentyl pH, wants to isolate the bacteria-inhibiting molecule in order to use it’s anti-bacterial properties. If successful, we could soon see coffee-based mouthwash, toothpaste and chewing gum on store shelves www.livebetx.com.
Everything in Moderation
Despite coffee’s health benefits, it’s important to remember that caffeine is a naturally-occurring drug, but a drug nonetheless, and consuming too much of it can have some unpleasant side effects. Some of those side effects include rapid heart rate, palpitations, insomnia, restlessness, nervousness, nausea and diarrhea. Caffeine can increase blood pressure, especially in people with hypertension, although regular coffee drinkers might build a small amount of tolerance to the effect. It can interfere with some prescription medications. And, some studies suggest, five or more cups of coffee a day can increase your risk of coronary heart disease.
Women who are pregnant, or thinking of getting pregnant, might want to consider quitting as well. “Some studies have found a significant association between very high caffeine intakes, particularly from coffee, and the risk of spontaneous abortion, and several studies found that maternal caffeine intakes ranging from 200-400 mg/day were associated with decreases in babies’ birth weights of about 3.5 oz.,” said Cynthia Sass.
Also, if you’re not getting enough sleep, coffee might make the situation worse. Most adults need seven to eight hours of sleep each night. Sleep loss is cumulative, and too much of it can turn into sleep deprivation. Using coffee to mask the sleep deprivation can lead to a vicious cycle of drowsy days and sleepless nights, shortening the length of time you sleep and increasing the number of times you wake up during the night. Then, when you wake up the next day, you crave that morning jolt of caffeine and the cycle starts again.
So, what can you do if you want to cut back? Do it gradually, for starters. Try drinking one less soda or coffee per day to get your body used to lower amounts of caffeine. Cutting out the caffeine too quickly can lead to withdrawals, which can last for a few days and include such symptoms as headaches, fatigue, drowsiness, irritability, difficulty concentrating and depression. You can also try switching to decaf, but keep in mind that decaf does actually contain caffeine! A study in 2006 found that if someone drinks five to 10 cups of decaf, it would equal about one or two cups of caffeinated coffee.
As with a lot of things in life, moderation seems to be the key when it comes to your daily java. Most researchers seem to agree that two to four cups of coffee a day can’t hurt, and might even help. So, drink up coffee lovers! 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Ron Anderson, 80
By Editor | May 23, 2018 | 0
Ron “Ronnie” Duane Anderson, 80, Moorhead, Minn., passed away peacefully in his home surrounded by his family Saturday, May 19, 2018.
Ron was born on Jan. 22, 1938 to John Levin and Martha (Hoglin) Anderson in Hallock, Minn.
After completing high school in Hallock and some other adventures, Ron joined the army in 1959 for three years.
In 1967, he married Judy White and together they had three children, Brad, Carrie, and Mark. Ron started working for R&O Elevators in Minneapolis, Minn., which lead to moving to Moorhead in 1976 to work for Otis Elevator Company and then Lagerquist Passenger and Freight Elevators as an elevator service mechanic and adjustor.
Ron enjoyed playing hockey, coaching youth hockey, deer hunting, and restoring old trucks. He enjoyed time spent with his family, but most of all, with his six grandchildren and one great-grandchild.
Ron is survived by his wife, Judy; children, Brad (Veronica) Anderson, Carrie (Dave) Gorman, and Mark (Angie) Anderson; grandchildren, Tyler, Seth, Kyle, Andrew, Ellie, and Charlee; great-grandchild, Adama; siblings, Linden Anderson, Jim (Joan) Anderson, and Janice (Kenny) Anderson; and many other loving relatives and friends.
He was preceded in death by his parents; siblings, Melvin Anderson, Leona Larson and Marlys Erickson.
Visitation will be Wednesday, May 23, from 5-7 p.m. with a prayer service beginning at 7 p.m. at Wright Funeral Home, Moorhead. Funeral services will be held Thursday, May 24, at 11 a.m. at Grace United Methodist Church in Moorhead with a visitation one hour prior to the service.
The family would like to especially thank the Hospice of the Red River Valley for the exceptional care and service they provided for Ron and his family.
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CONSUMER PRICE INDICES AND INFLATION RATES FOR FEBRUARY 2023
Posted on February 28, 2023 by Maurice Kamau
The overall year on year inflation rate as measured by the Consumer Price Index (CPI) was 9.2 per cent, in February 2023. As presented in Tables 1 and 2, the rise in inflation was largely due to increase in prices of commodities under food and non-alcoholic beverages (13.3%); housing, water, electricity, gas and other fuels (7.6%); and transport (12.9%) between February 2022 and February 2023 Read More
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By KEN SWEET, CHRISTOPHER RUGABER, CHRIS MEGERIAN and CATHY BUSSEWITZ The Associated Press
Treasury Secretary Janet Yellen listens as she testifies during a House Ways and Means committee hearing on President Joe Biden's fiscal year 2024 budget request, Friday, March 10, 2023, on Capitol Hill in Washington. (AP Photo/Mariam Zuhaib)[ASSOCIATED PRESS/Mariam Zuhaib]
NEW YORK (AP) — The U.S. government took extraordinary steps Sunday to stop a potential banking crisis after the historic failure of Silicon Valley Bank, assuring all depositors at the failed institution that they could access all their money quickly, even as another major bank was shut down.
The announcement came amid fears that the factors that caused the Santa Clara, California-based bank to fail could spread. Regulators had worked all weekend to try to find a buyer for the bank, which was the second-largest bank failure in history. Those efforts appeared to have failed Sunday.
In a sign of how fast the financial bleeding was occurring, regulators announced that New York-based Signature Bank had also failed and was being seized on Sunday. At more than $110 billion in assets, Signature Bank is the third-largest bank failure in U.S. history.
The near-financial crisis that U.S. regulators had to intervene to prevent left Asian markets jittery as trading began Monday. Japan’s benchmark Nikkei 225 sank 1.6% in morning trading, Australia’s S&P/ASX 200 lost 0.3% and South Korea’s Kospi shed 0.4%. But Hong Kong’s Hang Seng rose 1.4% and the Shanghai Composite increased 0.3%.
In an effort to shore up confidence in the banking system, the Treasury Department, Federal Reserve and FDIC said Sunday that all Silicon Valley Bank clients would be protected and able to access their money. They also announced steps that are intended to protect the bank’s customers and prevent additional bank runs.
A Silicon Valley Bank sign is shown outside branch in Wellesley, Mass on Saturday, March 11, 2023. Regulators have seized the assets of one of Silicon Valley’s top banks, marking the largest failure of a U.S. financial institution since the height of the financial crisis almost 15 years ago. (AP Photo/Peter Morgan)
Photo: ASSOCIATED PRESS/Peter Morgan
Speaker of the House Kevin McCarthy, R-Calif., speaks at the California GOP Organizing Convention in Sacramento, Calif., Saturday, March 11, 2023. (Juliana Yamada/San Francisco Chronicle via AP)
Photo: ASSOCIATED PRESS/Juliana Yamada
“This step will ensure that the U.S. banking system continues to perform its vital roles of protecting deposits and providing access to credit to households and businesses in a manner that promotes strong and sustainable economic growth,” the agencies said in a joint statement.
Under the plan, depositors at Silicon Valley Bank and Signature Bank, including those whose holdings exceed the $250,000 insurance limit, will be able to access their money on Monday.
Also Sunday, another beleaguered bank, First Republic Bank, announced that it had bolstered its financial health by gaining access to funding from the Fed and JPMorgan Chase.
In a separate announcement, the Fed late Sunday announced an expansive emergency lending program that’s intended to prevent a wave of bank runs that would threaten the stability of the banking system and the economy as a whole. Fed officials characterized the program as akin to what central banks have done for decades: Lend freely to the banking system so that customers would be confident that they could access their accounts whenever needed.
The lending facility will allow banks that need to raise cash to pay depositors to borrow that money from the Fed, rather than having to sell Treasuries and other securities to raise the money. Silicon Valley Bank had been forced to dump some of its Treasuries at at a loss to fund its customers’ withdrawals. Under the Fed’s new program, banks can post those securities as collateral and borrow from the emergency facility.
The Treasury has set aside $25 billion to offset any losses incurred under the Fed’s emergency lending facility. Fed officials said, however, that they do not expect to have to use any of that money, given that the securities posted as collateral have a very low risk of default.
Analysts said the Fed’s program should be enough to calm financial markets on Monday.
“Monday will surely be a stressful day for many in the regional banking sector, but today’s action dramatically reduces the risk of further contagion,” economists at Jefferies, an investment bank, said in a research note.
Though Sunday’s steps marked the most extensive government intervention in the banking system since the 2008 financial crisis, its actions are relatively limited compared with what was done 15 years ago. The two failed banks themselves have not been rescued, and taxpayer money has not been provided to the banks.
President Joe Biden said Sunday evening as he boarded Air Force One back to Washington that he would speak about the bank situation on Monday. In a statement, Biden also said he was “firmly committed to holding those responsible for this mess fully accountable and to continuing our efforts to strengthen oversight and regulation of larger banks so that we are not in this position again.”
Regulators had to rush to close Silicon Valley Bank, a financial institution with more than $200 billion in assets, on Friday when it experienced a traditional run on the bank where depositors rushed to withdraw their funds all at once. It is the second-largest bank failure in U.S. history, behind only the 2008 failure of Washington Mutual.
Some prominent Silicon Valley executives feared that if Washington didn’t rescue the failed bank, customers would make runs on other financial institutions in the coming days. Stock prices plunged over the last few days at other banks that cater to technology companies, including First Republic Bank and PacWest Bank.
Among the bank’s customers are a range of companies from California’s wine industry, where many wineries rely on Silicon Valley Bank for loans, and technology startups devoted to combating climate change. Sunrun, which sells and leases solar energy systems, had less than $80 million of cash deposits with Silicon Valley. Stitchfix, the clothing retail website, disclosed recently that it had a credit line of up to $100 million with Silicon Valley Bank and other lenders.
Tiffany Dufu, founder and CEO of The Cru, a New York-based career coaching platform and community for women, posted a video Sunday on LinkedIn from an airport bathroom, saying the bank crisis was testing her resiliency. Given that her money was tied up at Silicon Valley Bank, she had to pay her employees out of her personal bank account. With two teenagers to support who will be heading to college, she said she was relieved to hear that the government’s intent is to make depositors whole.
“Small businesses and early-stage startups don’t have a lot of access to leverage in a situation like this, and we’re often in a very vulnerable position, particularly when we have to fight so hard to get the wires into your bank account to begin with, particularly for me, as a Black female founder,” Dufu told The Associated Press.
Silicon Valley Bank began its slide into insolvency when its customers, largely technology companies that needed cash as they struggled to get financing, started withdrawing their deposits. The bank had to sell bonds at a loss to cover the withdrawals, leading to the largest failure of a U.S. financial institution since the height of the financial crisis.
Treasury Secretary Janet Yellen pointed to rising interest rates, which have been increased by the Federal Reserve to combat inflation, as the core problem for Silicon Valley Bank. Many of its assets, such as bonds or mortgage-backed securities, lost market value as rates climbed.
Sheila Bair, who was chairwoman of the FDIC during the 2008 financial crisis, recalled that with nearly all the bank failures then, “we sold a failed bank to a healthy bank. And usually, the healthy acquirer would also cover the uninsured because they wanted the franchise value of those large depositors so optimally, that’s the best outcome.”
But with Silicon Valley Bank, she told NBC’s “Meet the Press,” “this was a liquidity failure, it was a bank run, so they didn’t have time to prepare to market the bank. So they’re having to do that now, and playing catch-up.”
Rugaber and Megerian reported from Washington. Sweet and Bussewitz reported from New York.
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Italy’s coast guard, navy, bring hundreds of migrants ashore
By FRANCES D'EMILIO The Associated Press
Police check a fishing boat with some 500 migrants in the southern Italian port of Crotone, early Saturday, March 11, 2023. The Italian coast guard was responding to three smugglers boats carrying more than 1,300 migrants “in danger” off Italy’s southern coast, officials said Friday. Three small coast guard boats were rescuing a boat with 500 migrants about 700 miles off the Calabria region, which forms the toe of the Italian boot. (AP Photo/Valeria Ferraro)[ASSOCIATED PRESS/Valeria Ferraro]
ROME (AP) — Italian coast guard and navy vessels on Saturday ferried hundreds of rescued migrants toward shore, while elsewhere in the Mediterranean Sea thousands of migrants overflowed from a shelter on a tiny tourist island.
The influx of sea arrivals came in the face of a crackdown by Italy’s right-wing government on people smugglers announced only two days earlier.
The coast guard said in a statement that overcrowding on two vessels and adverse sea and weather conditions had complicated rescue operations that began on Friday in the Ionian Sea off Calabria.
A 94-meter (310-foot) -long coast guard vessel took 584 migrants aboard, while two smaller coast guard motorboats took on 379 and then transferred them to an Italian naval vessel, which was headed to Augusta, a port in eastern Sicily, as migrant shelters in Calabria quickly filled up.
Separately, a boat carrying 487 people, intercepted by Italian vessels some 60 nautical miles (112 kilometers) off Crotone in Calabria on Friday, was aided by two coast guard motorboats and a border police boat. The migrants disembarked in Crotone’s port before dawn on Saturday.
Some 500 migrants start disembarking from a fishing boat in the southern Italian port of Crotone, early Saturday, March 11, 2023. The Italian coast guard was responding to three smugglers boats carrying more than 1,300 migrants “in danger” off Italy’s southern coast, officials said Friday. Three small coast guard boats were rescuing a boat with 500 migrants about 700 miles off the Calabria region, which forms the toe of the Italian boot. (AP Photo/Valeria Ferraro)
Photo: ASSOCIATED PRESS/Valeria Ferraro
Some of nearly 500 migrants are seen waiting for medical checks on board a fishing boat in the southern Italian port of Crotone, early Saturday, March 11, 2023. The Italian coast guard was responding to three smugglers boats carrying more than 1,300 migrants “in danger” off Italy’s southern coast, officials said Friday. Three small coast guard boats were rescuing a boat with 500 migrants about 700 miles off the Calabria region, which forms the toe of the Italian boot. (AP Photo/Valeria Ferraro)
Police check a fishing boat with some 500 migrants in the southern Italian port of Crotone, early Saturday, March 11, 2023. The Italian coast guard was responding to three smugglers boats carrying more than 1,300 migrants “in danger” off Italy’s southern coast, officials said Friday. Three small coast guard boats were rescuing a boat with 500 migrants about 700 miles off the Calabria region, which forms the toe of the Italian boot. (AP Photo/Valeria Ferraro)
A beach in Cutro, a town south of Crotone, is where where survivors and bodies were found on Feb. 26 after a wooden boat, crowded with migrants who had set out from Turkey days earlier, broke apart on a sandbank.
The known death toll from the shipwreck climbed to 76 on Saturday after the bodies of two children and an adult were recovered, Italian news agency ANSA reported. Eighty passengers survived, but others were reported missing and are presumed dead.
Italian prosecutors are investigating whether authorities should have swiftly launched a rescue operation after a patrol plane operated by Frontex, the European Union’s border protection agency, spotted the wooden boat, hours before it broke apart dozens of meters (yards) from the beach.
Some 5,000 people, walking behind a bearer of a cross fashioned from the boat’s wreckage, joined a procession to the beach in Cutro on Saturday, demanding increased efforts to save migrants at sea.
Meanwhile, on tiny Lampedusa island, an Italian fishing and tourist location south of Sicily, some 3,000 newly arrived migrants overflowed from a shelter meant to hold less than 350. Hundreds of migrants spent the night sleeping on mattresses on the fenced-off grounds of the shelter.
Plans to ease some of the overcrowding on Lampedusa by transferring hundreds of migrants aboard a ferry were complicated by high winds whipping the island, making it impossible for the ship to dock on Saturday morning. Italian media reported that some 140 migrants were then transferred from the island by air.
Authorities on Lampedusa said many of the migrants arriving on the island, which is closer to northern Africa than to the Italian mainland, had sailed from the port of Sfax, in Tunisia, a route increasingly used by smugglers.
The U.N. migration agency estimates some 300 people have died or are missing and presumed dead along the perilous central Mediterranean route this year. | 2023-14/0000/en_head.json.gz/1350 | {"url": "https://www.kob.com/news/us-and-world-news/italys-coast-guard-navy-bring-hundreds-of-migrants-ashore/", "partition": "head_middle", "language": "en", "source_domain": "www.kob.com", "date_download": "2023-03-20T09:10:53Z", "digest": "sha1:NRDTEVFZ6LDKIDULNIMVMMLQP2NSJKMZ"} | {"ccnet_length": [[0, 5125, 5125.0]], "ccnet_original_length": [[0, 5125, 7045.0]], "ccnet_nlines": [[0, 5125, 20.0]], "ccnet_original_nlines": [[0, 5125, 69.0]], "ccnet_language_score": [[0, 5125, 0.96]], "ccnet_perplexity": [[0, 5125, 289.7]], "ccnet_bucket": [[0, 5125, 0.0]], "rps_doc_curly_bracket": [[0, 5125, 0.0]], "rps_doc_ldnoobw_words": [[0, 5125, 0.0]], "rps_doc_lorem_ipsum": [[0, 5125, 0.0]], "rps_doc_stop_word_fraction": [[0, 5125, 0.31813576]], "rps_doc_ut1_blacklist": [[0, 5125, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 5125, 0.34353335]], "rps_doc_frac_chars_dupe_5grams": [[0, 5125, 0.35787712]], "rps_doc_frac_chars_dupe_6grams": [[0, 5125, 0.34353335]], "rps_doc_frac_chars_dupe_7grams": [[0, 5125, 0.34353335]], "rps_doc_frac_chars_dupe_8grams": [[0, 5125, 0.34353335]], "rps_doc_frac_chars_dupe_9grams": [[0, 5125, 0.34353335]], "rps_doc_frac_chars_top_2gram": [[0, 5125, 0.0334688]], "rps_doc_frac_chars_top_3gram": [[0, 5125, 0.02032034]], "rps_doc_frac_chars_top_4gram": [[0, 5125, 0.01912503]], "rps_doc_frac_all_caps_words": [[0, 5125, 0.01823708]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 5125, 0.0]], "rps_doc_frac_no_alph_words": [[0, 5125, 0.18237082]], "rps_doc_frac_unique_words": [[0, 5125, 0.35558252]], "rps_doc_mean_word_length": [[0, 5125, 5.07645631]], "rps_doc_symbol_to_word_ratio": [[0, 5125, 0.0]], "rps_doc_unigram_entropy": [[0, 5125, 5.05114477]], "rps_doc_word_count": [[0, 5125, 824.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 61, 0.0], [61, 102, 0.0], [102, 599, 0.0], [599, 826, 1.0], [826, 971, 1.0], [971, 1166, 1.0], [1166, 1452, 1.0], [1452, 1732, 1.0], [1732, 2201, 0.0], [2201, 2241, 0.0], [2241, 2741, 0.0], [2741, 3204, 0.0], [3204, 3417, 1.0], [3417, 3664, 1.0], [3664, 3953, 1.0], [3953, 4151, 1.0], [4151, 4436, 1.0], [4436, 4747, 1.0], [4747, 4973, 1.0], [4973, 5125, 1.0]], "rps_lines_javascript_counts": [[0, 61, 0.0], [61, 102, 0.0], [102, 599, 0.0], [599, 826, 0.0], [826, 971, 0.0], [971, 1166, 0.0], [1166, 1452, 0.0], [1452, 1732, 0.0], [1732, 2201, 0.0], [2201, 2241, 0.0], [2241, 2741, 0.0], [2741, 3204, 0.0], [3204, 3417, 0.0], [3417, 3664, 0.0], [3664, 3953, 0.0], [3953, 4151, 0.0], [4151, 4436, 0.0], [4436, 4747, 0.0], [4747, 4973, 0.0], [4973, 5125, 0.0]], "rps_lines_num_words": [[0, 61, 9.0], [61, 102, 6.0], [102, 599, 77.0], [599, 826, 36.0], [826, 971, 24.0], [971, 1166, 32.0], [1166, 1452, 47.0], [1452, 1732, 44.0], [1732, 2201, 75.0], [2201, 2241, 4.0], [2241, 2741, 82.0], [2741, 3204, 75.0], [3204, 3417, 40.0], [3417, 3664, 40.0], [3664, 3953, 42.0], [3953, 4151, 33.0], [4151, 4436, 45.0], [4436, 4747, 51.0], [4747, 4973, 38.0], [4973, 5125, 24.0]], "rps_lines_numerical_chars_fraction": [[0, 61, 0.0], [61, 102, 0.0], [102, 599, 0.03950104], [599, 826, 0.0], [826, 971, 0.0], [971, 1166, 0.0], [1166, 1452, 0.04], [1452, 1732, 0.02941176], [1732, 2201, 0.04166667], [2201, 2241, 0.0], [2241, 2741, 0.03901437], [2741, 3204, 0.04222222], [3204, 3417, 0.00970874], [3417, 3664, 0.00826446], [3664, 3953, 0.0], [3953, 4151, 0.02083333], [4151, 4436, 0.02527076], [4436, 4747, 0.00977199], [4747, 4973, 0.0], [4973, 5125, 0.02013423]], "rps_lines_start_with_bulletpoint": [[0, 61, 0.0], [61, 102, 0.0], [102, 599, 0.0], [599, 826, 0.0], [826, 971, 0.0], [971, 1166, 0.0], [1166, 1452, 0.0], [1452, 1732, 0.0], [1732, 2201, 0.0], [2201, 2241, 0.0], [2241, 2741, 0.0], [2741, 3204, 0.0], [3204, 3417, 0.0], [3417, 3664, 0.0], [3664, 3953, 0.0], [3953, 4151, 0.0], [4151, 4436, 0.0], [4436, 4747, 0.0], [4747, 4973, 0.0], [4973, 5125, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 61, 0.01639344], [61, 102, 0.43902439], [102, 599, 0.06841046], [599, 826, 0.04405286], [826, 971, 0.0137931], [971, 1166, 0.02564103], [1166, 1452, 0.01748252], [1452, 1732, 0.02857143], [1732, 2201, 0.03624733], [2201, 2241, 0.45], [2241, 2741, 0.034], [2741, 3204, 0.03671706], [3204, 3417, 0.02347418], [3417, 3664, 0.03238866], [3664, 3953, 0.01384083], [3953, 4151, 0.01515152], [4151, 4436, 0.01754386], [4436, 4747, 0.01286174], [4747, 4973, 0.02654867], [4973, 5125, 0.02631579]], "rps_doc_ml_palm_score": [[0, 5125, 0.97133058]], "rps_doc_ml_wikipedia_score": [[0, 5125, null]], "rps_doc_ml_wikiref_score": [[0, 5125, 0.99148357]], "rps_doc_books_importance": [[0, 5125, -236.33392661]], "rps_doc_openwebtext_importance": [[0, 5125, 62.2191479]], "rps_doc_wikipedia_importance": [[0, 5125, 61.81192895]], "rps_doc_num_sentences": [[0, 5125, 32.0]]} |
The Knights Remember St. John Paul II
On the 15th anniversary of the Holy Father’s death, the Knights chronicle the relationship between the Order and St. John Paul II
By Andrew Fowler 4/1/2020
Following the death of St. John Paul II on April 2, 2005, Supreme Knight Carl Anderson wrote in Columbia that “Few popes in the 2000-year history of the Catholic Church have had so momentous an impact on the Church and the world at large as the man we can now properly call John Paul the Great. The 1.7 million members of the Knights of Columbus, who have had the privilege of supporting him in so many ways over the past 27 years, mourn his passing even as we recall the contribution of this extraordinary and holy man.”
The Knights of Columbus has developed close-working relationships with pontiffs dating back to 1920, but the relationship with St. John Paul II was different. It started when he was first installed. The Order covered the costs of the telecast of the installation of Pope John Paul II in October 1978, and would continue funding the broadcast of other pastoral events throughout his papacy.
One of significance came during the pontiff’s historical trip to Communist-controlled Poland. Communist leaders unsuccessfully tried to prevent St. John Paul II's visit to Poland, in part because of the Knights of Columbus. The Knights helped fund a documentary, that was smuggled into the country, to inspire the Polish people and prepare them for the Holy Father's visit. When St. John Paul II visited his homeland, an estimated 13 million people attended one of his public events and inspired the Polish people's love of freedom that eventually led to the fall of the Iron Curtain.
The Knights would later on support three films about St. John Paul II: John Paul II in America: Uniting a Continent, Liberating a Continent: John Paul II and the Fall of Communism and John Paul II in Ireland: A Plea for Peace.
The Knights not only had a part in the Holy Father’s telecommunication efforts, but also in the physical structure of the Holy See. The Order led a restoration project of St. Peter’s Basilica and funded a Polish chapel in the Vatican Grottoes. As a gift of appreciation, John Paul II presented to the Knights a copper cross once displayed as part of the statue of Christ on the roof of St. Peter’s.
The relationship didn’t stop there. St. John Paul II canonized six Knights — Mexican martyrs killed during the Cristero War in the 1920s — and he also beatified Carlos Manuel Rodriguez, a member of the Knights of Columbus in Puerto Rico. Meanwhile, the Knights supported World Youth Day, an initiative of John Paul II, including the largest English-language site in Kraków in 2016.
The Knights recognized the importance of St. John Paul II’s message, and St. John Paul II recognized the vital charitable outreach of the Knights as he noted in numerous papal letters. He praised the Knights, stating that they are an “outstanding example of Christian commitment” and commended the Order for upholding and promoting “Catholic teaching, above all in the area of the family and the defense of life.”
But even after the Holy Father’s death, the Knights of Columbus are carrying on his legacy. The Order sponsors the Pontifical John Paul II Institute for Studies on Marriage and Family in Washington, D.C., and the Pontifical School of Theology in Kraków. They also support the Saint John Paul II National Shrine in Washington, D.C. as well, which chronicles the life of the Holy Father along with housing some of his relics.
One of the items in the exhibit includes a handwritten letter from St. John Paul II to the Knights of Columbus that reads, “As long as I have breath within me I shall cry out: Peace, in the name of God.”
During his canonization in 2014, the Knights were there, lending financial support to Vatican television’s broadcast of the canonization ceremony, and hosting numerous pilgrims at K of C facilities.
As Supreme Knight Anderson said in a vigil for St. John Paul II, “The legacy of his personal life of holiness, his incredible public ministry, and his profound teaching about the faith, continue to resonate not only with the John Paul II generation – of bishops, priests, religious and laity – but also with so many others who were moved by his witness and teaching, especially in the area of human love.”
The full-extent of the relationship between the Knights of Columbus and St. John Paul II is explored in the new book The Knights of Columbus: An Illustrated History.
Share your story of how your council is helping strengthen people’s faith and offering support during this time. Email [email protected]. | 2023-14/0000/en_head.json.gz/1351 | {"url": "https://www.kofc.org/en/news-room/articles/knights-remember-st-john-paul-ii.html", "partition": "head_middle", "language": "en", "source_domain": "www.kofc.org", "date_download": "2023-03-20T09:58:07Z", "digest": "sha1:U7YYFCPR33AFF36JOPF75PXO2S55W6HY"} | {"ccnet_length": [[0, 4651, 4651.0]], "ccnet_original_length": [[0, 4651, 6647.0]], "ccnet_nlines": [[0, 4651, 16.0]], "ccnet_original_nlines": [[0, 4651, 79.0]], "ccnet_language_score": [[0, 4651, 0.96]], "ccnet_perplexity": [[0, 4651, 128.3]], "ccnet_bucket": [[0, 4651, 0.0]], "rps_doc_curly_bracket": [[0, 4651, 0.0]], "rps_doc_ldnoobw_words": [[0, 4651, 0.0]], "rps_doc_lorem_ipsum": [[0, 4651, 0.0]], "rps_doc_stop_word_fraction": [[0, 4651, 0.36247335]], "rps_doc_ut1_blacklist": [[0, 4651, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4651, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 4651, 0.0529819]], "rps_doc_frac_chars_dupe_6grams": [[0, 4651, 0.01597444]], "rps_doc_frac_chars_dupe_7grams": [[0, 4651, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 4651, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 4651, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 4651, 0.04898829]], "rps_doc_frac_chars_top_3gram": [[0, 4651, 0.05324814]], "rps_doc_frac_chars_top_4gram": [[0, 4651, 0.03514377]], "rps_doc_frac_all_caps_words": [[0, 4651, 0.03304904]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4651, 0.0]], "rps_doc_frac_no_alph_words": [[0, 4651, 0.14498934]], "rps_doc_frac_unique_words": [[0, 4651, 0.44779874]], "rps_doc_mean_word_length": [[0, 4651, 4.7245283]], "rps_doc_symbol_to_word_ratio": [[0, 4651, 0.0]], "rps_doc_unigram_entropy": [[0, 4651, 5.00391394]], "rps_doc_word_count": [[0, 4651, 795.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 38, 0.0], [38, 168, 0.0], [168, 194, 0.0], [194, 716, 1.0], [716, 1106, 1.0], [1106, 1691, 1.0], [1691, 1918, 1.0], [1918, 2317, 1.0], [2317, 2699, 1.0], [2699, 3113, 1.0], [3113, 3537, 1.0], [3537, 3741, 1.0], [3741, 3940, 1.0], [3940, 4346, 1.0], [4346, 4512, 1.0], [4512, 4651, 1.0]], "rps_lines_javascript_counts": [[0, 38, 0.0], [38, 168, 0.0], [168, 194, 0.0], [194, 716, 0.0], [716, 1106, 0.0], [1106, 1691, 0.0], [1691, 1918, 0.0], [1918, 2317, 0.0], [2317, 2699, 0.0], [2699, 3113, 0.0], [3113, 3537, 0.0], [3537, 3741, 0.0], [3741, 3940, 0.0], [3940, 4346, 0.0], [4346, 4512, 0.0], [4512, 4651, 0.0]], "rps_lines_num_words": [[0, 38, 7.0], [38, 168, 22.0], [168, 194, 4.0], [194, 716, 97.0], [716, 1106, 63.0], [1106, 1691, 95.0], [1691, 1918, 42.0], [1918, 2317, 72.0], [2317, 2699, 63.0], [2699, 3113, 68.0], [3113, 3537, 72.0], [3537, 3741, 41.0], [3741, 3940, 29.0], [3940, 4346, 72.0], [4346, 4512, 28.0], [4512, 4651, 20.0]], "rps_lines_numerical_chars_fraction": [[0, 38, 0.0], [38, 168, 0.01574803], [168, 194, 0.26086957], [194, 716, 0.02539062], [716, 1106, 0.02094241], [1106, 1691, 0.00350877], [1691, 1918, 0.0], [1918, 2317, 0.0], [2317, 2699, 0.02144772], [2699, 3113, 0.0], [3113, 3537, 0.0], [3537, 3741, 0.0], [3741, 3940, 0.02061856], [3940, 4346, 0.0], [4346, 4512, 0.0], [4512, 4651, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 38, 0.0], [38, 168, 0.0], [168, 194, 0.0], [194, 716, 0.0], [716, 1106, 0.0], [1106, 1691, 0.0], [1691, 1918, 0.0], [1918, 2317, 0.0], [2317, 2699, 0.0], [2699, 3113, 0.0], [3113, 3537, 0.0], [3537, 3741, 0.0], [3741, 3940, 0.0], [3940, 4346, 0.0], [4346, 4512, 0.0], [4512, 4651, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 38, 0.21052632], [38, 168, 0.07692308], [168, 194, 0.11538462], [194, 716, 0.04214559], [716, 1106, 0.04358974], [1106, 1691, 0.04444444], [1691, 1918, 0.13215859], [1918, 2317, 0.05764411], [2317, 2699, 0.07329843], [2699, 3113, 0.04347826], [3113, 3537, 0.08490566], [3537, 3741, 0.06372549], [3741, 3940, 0.02512563], [3940, 4346, 0.03448276], [4346, 4512, 0.08433735], [4512, 4651, 0.01438849]], "rps_doc_ml_palm_score": [[0, 4651, 0.74561566]], "rps_doc_ml_wikipedia_score": [[0, 4651, null]], "rps_doc_ml_wikiref_score": [[0, 4651, 0.77072984]], "rps_doc_books_importance": [[0, 4651, -101.61903318]], "rps_doc_openwebtext_importance": [[0, 4651, 93.50052711]], "rps_doc_wikipedia_importance": [[0, 4651, 144.80249807]], "rps_doc_num_sentences": [[0, 4651, 48.0]]} |
(1/4) When I was nine, my dad was diagnosed with an oncological disorder. He was given six months to live, but he actually ended up living until I was nineteen. I spent a majority of my childhood in and out of hospitals while he was sick, and because of that, I was able to see the significance of medical research in a way that many people probably don’t. I also watched how the nurses and doctors cared for him- and not just him, but my entire family. It made a huge impression on me. There wasn’t any doubt in my mind that I was going into oncology.
(2/4) Being a mother has made me a better doctor. I’m always thinking about what I would want, if it were my child who was sick. And that, to me, goes beyond the “clinical” treatment. These parents want honesty. We owe them that. Sometimes, we don’t have answers. And if I don’t have the answer, then I tell them that. But I also promise them that I won’t stop working until I find it, because that’s exactly what I would want someone to do for my boys.
(3/4) I was pregnant with my first child while I was doing my residency, and the attending physicians had warned me that I would never be able to view patients in the same way after he came. And boy, they were right. When I came back from my maternity leave, I walked into a room to treat one of my first patients- a baby with infantile leukemia, who was about the same age as my son. I had to go and put myself in time-out because I knew I wasn’t going to be able to hold myself together while I was in the room.
(4/4) When you turn on the news, you see so much of the bad stuff. But doing what I do gives me the chance to see so much good in people. These families are going through an unimaginable hell. And yet, I get texts from them thanking me. I have pictures hanging up all over my office that these kids have made for me. And it’s so humbling because they’re the ones in the trenches. In my mind, they’re doing the heavy lifting. I’ve watched some of these parents leave their own child’s bedside to go and be with the family of another child as they say goodbye to them. There is so much goodness, even in the midst of incredible heartache. | 2023-14/0000/en_head.json.gz/1352 | {"url": "https://www.kristinseward.com/christina-wiedl", "partition": "head_middle", "language": "en", "source_domain": "www.kristinseward.com", "date_download": "2023-03-20T09:58:36Z", "digest": "sha1:XCFJCUTTIK56AM22QEHBLWT5AMARM2NI"} | {"ccnet_length": [[0, 2157, 2157.0]], "ccnet_original_length": [[0, 2157, 2616.0]], "ccnet_nlines": [[0, 2157, 4.0]], "ccnet_original_nlines": [[0, 2157, 30.0]], "ccnet_language_score": [[0, 2157, 0.99]], "ccnet_perplexity": [[0, 2157, 197.5]], "ccnet_bucket": [[0, 2157, 0.0]], "rps_doc_curly_bracket": [[0, 2157, 0.0]], "rps_doc_ldnoobw_words": [[0, 2157, 0.0]], "rps_doc_lorem_ipsum": [[0, 2157, 0.0]], "rps_doc_stop_word_fraction": [[0, 2157, 0.52140078]], "rps_doc_ut1_blacklist": [[0, 2157, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2157, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2157, 0.01669648]], "rps_doc_frac_chars_top_3gram": [[0, 2157, 0.01192606]], "rps_doc_frac_chars_top_4gram": [[0, 2157, 0.01669648]], "rps_doc_frac_all_caps_words": [[0, 2157, 0.05252918]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2157, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2157, 0.16342412]], "rps_doc_frac_unique_words": [[0, 2157, 0.49047619]], "rps_doc_mean_word_length": [[0, 2157, 3.99285714]], "rps_doc_symbol_to_word_ratio": [[0, 2157, 0.0]], "rps_doc_unigram_entropy": [[0, 2157, 4.88083483]], "rps_doc_word_count": [[0, 2157, 420.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 553, 1.0], [553, 1007, 1.0], [1007, 1521, 1.0], [1521, 2157, 1.0]], "rps_lines_javascript_counts": [[0, 553, 0.0], [553, 1007, 0.0], [1007, 1521, 0.0], [1521, 2157, 0.0]], "rps_lines_num_words": [[0, 553, 107.0], [553, 1007, 87.0], [1007, 1521, 104.0], [1521, 2157, 122.0]], "rps_lines_numerical_chars_fraction": [[0, 553, 0.00372439], [553, 1007, 0.00458716], [1007, 1521, 0.004], [1521, 2157, 0.00322581]], "rps_lines_start_with_bulletpoint": [[0, 553, 0.0], [553, 1007, 0.0], [1007, 1521, 0.0], [1521, 2157, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 553, 0.01808318], [553, 1007, 0.03303965], [1007, 1521, 0.02140078], [1521, 2157, 0.0172956]], "rps_doc_ml_palm_score": [[0, 2157, 0.90495175]], "rps_doc_ml_wikipedia_score": [[0, 2157, null]], "rps_doc_ml_wikiref_score": [[0, 2157, 0.03893256]], "rps_doc_books_importance": [[0, 2157, -25.91985647]], "rps_doc_openwebtext_importance": [[0, 2157, 57.49823453]], "rps_doc_wikipedia_importance": [[0, 2157, -325.53711072]], "rps_doc_num_sentences": [[0, 2157, 27.0]]} |
White House initiative aims to help Asian Americans achieve equity
Asian American, Native Hawaiian and Pacific Islanders own about 10% of all the small businesses in the U.S. but only receive 2.8% of federal contracting dollars.
Author: ksdk.com
Published: 5:26 AM CST January 26, 2023
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Letters: Music for Dogs
By Scott Simon
Published March 18, 2005 at 10:00 PM MST
Scott Simon reads from the mailbag, and amends a recent story that indicated the late Stephen Jay Gould was a Boston Red Sox fan. The native New Yorker was a Yankee rooter. Most of the letters focused on a March 12 story about a CD of music for dogs.
Scott Simon is one of America's most admired writers and broadcasters. He is the host of Weekend Edition Saturday and is one of the hosts of NPR's morning news podcast Up First. He has reported from all fifty states, five continents, and ten wars, from El Salvador to Sarajevo to Afghanistan and Iraq. His books have chronicled character and characters, in war and peace, sports and art, tragedy and comedy.
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Veterans of '60s Voter-Registration Drive Reflect
By Nick Miroff
Published August 5, 2005 at 10:00 PM MDT
It's been 40 years since the US Congress passed the Voting Rights Act of 1965, making good on a section of the US Constitution that had long been denied to far too many people. The 15th Amendment had guaranteed black Americans the right to vote when it was ratified in 1870, but many counties throughout the South had imposed poll taxes, literacy tests, pop quizzes and other contrivances to deprive blacks of that right. Such discouragement was often backed up by intimidation, threats and violence.
But young civil rights workers, black and white, helped bring about a revolution of faith in the idea that all Americans could and should vote. In the summer of 1965, Bruce Miroff joined hundreds of white northern college students in a voter registration campaign called SCOPE. He and other volunteers went to James Island, South Carolina, 40 years ago this summer and returned this year. Reporter Nick Miroff sends us some recollections from that group, starting with his father's.
(Soundbite of voices)
Mr. BRUCE MIROFF (Former SCOPE Civil Rights Worker): When we first came to James Island and were going door-to-door, I remember a small child knocked on the door, saying, `Mom, it's the insurance man,' because the only white people they ever saw were insurance men collecting premiums. By the last week, we were working--we were so familiar to the community that a child answered the door and yelled back to his mother, `Mom, it's the voting man.'
Unidentified Man #1: That would be extolling...
Unidentified Woman: Yeah, maybe 20 people...
Ms. MARION C. BENNETT(ph) (Former SCOPE Civil Rights Worker): My name is Marion C. Bennett.
Unidentified Man #2: No, no, no. No, they were saying that.
Unidentified Woman: Maybe you could just get us a...
Ms. BENNETT: In the summer of 1965, I was in between my junior year and senior year at Harvard.
Ms. BENNETT: The summer of '65 was a year after Philadelphia, Mississippi, with the murder of Chaney, Goodwin and Schwerner. We all knew the stories of people who got arrested in the South. You got arrested, you might never again be heard of. If you were a woman, you could be raped. People were taken from jails and killed. So I didn't want to be a part of any of that. I was willing to work on the movement, but I very much valued my life. I wanted to live.
Unidentified Man #3: What provision is that?
Unidentified Woman #2: What kind of person is Lefty?
Mr. MIROFF: We asked people to go into Charleston to register. You could only go in to register the first Monday, Tuesday and Wednesday of each month. And I and my fellow volunteers had come out of an idealistic sense to take part in the struggle, but the people who lived here had a far deeper and more fundamental struggle.
Unidentified Man #4: ...of anybody here. I'll report to...
Mr. ISAAC WILLIAMS (Former SCOPE Civil Rights Worker; Aide to Congressman James E. Clyburn): My name is Isaac Williams. I'm a district aide to Congressman James E. Clyburn, South Carolina Sixth Congressional District. You know, the question of race and racial equality is one that's always going to be on the plate. The problem is whether we're going to continue to be committed to the same truths that we were committed to as young college students. And some of them, because they have a different ethnicity, can move in and out of the struggle at will. If you're white, you can put on your Brooks Brothers suit, cut your hair, shave your mustache, and you can move on Wall Street and life goes on as normal. But if you're black and you're Southern and you're underprivileged and you have been denied your rights, it's a daily battle, and you've got to be committed beyond just one event.
Unidentified Man #5: We all have a plan.
Mr. MIROFF: I do miss the connection to the black community. It was something I only had briefly. And I think it's very hard for most whites, even those most sympathetic to the cause of racial justice, to have completely transparent and comfortable relations. Race is so powerful in America. It's everywhere. It's a subtext of almost every encounter between whites and blacks. And I think it was only in that brief period for me as a civil rights worker where blacks were your colleagues and your supporters and the people you admired, and in the South, whites often were a source of danger. It was only when I felt safe in the black community and unsafe in the white community that I ever felt the kind of comfort level that I think Americans ought to hope some day they have between the races.
NICK MIROFF reporting:
And you never experienced that again?
Mr. MIROFF: Not really. I mean, I've had a few black friends over the years, but that sense of being in touch with a community as opposed to a few scattered individuals is something I've never experienced again.
SIMON: The voices of former civil rights workers at a 40-year reunion in South Carolina where they registered black voters in the summer of 1965. Transcript provided by NPR, Copyright NPR.
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New baseball rule hopes to reverse decades of fan loss
Enrique Rivera
Published July 22, 2022 at 2:32 PM MDT
Baseball has been losing fans for decades. Fewer people have been filling the stands at the old ballgame since even before the pandemic. And last year's World Series viewership was only about a quarter of what it was in 1978. But Major League Baseball, the MLB, is working to turn those trends around. They're experimenting with new rules to bring back a little more excitement to the game, like the pie-slice rule being rolled out in the minor leagues today. Joining us to explain how it works is LA Times baseball reporter Bill Shaikin. Welcome to ALL THINGS CONSIDERED.
BILL SHAIKIN: Great to be here.
SHAPIRO: It seems like the only thing more American than baseball is a slice of pie. So how does the pie-slice rule actually work?
SHAIKIN: Well, to step back just a little bit, we mentioned that the audience has dropped off for baseball, both in person and on television. And one of the working theories in Major League Baseball offices about that is that there's less action to the game. The game right now is a bunch of guys trying to hit home runs. And if they do, the ball goes over the fence, and a guy takes a slow jog around the bases. If they don't, they swing and miss, which is what happens more often than not, nothing happens either.
So how do we get more action? In the time when people were attending more games and watching more games, balls were put in the field of play. Guys stole bases. How do we get back to that? So the pie-slice rule is one example of how they're trying to consider ways to do that.
SHAPIRO: And it's basically carving out a wedge of the field where infielders are not allowed to stand until the pitch is thrown. Is that it?
SHAIKIN: Yeah. The idea is if you get more singles and not so many home runs and maybe you get more stolen bases, there's, again, more action that people like to see. So in the '70s and '80s, for example, there were pretty much defined positions. In other words, you're the second baseman. This is where the second baseman stands. What we know from statistical study now is if we can figure out where the guy is more likely to hit the ball, let's just move the second baseman right there. And what's happened is a lot more outs. So maybe baseball is going to turn the pendulum back and say, you know what? Even if a guy is more likely to hit the ball in the pie-slice area, you can't stand there.
SHAPIRO: So the pie slice is the section of the field where the ball is most likely to go. And now the league is saying you can't stand there, so we're less likely to catch the pop fly and more likely to get base hits. Is that right?
SHAIKIN: Yeah. And not even so much the pop fly, but, like, anybody who's played Little League is probably heard a coach say, hey; just try to hit it right back up the middle, right? The ball comes to you, hit it right back the same way. And if you do that, that should be a base hit. But now, if you do that too much, somebody will know that and be standing right there. So what baseball is saying now is let's consider a rule that says, no, no, you can't stand there.
SHAPIRO: The minor leagues are also testing out some other innovations - larger bases, pitch clocks, robo umpires. I mean, what's the bigger strategy here?
SHAIKIN: It's, again, just to try to get more action into the game. There's been a lot of evolution of the game, some of it analytically based. And while it's turned into a very good way to build a winning team, it's not necessarily the best way to build an audience. So for example, with a pitch clock, how long should it take you to catch the ball and make your next pitch? And if it's taking too long, let's put a clock on it. And where this has been tried in the minor leagues, they've been able to cut the time of game down by half hour. So you can get home a half hour earlier.
SHAPIRO: Do you think these innovations are likely to make their way to the major leagues?
SHAIKIN: There is a committee meeting right now - players are on the committee, owners are on the committee, representatives from the umpires are on the committee - to try to figure out which one should be adopted for next year. I would be shocked if the pitch clock wasn't one of them.
SHAPIRO: That's LA Times baseball reporter Bill Shaikin. Thanks a lot.
SHAIKIN: All right. Take care now. Transcript provided by NPR, Copyright NPR. | 2023-14/0000/en_head.json.gz/1356 | {"url": "https://www.ksut.org/2022-07-22/new-baseball-rule-hopes-to-reverse-decades-of-fan-loss", "partition": "head_middle", "language": "en", "source_domain": "www.ksut.org", "date_download": "2023-03-20T09:27:26Z", "digest": "sha1:7GRYYBYAGUHUEKLIIBF6ERWICCXZQWFB"} | {"ccnet_length": [[0, 4446, 4446.0]], "ccnet_original_length": [[0, 4446, 9695.0]], "ccnet_nlines": [[0, 4446, 18.0]], "ccnet_original_nlines": [[0, 4446, 289.0]], "ccnet_language_score": [[0, 4446, 0.97]], "ccnet_perplexity": [[0, 4446, 260.6]], "ccnet_bucket": [[0, 4446, 0.0]], "rps_doc_curly_bracket": [[0, 4446, 0.0]], "rps_doc_ldnoobw_words": [[0, 4446, 0.0]], "rps_doc_lorem_ipsum": [[0, 4446, 0.0]], "rps_doc_stop_word_fraction": [[0, 4446, 0.49853085]], "rps_doc_ut1_blacklist": [[0, 4446, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4446, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 4446, 0.0492183]], "rps_doc_frac_chars_dupe_6grams": [[0, 4446, 0.03532137]], "rps_doc_frac_chars_dupe_7grams": [[0, 4446, 0.01563405]], "rps_doc_frac_chars_dupe_8grams": [[0, 4446, 0.01563405]], "rps_doc_frac_chars_dupe_9grams": [[0, 4446, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 4446, 0.00868558]], "rps_doc_frac_chars_top_3gram": [[0, 4446, 0.01302837]], "rps_doc_frac_chars_top_4gram": [[0, 4446, 0.01476549]], "rps_doc_frac_all_caps_words": [[0, 4446, 0.02546523]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4446, 0.0]], "rps_doc_frac_no_alph_words": [[0, 4446, 0.15768854]], "rps_doc_frac_unique_words": [[0, 4446, 0.37889688]], "rps_doc_mean_word_length": [[0, 4446, 4.14148681]], "rps_doc_symbol_to_word_ratio": [[0, 4446, 0.0]], "rps_doc_unigram_entropy": [[0, 4446, 5.16187436]], "rps_doc_word_count": [[0, 4446, 834.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 55, 0.0], [55, 70, 0.0], [70, 109, 0.0], [109, 682, 1.0], [682, 714, 1.0], [714, 845, 1.0], [845, 1361, 1.0], [1361, 1637, 1.0], [1637, 1779, 1.0], [1779, 2476, 1.0], [2476, 2710, 1.0], [2710, 3180, 1.0], [3180, 3336, 1.0], [3336, 3920, 1.0], [3920, 4011, 1.0], [4011, 4298, 1.0], [4298, 4369, 1.0], [4369, 4446, 1.0]], "rps_lines_javascript_counts": [[0, 55, 0.0], [55, 70, 0.0], [70, 109, 0.0], [109, 682, 0.0], [682, 714, 0.0], [714, 845, 0.0], [845, 1361, 0.0], [1361, 1637, 0.0], [1637, 1779, 0.0], [1779, 2476, 0.0], [2476, 2710, 0.0], [2710, 3180, 0.0], [3180, 3336, 0.0], [3336, 3920, 0.0], [3920, 4011, 0.0], [4011, 4298, 0.0], [4298, 4369, 0.0], [4369, 4446, 0.0]], "rps_lines_num_words": [[0, 55, 10.0], [55, 70, 2.0], [70, 109, 8.0], [109, 682, 99.0], [682, 714, 6.0], [714, 845, 24.0], [845, 1361, 98.0], [1361, 1637, 55.0], [1637, 1779, 26.0], [1779, 2476, 133.0], [2476, 2710, 48.0], [2710, 3180, 94.0], [3180, 3336, 24.0], [3336, 3920, 117.0], [3920, 4011, 16.0], [4011, 4298, 51.0], [4298, 4369, 11.0], [4369, 4446, 12.0]], "rps_lines_numerical_chars_fraction": [[0, 55, 0.0], [55, 70, 0.0], [70, 109, 0.25], [109, 682, 0.00715564], [682, 714, 0.0], [714, 845, 0.0], [845, 1361, 0.0], [1361, 1637, 0.0], [1637, 1779, 0.0], [1779, 2476, 0.00597907], [2476, 2710, 0.0], [2710, 3180, 0.0], [3180, 3336, 0.0], [3336, 3920, 0.0], [3920, 4011, 0.0], [4011, 4298, 0.0], [4298, 4369, 0.0], [4369, 4446, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 55, 0.0], [55, 70, 0.0], [70, 109, 0.0], [109, 682, 0.0], [682, 714, 0.0], [714, 845, 0.0], [845, 1361, 0.0], [1361, 1637, 0.0], [1637, 1779, 0.0], [1779, 2476, 0.0], [2476, 2710, 0.0], [2710, 3180, 0.0], [3180, 3336, 0.0], [3336, 3920, 0.0], [3920, 4011, 0.0], [4011, 4298, 0.0], [4298, 4369, 0.0], [4369, 4446, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 55, 0.01818182], [55, 70, 0.13333333], [70, 109, 0.17948718], [109, 682, 0.06806283], [682, 714, 0.375], [714, 845, 0.07633588], [845, 1361, 0.02906977], [1361, 1637, 0.01811594], [1637, 1779, 0.06338028], [1779, 2476, 0.02295552], [2476, 2710, 0.04273504], [2710, 3180, 0.03191489], [3180, 3336, 0.05769231], [3336, 3920, 0.0239726], [3920, 4011, 0.08791209], [4011, 4298, 0.03135889], [4298, 4369, 0.1971831], [4369, 4446, 0.22077922]], "rps_doc_ml_palm_score": [[0, 4446, 0.58035517]], "rps_doc_ml_wikipedia_score": [[0, 4446, null]], "rps_doc_ml_wikiref_score": [[0, 4446, 0.37721539]], "rps_doc_books_importance": [[0, 4446, -86.51333525]], "rps_doc_openwebtext_importance": [[0, 4446, 90.63797573]], "rps_doc_wikipedia_importance": [[0, 4446, -369.22876067]], "rps_doc_num_sentences": [[0, 4446, 57.0]]} |
Here's every word from the 9th Jan. 6 committee hearing on its investigation
Published October 13, 2022 at 4:28 PM MDT
Alex Wong/Getty Images
The House Select Committee to Investigate the January 6th Attack on the U.S. Capitol votes to subpoena former President Donald Trump, in the Cannon House Office Building on October 13, 2022 in Washington, DC.
Below, read the full transcript from the Oct. 13 hearing of the House select committee investigating the Jan. 6 Capitol attack. The transcript was produced by CQ.
BENNIE THOMPSON: The Select Committee to investigate the January 6th attack on the United States Capitol will be in order. Without objection, the chair is authorized to declare the committee in recess at any point. Pursuant to House Deposition Authority Regulation 10, the chair announces the committee's approval to release the deposition material presented during today's hearing.
Good afternoon, and may God bless the United States of America. Four months ago, this committee started to present our findings to you, the American people. From the beginning, we understood that some people watching those proceedings would wrongly assume that the committee's investigation was a partisan exercise.
The Select Committee to investigate the January 6th attack on the United States Capitol will be in order. Without objection, the chair is authorized to declare the committee in recess at any point. Pursuant to House Deposition Authority Regulation 10, the chair announces the committee's approval to release the deposition material presented during today's hearing.
That's why I asked those who were skeptical of our work to — simply to listen, to listen to the evidence, to hear the testimony with an open mind, and to let the facts speak for themselves before reaching any judgment. Over the course of these hearings, the evidence has proven that there were a multipart plan led by former President Donald Trump to overturn the 2020 election.
Donald Trump lost his bid for reelection. As shown from the testimony of some of the president's closest allies and advisers, Donald Trump knew he lost. Despite this knowledge, Donald Trump went to court to contest the 2020 election, and he lost in court. The Electoral College met and declared Joe Biden the winner, yet Donald Trump continued to pull out all the stops in his attempt to stay in power.
What Donald Trump proceeded to do after the 2020 election is something no president has done before in our country. In a staggering betrayal of his oath, Donald Trump attempted a plan that led to an attack on a pillar of our democracy. It's still hard to believe, but the facts and testimony are clear, consistent, and undisputed.
How do we know this? How have we been able to present such a clear picture of what took place? Because of the testimony we've heard and that we have presented to you through these proceedings, because of the documentary evidence we've gathered and also made available directly to you, the American people.
When you look back at what has come out through this committee's work, the most striking fact is that all this evidence come almost entirely from Republicans. The evidence that has emerged did not come from Democrats or opponents of Donald Trump. Instead, look at who's written and testified and produced evidence.
Who has that been? Aides who've worked loyally for Donald Trump for years, Republican state officials and legislators, Republican electors, the chairwoman of the Republican National Committee, political professionals who worked at the highest levels of the Trump campaign, Trump appointees who served in the most senior positions in the Justice Department, President Trump's staff and closest advisers in the White House, members of the — President Trump's family, his own White House counsel.
I've served in Congress a long time. I can tell you it's tough for any Congressional investigation to obtain evidence like what we received, least of all such a detailed view into a president's inner circle. And I want to be clear. Not all these witnesses were thrilled to talk to us. Some up — put up quite a fight.
But ultimately, the vast majority cooperated with our investigation, and what we've shown you over the last four months has been centered on the evidence, evidence that has come overwhelmingly from Republican witnesses. So, I say to you again as I did in June, this investigation is not about politics. It's not about party.
It's about the facts, plain and simple. And it's about making sure our government functions under the rule of law as our Constitution demands. Today as in previous proceedings, my colleagues and I will present new evidence. That includes new testimony from additional Republicans who served in the Trump administration, never before seen footage of Congressional leaders on January 6th working to coordinate the response to the violence and ensure the people's business went forward, new materials produced to the committee by the Secret Service, details about the ongoing threat to American democracy.
Today's proceeding will also be grounded in the facts, but it won't look exactly like all our other hearings. We'll also take a step back and look at the evidence in a broader context, providing a summary of key facts we've uncovered, facts relevant to former President Trump's state of mind, about his motivation, and about his intent.
What did President Trump know? What was he told? What was his personal and substantial role in the multipart plan to overturn the election? For those of you who've watched our prior hearings, some of this evidence will look familiar. For those of you tuning in for the first time, we'll summarize some of the most important facts, and we urge you to go online and watch our hearing in full.
There's one more difference about today. Pursuant to the notice circulated prior to today's proceedings, we are convened today not as a hearing but as a formal committee business meeting so that, in addition to presenting evidence, we can potentially hold a committee vote on further investigative action based upon that evidence.
Before we get to that evidence, I'd recognize our distinguished Vice Chair, Ms. Cheney of Wyoming, for any opening statement she'd care to offer.
LIZ CHENEY:
Thank you very much, Mr. Chairman. Much has happened since our last public hearing on July 21st. As the chairman mentioned, we've received new and voluminous documentation from the Secret Service, which we continue to analyze. We've received new witness testimony, including about efforts to obstruct our investigation and conceal key facts.
And according to public reporting, the Department of Justice has been very active in pursuing many of the issues identified in our prior hearings. Our committee may ultimately decide to make a series of criminal referrals to the Department of Justice, but we recognize that our role is not to make decisions regarding prosecution.
The preamble to our Constitution recites among its purposes, to "establish justice." And our nation's judiciary and our US Department of Justice have that responsibility. A key element of this committee's responsibility is to propose reforms to prevent January 6th from ever happening again. We've already proposed and the House has now passed a bill to amend the Electoral Count Act to help ensure that no other future plots to overturn an election can succeed.
And we will make further specific recommendations in our final report based in part on the evidence you will hear today. Our hearings last summer began with an outline of President Trump's multipart plan to overturn the 2020 Presidential election. We then proceeded to demonstrate each of these elements in detail, with more than 20 hours of evidence.
Today we will see new evidence but, as the chairman said, we will also synthesize evidence you've seen before. The vast weight of evidence presented so far has shown us that the central cause of January 6th was one man, Donald Trump, who many others followed. None of this would have happened without him.
He was personally and substantially involved in all of it. Exactly how did one man cause all of this? Today we will focus on President Trump's state of mind, his intent, his motivations, and how he spurred others to do his bidding, and how another January 6th could happen again if we do not take necessary action to prevent it. As you view our evidence today, I would suggest a focus on the following points.
First, as you will see, President Trump had a premeditated plan to declare that the election was fraudulent and stolen before Election Day, before he knew the election results. He made his stolen election claims on election night against the advice of his campaign without any evidence in hand. Then, over the next two months, he sought to find those who would help him invent and spread lies about the widespread fraud.
Many of those who stepped forward to help, including Rudy Giuliani, knew they never had real evidence sufficient to change the election results. And on the evening of January 5th, they admitted they were still trying to find that phantom evidence. Of course, as a result of making intentionally false claims of election fraud, Mr. Giuliani's license to practice law has now been suspended.
Second, please recognize that President Donald Trump was in a unique position, better informed about the absence of widespread election fraud than almost any other American. President Trump's own campaign experts told him that there was no evidence to support his claims. His own Justice Department appointees investigated the election fraud claims and told him point blank they were false.
In mid-December 2020, President Trump's senior advisers told him the time had come to concede the election. Donald Trump knew the courts had ruled against him. He had all of this information, but still he made the conscious choice to claim fraudulently that the election was stolen, to pressure state officials to change election results, to manufacture fake electoral slates, to attempt to corrupt our Department of Justice, to summon tens of thousands of supporters to Washington.
Knowing that they were angry, knowing that some of them were armed, he sent them to the Capitol. Then as the riot was underway, he incited his supporters to further violence by publicly condemning his vice president. And then he refused for hours to disband his rioting supporters and instruct them to leave the Capitol, even when he was begged repeatedly to do so. None of this is normal or acceptable or lawful in our republic.
Third, please consider today who had a hand in defeating President Trump's efforts to overturn the election, Vice President Pence, Bill Barr, Jeff Rosen, and others at the Department of Justice, State Republican officials, White House staff who blocked proposals to mobilize the military to seize voting machines and run new elections, our Capitol Police, aided by the Metropolitan Police, other federal law enforcement, and our National Guard, who arrived later in the afternoon.
All of these people had a hand in stopping Donald Trump. This leads us to a key question. Why would Americans assume that our Constitution and our institutions and our republic are invulnerable to another attack? Why would we assume that those institutions will not falter next time? A key lesson of this investigation is this.
Our institutions only hold when men and women of good faith make them hold regardless of the political cost. We have no guarantee that these men and women will be in place next time. Any future president inclined to attempt what Donald Trump did in 2020 has now learned not to install people who could stand in the way.
And also, please consider this. The rulings of our courts are respected and obeyed because we as citizens pledge to accept and honor them. Most importantly, our president, who has a constitutional obligation to faithfully execute the laws, swears to accept them. What happens when the president disregards the court's rulings as illegitimate, when he disregards the rule of law?
That, my fellow citizens, breaks our republic. Finally, as you view the evidence today, also consider this. President Trump knew from unassailable sources that his election fraud claims were false. He admitted he had lost the election. He took actions consistent with that belief. Claims that President Trump actually thought the election was stolen are not supported by fact and are not a defense.
There is no defense that Donald Trump was duped or irrational. No president can defy the rule of law and act this way in a constitutional republic, period. Mr. Chairman, our nation's federal judges are sworn to do impartial justice to preserve our Constitution and preserve our union. Dozens of these judges have been addressing January 6th cases, and many have given us plain, unmistakable warnings about the direction of our republic.
Let me read from one judge's statement given at a recent sentencing hearing. "High ranking members of Congress and state officials, who know perfectly well the claim of fraud was and is untrue and that the election was legitimate, are so afraid of losing their power, they won't say so. It has to be crystal clear that it is not patriotism, it is not standing up for America to stand up for one man who knows full well that he lost instead of the Constitution he was trying to subvert." Mr. Chairman, the violence and lawlessness of January 6th was unjustifiable, but our nation cannot only punish the foot soldiers who stormed our Capitol.
Those who planned to overturn our election and brought us to the point of violence must also be accountable. With every effort to excuse or justify the conduct of the former president, we chip away at the foundation of our republic. Indefensible conduct is defended. Inexcusable conduct is excused. Without accountability, it all becomes normal and it will recur.
So, as we watch the evidence today, please consider where our nation is in its history. Consider whether we can survive for another 246 years. Most people in most places on Earth have not been free. America is an exception, and America continues only because we bind ourselves to our founders' principles, to our Constitution.
We recognize that some principles must be beyond politics, inviolate, and more important than any single American who has ever lived. Thank you, Mr. Chairman. I yield back.
BENNIE THOMPSON:
Without objections, the chair recognizes the gentlewoman from California, Ms. Lofgren, for an opening statement.
ZOE LOFGREN:
Thank you, Mr. Chairman. Very shortly after the election, oh — we begin this meeting by returning to election night, November 3rd, 2020. As the chairman noted, we've previously presented testimony about how the election results were expected to come in that night. In certain states, ballots cast by mail before Election Day would be counted only after the polls closed that evening.
That meant that election results would not be known for some time. Although President Trump's campaign manager, Bill Stepien, House Republican leader Kevin McCarthy, and Jared Kushner had advised Donald Trump to encourage mail in voting by Republicans, President Trump did not do so. [Begin videotape]
JARED KUSHNER:
I just remember generally, you know, you had people arguing that we had a — a very, very robust get out the vote effort and that, you know, mail in ballots could be a good thing for us if we looked at it correctly.
BILL STEPIEN:
There was one meeting that was had in particular.
I invited Kevin McCarthy to join the meeting, he being of like mind on — on the issue with me, in which we made our case for — for why we believed mail in balloting, mail in voting not to be a bad thing for his campaign, but, you know, the President's mind was made up. [End videotape]
So it was expected before the election that the initial counts in some states, in other words, those votes cast on Election Day, would be more heavily Republican and this would create the false perception of a lead for President Trump, a so-called red mirage. But as the results of the absentee ballots that were later counted, there could be trends towards Vice President Biden as those mail in ballots were counted.
Now on election night, Donald Trump's advisers specifically told him he didn't have a factual basis to declare victory, that he should wait for the remaining ballots to be counted. Here is campaign manager, Bill Stepien. [Begin videotape]
It was far too early to be making any calls like that. Ballots — ballots were still being counted. Ballots were still going to be counted for days. And it was far too early to be making any proclamation like that. I believe my recommendation was to say that votes were still being counted. It's too early to tell, too early to call the race.
[End videotape]
But President Trump did declare victory in the late hours of election night. Not only did he declare victory, he also called for the ongoing count of votes to just stop. Stopping the count would have violated both federal and state laws and also disenfranchised millions of voters who lawfully cast their vote.
He called for that action anyway. Here's what he said. [Begin videotape]
DONALD TRUMP:
This is a fraud on the American public. This is an embarrassment to our country. We were getting ready to win this election. Frankly, we did win this election. [applause] We want all voting to stop. [End videotape]
We now know more about President Trump's intention for election night. The evidence shows that his false victory speech was planned well in advance before any votes had been counted. It was a premeditated plan by the President to declare victory no matter what the actual result was. He made a plan to stay in office before Election Day. Now the Vice President's staff was concerned with what Donald Trump might do on election night.
They took steps to ensure that Mr. Pence would not echo a false victory announcement from President Trump. Here's what the Vice President's counsel, Greg Jacob, told us about his preparations with the Vice President's chief of staff, Marc Short. [Begin videotape]
GREG JACOB:
Marc had indicated to me that there was a possibility that there would be a declaration of victory within the White House that some might push for, and this is prior to the election results being known. And that he was trying to figure out a way of avoiding the Vice President sort of being thrust into a position of needing to opine on that when he might not have sufficient information to do so. [End videotape]
Now following this conversation, Mr. Jacob drafted a memo to Mr. Short, which the Select Committee got from the National Archives. The memo was sent on November 3rd, Election Day, and advised, "it is essential that the Vice President not be perceived by the public as having decided questions concerning disputed electoral votes prior to the full development of all relevant facts." A few days before the election, Mr. Trump also consulted with one of his outside advisers, inside activist, Tom Fitton, about the strategy for election night.
The Select Committee got this pre-prepared statement from the National Archives. As you can see, the draft statement, which was sent on October 31st, declares, "we had an election today - and I won." And the Fitton memo specifically indicates a plan that only the votes counted by the Election Day deadline, and there is no Election Day deadline, would matter.
Everyone knew that ballot counting would lawfully continue past Election Day, claiming that the counting on election night must stop before millions of votes were counted was as we now know a key part of President Trump's pre-meditated plan. On Election Day, just after 5 pm, Mr. Fitton indicated he'd spoken with the President about the statement.
"Sending along again. Just talked to him about the draft below." Again, this plan to keep — to declare victory was in place before any of the results had been determined. In the course of our investigation, we also interviewed Brad Parscale, President Trump's former campaign manager. He told us he understood that President Trump planned as early as July that he would say he won the election even if he lost.
And just a few days before the election, Steve Bannon, a former Trump chief White House strategist and outside adviser to President Trump, spoke to a group of his associates from China and said this. [Begin videotape]
STEVE BANNON:
And what Trump's going to do is just declare victory, right? He's gonna declare victory, but that doesn't mean he's the winner, he's just gonna say he's a winner. The Democrats — more of our people vote early that count. Theirs vote in mail, and so they're going to have a natural disadvantage and Trump's going to take advantage of it. That's our strategy.
He's gonna declare himself a winner. So when you wake up Wednesday morning, it's going to be a firestorm. Also — also if Trump is — if Trump is losing by 10:00 or 11:00 at night, it's going to be even crazier, you know, because he's gonna sit right there and say they stole it.
UNKNOWN:
Yeah, agree.
I'm directing the Attorney General to shut down all ballot places in all 50 states. It's going to be no, he's not going out easier. If Biden is winning, Trump is going to do some crazy shit. [End videotape]
As you know, Mr. Bannon refused to testify in our investigation. He's been convicted of criminal contempt of Congress and he's awaiting sentencing. But the evidence indicates that Mr. Bannon had advance knowledge of Mr. Trump's intent to declare victory falsely on election night, but also that Mr. Bannon knew about Mr. Trump's planning for January 6th. Here's what Bannon said on January 5th. [Begin videotape]
All hell is going to break loose tomorrow. It's all converging and now we're on, as they say, the point of attack, right, the point of attack tomorrow. I'll tell you this, it's not going to happen like you think it's going to happen. Ok. It's going to be quite extraordinarily different. And all I can say is strap in. You have made this happen and tomorrow it's game day.
So strap in, let's get ready. [End videotape]
Another close associate of Donald Trump apparently knew of Mr. Trump's intentions as well. Roger Stone is a political operative with a reputation for dirty tricks. In November 2019, he was convicted of lying to Congress and other crimes and sentenced to more than three years in prison. He's also a longtime adviser to President Trump and was in communication with President Trump throughout 2020. Mr. Trump pardoned Roger Stone on December 23rd, 2020. And recently the Select Committee got footage of Mr. Stone before and after the election from Danish filmmaker, Christopher Gilbranson [ph], pursuant to a subpoena.
Right before the election, here's Roger Stone talking about what President Trump would do after the election. [Begin videotape]
[off-mic]
ROGER STONE:
Let's just hope we're celebrating.
I suspect it'll be — I really do suspect it will still be up in the air. When that happens, the key thing to do is to claim victory. Possession is 9/10 of the law. No, we won. Fuck you. Sorry. Over. We won. You're wrong. Fuck you.
I said, fuck the voting, let's get right to the violence.
That's what I'm fucking saying. [laughter] There's no point.
We'll have to start smashing pumpkins if you know what I mean.
Oh yeah. [End videotape]
The select committee called Mr. Stone as a witness, but he invoked his Fifth Amendment right against self-incrimination. [Begin videotape]
You believe the violence on January 6th was justified?
On the advice of counsel, I respectfully re — decline to answer your question on the basis of the Fifth Amendment.
And Mr. Stone, did you have any role in planning for the violence on January 6th?
Once again, I will assert my Fifth Amendment right to decline to answer your question. [End videotape]
Although we don't yet have all the relevant records of Roger Stone's communications, even Stone's own social media posts acknowledge that he spoke with Donald Trump on December 27th as preparations for January 6th were underway. In this post, you can see how Roger Stone talked about his conversations with President Trump.
He wrote, "I also told the President exactly how he can appoint a special counsel with full subpoena power to ensure those who are attempting to steal the 2020 election through voter fraud are charged and convicted and to ensure Donald Trump continues as our President." As we know by now, the idea for a special counsel was not just an idle suggestion.
It was something President Trump had actually tried to do earlier that month. We know that Roger Stone was at the Willard Hotel on January 5th and 6th, and we know from other witness testimony that President Trump asked his chief of staff, Mark Meadows, to speak with Roger Stone and General Michael Flynn that night.
In addition to his connection to President Trump, Roger Stone maintained extensive direct connections to two groups responsible for violently attacking the Capitol, the Oath Keepers and the Proud Boys. Individuals from both of these organizations have been charged with the crime of seditious conspiracy. And what is seditious conspiracy?
It is a conspiracy to use violent force against the United States, to oppose the lawful authority of the United States. Multiple associates of Roger Stone from both the Oath Keepers and the Proud Boys have been charged with this crime. Close associates of Roger Stone, including Joshua James, have pled guilty to this crime.
We know that at least seven Oath Keepers, who have been criminally charged, provided personal security for Roger Stone or were seen with him on January 6th or in the weeks leading up to January 6th. For example, Joshua James, the leader of the Alabama Oath Keepers, provided security for Roger Stone and was with him on January 5th. This is the picture of the two together on January 5th. James entered the Capitol on January 6th. He assaulted a police officer.
Earlier this year, he pled guilty to seditious conspiracy and — and obstruction of Congress. Another example, is the married couple, Kelly and Connie Meggs. Kelly Meggs was the leader of the Florida chapter of the Oath Keepers. Both he and his wife provided security for Roger Stone, and both are charged with leading a military style stack attack of Oath Keepers attacking the Capitol on January 6th. Perhaps even more disturbing is Roger Stone's close association with Enrique Tarrio, the national chairman of the Proud Boys.
Roger Stone's connection with Enrique Tarrio and the Proud Boys is well documented by video evidence, with phone records the Select Committee has obtained. Tarrio, along with other Proud Boys, has been charged with multiple crimes concerning the attack on January 6th, including seditious conspiracy. During the attack, Tarrio sent a message to other Proud Boys claiming, we did that.
He also visited the White House on December 12th. Later that day, he posted a disturbing video claiming credit for the attack. This video, posted on January 6th, was apparently created prior to the attack. This big lie, President Trump's effort to convince Americans that he had won the 2020 election began before the election results even came in. It was intentional.
It was premeditated. It was not based on election results or any evidence of actual fraud affecting the results or any actual problems with voting machines. It was a plan concocted in advance to convince his supporters that he won. And the people who seemingly knew about that plan in advance would ultimately play a significant role in the events of January 6. Mr. Chairman, I yield back.
The gentlewoman yields back The Chair recognizes the gentleman from Illinois, Mr. Kinzinger, for an opening statement.
ADAM KINZINGER:
Thank you, Mr. Chairman. Very shortly after the election, the Trump campaign recognized that they had likely lost the election and they informed Donald Trump of that fact. Even before the networks called the race for President Biden on November 7th, His chances of pulling out a victory were virtually nonexistent, and President Trump knew it. [Begin videotape]
Do you know if anybody ever told the President that he had lost and that there wasn't a chance of him winning?
JASON MILLER:
The — I know that the President when the networks called it, of course, he was informed about the — the network decision. That afternoon at some point, myself And a handful of other folks went over and sat down with the President and communicated that the odds of us prevailing in legal challenges were very small.
[begin videotape]
You know, after the election as of November 7, in your judgment what were the chances of President Trump winning the election?
CHRIS STIREWALT:
After that point?
At times, President Trump acknowledged the reality of his loss. Although he publicly claimed that he had won the election, privately he admitted that Joe Biden would take over as President. Here's a few examples of that. [Begin videotape]
MARK MILLEY:
So we're in the Oval and there's a discussion going on. And the President says, I think — it could have been Pompeo, but he says words to the effect of, yeah, we lost. We — we need to let that issue go to the next guy, meaning President Biden.
ALYSSA FARAH:
I remember maybe a week after the election was called, I popped into the Oval just to like give the President the headlines and see how he was doing. And he was looking at the TV and he said, can you believe I lost to this effing guy?
CASSIDY HUTCHINSON:
Mark raised it with me on the 18th. And so following that conversation with the motorcade ride driving back to the White House, I said, look, does the President really think he lost? And he said, you know, a lot of times he'll tell me that he lost, but he wants to keep fighting it. He thinks that there might be enough to overturn the election, but you know, he — he pretty much has acknowledged that he — that he's lost.
Knowing that he had lost and that he had only weeks left in office, President Trump rushed to complete his unfinished business. One key example is this: President Trump issued an order for large-scale US troop withdrawals. He disregarded concerns about the consequences for fragile governments on the front lines of the fight against ISIS and Al-Qaeda terrorists.
Knowing he was leaving office, he acted immediately and signed this order on November 11th, which would have required the immediate withdrawal of troops from Somalia and Afghanistan, all to be complete before the Biden inauguration on January 20th. As you watch these clips, recall that General Keith Kellogg was the national security adviser to the vice president and had served as chief of staff to the National Security Council for President Trump.
And General Milley was the chairman of the Joint Chiefs of Staff at the Pentagon. [Begin videotape]
Are you familiar with a memo that the President reportedly signed on November 11, 2020, ordering that troops be withdrawn from Afghanistan and Somalia?
KEITH KELLOGG:
So I think you might have seen some things where there's a memo or something from Johnny McEntee to Douglas Macgregor. It says, here's your task, to get US forces out of out of Somalia, get US forces out of Afghanistan. When you first interviewed and met Colonel Douglas Macgregor, is it fair to say you discussed this decision of withdrawing from Somalia and Afghanistan, correct?
JOHN MCENTEE:
Yeah, I'm sure that was part of it, yeah.
And that was — the position that he was taking over there was senior advisor to the Secretary of Defense; is that correct?
So on that same day, just so I'm clear, he responded back to you that day, meaning DOD leadership was not going to do — take any of those steps without an order.
Without a directive, yeah.
DOUGLAS MACGREGOR:
I explained in language that should be in the order while I was in the meeting with McEntee, and this was my answer to him. I said, If you want this to happen or the President wants this to happen, he's got to write an order.
So you never wrote it down in any capacity.
Well, I sketched on a piece of paper for him some key statements. You know, the President directs. You know, this is — what's the right word — boilerplate language?
Who was — in his office drafted the order? It was myself and one of my assistants.
McEntee duly takes it up, brings it in to the President. The President signs it and boom, it's over — faxed over e-mail, scanned over. Kash Patel delivers it to me.
Was it by autopen or was it the President himself signing it? It was the President. And who obtained that signature? I did.
It is odd, it is nonstandard. It is potentially dangerous. I personally thought it was militarily not feasible nor wise.
And I proceeded to tell the PPO and proceeded to tell Macgregor that If I ever saw anything like that, I would do something physical. Because I thought what that was then was a tremendous disservice to the nation. And by the way, that was a very contested issue. There were people who did not agree with getting out of Afghanistan.
I appreciate their concerns. An immediate departure that that memo said would have been a catastrophic. It's the same thing what President Biden went through. It would have been a debacle. [End videotape]
Keep in mind the order was for an immediate withdrawal. It would have been catastrophic. And yet, President Trump signed the order. These are the highly consequential actions of a President who knows his term will shortly end. At the same time that President Trump was acknowledging privately that he had lost the election, he was hearing that there was no evidence of fraud or irregularities sufficient to change the outcome.
ALEX CANNON:
I remember a call with Mr. Meadows, where Mr. Meadows was asking me what I was finding and if I was finding anything. And I remember sharing with him that we weren't finding anything that would be sufficient to change the results in any of the key states.
When was that conversation?
Probably in November, mid to late November. I think it was before my child was born.
And what was Mr. Meadows' reaction to that information?
I believe the words he used were, so there's no there there?
It would be our job to track it down and come up dry because the allegation didn't prove to be true. And we'd have to, you know, relay the news that, yeah, that that — that tip that your — someone told you about those — those votes or that fraud or, you know, nothing came of it. That will be our job as — as, you know, the truth-telling squad and, you know, not a fun job to be — you know, it's — it's an easier job to be telling the President about, you know, wild allegations.
It's harder job to be telling him on the back end that, yeah, that's — that that wasn't true.
MATT MORGAN:
What was generally discussed on that topic was whether the fraud, maladministration, abuse or irregularities if aggregated and read most favorably to the campaign, would that be outcome determinative. And I think everyone's assessment in the room, at least amongst the staff, Marc Short, myself, and Greg Jacob, was that it was not sufficient to be outcome determinant. [End videotape]
Look, it's the right of any candidate to litigate genuine election disputes. Nobody argues that, but President Trump's litigation was completely unsuccessful. In our past hearings, we told you that the committee had identified a total of 62 election lawsuits filed by the Trump campaign and its allies between November 4th and January 6th of 2021. Those cases resulted in 61 losses and only a single victory, which did not affect the outcome for any candidate.
The claims were not supported by any sufficient evidence of fraud or irregularities. In fact, they were baseless as judges repeatedly recognized. In none of these 62 cases was President Trump able to establish any viable claims of election fraud sufficient to overturn the results of the election. In those hearings, we shared with you the words used by judges around the country in rejecting the Trump campaign's claims.
It's strong language criticizing the lack of evidentiary support for the claims of election fraud in those lawsuits. For example, a federal appeals court in Pennsylvania wrote, quote, charges require specific allegations and proof. We have neither here. A federal judge in Wisconsin wrote, quote, the court has allowed the former president the chance to make his case and he has lost on the merits.
Another judge in Michigan called the claims, quote, nothing but speculation and conjecture that votes for President Trump were either destroyed, discarded or switched to votes for Vice President Biden. A federal judge in Michigan sanctioned nine attorneys, including Sidney Powell, for making frivolous allegations in an election fraud case, describing the case as a historic and profound abuse of the judicial process.
Recently, a group of distinguished Republican intellectuals lawyers, former judges and elected officials, issued a report confirming the findings of the courts. In their report entitled, Lost Not Stolen, these prominent Republicans analyzed each election challenge and concluded this. Donald Trump and his supporters failed to present evidence of fraud or inaccurate results significant enough to invalidate the results of the 2020 Presidential election.
On December 11th, Trump's allies lost a lawsuit in the US Supreme Court that he regarded as his last chance at success in the courts. A newly obtained Secret Service message from that day shows how angry President Trump was about the outcome. Quote, just FYI, POTUS is pissed. Breaking news, Supreme Court denied his lawsuit.
He is livid now. Cassidy Hutchinson, an aide to chief of staff Mark Meadows, was present for that conversation and described it in this way. [Begin videotape]
This is the day that the Supreme Court had rejected that case. Mr. Meadows and I were in the White House residence at a Christmas reception. And as we were walking back from the Christmas reception that evening, the President was walking out of the Oval Office and we crossed paths in the Rose Garden colonnade.
The President was fired up about the Supreme Court decision. And so I was standing next to Mr. Meadows, but I had stepped back. So I was probably two or three feet catty-cornered, diagonal from him. The President just raging about the decision and how it's wrong, and why didn't we make more calls, and just this typical anger outburst at this decision.
And the President said I think — so he had said something to the effect of, I don't want people to know we lost, Mark. This is embarrassing. Figure it out. We need to figure it out. I don't want people to know that we lost. [End videotape]
Our country is a country of laws where every person, including the President, must follow the law and respect the judgment of our courts. President Trump's closest advisers held that view both then and now. [Begin videotape]
Well, Do you believe the President should abide by the rulings of the courts?
MIKE POMPEO:
Oh, yes, We should all comply with the law at all times, to the best of our ability, every one of us.
So once the courts have ruled and the Electoral College had met, the election was over in your view?
Yes, I think — I think I've said previously that when the Vice President made the certification and the litigation was complete, it was complete.
When the Electoral College met on the 14th?
Yes, as of December 14th; is that right? I think that's the right date, yes.
I assume, Pat, that you would agree the President is — is obligated to abide by the rulings of the courts.
PAT CIPOLLONE:
And I assume you also would --
Everybody is obligated to abide by rules of courts.
And I assume you also would agree the President has a particular obligation to take care that the laws be faithfully executed.
That is one of the President's obligations, correct.
Ivanka, do you — do you believe the President is obligated to abide by the rulings of the courts?
IVANKA TRUMP:
I do. [End videotape]
By mid-December of 2020, President Trump's senior staff were attempting to persuade him to concede the election outcome. [Begin videotape]
But — but if your question is did I believe he should concede the election at a point in time, yes, I did.
BILL BARR:
December 14th was the day that the states certified their votes and sent them to Congress. And in my view, that was the end of the matter. I didn't see — you know, I — I thought that this would lead inexorably to a new administration.
JUDD DEERE:
I told him that my personal viewpoint was that the Electoral College had met, which is the system that our country is — is set under to elect a president and vice president, and I believed at that point that the means for him to pursue litigation was probably closed.
And do you recall what his response, if any, was?
He disagreed. [End videotape]
Secretary of Labor Gene Scalia, the son of late Justice Scalia, visited President Trump in mid-December and explained the situation clearly. [Begin videotape]
EUGENE SCALIA:
So, I had put a call in to the president. I might have called on the 13th. We spoke, I believe, on the 14th, in which I conveyed to him that I thought that it was time for him to acknowledge that President Biden had prevailed in the election. But I communicated to the president that, you know, when that legal process is exhausted and when the electors are — have voted, that that's the point at which that outcome needs to be expected.
I told him that I did believe, yes, that once the — those legal processes were run, if fraud had not been established that had affected the outcome of the election, then unfortunately I believed that what had to be done was concede the outcome. [End videotape]
Not only did the courts reject President Trump's fraud and other allegations, his Department of Justice appointees, including Bill Barr, Jeffrey Rosen, and Richard Donoghue did as well. President Trump knew the truth. He heard what all his experts and senior staff were telling him. He knew he had lost the election, but he made the deliberate choice to ignore the courts, to ignore the Justice Department, to ignore his campaign leadership, to ignore senior advisers, and to pursue a completely unlawful effort to overturn the election.
His intent was plain. Ignore the rule of law and stay in power. Mr. Chairman, I yield back.
The gentleman yields back. The chair recognizes the gentlewoman from Virginia, Ms. Luria.
ELAINE LURIA:
Thank you, Mr. Chairman. Mid-December was a turning point. President Trump made a decision, a choice, to ignore the courts and his advisers and to push forward to overturn the election. His efforts to overturn the election were not random or disconnected, rather, they were part of a coordinated multipart plan to ensure that he stayed in power.
Donald Trump was the driver behind each part of this plan. He was personally and directly involved. Of course, a key element of the plan was continuing to convince tens of millions of Americans that he did not in fact lose. Again, he did this even though his own campaign advisers and his Justice Department officials told him his claims of fraud were wrong.
In this video, you'll see that, even when top law enforcement officials told the president his election fraud claims were false, he still repeated the claims in the days and weeks that followed, sometimes even the very next day. [Begin videotape]
I specifically raised the Dominion voting machines, which I found to be among the most disturbing allegations, disturbing in the sense that I saw absolutely zero basis for the allegations. I told them that it was — that it was crazy stuff and they were wasting their time on that, and it was doing a grave — grave disservice to the country.
We have a company that's very suspect. Its name is Dominion. With the turn of a dial or the change of a chip, you could press a button for Trump and the vote goes to Biden. What kind of a system is this?
RICHARD DONOGHUE:
We definitely talked about Antrim County again. That was sort of done at that point because the hand recount had been done and all that. But we cited back to that to say, you know, this is an example of what people are telling you and what's being filed in some of these court filings that are just not supported by the evidence.
And this is the problem, the problem that people keep telling you these things and they turn out not to be true.
In addition, there is the highly troubling matter of Dominion voting systems. In one Michigan county alone, 6,000 votes were switched from Trump to Biden, and the same systems are used in the majority of states in our country.
I went into this and would, you know, tell him how crazy some of these allegations were and how ridiculous some of them were. And I'm talking about some of the ones like, you know, more votes — more absentee votes were cast in Pennsylvania than there were absentee ballots request — you know, stuff like that was just easy to blow up. There was never — there was never an indication of interest in what the actual facts were.
There were more votes than there were voters. Think of that. You had more votes than you had voters. That's an easy one to figure, and it's by the thousands.
Then he raised the — the big vote dump, as he called it, in Detroit. And that — you know, he said people saw boxes coming in to the counting station at all hours of the morning. And I said, Mr. President, there are 630 precincts in Detroit. And unlike elsewhere in the state, they centralized the counting process so they're not counted in each precinct.
They're moved to counting stations. And so, the normal process would involve boxes coming in at all different hours.
This is Michigan. At 6:31 in the morning, a vote dump of 149,772 votes came in unexpectedly.
With regard to Georgia, we looked at the tape. We interviewed the witnesses. There is no suitcase. The president kept fixating on this suitcase that supposedly had fraudulent ballots and that the suitcase was rolled out from under the table. And I said, no, sir, there is no suitcase. You can watch that video over and over.
There is no suitcase. There is a wheeled bin where they carry the ballots, and that's just how they move ballots around that facility. There's nothing suspicious about that at all.
Election officials pulled boxes, Democrats, and suitcases of ballots out from under a table. You all saw it on television, totally fraudulent. [End videotape]
This happened over and over again, and our committee's report will document it, purposeful lies made in public directly at odds with what Donald Trump knew from unassailable sources, the Justice Department's own investigations and his own campaign. Donald Trump maliciously repeated this nonsense to a wide audience over and over again.
His intent was to deceive. President Trump's plan also involved trying to coerce government officials to change the election outcome in the states he lost. He personally reached out to numerous state officials and pressured them to take unlawful steps to alter the election results in those states. These actions, taken directly by the president himself, made it clear what his intentions were; to prevent the orderly transfer of power.
We all recall, for example, President Trump's tape recorded call with Georgia Secretary of State Brad Raffensperger. At the time this call occurred, President Trump had already been told repeatedly by the US Justice Department, by his campaign, and by his advisers that his allegations of fraud in Georgia were false.
So, look, now all I want to do is this. I just want to find 11,780 votes, which is one more than we have, because we won the state. Look, we need only 11,000 votes. We have far more than that as it stands now. We'll have more and more. So, what are we going to do here, folks? If I only need 11,000 votes.
Fellas, I need 11,000 votes. Give me a break. [End videotape]
I just want to find 11,780 votes. That's an extraordinary demand by the president, especially since he already knew from the Justice Department there was no genuine basis for this request. No one could think it would be legal for the secretary of state to simply find the votes the president needed in order to win.
Secretary Raffensperger told the president the truth, that he lost the election in Georgia, but President Trump did not accept that answer. Instead, he suggested that Secretary Raffensperger himself might be prosecuted. [Begin videotape]
That's the thing. You know, that's a criminal — that's a criminal offense. And — and, you know, you can't let that happen. That's — that's a big risk to you and to Ryan, your lawyer. That's a big risk. [End videotape]
We know that President Trump's White House advisers reacted negatively. Immediately after the call, Cassidy Hutchinson had a conversation with Chief of Staff Mark Meadows. [Begin videotape]
I remember looking at Mark. And I said, Mark, you can't possibly think we're going to pull this off. Like, that call was crazy. And he looks at me and just started shaking his head. He was like, no, Cass, you know, he knows it's over. He knows he lost, but we're going to keep trying. There's some good options out there still.
We're going to keep trying. [End videotape]
This call and other related activity is now the focus of an ongoing criminal investigation in Fulton County, Georgia. And Georgia's not the only state where President Trump tried to pressure state officials to change the results. He also attempted to press — pressure state officials in Arizona, Pennsylvania, and Michigan to change the results in those states as well.
While President Trump was pressuring state officials, he was also trying to use the Department of Justice to change the election result. His top officials told him that there was no evidence to support his claims of fraud, but he didn't care. As he told them, just say the election was corrupt and leave the rest to me and the Republican Congressmen.
When these officials would not do what he said, President Trump embarked in an effort to install Jeff Clark as acting attorney general, solely because he would — he would do what others in the department would not do. We know that Trump was doing so for a specific purpose, so Clark could corruptly employ the Justice Department's authority to help persuade the states to flip electoral votes.
For example, when Richard Donoghue and Jeff Rosen, both appointed by President Trump, learned of Mr. Clark's proposal, here's why they said they forcefully rejected it. [Begin videotape]
And I recall toward the end saying what you're proposing is nothing less than the United States Justice Department meddling in the outcome of a presidential election. But more importantly, this was not based on fact. This was actually contrary to the facts as developed by department investigations over the last several weeks and months.
So, I responded to that. And for the department to insert itself into the political process this way I think would have had grave consequences for the country. It may very well have spiraled us into a constitutional crisis. [End videotape]
We know from our investigation that President Trump offered Jeff Clark the position of acting attorney general and that Jeff Clark had decided to accept it. The only reason this ultimately did not happen is that the White House counsel and a number of Justice Department officials confronted the president in the Oval Office and threatened mass resignation.
And then — and I said something to the effect of you're going to have a huge personnel blowout within hours, because you're going to have all kinds of problems with resignations and other issues. And that's not going to be in anyone's interest. [End videotape]
The President ultimately relented only because the entire leadership of the Department of Justice as well as his White House counsel threatened to resign. Mr. Chairman, I yield back.
The gentlewoman yields back. The chair recognizes the gentlewoman from Florida, Mrs. Murphy, for an opening statement.
STEPHANIE MURPHY:
Thank you, Mr. Chairman. President Trump's efforts to unlawfully overturn the results of the 2020 election were not limited to the big lie and pressuring state officials and the Department of Justice officials. Another key part of the president's effort was a scheme to assemble fake electors to cast false electoral votes in the states that President Trump lost.
This was something done not only with the President's knowledge, but also with his direct participation. Ronna McDaniel, Chair of the Republican National Committee, testified before this committee that President Trump and his attorney Dr. John Eastman called her and asked her to arrange for the fake electors to meet and rehearse the process of casting their fake votes.
RONNA MCDANIEL:
When I received the call — again, I don't remember the exact date — it was — it was from the White House switchboard and it was President Trump who had contacted me.
And did President Trump have anyone else on the line with him?
He introduced me to a gentleman named John Eastman. So I vaguely remember him mentioning that he was a professor.
And then essentially, he turned the call over to Mr. Eastman who then proceeded to talk about the importance of the RNC helping the campaign gather these contingent electors, in case any of the legal challenges that were ongoing changed the result of any of the states. [End videotape]
These fake electors were ultimately part of the President's plan to replace genuine Biden electors with Trump electors on January 6. As part of this plan, the false electoral slates were sent to the National Archives into the Capitol.
The fake electors' plan was also tied to another plan, the coercive pressure campaign to make Vice President Mike Pence reject or refuse to count certain Biden electoral votes, so that President Donald Trump would, quote, win reelection instead. Here is what Vice President Pence has said about this scheme.
MIKE PENCE:
President Trump said I had the right to overturn the election, but President Trump is wrong. I had no right to overturn the election. The presidency belongs to the American people and the American people alone. And frankly, there is no idea more un-American than the notion that any one person could choose the American President.
Make no mistake, President Trump knew that what he was demanding Vice President Pence do was illegal. He was informed of this repeatedly and specifically on January 4th. Even his lawyer John Eastman admitted in front of President Trump that this plan would break the law by violating the Electoral Count Act. [Begin videotape]
Did John Eastman ever admit, as far as you know, in front of the President that his proposal would violate the Electoral Count Act?
I believe he died on the 4th. [End videotape]
And Dr. Eastman confirmed this in writing. Recall this email written on January 6 in which Vice President Pence's counsel asked Dr. Eastman; did you advise the President that in your professional judgment, the Vice President does not have power to decide things unilaterally? Dr. Eastman replied, he's been so advised.
Of course, President Trump's own White House counsel, Pat Cipollone, also recognized that this plan was unlawful. Here is Mr. Cipollone's testimony. [Begin videotape]
My view is that the Vice President had — didn't have the legal authority to do anything except what he did. [End videotape]
There is no doubt that President Trump's pressure campaign on Vice President Pence was significant. On the morning of January 6, President Trump called the Vice President from the Oval Office and demanded that he overturn the results of the election. Numerous witnesses told the Select Committee about the invective that President Trump leveled at his own Vice President.
NICHOLAS LUNA:
Something to the effect this is — the wording is wrong. I made the wrong decision four or five years ago.
And the word that she relayed to you that the President called the Vice President, I apologize for being impolite, but do you remember what she said her father called him?
JULIE RADFORD:
The P word. [End videotape]
But Vice President Pence didn't waver even when his own life was endangered by President Trump and the rioters at the Capitol on January 6, as you'll see in more detail later. A federal judge concluded, based on this and other evidence, that President Trump's pressure campaign against the Vice President likely violated multiple criminal statutes.
In the end, all these people, Department of Justice officials, state elections' officials, his own Vice President, stood strong in the face of President Trump's immense pressure. But as we now know, President Trump had already summoned tens of thousands of his supporters to Washington on January 6 to take back their country.
On December 19th, President Trump first told his supporters to come to Washington. In this and numerous other tweets, he fraudulently and repeatedly promoted January 6 as the day Americans could come in and change the election outcome. For weeks, President Trump worked with others to plan the rally, intending all along that he would send an assembled crowd of angry supporters to the Capitol after his speech on the Ellipse on January 6. We obtained a text message that one rally organizer sent on January 4th. In part it reads that, quote, POTUS is going to have us march there at the Capitol.
And POTUS is going to just call for it unexpectedly. Again, each of these examples, the big lie, the pressure campaigns against state officials, the pressure campaign against the Department of Justice and his Vice President, the fake electors summoning the mob; all of this demonstrates President Trump's personal and substantial role in the plot to overturn the election.
He was intimately involved. He was the central player. Thank you, Mr. Chairman, and I yield back.
The gentlewoman yields back. The Chair recognizes the gentleman from California, Mr. Schiff, for an opening statement.
ADAM SCHIFF:
Thank you, Mr. Chairman. In our past hearings, you have seen direct evidence that President Trump sent a crowd of his supporters to the Capitol on January 6th, knowing they were armed and angry. This was the last most desperate and dangerous prong of his plan to disrupt the joint session and prevent the orderly transition of power.
On the morning of the 6th, the Secret Service was at the Ellipse screening the members of the crowd as they entered the rally site. And they noticed something significant about the crowd. Tens of thousands of people were outside the rally site, but did not want to go through the magnetometers, the metal detectors that were used to screen for dangerous weapons.
Since our last hearings, the select committee has received greater cooperation from the Secret Service. Nevertheless, Secret Service text messages from this period were erased in the days and months following the attack on the Capitol, even though documents and materials related to January 6th had already been requested by the Department of Justice and Congress.
But we were able to obtain nearly one million emails, recordings, and other electronic records from the Secret Service. Over the month of August, the select committee began its review of hundreds of thousands of pages and multiple hours of that material, providing substantial new evidence about what happened on January 6th and the days leading up to it. That review continues.
What you're about to hear is just a sample of the new and relevant evidence that we have received, mounting evidence before January 6th predicted violence. And not just violence generally, but violence directed at the Capitol. Intelligence about this risk was directly available to the US Secret Service and others in the White House in advance of the Ellipse speech, in advance of the march to the Capitol.
The committee has shown evidence that President Trump was aware of the risk of violence. The FBI, US Capitol Police, Metropolitan Police and other agencies all gathered and disseminated intelligence, suggesting the possibility of violence at the Capitol prior to the riot. We're now going to show you just a sample of the evidence we have received.
Days before January 6, the President's senior advisers at the Department of Justice and FBI, for example, received an intelligence summary that included material indicating that certain people traveling to Washington were making plans to attack the Capitol. This summary noted online calls to occupy federal buildings, rhetoric about invading the Capitol building, and plans to arm themselves and to engage in political violence at the event.
Other agencies were also hearing predictions suggesting possible violence at the Capitol. On a call with President Trump's White House national security staff in early January 2021, Deputy Secretary of Defense David Norquist had warned about the potential that the Capitol would be the target of the attack.
Here is General Mark Milley, who was also present for this call, describing Deputy Secretary Norquist's warning. [Begin videotape]
So during these calls, I — I only remember in hindsight because he was almost like clairvoyant. Norquist says during one of these calls, the greatest threat is a direct assault on the Capitol. I'll never forget it. [End videotape]
This email, for example, was an alert that the Secret Service received on December 24th with the heading, Armed and Ready, Mr. President. According to the intelligence, multiple users online were targeting members of Congress, instructing others to march into the chambers on January 6th and make sure they know who to fear.
In this report received on December 26th, the Secret Service field office relayed a tip that had been received by the FBI. According to the source of the tip, the Proud Boys plan to march armed into DC. They think that they will have a large enough group to march into DC armed, the source reported, and will outnumber the police so they can't be stopped.
The source went on to say their plan is to literally kill people. Please, please take this tip seriously and investigate further. The source also made clear that the Proud Boys had detailed their plans on multiple websites like thedonald.win. Let's pause here. The Secret Service had advance information more than ten days beforehand regarding the Proud Boys' planning for January 6th. We know now, of course, that the Proud Boys and others did lead the assault on our Capitol building.
On December 31st, agents circulated intelligence reports that President Trump's supporters had proposed a movement to occupy Capitol Hill. In particular, they flagged spikes in violent hashtags like We Are the Storm, 1776 Rebel, and Occupy Capitols. On January 5th, a Secret Service open source unit flagged a social media account on thedonald.win that threatened to bring a sniper rifle to a rally on January 6th. The user also posted a picture of a handgun and rifle with the caption, Sunday Gun Day Providing Overwatch January 6th Will be Wild.
Later on the evening of January 5th, the Secret Service learned during an FBI briefing that right-wing groups were establishing armed QRFs or quick reaction forces readying to deploy for January 6th. Groups like the Oath Keepers were standing by at the ready should POTUS request assistance by invoking the Insurrection Act, agents were informed.
As we all know now, the Oath Keepers did play a specific role in January 6th and had stashed weapons in Virginia for further violence that evening. Also, on that day, the Secret Service was readying its security precautions for the President's speech at the Ellipse the next day. A Secret Service deputy chief instructed agents to add certain objects to the list of items that would be prohibited at the rally site, including ballistic vests, tactical vests, armored or not, and ballistic helmets.
By the morning of January 6th, it was clear that the Secret Service anticipated violence. It felt like the calm before the storm, one agent predicted, in a protective intelligence division chat group. Another remarked how agents were watching the crazies on live stream. By 9:09 that morning, the Secret Service could also see that many rally goers were assembled outside the security perimeter.
One agent emailed, possibly because they have stuff that couldn't come through would probably be an issue with this crowd. Just a thought. By 9:30 that morning, agents reported more than 25,000 people outside the rally site. An hour later, the Secret Service reported that the crowd was on the mall watching, but not in line.
The head of the President's Secret Service protective detail, Robert Engel, was specifically aware of the large crowds outside the magnetometers. He passed that information along to Tony Ornato who worked for Mark Meadows in the chief of staff's office. The documents we obtained from the Secret Service make clear that the crowd outside the magnetometers was armed and the agents knew it. Take a look at what they were seeing and hearing on the ground.
One report from the rally site at 7:58 a.m. said, some members of the crowd are wearing ballistic helmets, body armor, carrying radio equipment and military grade backpacks. Another from 9:30 a.m. said that there were possibly OC spray, meaning pepper spray, and/or plastic riot shields. At 11:23 a.m., agents also reported possible armed individuals, one with a glock, one with a rifle.
Over the next hour, agents reported possible man with a gun reported, confirmed pistol on hip located in a tree; and one detained at 14th and I Street northwest; individual had an assault rifle on his person.
Minutes before President Trump began his speech, members of the Federal Protective Service, an agency tasked with protecting federal buildings, were alerted about an arrest of a protester with a gun on his waistband. And during the speech, the weapons related arrests continued. At 12:13 PM, United States Park Police arrested a man with a rifle in front of the World War II Memorial. These agents remarked on the number of weapons that had been seized that day, speculating that the situation could get worse.
"With so many weapons found so far, you wonder how many are unknown," one agent wrote at 12:36 PM, "Could be sporty after dark." At 12:47 PM, another agent responded, "No doubt. The people at the Ellipse said they are moving to the Capitol after the POTUS speech." As the documents we've received make clear, the Secret Service was aware of weapons possessed by those gathered at rallies in DC as early as the evening before.
Take this document for instance, which details multiple arrests in the crowds demonstrating on January 5th. Those arrests were for weapons offenses, handguns, high capacity feeding devices, ammunition. What the Secret Service saw on the 6th was entirely consistent with the violent rhetoric circulating in the days before the joint session on pro-Trump websites, at times amplified by the president's own advisers.
On one of these sites — as you've heard, one of those was called TheDonald.win. The Select Committee has obtained a text message that Jason Miller, a senior communications adviser, sent to Mark Meadows less than a week before January 6th. "I got the base fired up," he wrote in all caps. He sent a link to this page on TheDonald.win.
The linked web page had comments about the joint session of Congress on January 6th. Take a look at some of those comments. "Gallows don't require electricity." "If the filthy commie maggots try to push their fraud through, there will be hell to pay." "Our lawmakers in Congress can leave one of two ways; one, in a body bag, two, after rightfully certifying Trump the winner." Mr. Miller claimed that he had no idea about the hundreds of comments like these in the link that he sent to Mark Meadows.
If I had seen something like that, I probably would have flipped it to someone at the White — or if I had seen something of that nature, I would have said we gotta flag this for Secret Service or something of that nature." [End videotape]
But the Trump administration was aware of this type of violent record — rhetoric prior to January 6th. In fact, as we have seen, the Secret Service and other agencies knew of the prospect of violence well in advance of the president's speech at the Ellipse. Despite this, certain White House and Secret Service witnesses previously testified that they had received no intelligence about violence that could have potentially threatened any of the protectees on January 6th, including the vice president.
Evidence strongly suggests that this testimony is not credible, and the committee is reviewing additional material from the Secret Service and other sources. The Secret Service was monitoring this kind of online activity and was sharing and receiving the results of that effort. They'd worked closely with other agencies, sharing intelligence about the joint session of Congress derived from social media and other sources.
The same day Jason Miller sent his text message, agents received reports about a spike in activity on another platform called Parler. This was December 30th. In this email, an agent received a report noting a lot of violent rhetoric on Parler directed at government people and entities, including Secret Service protectees.
One of these protectees was Vice President Pence, perhaps the primary target of President Trump's pressure campaign in the days leading up to January 6th. The day before the joint session, on January 5th, Secret Service was aware of increased chatter focused on Vice President Pence, in particular whether he would do what President Trump wanted him to do, reverse the results of the election in the joint session the next day, January 6th. On the morning of the 6th, agents received alerts of online threats that Vice — Vice President Pence would be "a dead man walking if he doesn't do the right thing." Another agent reported, "I saw several other alerts saying they will storm the Capitol if he doesn't do the right thing." The anger reflected in these postings was obvious, the man at the center of the storm on January 6th, President Trump.
On the evening of January 5th, President Trump gathered a few of his communications staffers in the Oval Office. The door was open, allowing the president and others assembled there to hear the sounds of the crowd gathered at Freedom Plaza, just a few blocks from the White House. President Trump could tell that his supporters were riled up. Here again is Judd Deere, a deputy White House press secretary describing the president's reaction.
He fairly quickly moved to how fired up the crowd is or was going to be.
And what did they say about it?
Just that they were — they were fired up. They were angry. They feel like the election's been stolen, that the election was rigged, that — he went on and on about that for a little bit. [End videotape]
Yes, the president knew the crowd was angry because he had stoked that anger. He knew that they believed that the election had been rigged and stolen because he had told them falsely that it had been rigged and stolen. And by the time he incited that angry mob to march on the Capitol, he knew they were armed and dangerous, all the better to stop the peaceful transfer of power.
Mr. Chairman, I yield back.
The gentleman yields back. At this point our — in our meeting, we'll take a brief recess. Pursuant to the order of the committee of today, the chair declares the committee in recess for a period of approximately 10 minutes. [In recess] The chair recognizes the gentleman from California, Mr. Aguilar, for an opening statement.
PETE AGUILAR:
Thank you, Mr. Chairman. On the morning of January 6th, President Trump knew that the crowd was angry. He knew that they were armed and dangerous, and he knew that they were going to the Capitol. It's important to understand the lengths the president was willing to go to physically be at the Capitol, because it was part of his strategy to disrupt Congress and to stay in power.
As the time for the Ellipse rally approached, an email was circulated among intelligence officials, including Secret Service intelligence official, attaching communications among rally goers that specifically contemplated violence. "Trump has given us marching orders," one post on TheDonald.win wrote. "Basically if you're east of the Mississippi, you can and should be there.
Advance on the Capitol. Keep your guns hidden. Don't fuck around. Full kits, 180 rounds minimum for main rifle, another 54 sidearm per person." What is clear from this record is that the White House had more than enough warning to warrant stopping any plan for an ellipse rally, and certainly for stopping any march to the Capitol.
And as evidence from our prior hearings has suggested, the president was aware of this information. But despite awareness of the potential for violence and weapons among the crowd, the Ellipse event nevertheless went forward, and Donald Trump instructed the angry crowd, some of whom were armed, to march to the Capitol.
As my colleague Mr. Schiff just described, the Secret Service reported that thousands in the crowd near the Washington Monument would not enter the rally area because magnetometers used in screening attendees would detect any prohibited items they carried. Mr. Trump knew this. His Secret Service had told him about it that morning.
Even in spite of these warnings, Cassidy Hutchinson overheard the president say this shortly before he took stage. [Begin videotape]
He wanted it full, and he was angry that we weren't letting people through the mags with weapons, what the Secret Service deemed as weapons and are — are weapons. I was in the vicinity of a conversation where I overheard the president say something to the effect of, you know, I don't f'ing care that they have weapons.
They're not here to hurt me. Take the f'ing mags away. Let my people in. They can march to the Capitol from here. Let the people in. Take that f'ing mags away. [End videotape]
And when he went on stage, President Trump himself asked law enforcement to let his supporters in the rally site. [Begin videotape]
And I'd love to have, if those tens of thousands of people would be allowed, the military, the Secret Service — and we want to thank you, and the police, law enforcement, great. You're doing a great job. [Applause] But I'd love it if they could be allowed to come up here with us. Is that possible? Can you just let them come up, please?
President Trump then told his supporters to march to the Capitol. Let's pause at this point to consider President Trump's state of mind, his motivation at this moment. By that point, it was known to Secret Service that members of the crowd were armed. President Trump had been told, and there was no doubt that President Trump knew what he was going to do, sending an angry mob, a number of whom were clad in tactical gear and military garb, armed with various weapons to the Capitol.
There's no scenario where that action is benign, and there's no scenario where an American president should have engaged in that conduct. It did not matter whether President Trump believed the election had been stolen or not. This could not be justified on any basis for any reason. You may also recall testimony from our summer hearings regarding Mr. Trump's efforts to lead the mob to the Capitol himself and his angry altercation in the presidential SUV when the Secret Service told him it was far too dangerous for him to go. As we detailed in testimony from the Metropolitan Police and White House personnel during our July 21st hearing, information about the altercation was widely known, so widely known that one former White House employee with national security responsibilities explained that this information was in fact water cooler talk in the White House complex.
As that professional told us, they remember hearing in the days after January 6th how angry the president was when he was in the limo that afternoon. That professional also testified that they were specifically informed of the --president's irate behavior in the SUV by Mr. Ornato in Mr. Ornato's office. It was Mr. Engel, with Mr. Ornato in that office.
"They'd expressed to me that the president was irate, you know, on the drive up. Mr. Engle did not deny the fact that the president was irate." That of course corresponds closely with the testimony you saw this summer from Cassidy Hutchinson, a Metropolitan Police officer who was in the motorcade, and from multiple sources.
Additionally, after concluding its review of the voluminous additional Secret Service communications from January 5th and January 6th, the committee will be recalling witnesses and conducting further investigative depositions based on that material. Following that activity, we will provide even greater detail in our final report.
And I will also note this. The committee is reviewing testimony regarding potential obstruction on this issue, including testimony about advice given not to tell the committee about this specific topic. We will address this matter in our report.
We also want to remind you now of how security professionals working in the White House complex and who reported to national security officials responded when they learned that Mr. Trump intended to lead the mob to the Capitol. [Begin videotape]
To be completely honest, we were all in a state of shock. Because why? Because — because we just — one, I think the actual physical feasibility of doing it, and then also we all knew what that indicated and what that meant, that this was no longer a rally, that this was going to move to something else if he physically walked to the Capitol.
I — I don't know if you want to use the word insurrection, coup, whatever. We all knew that this would move from a normal democratic, you know, public event into something else. Why were we are alarmed?
The president wanted to lead tens of thousands of people to the Capitol. I think that was enough grounds for us to be alarmed.
President Trump was still considering traveling to the Capitol even after returning to the White House. He knew well before 2:00 PM that a violent riot was underway at the Capitol. He was aware of the ongoing lawlessness. But his motorcade was held on West Executive Avenue outside the White House because he still wanted to join the crowd.
Here's Kayleigh McEnany, the White House press secretary, describing an — an exchange she had with the president as soon as he arrived back at the White House. [Begin videotape]
KAYLEIGH MCENANY:
So, to the best of my recollection, I recall him being — wanting to — saying that he wanted to physically walk and be a part of the march, and then saying that he would ride the beast if — if he needed to, ride in the presidential limo. [End videotape]
From the Secret Service, the Select Committee has also obtained important new evidence on this issue. It shows how frantic this hour must have been for the Secret Service, scrambling to get the president of the United States to back down from a dangerous and reckless decision that put people in harm's way.
Take a look at the Secret Service email from 1:19 PM on January 6th, the minute that President Trump got out of the presidential vehicle back at the White House. As soon as the president left his motorcade, leadership from the Secret Service contacted Bobby Engel, the lead agent for the presidential detail, and warned him that they were "concerned about an OTR," an off the record movement to the Capitol.
The people sworn to protect the safety of the president of the United States and who routinely put themselves in harm's way were convinced that this was a bad idea. Secret Service documents also reveal how agents were poised to take President Trump to the Capitol later that afternoon. Agents were instructed to don their protective gear and prepare for a movement.
A few minutes later, they were told the president would leave for the Capitol in two hours. It wasn't until 1:55 PM that the president's lead Secret Service agent told them to stand down. "We are not doing an OTR to the Capitol." By then rioters had breached the Capitol and were violently attacking the efforts of the brave men and women in law enforcement trying to resist the mob.
President Trump may not have gone to the Capitol on January 6th, but what he did from the White House cannot be justified. While Congressional leaders, both Democrats and Republicans, worked with Vice President Pence to try and address the violence, President Trump refused urgent pleas for help from nearly everyone around him.
And what he did do only made the situation worse. Mr. Chairman, I yield back.
The gentleman yields back. The chair recognizes the gentleman from Maryland, Mr. Raskin, for an opening statement.
JAMIE RASKIN:
Thank you, Mr. Chairman. The president was still exhorting his supporters at the Ellipse to go fight like hell at 12:50, around the time that the first wave of rioters first breached barricades defending the Capitol. Secret Service documents we recently received give a timeline of precisely what the White House knew and when.
At 1:19, the president's Emergency Operations Center sent an e-mail to Secret Service, national security, and military advisers, to the president and vice president informing them that "hundreds of Trump supporters stormed through metal barricades at the back of the Capitol building about 1:00 PM Wednesday, running past security guards and breaking fences.
When the president returned to the White House around 1:20, he entered the Oval Office and was told right then about the onset of violence at the Capitol. From that point until approximately 4:00 PM, over the next two hours and 40 minutes, the president stayed in the White House dining room attached to the Oval Office and watched this unprecedented assault take place at the Capitol.
We have testimony from several members of the president's White House staff establishing that President Trump refused entreaties from his closest advisers and family members to tell his supporters to stand down and leave the Capitol. Here's the testimony of President Trump's White House counsel, Pat Cipollone.
I can't talk about conversations with the president, but I can generically say that I said, you know, people need to be told — there needs to be a public announcement fast that they need to leave the Capitol.
And Pat, could you let us know approximately when you said that?
Approximately when? Almost immediately after I found out people were getting into the Capitol or approaching the Capitol in a way that was — was violent.
Who on the staff did not want people to leave the Capitol?
On the staff?
In the White House.
I — I don't — I can't think of anybody, you know, on that day who didn't want people to get out of the — the Capitol once the — you know, particularly once the violence started, no. I mean --
What about the president?
Well, she said the staff, so I answered.
No, I said in the White House.
Oh, I'm sorry. I — I apologize. I thought you said who on — who else on the staff. Yeah, I — I can't reveal communications, but obviously I think, you know — yeah. [End videotape]
Mr. Cipollone's testimony is corroborated by multiple other White House staff members, including Cassidy Hutchinson. Here's Ms. Hutchinson describing what she heard from Mark Meadows. [Begin videotape]
He had said something to the effect of, you know, you heard him, Pat. He doesn't want to do anything more. He doesn't think they're doing anything wrong. [End videotape]
A former White House employee with national security duties similarly recalled an exchange between Mr. Cipollone and Eric Herschmann about President Trump's inaction against the mob assault underway at the Capitol. Mr. Herschmann said something to Mr. Cipollone. He seemed to relay that, you know, the president didn't want anything done.
Throughout this period, some of the president's most important political allies, family members, and senior staff all begged him to tell his supporters to disperse and go home. They included Sean Hannity, Laura Ingraham, and other allies at Fox News, his son Donald Trump Jr, the House minority leader Kevin McCarthy, others in Congress, and officials in the cabinet and the executive branch.
All of them made appeals to Donald Trump, which he rejected and he ignored. The Select Committee interviewed several people who were in the dining room with Donald Trump that afternoon, and every single one of these witnesses told us that he was watching the violent battles rage on television. He did not call his secretary of defense or the National Guard, the chief of the Capitol Police, or the chief of the Metropolitan Police Department.
And to your knowledge, was the president in that private dining room the whole time that the attack on the Capitol was going on, or did he ever go to — again, only to your knowledge, to the Oval Office, to the White House Situation Room, anywhere else?
To the best of my recollection, he was always in the dining room.
Yeah. What did they say, Mr. Meadows or the president, at all during that brief encounter with you in the dining room? What do you recall? I think they were — everyone was watching the TV. Do you know whether he was watching TV in the dining room when you talked to him on January 6th?
MOLLY MICHAEL:
It's my understanding he was watching television.
When you were in the dining room in these discussions, was that it — was the violence at the Capitol visible on the screen on the — in — on the television?
Yes. [End videotape]
As the president watched the bloody attack unfold on Fox News from his dining room, members of Congress and other government officials stepped into the gigantic leadership void created by the president's chilling and studied passivity that day. What you're about to see is previously unseen footage of Congressional leaders, both Republicans and Democrats, as they were taken to a secure location during the riot.
You'll see how everyone involved was working actively to stop the violence, to get federal law enforcement deployed to the scene, to put down the violence and secure the Capitol complex. Not just Democrats like Speaker Nancy Pelosi and House Majority Leader Steny Hoyer, but Republicans like Vice President Pence, Senate Majority Leader Mitch McConnell, Majority Whip John Thune, and countless other appointees across the administration.
All of them did what President Trump was not doing, what he simply refused to do. Take a listen. [Begin videotape]
We're starting to get surrounded. They're taking the north front scaffolding. Unless we get more munitions, we are not going to be able to hold. The door has been breached and people are gaining access into the Capitol.
NANCY PELOSI:
But you know what? We have got to get — finish the proceedings or else they're going to have the Trump presidency.
USA, USA, USA, USA. Senator Schumer is at a secure location, and they're locked down in the Senate.
There has to be some way we can maintain the sense that people have that there is some security or some confidence that government can function and that we can elect the president of United States. Did we go back into session?
We did go back into session, but now apparently everybody on the floor is putting on tear gas masks to prepare for a breach. I'm trying to get more information.
They're putting on their --
Tear gas masks.
Do you believe this? Do you believe this?
I can't. We need a area for the House members. They're all walking over now through the tunnel. Bring her out here. Hey, boys, we're coming in if you don't bring her out.
CHUCK SCHUMER:
I'm going to call up the f'ing secretary of DOD. We have some Senators who are still in their hideaways. They need massive personnel now. Can you get the Maryland National Guard to come too?
I have something to say, Mr. Secretary. We're — I'm going to call the mayor of Washington DC right now and see what other outreach she has to other police departments, as Steny — Leader Hoyer has mentioned.
Officer down. Get him up. Get him up. Hold him. Get him up. Hold up.
Hi, Governor. This is Nancy. Governor, I don't know if you have been approached about the Virginia National Guard. Mr. Hoyer was connect — speaking to Governor Hogan, but I still think you probably need the Ok of the federal government in order to come in to another jurisdiction. Thank you.
I called the secretary of the Army. His office advised that --
Oh, my gosh, they're just breaking windows. They're doing all --
Can you get your governor to call anyone --
All kinds of — it's really that — they said somebody was shot. It's just — it's just horrendous. And all at the instigation of the president of the United States. Ok, thank you, Governor. I appreciate what you're doing. And if you don't mind, I'd like to stay in touch. Thank you. Thank you.
Virginia Guard has been called in.
You know, I was just talked to Governor Northam, and what he said is they sent 200 state police and a unit of the National Guard. They're breaking windows and going in, obviously ransacking our offices and all the rest of that. That's nothing. The concern we have about personal harm.
Personal safety is — it just transcends everything. But the fact is on any given day, they're breaking the law in many different ways, and quite frankly, much of it at the instigation of the president of the United States. And now if he could — could — at least somebody.
Yeah, why don't you get the president to tell them to leave the Capitol, Mr. Attorney General, in your law enforcement responsibility, a public statement they should all leave.
USA, USA, USA, USA, USA.
This cannot be just we're waiting for so-and-so. We need them there now, whoever you got, Ok?
STENY HOYER:
You have — you also have troops — this is Steny Hoyer, troops --
Ok, so we have a little bit of time to make that decision --
Fort McNair, Andrews Air Force Base --
Other military bases.
Thank you. Thank you, Paul. Bye.
We need active duty, National Guard.
How soon in the future can you have the place evacuated and the whole thing cleaned out?
I don't want to speak for the leadership that's going to be responsible for executing the operation, so I'm not going to say that. Because they are meeting on the ground and they're the experts [Inaudible]
Well, just pretend — just pretend for a moment it was the Pentagon or the White House or some other entity that was under siege. Let me say you can logistically get people there as you make the plan. We're trying to figure out how we can get this job done today. We talked to Mitch about it earlier. He's not in the room right now, but he was with us earlier and said, you know, we want to expedite this and hopefully they could confine it to just one complaint, Arizona, and then we could vote and that would be — you know, then just move forward with the rest of the state.
The overriding wish is to do it at the Capitol. What we are being told very directly is it's going to take days for the Capitol to be Ok again. We've gotten a very bad report about the condition of the House floor, defecation and all that kind of thing as well. I don't think that that's hard to clean up, but I do think it is more from a security standpoint of making sure that everybody is out of the building and how long will that take.
I just got off with the Vice President.
And I got off with the Vice-President Elect.
Ok. But what we left the conversation with, because he said he had the impression from Mitch that Mitch wanted to get everybody back to do it there.
I said, we'll, we're getting a counter point that is — that could take time to clean up the poo poo that they're making all over the — literally and figuratively in the Capitol, and that it may take days to get back.
Nancy, so I'm at the Capitol building. I'm literally standing with the Chief of Police of — you know, the US Capitol Police. He just informed me what you will hear through official channels, Paul Irving, your Sergeant-at-Arms, will inform you that their best information is that they believe that the House and the Senate will be able to reconvene in roughly an hour.
Your Sergeant at Arms will be in touch about the process for getting members back into the building.
Thank you very much, Mr. Vice President. [End videotape]
In this video, you just saw Senator Chuck Schumer urging Acting Attorney General Jeff Rosen to get President Trump to call off the rioters. Of course, acting AG Rosen did take action to defend the government, as did many other officials. But Congressional leadership recognized on a bipartisan basis that President Trump was the only person who could get the mob to end its violent siege of the Congress, leave the Capitol and go home.
Here is Senator McConnell speaking after January 6th about how President Trump abandoned his duties and failed to do his job. [Begin videotape]
MITCH MCCONNELL:
It was obvious that only President Trump could end this. He was the only one who could. Former aides publicly begged him to do so. Loyal allies frantically called the administration. But the President did not act swiftly. He did not do his job. He didn't take steps so federal law could be faithfully executed and order restored.
No. [End videotape]
In the midst of this violent chaos. Kevin McCarthy implored Donald Trump to tell his supporters in the mob to leave the Capitol. And when that didn't work, McCarthy called Trump's adult children to try to get them to intercede with Trump to call off the insurrectionary violence. In our prior hearings, we showed you a description of what McCarthy told Republican Congresswoman Jaime Herrera Butler about his conversation with Trump during the violence.
Another witness, Mick Mulvaney, President Trump's former chief of staff, has also come forward and corroborated her shocking account. [Begin videotape]
JAIME HERRERA BUTLER:
You know, I asked Kevin McCarthy who's the Republican leader about this and — and he said he called --he finally got through to Donald Trump and he said, you have got to get on TV. You've got to get on Twitter. You've got to call these people off. You know what the President said to him? This is as it's happening.
He said, well, Kevin, these aren't my people. You know, these are — these are Antifa. And Kevin responded and said, no, they're your people. They literally just came through my office windows, and my staff are running for cover. I mean, they're running for their lives. You need to call them off. And the President's response to Kevin to me was chilling.
He said, well, Kevin, I guess they're just more upset about the election, you know, theft than you are. And that's — you know, you've seen widespread reports of Kevin McCarthy and the President having a — basically a swearing conversation. That's when the swearing commenced, because the President was basically saying, no, I'm — I'm Ok with this.
MICK MULVANEY:
I had — I had a conversation at some point in the day or week after the — the riot with Kevin McCarthy. Yeah, It was very similar to what Jaime had, the conversation she had retold about how he called and asked the President to get them to stop. And the President told him something along the lines of, Kevin, maybe these people are just more angry about this than you are, maybe more upset.
I had the conversation similar to that with Kevin in the days and weeks after the riot. [End videotape]
And we know how Kevin McCarthy described President Trump's conduct, both in public and in private. [Begin Videotape]
KEVIN MCCARTHY:
The President bears responsibility for Wednesday's attack on Congress by mob rioters. He should have immediately denounced the mob when he saw what was unfolding. These facts require immediate action by President Trump. Accept his share of responsibility, quell the brewing unrest, and ensure President-elect Biden is able to successfully begin his term.
But let me be very clear to all of you and I've been very clear to the President; he bears responsibilities for his words and actions, no ifs, ands or buts. I asked him personally today, does he hold responsibility for what happened? Does he feel bad about what happened? He told me, he does have some responsibility for what happened and he need to acknowledge that.
2:24 p.m. Knowing the deadly riot was now bearing down on his own Vice President, President Trump composed and sent a tweet attacking Vice President Pence, accusing him of cowardice for not unilaterally rejecting Electoral College votes for Joe Biden and simply handing Trump the presidency. The impact of that tweet was foreseeable and predictable.
It further inflamed the mob which was chanting, hang Mike Pence, and provoked them to even greater violence. This deliberate decision to further enrage the mob against Vice President Pence cannot be justified by anything that President Trump might have thought about the election. The tweet came precisely at the time Pence's Secret Service detail was most seriously concerned for the Vice President's physical safety.
We've obtained new documents from the Secret Service, real time chats that underscore the threat they knew the Vice President would be facing because of the President's escalating incitement of the mob. After Trump's tweet, one agent in the Secret Services Intelligence Division immediately warned, POTUS just tweeted about Pence; probably not going to be good for Pence.
Another agent reported the dramatic impact of Trump's anti-Pence tweet on his followers. POTUS said "he lacked courage; over 24,000 likes in under 2 minutes." Employees at Twitter were nervously monitoring the situation. They knew that certain Twitter users were rioting at the Capitol and tweeting about it at the same time.
As the afternoon progressed, the company detected a surge in violent hashtags on the platform, including lines of lethal incitement like, execute Mike Pence. Listen to this former Twitter employee, Anika Navaroli, who first came to the committee anonymously, but has now bravely agreed to be named because she wants to speak out about the magnitude of the threats facing our people.
And you're also seeing content on the platform at the time that was driving towards the Vice President hashtag that came to pass.
ANIKA COLLIER NAVAROLI:
Yes. They were literally calling for his execution.
As this tweet was going on.
Yes, and after in response to this, too. Because I think as many as many of Donald Trump's tweets did, it again fanned the flames. And it was individuals who were already constructing gallows, who were already willing, able and wanting to execute someone and looking for someone to be killed. Now, the individual was called upon then to begin this coup is now pointing the finger at another individual while they're ready to do this.
Here's a small sample of the reactions that President Trump's fanned the flames tweet provoked among Capitol rioters in real time. [Begin videotape]
What percentage of the crowd has gone to the Capitol?
JESSICA WATKINS:
100%. It has — it has spread like wildfire that Pence has betrayed us and everybody is marching on the Capitol, all million of us. It's insane.
Mike Pence will not stick up for Donald Trump. Mike Pence traitor. Mike Pence has screwed us, in case you haven't heard yet. What happened? What happened? I keep hearing that Mike Pence has screwed us. That's the word I keep hearing reports that Mike Pence has screwed us. [End videotape]
Between 2:30 and 2:35, within 10 minutes of President Trump's tweet, thousands of rioters overran the line that the Metropolitan Police Force's Civil Disturbance Unit was holding on the west side of the Capitol. This was the first time in the history of the Metropolitan Police Department that a security line like that had ever been broken.
President Trump's conduct that day was so shameful and so outrageous that it prompted numerous members of the White House staff and other Trump appointees to resign. In prior hearings, you've heard Deputy National Security Adviser Matt Pottinger and Deputy White House Press Secretary Sarah Matthews explain why they felt compelled to resign on that day.
Since then, we've spoken to more high ranking officials like President Trump's envoy to Northern Ireland and former Chief of Staff Mick Mulvaney, and Transportation Secretary Elaine Chao, who resigned after the 6th in protest of Trump's misconduct and to dissociate themselves from his role in the violence.
Take a listen to what they had to say. [Begin videotape]
I was stunned by violence, and I was stunned by the President's apparent indifference to the violence. And now is the time for the President to be presidential. I thought he failed at doing it. I thought he failed at a critical time to be the sort of leader that the nation needed.
ELAINE CHAO:
I think the events at the Capitol, however they occurred, were shocking. And it was something that, as I mentioned in my statement, that I could not put aside. And at a particular point, the events were such that it was impossible for me to continue given my personal values and my philosophy. I came as an immigrant to this country.
I believe in this country. I believe in a peaceful transfer of power. I believe in democracy. And so I was a — it was a decision that I made on my own. [End videotape]
When security assistance began to arrive at the Capitol and the tide turned against the insurrection, President Trump finally gave his painfully belated instruction at 4:17 p.m. So after multiple hours of rioting and more than 100 serious injuries suffered by our law enforcement officers, the crowd finally began to disperse.
Listen carefully to what they said as they decided to leave the Capitol. [Begin videotape]
We are delivering the President's message. Donald Trump has asked everybody to go home. That's our order. [Inaudible] He says, go home. [End videotape]
Finally, at 6:01, President Trump tweeted again not to condemn the mass violence in any way, but rather to excuse and glorify it. Significantly, he made it clear that he considered the violence perfectly foreseeable and predictable. Check it out. These are the things and events that happen when a sacred landslide election victory is so unceremoniously, viciously, stripped away from great patriots who have been badly unfairly treated for so long.
These are the things that happen, he said, giving the whole game away. Trump was telling us that the Vice President, the Congress, and all the injured and wounded cops, some of whom are with us today, got what was coming to us. According to Trump. January 6 should not be a day that lives in shame in infamy in our history, but rather in glory.
Remember this day forever, he wrote proudly, as if he were talking about D-Day or the Battle of Yorktown. Trump did nothing to stop the deadly violence for obvious reasons. He thought it was all justified. He incited it and he supported it. [Begin videotape]
Would it have been possible at any moment for the president to walk down to the podium in the briefing room and — and tell — talk to the nation at any time between when you first gave him that advice at 2:00 and 4:17 when — the video statement? Would that have been possible?
Would have been possible?
Well, yes, it would have been possible.
SARAH MATTHEWS:
If the president had wanted to make a statement and address the American people, he could have been on camera almost instantly. And conversely, the White House press corps has offices that are located directly behind the briefing room. And so, if he had wanted to make an address from the Oval Office, we could have assembled the White House press corps probably in a matter of minutes to get them into the Oval for him to do an on camera address.
Mr. Chairman, nothing in law or fact could justify the president's failure to act. [Begin videotape]
And — and I assume you also would agree the president has a particular obligation to take care that the laws be faithfully executed?
That is one of the president's obligations, correct. [End videotape]
Mr. Chairman, in numerous places, our Constitution strongly opposes insurrection and rebellion. Article I gives Congress the power to call forth the militia to suppress insurrections. Section 3 of the 14th Amendment disqualified from holding federal and state office anyone who has sworn an oath to defend the Constitution, but betrays it by engaging in insurrection or rebellion.
It was President Lincoln, at the start of the Civil War in 1861, who best explained why democracy rejects insurrection. Insurrection, he said, is a war upon the first principle of popular government, the rights of the people. American democracy belongs to all the American people, not to a single man. Thank you, Mr. Chairman.
I yield back.
The gentleman yields back. During this committee's first hearing in July of last year, our witnesses were four police officers who helped repel the riots of January 6th. We asked them what they hoped to see the committee accomplish over the course of our investigation. Officer Grinnell wanted to know why the rioters were made to believe that the election process was rigged.
Officer Fanone asked us to look into the actions and activities that resulted in the day's events. Officer Hodges was concerned about whether anyone in power had a role. Officer Dunn put it simply, get to the bottom of what happened. We've worked for more than a year to get those answers. We've conducted more than a thousand interviews and depositions.
We received and reviewed hundreds of thousands of pages of documents. Thanks to the tireless work of our members and investigators, we've left — we have left no doubt, none, that Donald Trump led an effort to up end American democracy that directly resulted in the violence of January 6th. He tried to take away the voice of the American people in choosing their president and replace the will of the voters with his will to remain in power.
He is the one person at the center of the story of what happened on January 6th, so we want to hear from him. The committee needs to do everything in our power to tell the most complete story possible and provide recommendations to help ensure nothing like January 6th ever happens again. We need to be fair and thorough and gain a full context for the evidence we've obtained.
But the need for this committee to hear from Donald Trump goes beyond our fact finding. This is a question about accountability to the American people. He must be accountable. He is required to answer for his actions. He's required to answer to those police officers who put their lives and bodies on the line to defend our democracy.
He's required to answer to those millions of Americans who votes he wanted to throw out as part of his scheme to remain in power. And whatever is underway to ensure this accountability under law, this committee will demand a full accounting to every American person of the events of January 6th. So, it is our obligation to seek Donald Trump's testimony.
There's precedent in American history for Congress to compel the testimony of a precedent — president. There's also precedent for presidents to provide testimony and documentary evidence to Congressional investigators. We also recognize that a subpoena to a former president is a serious and extraordinary action.
That's why we want to take this step in full view of the American people, especially because the subject matter at issue is so important to the American people and the stakes are so high for our future and our democracy. And so, I recognize the Vice Chair, Ms. Cheney of Wyoming, to offer a motion.
Mr. Chairman, pursuant to today's notice, I send to the desk a committee resolution and ask for its immediate consideration.
The clerk will report the resolution.
Committee Resolution 1, resolved, that the chairman be and is hereby directed to subpoena Donald J. Trump for documents and testimony in connection with the January 6th attack on the United States Capitol, pursuant to Section 5(c4) of House Resolution 503 and clause 2(m) of Rule XI of the rules of the House of Representatives.
The gentlewoman from Wyoming is recognized on her resolution.
Thank you, Mr. Chairman. Mr. Chairman, our committee now has sufficient information to answer many of the critical questions posed by Congress at the outset. We have sufficient information to consider criminal referrals for multiple individuals and to recommend a range of legislative proposals to guard against another January 6th, but a key task remains.
We must seek the testimony under oath of January 6th's central player. More than 30 witnesses in our investigation have invoked their Fifth Amendment right against self-incrimination, and several of those did so specifically in response to questions about their dealings with Donald Trump directly. Here are a few examples.
This is Roger Stone with Oath Keepers at the Willard Hotel on the morning of January 6th, and here is Mr. Stone testifying before our committee. [Begin videotape]
Did you speak to President Trump on his private cell phone on either January 5th or January 6th?
Once again, on the advice of counsel, I will assert my Fifth Amendment right to respectfully decline to answer your question. [End videotape]
This is General Michael Flynn walking with Oath Keepers on December 12, 2020, and here is General Flynn's testimony before our committee. [Begin videotape]
Did you, General Flynn, talk to President Trump at any point on January 6, 2021?
MICHAEL FLYNN:
The fifth. [End videotape]
Here is John Eastman fraudulently instructing tens of thousands of angry protesters that the Vice President could change the election outcome on January 6th. Later on this same day, Dr. Eastman acknowledged in writing that Donald Trump knew what he was attempting was illegal. Here is John Eastman testifying before our committee.
Did President Trump authorize you to discuss publicly your January 4, 2021 conversation with him?
JOHN EASTMAN:
Fifth.
So is it your position that you can discuss in the media direct conversations you had with the President of the United States, but you will not discuss those same conversations with this committee.
Fifth. [End videotape]
Here is Jeff Clark who conspired with Donald Trump to corrupt the Department of Justice. President Trump wanted to appoint Jeff Clark as acting attorney general. And as you can see in this call log we obtained from the National Archives, he did so. And here is Mr. Clark testifying before our committee. [Begin videotape]
Mr. Clark, when did you first talk directly with President Trump?
JEFFREY CLARK:
Mr. Clark, did you discuss with President Trump allegations of fraud in the 2020 election?
Other witnesses have also gone to enormous lengths to avoid testifying about their dealings with Donald Trump. Steve Bannon has been tried and convicted by a jury of his peers for contempt of Congress. He is scheduled to be sentenced for this crime later this month. Criminal proceedings regarding Peter Navarro continue.
And Mark Meadows, Donald Trump's former chief of staff, has refused to testify based upon executive privilege. The committee's litigation with him continues. Mr. Chairman, at some point the Department of Justice may well unearth the facts that these and other witnesses are currently concealing. But our duty today is to our country and our children and our Constitution.
We are obligated to seek answers directly from the man who set this all in motion. And every American is entitled to those answers, so we can act now to protect our Republic. So this afternoon, I am offering this resolution that the committee direct the chairman to issue a subpoena for relevant documents and testimony under oath from Donald John Trump in connection with the January 6th attack on the United States Capitol.
Thank you, Mr. Chairman. I yield back.
The gentlelady yield back. If there's no further debate, the question is on agreeing to the resolution. Those in favor will say aye.
Those opposes, no. In the opinion of the Chair, the ayes have it.
Mr. Chairman, I request a recorded vote.
A recorded vote is requested. The clerk will call the roll.
Ms. Cheney?
Ms. Cheney, aye. Ms. Lofgren?
Ms. Lofgren, aye. Mr. Schiff?
Mr. Schiff, aye. Mr. Aguilar?
Mr. Aguilar, aye. Mrs. Murphy?
Mrs. Murphy, aye. Mr. Raskin?
Mr. Raskin, aye. Mrs. Luria?
Mrs. Luria, aye. Mr. Kinzinger?
Mr. Kinzinger, aye. Mr. Chairman?
Mr. Chairman, aye.
The Clerk will report the vote.
Mr. Chairman, on this vote there are 9 ayes and zero nos.
The resolution is agreed to. Without objection, a motion to reconsider is laid on the table. The Chair requests that those in the hearing room remain seated until the Capitol Police have escorted members from the room. Without objection, the committee stands adjourned.
List of Panel Members PANEL MEMBERS:
REP. BENNIE THOMPSON (D-MISS.), CHAIRMAN
REP. ZOE LOFGREN (D-CALIF.)
REP. ADAM SCHIFF (D-CALIF.)
REP. PETE AGUILAR (D-CALIF.)
REP. STEPHANIE MURPHY (D-FLA.)
REP. JAMIE RASKIN (D-MD.)
REP. ELAINE LURIA (D-VA.)
REP. LIZ CHENEY (R-WYO.), VICE CHAIRWOMAN
REP. ADAM KINZINGER (R-ILL.)
Corrected: October 18, 2022 at 10:00 PM MDT
A previous version of this transcript incorrectly attributed a quote from Roger Stone to Rep. 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With Title 42 set to end, questions loom about the future of migrants and asylum
By Joel Rose
Published December 8, 2022 at 3:02 AM MST
Carolina Cuellar/TPR
Haitian migrants gather outside a shelter in Reynosa, Mexico earlier this week. Immigration authorities are bracing for an influx of migrants when pandemic border restrictions end.
Updated December 9, 2022 at 7:47 AM ET
Just across the border from South Texas, hundreds of migrants are living in small, makeshift camps scattered around Reynosa, Mexico.
Many are hoping to apply for asylum in the U.S. but they're blocked, for now, by the pandemic border restrictions known as Title 42, which allows immigration authorities to quickly expel many migrants without allowing them to apply for asylum while in the U.S.
There's a lot of confusion in the camp about Title 42 and whether it's really ending or not on Dec. 21, as ordered by a federal judge.
"People know it ain't going to be easy for us," says Nicodemus Pierre-Louis, who is originally from Haiti. "We don't really know. We're just waiting to see what's going to happen."
Another Haitian, who identifies himself only by his first name, Kendis, says he's eager to cross the border as soon as Title 42 is lifted.
"I need asylum," he says in Spanish. "If I'm allowed to apply for asylum, I'm going. No problem."
There's some confusion on this side of the border, too. The federal judge who ordered the policy to come to a close ruled that the Title 42 is unlawful. The ruling was hailed as a victory by immigrant advocates, who have long argued that Title 42 was intended to block access to asylum protections under the pretense of protecting public health during the worst parts of the pandemic.
The Biden administration said this week that it will appeal that ruling, but will not seek to keep Title 42 in place while the case plays out. The appeal, instead, is about preserving the legal authority of the Centers for Disease Control and Prevention, the agency that originally instituted the policy, says an administration official who asked not to be named because they were not authorized to speak for this story.
With the restrictions set to lift in less than two weeks, federal and local officials are bracing for an influx of migrants who've been waiting in border communities from Reynosa to Tijuana. That looming deadline has also prompted Congress and the White House to float proposals to extend Title 42, or limit access to asylum in other ways. And immigrant advocates say they worry that the right to seek asylum is still in jeopardy.
/ Carolina Cuellar/TPR
A street near the Senda de Vida migrant shelter in Reynosa, Mexico.
Comparisons to Trump's asylum policies
In particular, advocates are concerned that the Biden administration is considering an asylum policy similar to one originally devised by the administration of former President Donald Trump, as reported by Axios and other outlets.
That was known as the transit ban. It would have denied asylum to migrants if they had already passed through other countries on the way to the U.S. without first seeking protection in those countries. It was eventually blocked in court.
"It's deeply disappointing that they could even be considering this policy," says Robyn Barnard, a lawyer with the non-profit Human Rights First during a call with reporters this week. "If the administration makes the mistake of going down this path, we will fight tooth and nail against it, again."
The White House disputes that the policies under discussion now would work the same way as Trump's transit ban. The Biden administration prefers to compare the proposals under consideration to a new program for Venezuelans that was announced in October.
In that case, the administration created a legal pathway for up to 24,000 Venezuelans, but only those who apply from outside the U.S. qualify. At the same time, the administration began turning away Venezuelans under Title 42 if they crossed the border illegally.
Haitian migrants at a makeshift encampment near the Rio Grande in Reynosa, Mexico. Hundreds of migrants are living in small camps scattered around the city.
Asylum system under strain
Immigration hardliners have been trying for years to limit who can apply for asylum. They argue that many migrants are abusing the U.S. system because they know they'll be able to live and work in the country for years while waiting for their claims to be heard in immigration court.
"If the asylum system is not fixed, this won't end," said U.S. Sen. Rob Portman, a Republican from Ohio, during a congressional hearing earlier this month. "We've got a crisis. And if we don't fix this crisis at the border, we'll continue to see these same results."
That echoes the rhetoric of the Trump administration, which tried a broad range of policies to limit access to asylum.
The Biden administration has launched a new system aimed at deciding asylum claims more quickly, with asylum officers at the Department of Homeland Security hearing some cases initially instead of first sending them to overloaded immigration judges.
But that's still a relatively small pilot program, while the number of migrant apprehensions climbed to record levels last year, straining the resources of immigration authorities and border communities.
Haitian migrants gather around a reporter in Reynosa, Mexico earlier this week. There's a lot of confusion in the camp about Title 42, and whether it's ending or not.
A possible extension of Title 42
U.S. Sens. Kyrsten Sinema, a (soon-to-be former) Democrat from Arizona, and Thom Tillis, a Republican from North Carolina, reportedly want to continue Title 42 restrictions temporarily as a part of a broader deal that would also dedicate more funds for border security and create a pathway to citizenship for young immigrants known as Dreamers.
Their proposal got a chilly reception from Senate Republicans, who want to see border apprehensions come down from their near-record highs before considering any reforms to the immigration system.
Meanwhile, immigrant advocates welcomed the idea of bipartisan negotiations, but not the extension of Title 42.
"If we just keep trying to extend Title 42, we're only putting a Band-Aid on what is something that just needs far greater attention," says Angela Kelley, a former Biden administration advisor who's now with the American Immigration Lawyers Association.
Many of the migrants coming to the border are fleeing failed states in Venezuela, Nicaragua, Cuba and Haiti, Kelley says. She wants to see the Biden administration open more legal pathways so that these migrants don't have to cross the border illegally, citing the new program for Venezuelans as an example.
"If you create legal pathways for people, people would much rather come with, you know, a visa than with a smuggler," Kelley says, "rather than just trying to build either metaphorical or actual walls to keep people out. That won't work."
Joel Rose
Joel Rose is a correspondent on NPR's National Desk. He covers immigration and breaking news.
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In-N-Out brings 'animal style' to Tennessee with plans to expand further in the U.S.
By Joe Hernandez
Frederic J. Brown
Drivers wait in the drive-thru line at an In-N-Out Burger restaurant in Alhambra, California, on August 30, 2018.
In-N-Out Burger is "double-doubling" down on growing its business, announcing it would open new locations in Tennessee, the farthest east the company has ever gone.
The California-based fast food chain – where you can order your burger "Animal Style" off the company's "not-so-secret menu" – said Tuesday that it would open new restaurants in Tennessee as well as an "eastern territory office" in Franklin, just south of Nashville.
In-N-Out owner and president Lynsi Snyder – who is also the only granddaughter of founders Harry and Esther Snyder – said the company was eager to expand into Tennessee.
"In every decision I make, I always consider what my family would want. I have no doubt that my grandparents, dad and uncle would be proud of this decision to grow our Associate family and serve even more amazing Customers beginning in Nashville and the surrounding areas," Snyder said in a statement.
State officials, who cheered the announcement, said In-N-Out's planned administrative office in Tennessee is expected to be a $125.5 million investment that will create 277 new jobs in Williamson County.
"I'm proud to welcome In-N-Out Burger, an iconic American brand, to the Volunteer State," Gov. Bill Lee said in a statement. "Tennessee's unmatched business climate, skilled workforce and central location make our state the ideal place for this family-run company to establish its first eastern United States hub."
The iconic burger joint that began in 1948 as a 10' x 10' stand in Baldwin Park, Calif., now boasts a total of 385 locations across the state as well as in Nevada, Arizona, Utah, Texas, Oregon and Colorado.
In-N-Out plans to complete construction on its office in Franklin and open its new restaurants in and around Nashville by 2026.
Snyder told the Associated Press that the company will likely expand across the region, too, since deliveries from its Texas warehouse would cross through multiple nearby states.
It's not the only fast food chain with a devoted fanbase expanding eastward. The Texas-based Whataburger opened its first restaurants in Tennessee last year.
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Big Basin Redwoods State Park partially reopens July 22
By Taila Lee
Big Basin State Park, the oldest state park in California, reopens partially on July 22. (Photo credit: Big Basin Redwoods State Park)
BOULDER CREEK, Calif. - Big Basin Redwoods State Park will reopen with limited public access on July 22, almost two years after the CZU Fire unleashed extensive damage.
The park requires reservations for limited day-use access and will be open from 8 a.m. to sunset. Entry is $8 including the $2 reservation fee, and 45 reservation spots will be available daily.
Most of the park remains closed to the public due to fire-related safety precautions, but the Redwood Loop Trail, Dool Trail and other small sections of the park will be available for visitors. An interim visitor center will be open, as the CZU fire destroyed all the park's facilities.
In August 2020, the CZU Lightning Complex Fire burned over 97% of the park, burning about 18,000 acres and destroying most structures.
"The changes to Big Basin are profound, but the forest is starting to recover and it’s amazing to witness," said California State Parks Santa Cruz District Superintendent Chris Spohrer in a statement. "We’re excited to be able to welcome visitors back on a limited basis as we near the two-year anniversary of the fire."
A video, produced by the Mountain Parks Foundation, documents the fire and the changes that have taken place at the park in the past two years. "The video was very cathartic to create, it was very difficult to experience the fire," said Elizabeth Hammack, a state parks interpreter and co-creator of the video. "I, along with our historian, realized that this is history. This is part of Big Basin's history and we need to document this story," Hammack said.
Acquired in 1902, Big Basin Redwoods State Park is California's oldest state park. The park has about 18 miles of hiking trails, and offers guided walks for environmental learning. Mountain bikes are permitted on some roads.
"Managing parks for a healthy future for environmental systems as well as humanity could not be more important at this moment in history," said California State Parks Director Armando Quintero in a statement. "We welcome all Californians and visitors from around the world as we enter the next era for this iconic and much beloved state park."
Reservations will be available online or by phone (831) 338-8867.
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Suspects arrested in connection with series of vehicle break-ins in city; 13-year-old boy also a suspect
At least three Watsonville schools to close Monday for storms
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Inbound 2012: What I Learned from 30 Minutes with C.C. Chapman
By Brianne Carlon RushAug 28 /2012
Tucked away in the corner of the sponsor hall at Inbound 2012, there was a small Q&A happening with C.C. Chapman. It turned out to be a half hour spent learning small nuggets of pure treasure. I wasn’t planning on attending, but I am sure glad I did. If you couldn’t attend (and I am sure you didn’t since there were only about seven of us lucky enough to), here are a few of my favorite lessons about inbound marketing, content and life learned from 30 minutes with C.C. Chapman.
Make Your Customers the Heroes
Thanks C.C.! What a great concept for those of us who are constantly asking, “What should we write about?” Find customers who have a great story to tell, then put them front and center. People like hearing about products and services from other people; what works, what doesn’t work. What they recommend or recommend you stay away from. So seeing a real person (a real customer) talk about your product or service speaks multitudes. So get out there, get friendly with your customers and make them feel like a million bucks by helping them tell their stories.
The Importance of Your Blogs’ Voice
Sometimes we rely on other people to write our content. It is OK. We have all been there; we have all done it. In fact, here at Kuno, we offer content writing services. But what we strive to do for our clients is to create or work within a voice for each brand. Why? Because it is important to your audience. In their personal lives, business execs and decision makers read something that they actually enjoy, like ESPN or Marie Claire online. Why not emulate that? Find a voice that works for your brand and stick to it.
Don’t Forget to Listen!
Nike is known for listening to their customers, audiences and people who are just talking about them. When C.C. wrote a blog about NikeFuel, Nike found it, asked if it could retweet the article, and then promoted it. Awesome! (Nike, if you are listening, feel free to retweet me!) Make sure you are listening to what people are saying about your company and your product. Building that relationship is crucial. And once consumers like you and trust you, they will be loyal.
It’s OK to Live the Life that Makes You Happy
This lesson is more of a personal note, but a good one for sure. C.C. works for himself from his home. He left the big corporate world and couldn't be happier. “No one told me I couldn’t do it. If you work really hard and love what you do, amazing things will happen. It is not easy, but it is the best thing in the world.” He will tell you more about it in his new book, Amazing Things Will Happen, due out before Christmas.
Thanks for taking time to speak at Inbound 2012, C.C.. We learned a great deal. And I am looking forward to the book!
Brianne Carlon Rush
Brianne works with Fortune 500 clients to strategize digital marketing efforts that help sales teams close deals faster. Additionally, she focuses on Kuno’s sales and marketing alignment and employee empowerment. Prior to Kuno, Brianne helped market OverDrive, the leading digital reading platform for libraries and schools, and was the youngest person to be promoted to managing editor position at MacFadden Performing Arts Media in NYC. | 2023-14/0000/en_head.json.gz/1361 | {"url": "https://www.kunocreative.com/blog/bid/78205/inbound-2012-what-i-learned-from-30-minutes-with-c-c-chapman", "partition": "head_middle", "language": "en", "source_domain": "www.kunocreative.com", "date_download": "2023-03-20T10:38:59Z", "digest": "sha1:DURDC5YGTP2QBY47M2VO54GQKFBVOGRH"} | {"ccnet_length": [[0, 3274, 3274.0]], "ccnet_original_length": [[0, 3274, 5456.0]], "ccnet_nlines": [[0, 3274, 14.0]], "ccnet_original_nlines": [[0, 3274, 136.0]], "ccnet_language_score": [[0, 3274, 0.96]], "ccnet_perplexity": [[0, 3274, 280.9]], "ccnet_bucket": [[0, 3274, 0.0]], "rps_doc_curly_bracket": [[0, 3274, 0.0]], "rps_doc_ldnoobw_words": [[0, 3274, 0.0]], "rps_doc_lorem_ipsum": [[0, 3274, 0.0]], "rps_doc_stop_word_fraction": [[0, 3274, 0.40651558]], "rps_doc_ut1_blacklist": [[0, 3274, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3274, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3274, 0.02545314]], "rps_doc_frac_chars_dupe_6grams": [[0, 3274, 0.02545314]], "rps_doc_frac_chars_dupe_7grams": [[0, 3274, 0.02545314]], "rps_doc_frac_chars_dupe_8grams": [[0, 3274, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3274, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3274, 0.00617046]], "rps_doc_frac_chars_top_3gram": [[0, 3274, 0.01504049]], "rps_doc_frac_chars_top_4gram": [[0, 3274, 0.01542615]], "rps_doc_frac_all_caps_words": [[0, 3274, 0.03824363]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3274, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3274, 0.15864023]], "rps_doc_frac_unique_words": [[0, 3274, 0.49230769]], "rps_doc_mean_word_length": [[0, 3274, 4.43247863]], "rps_doc_symbol_to_word_ratio": [[0, 3274, 0.0]], "rps_doc_unigram_entropy": [[0, 3274, 5.27483566]], "rps_doc_word_count": [[0, 3274, 585.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 63, 0.0], [63, 98, 0.0], [98, 579, 1.0], [579, 610, 0.0], [610, 1170, 1.0], [1170, 1206, 0.0], [1206, 1728, 1.0], [1728, 1752, 1.0], [1752, 2226, 1.0], [2226, 2272, 0.0], [2272, 2698, 1.0], [2698, 2816, 1.0], [2816, 2836, 0.0], [2836, 3274, 1.0]], "rps_lines_javascript_counts": [[0, 63, 0.0], [63, 98, 0.0], [98, 579, 0.0], [579, 610, 0.0], [610, 1170, 0.0], [1170, 1206, 0.0], [1206, 1728, 0.0], [1728, 1752, 0.0], [1752, 2226, 0.0], [2226, 2272, 0.0], [2272, 2698, 0.0], [2698, 2816, 0.0], [2816, 2836, 0.0], [2836, 3274, 0.0]], "rps_lines_num_words": [[0, 63, 11.0], [63, 98, 6.0], [98, 579, 90.0], [579, 610, 5.0], [610, 1170, 97.0], [1170, 1206, 6.0], [1206, 1728, 98.0], [1728, 1752, 4.0], [1752, 2226, 82.0], [2226, 2272, 10.0], [2272, 2698, 85.0], [2698, 2816, 23.0], [2816, 2836, 3.0], [2836, 3274, 65.0]], "rps_lines_numerical_chars_fraction": [[0, 63, 0.10169492], [63, 98, 0.18181818], [98, 579, 0.01290323], [579, 610, 0.0], [610, 1170, 0.0], [1170, 1206, 0.0], [1206, 1728, 0.0], [1728, 1752, 0.0], [1752, 2226, 0.0], [2226, 2272, 0.0], [2272, 2698, 0.0], [2698, 2816, 0.03603604], [2816, 2836, 0.0], [2836, 3274, 0.00696056]], "rps_lines_start_with_bulletpoint": [[0, 63, 0.0], [63, 98, 0.0], [98, 579, 0.0], [579, 610, 0.0], [610, 1170, 0.0], [1170, 1206, 0.0], [1206, 1728, 0.0], [1728, 1752, 0.0], [1752, 2226, 0.0], [2226, 2272, 0.0], [2272, 2698, 0.0], [2698, 2816, 0.0], [2816, 2836, 0.0], [2836, 3274, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 63, 0.12698413], [63, 98, 0.14285714], [98, 579, 0.03326403], [579, 610, 0.12903226], [610, 1170, 0.01785714], [1170, 1206, 0.13888889], [1206, 1728, 0.03639847], [1728, 1752, 0.125], [1752, 2226, 0.02531646], [2226, 2272, 0.17391304], [2272, 2698, 0.03286385], [2698, 2816, 0.05932203], [2816, 2836, 0.15], [2836, 3274, 0.03881279]], "rps_doc_ml_palm_score": [[0, 3274, 0.04437298]], "rps_doc_ml_wikipedia_score": [[0, 3274, null]], "rps_doc_ml_wikiref_score": [[0, 3274, 0.02380413]], "rps_doc_books_importance": [[0, 3274, -119.81849591]], "rps_doc_openwebtext_importance": [[0, 3274, 2.43231097]], "rps_doc_wikipedia_importance": [[0, 3274, -344.32527845]], "rps_doc_num_sentences": [[0, 3274, 54.0]]} |
Review Article| Volume 29, ISSUE 4, P635-647, December 2009
Developments in Immunologic Assays for Respiratory Viruses
Marie Louise Landry, MD
Marie Louise Landry
Department of Laboratory Medicine, Yale University School of Medicine, PO Box 208035, 333 Cedar Street, New Haven, CT 06520-8035.
Department of Laboratory Medicine, Yale University School of Medicine, PO Box 208035, 333 Cedar Street, New Haven, CT 06520-8035, USA
Department of Laboratory Medicine, Yale New Haven Hospital, Clinical Virology Laboratory, New Haven, 20 York Street, CT 06504, USA
DOI:https://doi.org/10.1016/j.cll.2009.07.003
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Lateral flow assay | 2023-14/0000/en_head.json.gz/1362 | {"url": "https://www.labmed.theclinics.com/article/S0272-2712(09)00067-5/fulltext", "partition": "head_middle", "language": "en", "source_domain": "www.labmed.theclinics.com", "date_download": "2023-03-20T09:25:19Z", "digest": "sha1:PDYMHOTXC6557KEOZLSEIN6OQLXJRHA6"} | {"ccnet_length": [[0, 856, 856.0]], "ccnet_original_length": [[0, 856, 4013.0]], "ccnet_nlines": [[0, 856, 11.0]], "ccnet_original_nlines": [[0, 856, 165.0]], "ccnet_language_score": [[0, 856, 0.7]], "ccnet_perplexity": [[0, 856, 293.0]], "ccnet_bucket": [[0, 856, 0.0]], "rps_doc_curly_bracket": [[0, 856, 0.0]], "rps_doc_ldnoobw_words": [[0, 856, 0.0]], "rps_doc_lorem_ipsum": [[0, 856, 0.0]], "rps_doc_stop_word_fraction": [[0, 856, 0.10119048]], "rps_doc_ut1_blacklist": [[0, 856, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 856, 0.29671897]], "rps_doc_frac_chars_dupe_5grams": [[0, 856, 0.34522111]], "rps_doc_frac_chars_dupe_6grams": [[0, 856, 0.29671897]], "rps_doc_frac_chars_dupe_7grams": [[0, 856, 0.29671897]], "rps_doc_frac_chars_dupe_8grams": [[0, 856, 0.29671897]], "rps_doc_frac_chars_dupe_9grams": [[0, 856, 0.29671897]], "rps_doc_frac_chars_top_2gram": [[0, 856, 0.04564907]], "rps_doc_frac_chars_top_3gram": [[0, 856, 0.09415121]], "rps_doc_frac_chars_top_4gram": [[0, 856, 0.12838802]], "rps_doc_frac_all_caps_words": [[0, 856, 0.06547619]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 856, 0.0]], "rps_doc_frac_no_alph_words": [[0, 856, 0.33928571]], "rps_doc_frac_unique_words": [[0, 856, 0.5862069]], "rps_doc_mean_word_length": [[0, 856, 6.04310345]], "rps_doc_symbol_to_word_ratio": [[0, 856, 0.0]], "rps_doc_unigram_entropy": [[0, 856, 4.04974434]], "rps_doc_word_count": [[0, 856, 116.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 60, 0.0], [60, 119, 0.0], [119, 143, 0.0], [143, 163, 0.0], [163, 293, 1.0], [293, 427, 0.0], [427, 558, 0.0], [558, 604, 0.0], [604, 684, 0.0], [684, 838, 0.0], [838, 856, 0.0]], "rps_lines_javascript_counts": [[0, 60, 0.0], [60, 119, 0.0], [119, 143, 0.0], [143, 163, 0.0], [163, 293, 0.0], [293, 427, 0.0], [427, 558, 0.0], [558, 604, 0.0], [604, 684, 0.0], [684, 838, 0.0], [838, 856, 0.0]], "rps_lines_num_words": [[0, 60, 9.0], [60, 119, 7.0], [119, 143, 4.0], [143, 163, 3.0], [163, 293, 19.0], [293, 427, 20.0], [427, 558, 19.0], [558, 604, 1.0], [604, 684, 9.0], [684, 838, 22.0], [838, 856, 3.0]], "rps_lines_numerical_chars_fraction": [[0, 60, 0.24074074], [60, 119, 0.0], [119, 143, 0.0], [143, 163, 0.0], [163, 293, 0.14754098], [293, 427, 0.14285714], [427, 558, 0.05645161], [558, 604, 0.45454545], [604, 684, 0.0], [684, 838, 0.0], [838, 856, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 60, 0.0], [60, 119, 0.0], [119, 143, 0.0], [143, 163, 0.0], [163, 293, 0.0], [293, 427, 0.0], [427, 558, 0.0], [558, 604, 0.0], [604, 684, 0.0], [684, 838, 0.0], [838, 856, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 60, 0.16666667], [60, 119, 0.08474576], [119, 143, 0.20833333], [143, 163, 0.15], [163, 293, 0.12307692], [293, 427, 0.14179104], [427, 558, 0.14503817], [558, 604, 0.06521739], [604, 684, 0.1], [684, 838, 0.11038961], [838, 856, 0.05555556]], "rps_doc_ml_palm_score": [[0, 856, -9.18e-06]], "rps_doc_ml_wikipedia_score": [[0, 856, null]], "rps_doc_ml_wikiref_score": [[0, 856, 0.17270267]], "rps_doc_books_importance": [[0, 856, -95.58694686]], "rps_doc_openwebtext_importance": [[0, 856, -40.85766638]], "rps_doc_wikipedia_importance": [[0, 856, -8.94592217]], "rps_doc_num_sentences": [[0, 856, 8.0]]} |
Rougeau v. Firestone Tire & Rubber Co. case brief
Rougeau v. Firestone Tire & Rubber Co. case brief summary
274 So.2d 454 (1973)
Appellant employee sought review of a judgment of the 14th Judicial District Court, Parish of Calcasieu (Louisiana), which denied him recovery in a tort action he brought against appellee employer for damages for defamation and false imprisonment. The instant action followed unsuccessful administrative complaints that were filed by the discharged employee against the employer.
The employee worked as a guard-fireman for his employer. Two lawnmowers belonging to the employer were stolen from the employer, and the employee refused to cooperate with the investigation. Subsequently, the employee brought two unsuccessful administrative actions against the company in which he complained that he was wrongfully discharged. The employee then filed a tort action in which he claimed defamation and false imprisonment.
The trial court found that no proof was presented that any notoriety or publication was made by the company concerning the investigation.
As to the false imprisonment claim, the facts showed that the employee refused to allow agents of the employer's to search his home for the missing property, so he was asked to wait in the employer's guardhouse.
The guards testified that they did not consider the employee to be a prisoner, and he spent less than 30 minutes in the guardhouse.
The trial court found that the employee was not falsely imprisoned, and the court on review agreed.
The court affirmed the judgment of the trial judge that denied recovery to the employee in a tort action he filed against his employer. Costs were assessed against the employee. | 2023-14/0000/en_head.json.gz/1363 | {"url": "https://www.lawschoolcasebriefs.net/2014/01/rougeau-v-firestone-tire-rubber-co-case.html", "partition": "head_middle", "language": "en", "source_domain": "www.lawschoolcasebriefs.net", "date_download": "2023-03-20T10:44:48Z", "digest": "sha1:DBLUMJK2M4OUTJOAKHI3Z3D5DOQSG22B"} | {"ccnet_length": [[0, 1705, 1705.0]], "ccnet_original_length": [[0, 1705, 4782.0]], "ccnet_nlines": [[0, 1705, 10.0]], "ccnet_original_nlines": [[0, 1705, 57.0]], "ccnet_language_score": [[0, 1705, 0.98]], "ccnet_perplexity": [[0, 1705, 258.6]], "ccnet_bucket": [[0, 1705, 0.0]], "rps_doc_curly_bracket": [[0, 1705, 0.0]], "rps_doc_ldnoobw_words": [[0, 1705, 0.0]], "rps_doc_lorem_ipsum": [[0, 1705, 0.0]], "rps_doc_stop_word_fraction": [[0, 1705, 0.40196078]], "rps_doc_ut1_blacklist": [[0, 1705, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1705, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1705, 0.15203426]], "rps_doc_frac_chars_dupe_6grams": [[0, 1705, 0.05424697]], "rps_doc_frac_chars_dupe_7grams": [[0, 1705, 0.05424697]], "rps_doc_frac_chars_dupe_8grams": [[0, 1705, 0.05424697]], "rps_doc_frac_chars_dupe_9grams": [[0, 1705, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1705, 0.07066381]], "rps_doc_frac_chars_top_3gram": [[0, 1705, 0.0235546]], "rps_doc_frac_chars_top_4gram": [[0, 1705, 0.02997859]], "rps_doc_frac_all_caps_words": [[0, 1705, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1705, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1705, 0.12091503]], "rps_doc_frac_unique_words": [[0, 1705, 0.46096654]], "rps_doc_mean_word_length": [[0, 1705, 5.20817844]], "rps_doc_symbol_to_word_ratio": [[0, 1705, 0.0]], "rps_doc_unigram_entropy": [[0, 1705, 4.36219298]], "rps_doc_word_count": [[0, 1705, 269.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 50, 0.0], [50, 108, 0.0], [108, 129, 0.0], [129, 509, 1.0], [509, 946, 1.0], [946, 1084, 1.0], [1084, 1296, 1.0], [1296, 1428, 1.0], [1428, 1528, 1.0], [1528, 1705, 1.0]], "rps_lines_javascript_counts": [[0, 50, 0.0], [50, 108, 0.0], [108, 129, 0.0], [129, 509, 0.0], [509, 946, 0.0], [946, 1084, 0.0], [1084, 1296, 0.0], [1296, 1428, 0.0], [1428, 1528, 0.0], [1528, 1705, 0.0]], "rps_lines_num_words": [[0, 50, 8.0], [50, 108, 9.0], [108, 129, 4.0], [129, 509, 54.0], [509, 946, 64.0], [946, 1084, 22.0], [1084, 1296, 37.0], [1296, 1428, 24.0], [1428, 1528, 17.0], [1528, 1705, 30.0]], "rps_lines_numerical_chars_fraction": [[0, 50, 0.0], [50, 108, 0.0], [108, 129, 0.64705882], [129, 509, 0.00536193], [509, 946, 0.0], [946, 1084, 0.0], [1084, 1296, 0.0], [1296, 1428, 0.01550388], [1428, 1528, 0.0], [1528, 1705, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 50, 0.0], [50, 108, 0.0], [108, 129, 0.0], [129, 509, 0.0], [509, 946, 0.0], [946, 1084, 0.0], [1084, 1296, 0.0], [1296, 1428, 0.0], [1428, 1528, 0.0], [1528, 1705, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 50, 0.1], [50, 108, 0.0862069], [108, 129, 0.04761905], [129, 509, 0.02105263], [509, 946, 0.00915332], [946, 1084, 0.00724638], [1084, 1296, 0.00471698], [1296, 1428, 0.00757576], [1428, 1528, 0.01], [1528, 1705, 0.01129944]], "rps_doc_ml_palm_score": [[0, 1705, 0.4370656]], "rps_doc_ml_wikipedia_score": [[0, 1705, null]], "rps_doc_ml_wikiref_score": [[0, 1705, 0.38676256]], "rps_doc_books_importance": [[0, 1705, 17.60564514]], "rps_doc_openwebtext_importance": [[0, 1705, 45.36299466]], "rps_doc_wikipedia_importance": [[0, 1705, 59.17413324]], "rps_doc_num_sentences": [[0, 1705, 17.0]]} |
New Zealand Law Society - No extensions for insultation-avoiding landlords
No extensions for insultation-avoiding landlords
The Ministry of Business, Innovation and Employment says landlords have just over one month to ensure their rental properties meet the 2016 insulation requirements.
MBIE says those who don't meet requierments face exemplary damages of up to $4,000 under the Residential Tenancies Act 1986 and there will be no room for extensions.
From 1 July 2019, a landlord who has not installed ceiling and floor insulation where reasonably practicable will be in breach of the Act and may face the Tenancy Tribunal.
“The Act does not allow for extensions, and this would be unfair to those landlords who have acted in time to do the right thing,” says Peter Hackshaw, Acting National Manager, Tenancy Compliance and Investigations.
“The requirement to insulate was widely publicised in 2016 when the changes to the Act were made, and Tenancy Services has worked hard to ensure landlords are aware of their responsibilities by running an extensive information and education campaign.
“Landlords have had ample time and information to get the required work done and failing to comply is not only unlawful, it also exposes tenants to potential harm by not having a home that is warm and dry enough during the winter months.”
Any tenant who feels that their landlord has failed to meet their responsibilities to have the correct insulation installed by the 1 July 2019 deadline can apply to the Tenancy Tribunal for an order resolving that dispute.
Information on insulation requirements for rental homes is available on the Tenancy Services website. | 2023-14/0000/en_head.json.gz/1364 | {"url": "https://www.lawsociety.org.nz/news/legal-news/no-extensions-for-insultation-avoiding-landlords/", "partition": "head_middle", "language": "en", "source_domain": "www.lawsociety.org.nz", "date_download": "2023-03-20T08:50:30Z", "digest": "sha1:GFP4PZRB5ONK7XPD3W6I2SV5ZF7TIFM2"} | {"ccnet_length": [[0, 1658, 1658.0]], "ccnet_original_length": [[0, 1658, 3505.0]], "ccnet_nlines": [[0, 1658, 10.0]], "ccnet_original_nlines": [[0, 1658, 88.0]], "ccnet_language_score": [[0, 1658, 0.96]], "ccnet_perplexity": [[0, 1658, 285.6]], "ccnet_bucket": [[0, 1658, 0.0]], "rps_doc_curly_bracket": [[0, 1658, 0.0]], "rps_doc_ldnoobw_words": [[0, 1658, 0.0]], "rps_doc_lorem_ipsum": [[0, 1658, 0.0]], "rps_doc_stop_word_fraction": [[0, 1658, 0.4334471]], "rps_doc_ut1_blacklist": [[0, 1658, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1658, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1658, 0.06268222]], "rps_doc_frac_chars_dupe_6grams": [[0, 1658, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 1658, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1658, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1658, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1658, 0.02186589]], "rps_doc_frac_chars_top_3gram": [[0, 1658, 0.02186589]], "rps_doc_frac_chars_top_4gram": [[0, 1658, 0.04956268]], "rps_doc_frac_all_caps_words": [[0, 1658, 0.00341297]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1658, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1658, 0.11604096]], "rps_doc_frac_unique_words": [[0, 1658, 0.5719697]], "rps_doc_mean_word_length": [[0, 1658, 5.1969697]], "rps_doc_symbol_to_word_ratio": [[0, 1658, 0.0]], "rps_doc_unigram_entropy": [[0, 1658, 4.7049457]], "rps_doc_word_count": [[0, 1658, 264.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 75, 0.0], [75, 124, 0.0], [124, 289, 1.0], [289, 455, 1.0], [455, 628, 1.0], [628, 844, 1.0], [844, 1095, 1.0], [1095, 1334, 1.0], [1334, 1557, 1.0], [1557, 1658, 1.0]], "rps_lines_javascript_counts": [[0, 75, 0.0], [75, 124, 0.0], [124, 289, 0.0], [289, 455, 0.0], [455, 628, 0.0], [628, 844, 0.0], [844, 1095, 0.0], [1095, 1334, 0.0], [1334, 1557, 0.0], [1557, 1658, 0.0]], "rps_lines_num_words": [[0, 75, 9.0], [75, 124, 5.0], [124, 289, 24.0], [289, 455, 28.0], [455, 628, 30.0], [628, 844, 35.0], [844, 1095, 39.0], [1095, 1334, 43.0], [1334, 1557, 37.0], [1557, 1658, 14.0]], "rps_lines_numerical_chars_fraction": [[0, 75, 0.0], [75, 124, 0.0], [124, 289, 0.02469136], [289, 455, 0.04968944], [455, 628, 0.02941176], [628, 844, 0.0], [844, 1095, 0.01612903], [1095, 1334, 0.0], [1334, 1557, 0.02262443], [1557, 1658, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 75, 0.0], [75, 124, 0.0], [124, 289, 0.0], [289, 455, 0.0], [455, 628, 0.0], [628, 844, 0.0], [844, 1095, 0.0], [1095, 1334, 0.0], [1334, 1557, 0.0], [1557, 1658, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 75, 0.06666667], [75, 124, 0.02040816], [124, 289, 0.03030303], [289, 455, 0.04216867], [455, 628, 0.02890173], [628, 844, 0.0462963], [844, 1095, 0.01593625], [1095, 1334, 0.0041841], [1334, 1557, 0.01793722], [1557, 1658, 0.02970297]], "rps_doc_ml_palm_score": [[0, 1658, 0.02470946]], "rps_doc_ml_wikipedia_score": [[0, 1658, null]], "rps_doc_ml_wikiref_score": [[0, 1658, 0.24509317]], "rps_doc_books_importance": [[0, 1658, -45.08249815]], "rps_doc_openwebtext_importance": [[0, 1658, 21.14416478]], "rps_doc_wikipedia_importance": [[0, 1658, -48.15213876]], "rps_doc_num_sentences": [[0, 1658, 8.0]]} |
Steve Stevens Goes Wireless With Lectrosonics IS400
Category: Press Releases
RIO RANCHO, NEW MEXICO: Lectrosonics introduced the IS400 Digital Hybrid Wireless™ Instrument System only a few months ago and it's already a hit with Steve Stevens. The renowned guitarist, who has been performing and writing with Billy Idol for all but a few of the last 23 years, is currently mid-tour promoting the singer's new album, "Devil's Playground," the first album of new material from Idol and Stevens together in over 12 years.
Designed for use with both electric and acoustic instruments, the Lectrosonics IS400, consisting of the IM transmitter and R400A receiver, utilizes a proprietary digital algorithm to encode the audio signal into an analog format for transmission over an FM wireless carrier, which is then converted back into digital audio via DSP at the receiver. According to Stevens' guitar tech, Tim Kennedy, it was about time. "We've been waiting for years for something like this to appear," he says.
Having researched the options online, Stevens had Kennedy contact Karl Winkler, director of business development at Lectrosonics. "Karl came to our show in Albuquerque with a brand new unit for us to try out. Steve plugged into it, played a couple of chords through it, and then I plugged him into a cable to hear the difference. It was really, really close to the sound of the cable. Steve said, that's it, it's the best one I've ever heard."
Kennedy continues, "It's as close to a straight wire that we've been able to find. My ears aren't the greatest from years of abuse but even I could tell the difference! And Steve's still over the moon about it."
The design of the IS400 effectively eliminates the need for an analog compander circuit and provides superior audio dynamic and frequency response when compared to analog systems. Kennedy confirms, "It has an overall great sound, a nice warmth to it, and an all-around full sound, as you'd get from a cable."
Setup could not be easier, according to Kennedy. "It's very user friendly from a tech aspect. One cool feature is SmartTune™. It basically scans the frequencies and finds the best frequency at that location. Even if the frequency you used the night before comes up, it may not be the cleanest frequency available at the moment."
Performance and reliability have also been rock solid, he observes. "We haven't had any issues with the RF side. From a small club stage to a festival stage with 50,000 people, we haven't had any signal loss, no dropout and no compromise to the sound. Lectrosonics did their homework and built a great product."
It has been completely trouble free, according to Kennedy. "We've been using it for about two months and, other than operator error, have not had any problems with it. Any issues I have had, the people at Lectrosonics have been great and taken care of us right away. It really is a great product. And a little known secret, but within the year it'll be the hot little kid in the neighborhood."
Idol and Stevens have been busy promoting the new release all over Europe and are currently performing throughout the U.S., including the Lollapalooza Festival in Chicago, and dates across Canada. "It's a good show, and for the most part we're selling out everywhere we go," Kennedy shares. "We're also doing some dates on the Warped Tour and showing the little punk skater kids how it's supposed to be done!"
Well respected within the film, broadcast, and theater technical communities since 1971, Lectrosonics wireless microphone systems and audio processing products are used daily in mission-critical applications by audio engineers familiar with the company's dedication to quality, customer service, and innovation. Lectrosonics is a US manufacturer based in Rio Rancho, New Mexico. | 2023-14/0000/en_head.json.gz/1365 | {"url": "https://www.lectrosonics.com/press-releases/steve-stevens-goes-wireless-with-lectrosonics-is400.html", "partition": "head_middle", "language": "en", "source_domain": "www.lectrosonics.com", "date_download": "2023-03-20T09:56:42Z", "digest": "sha1:RD2VCBFQ5OI3XVVBXABLSHNC4HV3BKTI"} | {"ccnet_length": [[0, 3796, 3796.0]], "ccnet_original_length": [[0, 3796, 6219.0]], "ccnet_nlines": [[0, 3796, 12.0]], "ccnet_original_nlines": [[0, 3796, 86.0]], "ccnet_language_score": [[0, 3796, 0.97]], "ccnet_perplexity": [[0, 3796, 269.0]], "ccnet_bucket": [[0, 3796, 0.0]], "rps_doc_curly_bracket": [[0, 3796, 0.0]], "rps_doc_ldnoobw_words": [[0, 3796, 0.0]], "rps_doc_lorem_ipsum": [[0, 3796, 0.0]], "rps_doc_stop_word_fraction": [[0, 3796, 0.4344473]], "rps_doc_ut1_blacklist": [[0, 3796, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3796, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3796, 0.00658762]], "rps_doc_frac_chars_top_3gram": [[0, 3796, 0.00790514]], "rps_doc_frac_chars_top_4gram": [[0, 3796, 0.01185771]], "rps_doc_frac_all_caps_words": [[0, 3796, 0.02570694]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3796, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3796, 0.15938303]], "rps_doc_frac_unique_words": [[0, 3796, 0.51582278]], "rps_doc_mean_word_length": [[0, 3796, 4.80379747]], "rps_doc_symbol_to_word_ratio": [[0, 3796, 0.0]], "rps_doc_unigram_entropy": [[0, 3796, 5.27899364]], "rps_doc_word_count": [[0, 3796, 632.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 52, 0.0], [52, 77, 0.0], [77, 518, 1.0], [518, 1008, 1.0], [1008, 1452, 0.0], [1452, 1664, 0.0], [1664, 1973, 0.0], [1973, 2302, 0.0], [2302, 2614, 0.0], [2614, 3008, 0.0], [3008, 3418, 0.0], [3418, 3796, 1.0]], "rps_lines_javascript_counts": [[0, 52, 0.0], [52, 77, 0.0], [77, 518, 0.0], [518, 1008, 0.0], [1008, 1452, 0.0], [1452, 1664, 0.0], [1664, 1973, 0.0], [1973, 2302, 0.0], [2302, 2614, 0.0], [2614, 3008, 0.0], [3008, 3418, 0.0], [3418, 3796, 0.0]], "rps_lines_num_words": [[0, 52, 7.0], [52, 77, 3.0], [77, 518, 73.0], [518, 1008, 78.0], [1008, 1452, 79.0], [1452, 1664, 39.0], [1664, 1973, 51.0], [1973, 2302, 56.0], [2302, 2614, 54.0], [2614, 3008, 72.0], [3008, 3418, 69.0], [3418, 3796, 51.0]], "rps_lines_numerical_chars_fraction": [[0, 52, 0.05882353], [52, 77, 0.0], [77, 518, 0.01643192], [518, 1008, 0.01263158], [1008, 1452, 0.0], [1452, 1664, 0.0], [1664, 1973, 0.01006711], [1973, 2302, 0.0], [2302, 2614, 0.01672241], [2614, 3008, 0.0], [3008, 3418, 0.0], [3418, 3796, 0.01086957]], "rps_lines_start_with_bulletpoint": [[0, 52, 0.0], [52, 77, 0.0], [77, 518, 0.0], [518, 1008, 0.0], [1008, 1452, 0.0], [1452, 1664, 0.0], [1664, 1973, 0.0], [1973, 2302, 0.0], [2302, 2614, 0.0], [2614, 3008, 0.0], [3008, 3418, 0.0], [3418, 3796, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 52, 0.15384615], [52, 77, 0.12], [77, 518, 0.07936508], [518, 1008, 0.03673469], [1008, 1452, 0.02927928], [1452, 1664, 0.02830189], [1664, 1973, 0.01618123], [1973, 2302, 0.02431611], [2302, 2614, 0.01923077], [2614, 3008, 0.02030457], [3008, 3418, 0.03414634], [3418, 3796, 0.02380952]], "rps_doc_ml_palm_score": [[0, 3796, 0.87478471]], "rps_doc_ml_wikipedia_score": [[0, 3796, null]], "rps_doc_ml_wikiref_score": [[0, 3796, 0.77139312]], "rps_doc_books_importance": [[0, 3796, 18.85350362]], "rps_doc_openwebtext_importance": [[0, 3796, 76.22131658]], "rps_doc_wikipedia_importance": [[0, 3796, -96.30191578]], "rps_doc_num_sentences": [[0, 3796, 36.0]]} |
Current: Survey: Smart Phones are Reshaping Consumer Purchasing Habits
Survey: Smart Phones are Reshaping Consumer Purchasing Habits
Boston, MA – August 17, 2011 – Retailers and brands will need to shift their sales and marketing strategies to respond to the growing influence of mobile devices on consumer behavior, according to the new L.E.K. Consulting Mobile Commerce Survey. Broadly, two-thirds of smart phone or tablet owners today have used their devices to make purchases and more than 80% have used them to assist in purchasing decisions through product research at least once during the past year.
Digging deeper, L.E.K. found that 39% actually make purchases with their handheld devices at least every month (excluding music and video downloads), with 60% using smart phones to research purchases each month in a variety of ways – we refer to these consumers as “Active Mobile Consumers” and those smart phone owners who shop less frequently as “Mobile Window Shoppers.”
“Mobile is the enabler: consumers using mobile for shopping have new expectations for pricing standardization across channels, require a steady stream of promotions to remain engaged, and want to capitalize on powerful tools that enable them to access independent recommendations, price comparisons, the opinions of friends, and reviews anytime, anywhere,” said Jon Weber, Vice President of L.E.K. Consulting. “Now is the time for retailers and brands to ensure that they meet the needs of the new mobile consumer, and are ready to compete in this new marketplace.”
The L.E.K Consulting Mobile Commerce Survey identifies four key findings that will impact businesses:
1. Driving Price Harmonization: During the past six months, more than half of Active Mobile Consumers surveyed reported using at least one mobile coupon app (e.g., Coupon Clipper), nearly one-third checked a pricing comparison tool (e.g., RedLaser), and 29% tapped a loyalty or similar tool (e.g., Shopkick). And they did this while standing in store aisles.
This new level of price transparency across stores and channels provides consumers with added impetus to seek out the best deals – and demand that pricing be consistent across a retailer or a brand’s distribution channels.
2. Fostering Deeper Customer Relationships: More than half of Active Mobile Consumers are willing to share their location with brands in exchange for real-time offers when they “check in” via Foursquare or similar geolocation-based apps, which is twice the rate of Mobile Window Shoppers. And 37% of Active Mobile Consumers are willing to have brands track them all the time in order to receive special deals. By contrast, only 14% of Mobile Window Shoppers are willing to do the same. Based on our broader work in this area, it appears that privacy concerns significantly outweigh the allure of special offers for this group.
However, brands must provide the right incentives to keep mobile consumers engaged and willing to share certain information. Marketing tactics with an immediate payoff resonate strongly with this consumer group (e.g., coupons, discounts, rewards or loyalty points).
3. Increasing the Influence on Social Media: Active Mobile Consumers are much less influenced by traditional information sources than their older counterparts. Instead, they turn to independent reviews, friends and family for recommendations before making purchases; and mobile puts these powerful influences in the palm of their hand in the aisle.
4. Enabling Flash Retailers: The immediacy of mobile shopping creates new opportunities for consumers to keep up with the latest deals on flash sales sites like Gilt Groupe and Rue La La. More than 40% of Active Mobile Consumers use flash sites, which is more than twice the percentage of Mobile Window Shoppers.
Importantly, flash sites are also disrupting the market by capturing share of planned purchases from other channels. L.E.K. found that flash sites are successfully penetrating traditional purchasing decisions for Active Mobile Consumers, and driving conversion given the immediacy and perishability of the mobile flash proposition.
“While the dollars being spent on mobile devices today are still small, our research shows that the influence of mobile devices on the behavior of consumers is much more significant and has more immediate implications for both retailers and brands,” said Alan Lewis, Vice President of L.E.K. Consulting. “Our research also highlights that these trends apply across all categories as consumers have a similar mix of category purchases on their mobile devices as they do on the web.”
The report is based on L.E.K.’s survey of 1,600 U.S. consumers to better understand how mobile technology is changing consumers’ decision-making and purchase behavior. Additional findings are available in the L.E.K. Executive Insightsreport titled, “The Marketplace of the Mobile Consumer: What to Expect.”
L.E.K. Consulting is a global management consulting firm that uses deep industry expertise and analytical rigor to help clients solve their most critical business problems. Founded more than 25 years ago, L.E.K. employs more than 900 professionals in 20 offices across Europe, the Americas and Asia-Pacific. L.E.K. advises and supports global companies that are leaders in their industries – including the largest private and public sector organizations, private equity firms and emerging entrepreneurial businesses. L.E.K. helps business leaders consistently make better decisions, deliver improved business performance and create greater shareholder returns.
L.E.K. helps retailers, consumer goods companies, food & beverage brands, and restaurants improve the value and relevance of their brands to consumers. We uncover unmet customer needs and neglected industry segments. The result is insights and ideas to help our clients optimize their brands through the best possible combinations of product features, service offerings and pricing for targeted customer segments. For more information, go to www.lek.com.
[email protected]
L.E.K. Consulting Report Identifies How Retailers and Brands Need to Address the Mobile Shopper | 2023-14/0000/en_head.json.gz/1366 | {"url": "https://www.lek.com/press/survey-smart-phones-are-reshaping-consumer-purchasing-habits", "partition": "head_middle", "language": "en", "source_domain": "www.lek.com", "date_download": "2023-03-20T10:06:00Z", "digest": "sha1:56L362JPFP6BCN2343NBP3LMICF63PNU"} | {"ccnet_length": [[0, 6135, 6135.0]], "ccnet_original_length": [[0, 6135, 20292.0]], "ccnet_nlines": [[0, 6135, 19.0]], "ccnet_original_nlines": [[0, 6135, 816.0]], "ccnet_language_score": [[0, 6135, 0.93]], "ccnet_perplexity": [[0, 6135, 280.5]], "ccnet_bucket": [[0, 6135, 0.0]], "rps_doc_curly_bracket": [[0, 6135, 0.0]], "rps_doc_ldnoobw_words": [[0, 6135, 0.0]], "rps_doc_lorem_ipsum": [[0, 6135, 0.0]], "rps_doc_stop_word_fraction": [[0, 6135, 0.33622937]], "rps_doc_ut1_blacklist": [[0, 6135, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 6135, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 6135, 0.0788794]], "rps_doc_frac_chars_dupe_6grams": [[0, 6135, 0.04430757]], "rps_doc_frac_chars_dupe_7grams": [[0, 6135, 0.04430757]], "rps_doc_frac_chars_dupe_8grams": [[0, 6135, 0.021061]], "rps_doc_frac_chars_dupe_9grams": [[0, 6135, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 6135, 0.01112656]], "rps_doc_frac_chars_top_3gram": [[0, 6135, 0.02503477]], "rps_doc_frac_chars_top_4gram": [[0, 6135, 0.01827936]], "rps_doc_frac_all_caps_words": [[0, 6135, 0.03909644]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 6135, 0.0]], "rps_doc_frac_no_alph_words": [[0, 6135, 0.17289314]], "rps_doc_frac_unique_words": [[0, 6135, 0.46824543]], "rps_doc_mean_word_length": [[0, 6135, 5.41765339]], "rps_doc_symbol_to_word_ratio": [[0, 6135, 0.0]], "rps_doc_unigram_entropy": [[0, 6135, 5.48441933]], "rps_doc_word_count": [[0, 6135, 929.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 71, 0.0], [71, 133, 0.0], [133, 608, 1.0], [608, 982, 1.0], [982, 1548, 1.0], [1548, 1650, 0.0], [1650, 2009, 1.0], [2009, 2232, 1.0], [2232, 2859, 1.0], [2859, 3125, 1.0], [3125, 3474, 1.0], [3474, 3787, 1.0], [3787, 4119, 1.0], [4119, 4601, 1.0], [4601, 4908, 1.0], [4908, 5569, 1.0], [5569, 6024, 1.0], [6024, 6040, 0.0], [6040, 6135, 0.0]], "rps_lines_javascript_counts": [[0, 71, 0.0], [71, 133, 0.0], [133, 608, 0.0], [608, 982, 0.0], [982, 1548, 0.0], [1548, 1650, 0.0], [1650, 2009, 0.0], [2009, 2232, 0.0], [2232, 2859, 0.0], [2859, 3125, 0.0], [3125, 3474, 0.0], [3474, 3787, 0.0], [3787, 4119, 0.0], [4119, 4601, 0.0], [4601, 4908, 0.0], [4908, 5569, 0.0], [5569, 6024, 0.0], [6024, 6040, 0.0], [6040, 6135, 0.0]], "rps_lines_num_words": [[0, 71, 9.0], [71, 133, 8.0], [133, 608, 78.0], [608, 982, 60.0], [982, 1548, 87.0], [1548, 1650, 14.0], [1650, 2009, 56.0], [2009, 2232, 36.0], [2232, 2859, 103.0], [2859, 3125, 37.0], [3125, 3474, 51.0], [3474, 3787, 53.0], [3787, 4119, 45.0], [4119, 4601, 78.0], [4601, 4908, 43.0], [4908, 5569, 91.0], [5569, 6024, 65.0], [6024, 6040, 1.0], [6040, 6135, 14.0]], "rps_lines_numerical_chars_fraction": [[0, 71, 0.0], [71, 133, 0.0], [133, 608, 0.01727862], [608, 982, 0.01101928], [982, 1548, 0.0], [1548, 1650, 0.0], [1650, 2009, 0.00898204], [2009, 2232, 0.0], [2232, 2859, 0.00815661], [2859, 3125, 0.0], [3125, 3474, 0.00293255], [3474, 3787, 0.00980392], [3787, 4119, 0.0], [4119, 4601, 0.0], [4601, 4908, 0.01369863], [4908, 5569, 0.01095462], [5569, 6024, 0.0], [6024, 6040, 0.0], [6040, 6135, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 71, 0.0], [71, 133, 0.0], [133, 608, 0.0], [608, 982, 0.0], [982, 1548, 0.0], [1548, 1650, 0.0], [1650, 2009, 0.0], [2009, 2232, 0.0], [2232, 2859, 0.0], [2859, 3125, 0.0], [3125, 3474, 0.0], [3474, 3787, 0.0], [3787, 4119, 0.0], [4119, 4601, 0.0], [4601, 4908, 0.0], [4908, 5569, 0.0], [5569, 6024, 0.0], [6024, 6040, 0.0], [6040, 6135, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 71, 0.11267606], [71, 133, 0.11290323], [133, 608, 0.02736842], [608, 982, 0.02673797], [982, 1548, 0.01766784], [1548, 1650, 0.07843137], [1650, 2009, 0.0362117], [2009, 2232, 0.0044843], [2232, 2859, 0.03349282], [2859, 3125, 0.0075188], [3125, 3474, 0.02292264], [3474, 3787, 0.05111821], [3787, 4119, 0.02108434], [4119, 4601, 0.02074689], [4601, 4908, 0.05863192], [4908, 5569, 0.02723147], [5569, 6024, 0.01318681], [6024, 6040, 0.0], [6040, 6135, 0.13684211]], "rps_doc_ml_palm_score": [[0, 6135, 0.11650991]], "rps_doc_ml_wikipedia_score": [[0, 6135, null]], "rps_doc_ml_wikiref_score": [[0, 6135, 0.08941585]], "rps_doc_books_importance": [[0, 6135, -416.82795958]], "rps_doc_openwebtext_importance": [[0, 6135, -22.74309505]], "rps_doc_wikipedia_importance": [[0, 6135, -150.98926505]], "rps_doc_num_sentences": [[0, 6135, 91.0]]} |
Bevin Recognizes Historic Gorge Rescue Using Blackhawk Chopper
(LEX 18) — On Monday, Gov. Matt Bevin recognized a historic rescue in which a UH-60 Blackhawk was used for the first time in Kentucky for such a mission.
On the way home from training May 18, soldiers with the Kentucky National Guard received a call that a woman hiking in the Red River Gorge was having a medical emergency and needed to be rescued.
“The area’s kind of isolated, so to get somebody down by hand or by foot could take a long time. But with us, we can get there in a short amount of time and transfer them to a hospital,” said Staff Sgt. Shaun Morris.
For the first time in Kentucky, a UH-60 Blackhawk was deployed for a rescue mission.
“It’s really the only three specialized helicopters in the state that are able to do this kind of mission with a hoist,” said Staff Sgt. Jeremy Lowe. “Once he put me down, it was just, making sure I was safe getting down to the area, locating the patient, packaging her up, making sure she was gonna be safe for travel.”
“We trained up for it. We did a lot of work with those guys last year, and this was the time we were able to get out the door and make it happen,” said Captain Jonathan Strayer.
With the help from Wolfe and Powell County Search and Rescue teams, and Red Squad, the victim was recovered, hoisted onto the helicopter, and flown to the University of Kentucky Medical Center.
“It was awesome, especially the next day when we got the word she was doing good, she was recovering, fully-recovered, and back home with her family,” said Strayer. | 2023-14/0000/en_head.json.gz/1367 | {"url": "https://www.lex18.com/news/covering-kentucky/2019/06/03/bevin-recognizes-historic-gorge-rescue-using-blackhawk-chopper/", "partition": "head_middle", "language": "en", "source_domain": "www.lex18.com", "date_download": "2023-03-20T10:25:27Z", "digest": "sha1:GAYXCFFLLQUJEEEMMUBUFI4OFGNNTPGY"} | {"ccnet_length": [[0, 1572, 1572.0]], "ccnet_original_length": [[0, 1572, 4177.0]], "ccnet_nlines": [[0, 1572, 9.0]], "ccnet_original_nlines": [[0, 1572, 153.0]], "ccnet_language_score": [[0, 1572, 0.98]], "ccnet_perplexity": [[0, 1572, 247.2]], "ccnet_bucket": [[0, 1572, 0.0]], "rps_doc_curly_bracket": [[0, 1572, 0.0]], "rps_doc_ldnoobw_words": [[0, 1572, 0.0]], "rps_doc_lorem_ipsum": [[0, 1572, 0.0]], "rps_doc_stop_word_fraction": [[0, 1572, 0.44897959]], "rps_doc_ut1_blacklist": [[0, 1572, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 1572, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 1572, 0.04025765]], "rps_doc_frac_chars_dupe_6grams": [[0, 1572, 0.04025765]], "rps_doc_frac_chars_dupe_7grams": [[0, 1572, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 1572, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 1572, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 1572, 0.01449275]], "rps_doc_frac_chars_top_3gram": [[0, 1572, 0.02254428]], "rps_doc_frac_chars_top_4gram": [[0, 1572, 0.0273752]], "rps_doc_frac_all_caps_words": [[0, 1572, 0.01166181]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 1572, 0.0]], "rps_doc_frac_no_alph_words": [[0, 1572, 0.1574344]], "rps_doc_frac_unique_words": [[0, 1572, 0.57093426]], "rps_doc_mean_word_length": [[0, 1572, 4.29757785]], "rps_doc_symbol_to_word_ratio": [[0, 1572, 0.0]], "rps_doc_unigram_entropy": [[0, 1572, 4.74517635]], "rps_doc_word_count": [[0, 1572, 289.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 63, 0.0], [63, 217, 1.0], [217, 413, 1.0], [413, 630, 1.0], [630, 715, 1.0], [715, 1036, 1.0], [1036, 1214, 1.0], [1214, 1408, 1.0], [1408, 1572, 1.0]], "rps_lines_javascript_counts": [[0, 63, 0.0], [63, 217, 0.0], [217, 413, 0.0], [413, 630, 0.0], [630, 715, 0.0], [715, 1036, 0.0], [1036, 1214, 0.0], [1214, 1408, 0.0], [1408, 1572, 0.0]], "rps_lines_num_words": [[0, 63, 8.0], [63, 217, 29.0], [217, 413, 36.0], [413, 630, 44.0], [630, 715, 15.0], [715, 1036, 60.0], [1036, 1214, 37.0], [1214, 1408, 32.0], [1408, 1572, 28.0]], "rps_lines_numerical_chars_fraction": [[0, 63, 0.0], [63, 217, 0.02721088], [217, 413, 0.01036269], [413, 630, 0.0], [630, 715, 0.02469136], [715, 1036, 0.0], [1036, 1214, 0.0], [1214, 1408, 0.0], [1408, 1572, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 63, 0.0], [63, 217, 0.0], [217, 413, 0.0], [413, 630, 0.0], [630, 715, 0.0], [715, 1036, 0.0], [1036, 1214, 0.0], [1214, 1408, 0.0], [1408, 1572, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 63, 0.12698413], [63, 217, 0.07792208], [217, 413, 0.04081633], [413, 630, 0.02764977], [630, 715, 0.05882353], [715, 1036, 0.02180685], [1036, 1214, 0.02808989], [1214, 1408, 0.06185567], [1408, 1572, 0.01219512]], "rps_doc_ml_palm_score": [[0, 1572, 0.63829827]], "rps_doc_ml_wikipedia_score": [[0, 1572, null]], "rps_doc_ml_wikiref_score": [[0, 1572, 0.6598773]], "rps_doc_books_importance": [[0, 1572, -19.77730176]], "rps_doc_openwebtext_importance": [[0, 1572, 67.88994733]], "rps_doc_wikipedia_importance": [[0, 1572, -59.42160789]], "rps_doc_num_sentences": [[0, 1572, 14.0]]} |
SBA Update: Less Than 1% Minority Shareholder Interest Could Impact Eligibility for Small Business Contract Awards
By Brendan Lill & Marta Thompson on July 26, 2018
The U.S. Small Business Administration (SBA) Office of Hearings & Appeals (OHA) recently held that an entity may be affiliated with another entity solely because it holds a very small minority ownership interest (less than 1%) in that entity. OHA’s ruling is noteworthy because under the SBA’s rules, the employees or revenue (depending on the NAICS code) of a concern and its “affiliates” must be aggregated when determining a small business concern’s size and eligibility for small business set-aside contracts. The decision should disabuse contractors and investors alike of any perception that very small minority ownership interests cannot give rise to affiliation.
Entities are considered affiliates under the SBA’s rules if one controls or has the power to control the other, or if a third party or parties controls or has the power to control both. It is well-established that one entity does not need to have controlling share of stock ownership (above 50%) in another for the two entities to be deemed affiliates under the SBA’s rules. However, some government contractors might believe that a very small minority ownership interest cannot create affiliation. OHA’s decision in Melton Sales & Service, Inc., SBA No. SIZ-5893 (Mar. 29, 2018) (Melton) confirms that such belief is mistaken.
In Melton, an unsuccessful offeror in an Army procurement protested the size status of the awardee, MTP Drivetrain Service, LLC (MTP). The protester contended that one of MTP’s affiliates, Joe Gear Holdings, LLC (Joe Gear), was also affiliated with VIPAR Heavy Duty Inc. (VIPAR) in part because Joe Gear was one of 120 stockholders that each held one voting share in VIPAR (an approximate 0.8% interest). The protester argued that because Joe Gear was affiliated with VIPAR, and MTP was affiliated with Joe Gear, that VIPAR was affiliated with MTP and that VIPAR’s employees should be counted when determining MTP’s size. OHA agreed, noting that Joe Gear was one of multiple minority shareholders in VIPAR whose investments were equal or approximately equal in size, and therefore there was a rebuttable presumption that each minority shareholder controlled VIPAR. OHA relied on the following SBA regulation at 13 C.F.R. § 121.103(c)(2):
If two or more persons (including any person, concern or other entity) each owns, controls, or has the power to control less than 50 percent of a concern’s voting stock, and such minority holdings are equal or approximately equal in size, and the aggregate of these minority holdings is large compared with any other stock holding, SBA presumes that each such person controls or has the power to control the concern whose size is at issue. This presumption may be rebutted by a showing that such control or power to control does not in fact exist.
Critically, OHA stated that the presumption that each minority shareholder controls an entity “may be rebutted with evidence to the contrary, such as evidence demonstrating another party such as the Board of Directors and CEO or President controls the concern,” but that absent “clear evidence demonstrating control or the power to control by another party, it is presumed that each minority shareholder has equal control over the subject concern, regardless of the size of the shareholder’s interests.” OHA also described the inability of any one of the 120 stockholders to individually exercise actual control over the entity as “immaterial” to the affiliation analysis. Because MTP in Melton did not establish that any party other than the 120 stockholders controlled the entity, it failed to rebut the presumption of affiliation.
OHA’s ruling in Melton did not impact the awardee’s eligibility for the contract award because affiliation with VIPAR did not push MTP above the size standard threshold that applied to the procurement. In many circumstances, however, affiliation with other entities can render a contractor ineligible for small business contract awards. Small business contractors doing deals therefore should be cautious in deciding how to structure minority investments in other entities. An investment may not make strategic sense if it results in the business being determined ineligible for small business contract awards. Similarly, private equity groups and other parties seeking to invest in small business concerns should be careful when structuring such investments because a minority investment that appears to give the investor no actual control over the company could be sufficient to create affiliation between the concern and the investor.
The authors are available for questions. The Government Contracts Practice at Hogan Lovells helps advise companies that may have questions concerning SBA regulatory implications of transactions with small business contractors.
Focus on Regulation
Hogan Lovells | 2023-14/0000/en_head.json.gz/1368 | {"url": "https://www.lexblog.com/2018/07/26/sba-update/", "partition": "head_middle", "language": "en", "source_domain": "www.lexblog.com", "date_download": "2023-03-20T10:38:43Z", "digest": "sha1:DKQRHH664LGVMCHYGVYKCRUN6VGX26KV"} | {"ccnet_length": [[0, 4982, 4982.0]], "ccnet_original_length": [[0, 4982, 6103.0]], "ccnet_nlines": [[0, 4982, 11.0]], "ccnet_original_nlines": [[0, 4982, 57.0]], "ccnet_language_score": [[0, 4982, 0.95]], "ccnet_perplexity": [[0, 4982, 337.3]], "ccnet_bucket": [[0, 4982, 0.0]], "rps_doc_curly_bracket": [[0, 4982, 0.0]], "rps_doc_ldnoobw_words": [[0, 4982, 0.0]], "rps_doc_lorem_ipsum": [[0, 4982, 0.0]], "rps_doc_stop_word_fraction": [[0, 4982, 0.38864629]], "rps_doc_ut1_blacklist": [[0, 4982, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4982, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 4982, 0.13079551]], "rps_doc_frac_chars_dupe_6grams": [[0, 4982, 0.08394339]], "rps_doc_frac_chars_dupe_7grams": [[0, 4982, 0.04734017]], "rps_doc_frac_chars_dupe_8grams": [[0, 4982, 0.01610542]], "rps_doc_frac_chars_dupe_9grams": [[0, 4982, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 4982, 0.02855051]], "rps_doc_frac_chars_top_3gram": [[0, 4982, 0.0204978]], "rps_doc_frac_chars_top_4gram": [[0, 4982, 0.02074183]], "rps_doc_frac_all_caps_words": [[0, 4982, 0.04803493]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4982, 0.0]], "rps_doc_frac_no_alph_words": [[0, 4982, 0.14847162]], "rps_doc_frac_unique_words": [[0, 4982, 0.375]], "rps_doc_mean_word_length": [[0, 4982, 5.28092784]], "rps_doc_symbol_to_word_ratio": [[0, 4982, 0.0]], "rps_doc_unigram_entropy": [[0, 4982, 5.14503045]], "rps_doc_word_count": [[0, 4982, 776.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 115, 0.0], [115, 165, 0.0], [165, 836, 1.0], [836, 1464, 1.0], [1464, 2402, 0.0], [2402, 2950, 1.0], [2950, 3784, 1.0], [3784, 4722, 1.0], [4722, 4949, 1.0], [4949, 4969, 0.0], [4969, 4982, 0.0]], "rps_lines_javascript_counts": [[0, 115, 0.0], [115, 165, 0.0], [165, 836, 0.0], [836, 1464, 0.0], [1464, 2402, 0.0], [2402, 2950, 0.0], [2950, 3784, 0.0], [3784, 4722, 0.0], [4722, 4949, 0.0], [4949, 4969, 0.0], [4969, 4982, 0.0]], "rps_lines_num_words": [[0, 115, 16.0], [115, 165, 9.0], [165, 836, 101.0], [836, 1464, 102.0], [1464, 2402, 149.0], [2402, 2950, 96.0], [2950, 3784, 129.0], [3784, 4722, 139.0], [4722, 4949, 30.0], [4949, 4969, 3.0], [4969, 4982, 2.0]], "rps_lines_numerical_chars_fraction": [[0, 115, 0.00892857], [115, 165, 0.13043478], [165, 836, 0.00153374], [836, 1464, 0.01986755], [1464, 2402, 0.01550388], [2402, 2950, 0.00372439], [2950, 3784, 0.00728155], [3784, 4722, 0.0], [4722, 4949, 0.0], [4949, 4969, 0.0], [4969, 4982, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 115, 0.0], [115, 165, 0.0], [165, 836, 0.0], [836, 1464, 0.0], [1464, 2402, 0.0], [2402, 2950, 0.0], [2950, 3784, 0.0], [3784, 4722, 0.0], [4722, 4949, 0.0], [4949, 4969, 0.0], [4969, 4982, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 115, 0.13913043], [115, 165, 0.12], [165, 836, 0.04023845], [836, 1464, 0.03980892], [1464, 2402, 0.10554371], [2402, 2950, 0.00912409], [2950, 3784, 0.02158273], [3784, 4722, 0.01705757], [4722, 4949, 0.04405286], [4949, 4969, 0.1], [4969, 4982, 0.15384615]], "rps_doc_ml_palm_score": [[0, 4982, 0.20100355]], "rps_doc_ml_wikipedia_score": [[0, 4982, null]], "rps_doc_ml_wikiref_score": [[0, 4982, 0.48447984]], "rps_doc_books_importance": [[0, 4982, -242.63565249]], "rps_doc_openwebtext_importance": [[0, 4982, 55.93164675]], "rps_doc_wikipedia_importance": [[0, 4982, -50.64012391]], "rps_doc_num_sentences": [[0, 4982, 35.0]]} |
Our community agreements are the foundation of having an environment of trust and safety in all our courses and programs at the Life of Wellness Institute. We know that the work of creating a safe and positive group environment does not lie with the facilitator alone; in fact each community member is critical in creating this space. Each person’s intentions and actions are important and have an impact; collectively these thoughts and actions create the space that the group shares together.
We invite all our students and participants to commit to the following community agreements. These agreements are designed to help us each co-create a space for you, and your peers for healing, connection, and growth. The following is our starting point; if you wish to give feedback or request additional agreements, please contact our Founder.
We affirm each person’s right to privacy. We agree to keep all information shared in the group confidential. This includes names and personal information (e.g. email, phone number, location), as well as anything another group member shares about themselves or others. When in doubt, we agree to ask and obtain permission from the person who shared the information directly. If we are worried another person is in danger, we agree to speak privately with the lead teacher of your program, who will determine the right course of action.
We affirm each person’s right to direct their own life and class experience. In practice, this means that we understand that everything offered in our training is optional and respect others’ right to make their own choices. We understand we have the right to opt out of any activity or discussion, and we don’t pressure or ask other group members to share information or participate in activities if they don’t wish to. We acknowledge and honor each person’s innate capacity to choose and act in accordance with their own best interests.
We affirm each person’s worth and value. We agree to treat everyone in the group with kindness and respect. In practice, this means we speak and act with kindness, integrity, curiosity, and understanding. We do not engage in violence, deception, or manipulation. We consider how our speech and actions may be received by our fellow group members, and work to communicate clearly and without causing harm. If we become aware of harm, we acknowledge the harm directly and seek resolution. In the case of conflict, we speak with the person directly rather than speaking about the incident or person with others. In the case of abuse, please speak directly to your program lead teacher to report the conflict and seek a solution.
We affirm, respect, and honor each person’s diverse experience and expression. In practice, this means we do not engage in discriminatory speech or behavior of any kind; whether based on race/ethnicity, gender identity or expression, age, (dis)ability, or any other aspect of a person’s experience and/or identity. We actively work to understand our own biases and assumptions and recognize that even with the best of intentions we can still do harm. We actively strive to understand harms when they are brought to our attention, make amends when appropriate, and deepen our understanding of our fellow group members’ experience, identity, and expression.
SOBER STATE
We affirm our responsibility to engage in the group in a sober state of mind. We acknowledge the impact our presence has on others, the sensitivity of the topics at hand, and the need for awareness, care and conscious participation. We agree not to participate in the course while under the influence of alcohol, marijuana, illicit drugs, or any substances that may impair our judgment or interfere with our capacity to be fully present with others in the group. This includes legally-prescribed pharmaceutical drugs (e.g. opiates or sedatives) that may interfere with our capacity to make sound judgment and access all our mental faculties.
SAFETY AND STABILITY
We affirm our responsibility to care for our mental health. We recognize the limitations of this organization’s work; namely that it is not equipped to support or treat severe mental health challenges (i.e. psychosis, suicidality, self-harm, etc). We acknowledge that yoga, group discussions, and psychoeducation activities can be more destabilizing than supportive when we’re in the midst of these experiences. We commit to honor and care for ourselves if these experiences arise.
There is no shame in feeling suicidal, disconnected from reality, or self-destructive. These experiences are a valid and even valuable aspect of the human experience, more common than most people believe. But we recognize these experiences deserve great care and attention, and that the right resources at the right time can make all the difference. In practice, this means we are honest if these experiences arise, consider the impact they may have on our participation in the group, and seek appropriate professional treatment. If we can, we make every effort to be honest about what we are experiencing with our facilitator, who may be able to refer us to quality mental health treatment. We understand that the right course of action may be to take a break from the group temporarily. We honor ourselves and our fellow group members enough to make that choice, knowing that we are held by the community and can return to the group when it can be more supportive to our experience.
We affirm our commitment to regular attendance. We recognize that our absence in sessions affects others, as well as ourselves. We understand that a positive group dynamic emerges from relationships, that relationships depend on trust, and that trust can only emerge from consistency and presence. We make every effort to attend the entirety of all sessions of the course, unless extenuating circumstances prevent us from being present. If we are unable to attend a session, we try to notify the lead teacher in advance.
PRESENCE AND ATTENTION
We affirm our responsibility to be fully present in sessions. We understand our attention is a gift we give to our fellow group members, and that phone calls, text messages, and outside distractions can erode the group dynamic. We listen and engage in sessions without distractions. We agree not to use electronic devices during the session unless extenuating circumstances require it. We don’t text, speak on the phone, or otherwise engage in outside conversations during the course sessions. If circumstances require that we use an electronic device during a session, we agree to inform the facilitator ahead of time. | 2023-14/0000/en_head.json.gz/1369 | {"url": "https://www.lifeofwellness.ca/community-agreements/", "partition": "head_middle", "language": "en", "source_domain": "www.lifeofwellness.ca", "date_download": "2023-03-20T09:29:37Z", "digest": "sha1:XCZOXM3RL53BT6UUCUET6ZMUFWXRGXG5"} | {"ccnet_length": [[0, 6602, 6602.0]], "ccnet_original_length": [[0, 6602, 7613.0]], "ccnet_nlines": [[0, 6602, 14.0]], "ccnet_original_nlines": [[0, 6602, 53.0]], "ccnet_language_score": [[0, 6602, 0.94]], "ccnet_perplexity": [[0, 6602, 265.9]], "ccnet_bucket": [[0, 6602, 0.0]], "rps_doc_curly_bracket": [[0, 6602, 0.0]], "rps_doc_ldnoobw_words": [[0, 6602, 0.0]], "rps_doc_lorem_ipsum": [[0, 6602, 0.0]], "rps_doc_stop_word_fraction": [[0, 6602, 0.44995997]], "rps_doc_ut1_blacklist": [[0, 6602, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 6602, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 6602, 0.07572383]], "rps_doc_frac_chars_dupe_6grams": [[0, 6602, 0.01002227]], "rps_doc_frac_chars_dupe_7grams": [[0, 6602, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 6602, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 6602, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 6602, 0.01336303]], "rps_doc_frac_chars_top_3gram": [[0, 6602, 0.00835189]], "rps_doc_frac_chars_top_4gram": [[0, 6602, 0.01410542]], "rps_doc_frac_all_caps_words": [[0, 6602, 0.00640512]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 6602, 0.0]], "rps_doc_frac_no_alph_words": [[0, 6602, 0.12409928]], "rps_doc_frac_unique_words": [[0, 6602, 0.3516791]], "rps_doc_mean_word_length": [[0, 6602, 5.0261194]], "rps_doc_symbol_to_word_ratio": [[0, 6602, 0.0]], "rps_doc_unigram_entropy": [[0, 6602, 5.18641287]], "rps_doc_word_count": [[0, 6602, 1072.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 495, 1.0], [495, 841, 1.0], [841, 1376, 1.0], [1376, 1915, 1.0], [1915, 2641, 1.0], [2641, 3297, 1.0], [3297, 3309, 0.0], [3309, 3951, 1.0], [3951, 3972, 0.0], [3972, 4454, 1.0], [4454, 5439, 1.0], [5439, 5960, 1.0], [5960, 5983, 0.0], [5983, 6602, 1.0]], "rps_lines_javascript_counts": [[0, 495, 0.0], [495, 841, 0.0], [841, 1376, 0.0], [1376, 1915, 0.0], [1915, 2641, 0.0], [2641, 3297, 0.0], [3297, 3309, 0.0], [3309, 3951, 0.0], [3951, 3972, 0.0], [3972, 4454, 0.0], [4454, 5439, 0.0], [5439, 5960, 0.0], [5960, 5983, 0.0], [5983, 6602, 0.0]], "rps_lines_num_words": [[0, 495, 81.0], [495, 841, 55.0], [841, 1376, 88.0], [1376, 1915, 91.0], [1915, 2641, 122.0], [2641, 3297, 101.0], [3297, 3309, 2.0], [3309, 3951, 104.0], [3951, 3972, 3.0], [3972, 4454, 72.0], [4454, 5439, 167.0], [5439, 5960, 84.0], [5960, 5983, 3.0], [5983, 6602, 99.0]], "rps_lines_numerical_chars_fraction": [[0, 495, 0.0], [495, 841, 0.0], [841, 1376, 0.0], [1376, 1915, 0.0], [1915, 2641, 0.0], [2641, 3297, 0.0], [3297, 3309, 0.0], [3309, 3951, 0.0], [3951, 3972, 0.0], [3972, 4454, 0.0], [4454, 5439, 0.0], [5439, 5960, 0.0], [5960, 5983, 0.0], [5983, 6602, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 495, 0.0], [495, 841, 0.0], [841, 1376, 0.0], [1376, 1915, 0.0], [1915, 2641, 0.0], [2641, 3297, 0.0], [3297, 3309, 0.0], [3309, 3951, 0.0], [3951, 3972, 0.0], [3972, 4454, 0.0], [4454, 5439, 0.0], [5439, 5960, 0.0], [5960, 5983, 0.0], [5983, 6602, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 495, 0.01212121], [495, 841, 0.01156069], [841, 1376, 0.00934579], [1376, 1915, 0.00742115], [1915, 2641, 0.01101928], [2641, 3297, 0.00609756], [3297, 3309, 0.83333333], [3309, 3951, 0.00623053], [3951, 3972, 0.85714286], [3972, 4454, 0.00829876], [4454, 5439, 0.0071066], [5439, 5960, 0.00959693], [5960, 5983, 0.86956522], [5983, 6602, 0.00969305]], "rps_doc_ml_palm_score": [[0, 6602, 0.13073492]], "rps_doc_ml_wikipedia_score": [[0, 6602, null]], "rps_doc_ml_wikiref_score": [[0, 6602, 0.03821623]], "rps_doc_books_importance": [[0, 6602, -161.46074562]], "rps_doc_openwebtext_importance": [[0, 6602, 100.87837858]], "rps_doc_wikipedia_importance": [[0, 6602, -376.30405097]], "rps_doc_num_sentences": [[0, 6602, 59.0]]} |
Meditating: It’s not all Unicorns and Rainbows
Mental health is a tender human experience, and we must be mindful of how we discuss it and share practices, like meditating, that may support us through it. Meditating is often touted as a “cure-all” for mental health. While it may be a helpful practice, it is neither a panacea nor easy. This misinformation is a disservice to those who may be helped by meditating. Continue Reading | 2023-14/0000/en_head.json.gz/1370 | {"url": "https://www.lifeofwellness.ca/tag/meditating/", "partition": "head_middle", "language": "en", "source_domain": "www.lifeofwellness.ca", "date_download": "2023-03-20T10:45:48Z", "digest": "sha1:SPDDIFXFLHGFWSTX7TYVDVMFNY6MAIG2"} | {"ccnet_length": [[0, 431, 431.0]], "ccnet_original_length": [[0, 431, 1492.0]], "ccnet_nlines": [[0, 431, 2.0]], "ccnet_original_nlines": [[0, 431, 37.0]], "ccnet_language_score": [[0, 431, 0.94]], "ccnet_perplexity": [[0, 431, 282.4]], "ccnet_bucket": [[0, 431, 0.0]], "rps_doc_curly_bracket": [[0, 431, 0.0]], "rps_doc_ldnoobw_words": [[0, 431, 0.0]], "rps_doc_lorem_ipsum": [[0, 431, 0.0]], "rps_doc_stop_word_fraction": [[0, 431, 0.49438202]], "rps_doc_ut1_blacklist": [[0, 431, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 431, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 431, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 431, 0.06896552]], "rps_doc_frac_chars_top_3gram": [[0, 431, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 431, 0.0]], "rps_doc_frac_all_caps_words": [[0, 431, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 431, 0.0]], "rps_doc_frac_no_alph_words": [[0, 431, 0.14606742]], "rps_doc_frac_unique_words": [[0, 431, 0.7027027]], "rps_doc_mean_word_length": [[0, 431, 4.7027027]], "rps_doc_symbol_to_word_ratio": [[0, 431, 0.0]], "rps_doc_unigram_entropy": [[0, 431, 3.78069867]], "rps_doc_word_count": [[0, 431, 74.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 47, 0.0], [47, 431, 0.0]], "rps_lines_javascript_counts": [[0, 47, 0.0], [47, 431, 0.0]], "rps_lines_num_words": [[0, 47, 7.0], [47, 431, 67.0]], "rps_lines_numerical_chars_fraction": [[0, 47, 0.0], [47, 431, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 47, 0.0], [47, 431, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 47, 0.08510638], [47, 431, 0.015625]], "rps_doc_ml_palm_score": [[0, 431, 0.71431315]], "rps_doc_ml_wikipedia_score": [[0, 431, null]], "rps_doc_ml_wikiref_score": [[0, 431, 0.00056237]], "rps_doc_books_importance": [[0, 431, -14.92772574]], "rps_doc_openwebtext_importance": [[0, 431, 6.03467052]], "rps_doc_wikipedia_importance": [[0, 431, -24.52629517]], "rps_doc_num_sentences": [[0, 431, 5.0]]} |
Stamps trace evolution of Kingdom of Serbs, Croats and Slovenes
May 2, 2021, 5 PM
A Yugoslavia-Slovenia 50-filler Allegory of Freedom stamp (Scott 3L18).
A Yugoslavia-Croatia 1-krone Falcon, Symbol of Liberty stamp (Scott 2L39), issued in 1919.
A Yugoslavia-Bosnia and Herzegovina 2-krone overprinted on Austria St. Luke’s Campanile stamp (Scott 1L13).
A Yugoslavia-Kingdom of Serbs, Croats and Slovenes 1-dinar King Peter I stamp (Scott 10), issued Jan. 16, 1921.
A Serbia 1-para King Peter I and Prince Alexander stamp (Scott 155), from the period after Serbia’s merger with Montenegro.
A 1-para King Nicholas I stamp from Montenegro (Scott 99).
This Bulgaria 1-lev Allegory of Macedonia stamp was prepared in 1917 but not officially issued.
By Rick Miller
The Kingdom of Serbs, Croats and Slovenes, a name expressing more truth than poetry, arose out of the ashes of World War I as a marriage of convenience.
It issued stamps from 1918 until the name of the country was officially changed to Yugoslavia (land of the Southern Slavs) on Oct. 3, 1929.
Serbia and Montenegro had been on the winning side in World War I, but they took a beating. Serbia suffered more casualties as a percentage of population, than any other country in the war.
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After Serbia and Montenegro were defeated and occupied by the Austro-Hungarian, Bulgarian, and German armies in 1915-1916, the Serbian and Montenegrin armies were evacuated to the Western Front, where they continued to fight.
When the Allies launched an invasion of the Balkans through Greece, the Serbian and Montenegrin armies returned as part of the invasion force.
After the war, Serbia expected to be rewarded. It happened that King Peter I of Serbia was the son-in-law of King Nicholas I of Montenegro. King Peter’s son, Crown Prince Alexander, was the grandson of King Nicholas.
King Peter was elderly, and Crown Prince Alexander was already effectively running much of the government. Although Montenegro had been on the winning side, the Allies countenanced Serbia engineering a merger with Montenegro.
King Nicholas and his sons were shunted aside in favor of King Peter and Alexander. It was hoped that because Alexander was the grandson of King Nicholas, the merger would be generally acceptable, but it was not in accordance with the wishes of the Montenegrin people.
Serbia acquired much of Macedonia from its victories in the First and Second Balkan Wars. After World War I, Serbia got much of the rest of Macedonia from Bulgaria, which had been on the losing side.
It was not a happy acquisition, and the Internal Macedonian Revolutionary Organization would carry out guerilla warfare and terrorist attacks and assassination against Serbia for much of the interwar period.
Croatia had been part of the Kingdom of Hungary since 1091, and with Hungary it joined the Habsburg Empire in 1526. Slovenia became part of the Habsburg Empire in the 13th century. Bosnia, which included Herzegovina, was a province of the Ottoman Empire.
In 1878, Austria-Hungary was given the right to administer the province. In 1908, Austria-Hungary annexed Bosnia outright, angering both the large Serbian population who lived there and the adjacent Kingdom of Serbia.
Croatia, Slovenia, and Bosnia had all been relatively loyal parts of the Austro-Hungarian Empire, contributing troops and support to the war effort.
But as the empire broke apart in 1918, it was clear that the successor states of the empire would be punished by the victorious Allies with loss of territory and reparations payments.
When approached by the Serbians with the possibility of forming one country, all three saw it as an opportunity to change their status from a defeated Central Power to a victorious Ally, so they agreed.
From 1918 to January 1921, Serbia, Croatia, Slovenia, and Bosnia operated separate postal systems, issued their own stamps, and even used different monetary systems.
The stamps of Serbia only bear that country’s name, but the stamps of the other three nations bear their own name plus the abbreviation “S H S” for the Kingdom of Serbia, Croatia (Hrvatska in Croatian) and Slovenia.
In January 1921, the separate postal systems and currencies were amalgamated into one system, and each country ceased to issue its own stamps.
The general-issue stamps prepared for use throughout the country were inscribed Kingdom of Serbs, Croats and Slovenes in Cyrillic and Latin letters and denominated in paras and dinars.
The country was doomed to failure by its inherent contradictions.
The Serbs tended to view the country as Greater Serbia, while the Croats and Slovenes in particular had in mind a relatively loose confederation.
The Serbs, Croats, and Bosnians all spoke the same language (Serbo-Croatian), but the Serbs used the Cyrillic alphabet while the others used the Latin alphabet.
The Slovenes, Macedonians, and the Albanian minority in Serbia and Montenegro had their own languages.
The Serbs, Montenegrins, and Macedonians were Eastern Orthodox Christians. The Croats and Slovenes were Roman Catholic. The Bosniaks and the large Albanian minority were Muslim.
The populations were all mixed in together, with Serbs living in Croatia and Bosnia, Croats living in Serbia and Bosnia, and Albanians living in Serbia and Macedonia.
The country staggered on, an unhappy conglomeration with conflicting aspirations and identities, until Germany crushed it in 1941 prior to invading the Soviet Union.
After the war, the corpse of the country was unnaturally held together by communism.
With the collapse of communism in the 1990s, the country finally broke into its constituent pieces, although not without great bloodshed and destruction. | 2023-14/0000/en_head.json.gz/1371 | {"url": "https://www.linns.com/news/us-stamps-postal-history/stamps-trace-evolution-of-kingdom-of-serbia--croatia-and-sloveni.html", "partition": "head_middle", "language": "en", "source_domain": "www.linns.com", "date_download": "2023-03-20T09:48:44Z", "digest": "sha1:ZB6Y4NMDZ3F2JYVLTSYWGAQ4STRL3BJU"} | {"ccnet_length": [[0, 5736, 5736.0]], "ccnet_original_length": [[0, 5736, 9408.0]], "ccnet_nlines": [[0, 5736, 40.0]], "ccnet_original_nlines": [[0, 5736, 166.0]], "ccnet_language_score": [[0, 5736, 0.97]], "ccnet_perplexity": [[0, 5736, 173.1]], "ccnet_bucket": [[0, 5736, 0.0]], "rps_doc_curly_bracket": [[0, 5736, 0.0]], "rps_doc_ldnoobw_words": [[0, 5736, 0.0]], "rps_doc_lorem_ipsum": [[0, 5736, 0.0]], "rps_doc_stop_word_fraction": [[0, 5736, 0.36032757]], "rps_doc_ut1_blacklist": [[0, 5736, 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Tag Archives: Selfish
To Be Selfish — or Not?
Posted on February 27, 2023 by Lisa Kothari
Selfish or Selfless?
To be selfish — or not? That is the question.
I am always reading the news and find myself stumbling upon articles around mental health, which, of course, catch my attention. This week it was an article in the Times about The Benefits of Wise Selfishness. I had to laugh out loud as I read how the article had to spin selfishness (something our society judges as a bad thing) into something that is OK to be these days. Actually necessary.
I tend to agree with this article, but I wouldn’t call it “wise” but rather absolutely necessary and critical to our own mental health. And it is mind boggling to me that people feel that it is wrong to think about themselves and hold their interests in mind. Like everything, just because we are thinking about ourselves does not mean we can’t also think about the other.
If you think about it, in the airplanes, during the safety instructions, parents are always told to put on their own oxygen mask on before putting it on their child. Intuitively, we must be cared for before we can offer care to another — even our own child in this case!
It is important that we hold ourselves in minds throughout our days that make up our lives. That we are living out of alignment with who we are, our values, our bliss, our boundaries, and more. It may sound selfish, but I don’t see it that way, I would actually argue if we cannot hold ourselves in mind and take care of our desires, needs, and wants we really cannot extend that to another in an authentic and true way. When we turn our backs on our own selves to be selfless there is something inauthentic about how we are doing for others — rather than it springing forth from a full well of ourselves, it is motivated by a turning away from ourselves to sink into the other, perhaps putting their needs above our own.
This is then applauded by society. This type of person is so selfless and does for others with asking for nothing in return for themselves. What exactly is going on here is where my mind goes? Why is it so difficult for the person to be with herself and be there for one’s self? Often the message is you are selfish and bad for thinking about yourself.
Ah, selfish, selfless — such judgements on people and situations which we hardly know the truth of it at all. It isn’t wise to be selfish and it isn’t unwise to be selfless. We love to organize our minds with things being all good or all bad. The truth is holding yourself in mind is mentally healthy and then allows for us to be there for others that are authentic and true to who we are as we are also held in mind alongside the others we are holding in mind. This can be in parallel and does not need to be an “either/or” situation.
Let’s all practice remembering ourselves first as a basic tenet of good mental health. From there, it’s up to you how you would like to do or not do for others. Selfish, selfless — it’s time to drop these judgments.
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Bridging the digital divide and addressing the need of Rural Communities with Cost-effective and Environmental-Friendly Connectivity Solutions
COMMECT
Rural and remote areas remain largely unconnected to the internet as they face several challenges, ranging from obvious ones - lower population density, greater distances, and rough terrain – to less obvious ones that greatly affect the success of the deployment process: policies, regulations, cost of deployment, difficulty in attracting investment, lack of technical knowledge to select the most appropriate connectivity, and more. As recognised by the EU, digital access is an imperative to ensure that every citizen has an equal opportunity to thrive. Reliable high-speed broadband connectivity is therefore a primary need for the sustainability of rural communities, to improve their lives in the immediate as well as the long-term.
COMMECT will support the specific needs and opportunities of rural areas and their populations, helping them overcome current challenges. To bridge the digital divide, COMMECT will provide quality, reliable and secure access for all in rural and remote areas. The goal of extending broadband connectivity in rural and remote areas will be achieved by integrating Non- Terrestrial Networks (NTNs) with terrestrial cellular XG networks, and low-cost Internet of Things (IoT). Artificial Intelligence, Edge and Network Automation will be adopted to reduce energy consumption, both at connectivity and computing level, with the final objective of designing energy-efficient, and environmental-friendly connectivity solutions.
COMMECT is an EU project, funded under the Horizon Europe programme, which proposes a two-pronged approach toward digital inclusion of rural communities: (1) easy access to fast and reliable broadband Internet (making it affordable for all, and able to meet different end-user’s needs), and (2) training rural communities and businesses toward the adoption of the digital technologies.
A joint approach with end-users and ICT experts working together on development challenges will be the key for the digitalisation of the agro—forest sector. To ensure the rich exchange of best-practice and technical knowledge among the actors of the agro-forestry value chain, COMMECT will set up five Living Labs across and outside Europe: digitalisation of viticulture in Luxembourg, connected forestry in Norway, connected livestock transport in Denmark, smart olive tree farming in Turkey, and sustainable agriculture and preservation of natural environment in Serbia.
In the Living Labs, the end-users' pains and connectivity gains will be discussed, but from different perspectives, e.g. societal, economic, and environmental. These Labs will ensure co- production of knowledge; continuous participation and involvement of end-users and other relevant stakeholders; experimental approaches in real-life contexts, toward the design of a purpose-driven digital infrastructure, tailored to the real needs of the rural communities.
COMMECT aims at contributing to a balanced territorial development of the EU’s rural areas and their communities by making smart agriculture and forest services accessible to all. COMMECT will facilitate that, by developing a decision-making support tool (DST) able to advise on the best connectivity solution, according to technical, socio-economic, and environmental considerations. This tool, incorporating collaborative business models, will be a key enabler for jobs, business, and investment in rural areas, as well for improving the quality of life in areas such as healthcare, education, e-government, among others. The DST will lay the groundwork for a sustainable, balanced, and inclusive development of rural areas beyond agriculture, farming and forestry. COMMECT will also contribute towards the achievement of UN Sustainable Development Goals (SDG), in particular, SDG 9 Industry, Innovation and Infrastructure, SDG 10 Reduced Inequalities and SDG 11 Sustainable Cities and Communities, SDG 12 Responsible Consumption and Production, SDG 13 Climate Action, and SDG 17 Partnerships for the Goals.
COMMECT brings together a consortium of 20 partners from 11 different countries. LIST is coordinating the entire consortium, and project activities, in particular the coordination and collaboration among the 5 Living labs and leading the Living lab in Luxembourg on viticulture.
Research domains
Project Factsheet
Download PDF Factsheet
University of Aarhus (DK)
Aalborg Universitet (DK)
Inland Norway University of Applied Sciences (NO)
Nederlandse Organisatie voor toegepast-natuurwetenschappelijk onderzoek (NL)
Seinäjoki University of Applied Sciences (FI)
SES Techcom S.A. (LU)
Telenor ASA (NO)
Turkcell Teknoloji Araştırma ve Geliştirme Anonim Şirketi (TR)
DunavNET doo (SRB)
Huawei Technologies (Ireland) Co Limited (IRL)
Luxsense (LU)
Padborg Transportcenter F.m.b.a. (DK)
Viveris Technologies (FR)
Institut fir biologesch Landwirtschaft an Agrarkultur Luxemburg (LU)
Klosser innovasjon (NO)
Ministry of Agriculture and Forestry (TR)
Local Council Gospodjinci (SRB)
Zemljoradnicka zadruga Solar Agro (SRB)
Huawei Technologies Duesseldorf GMBH (DE)
Dr Maria Rita PALATTELLA
Website (live soon)
Linked projects
LORSAT
Lux5GCloud
HEMS
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We’re a mixed up bunch
In Albury-Wodonga, the weekly free newspapers used to include a column of reflections. They were written by local ministers, or similar (authors included a local Baha’i leader, as well as someone from the local humanist society branch). I don’t know why they stopped. Equally, I don’t know if they achieved anything!
Cleaning up my computer, I found a few of mine. In the interests of recycling, I will re-release them on this blog.
July does the same thing every year. The weather makes it less appealing to ride my bike. The TV makes it more inviting to watch others ride their bikes. Yes – I’m addicted to the Tour de France.
Each year I again fall for the helicopter shots of tourist sites, for the speed of fast flat racing, for the pain of riding up ridiculously long mountain roads. There’s a lot to see: fanatical fans; beautiful country; selfless teamwork; athleticism.
This year there was even the chance of an Australian winner. I hope I’m not crazy, but I tried to support Cadel Evans by riding my bike down Cadell St in Albury a few times.
Yet cycling has a problem. Drugs. Again in 2007 there were accusations of cheating and lying. Some cyclists were caught, some teams were kicked out.
There’s no excuse for cheating, but I am not surprised that people try.
These ups and downs are simply an expression of what people are like. We’re a mixed-up bunch, both wonderful and awful at the same time. I started with the Tour de France, so here’s a famous French thinker. Blaise Pascal called people ‘the glory and the shame of the universe.’
If there’s a shadow over cycling it is because there is a shadow over humanity.
Jesus also knew that we’re a mixed-up bunch. Talking about families in Luke’s gospel chapter 11, Jesus pointed out that we don’t give our children scorpions if they ask for food. Yet we are far from perfect. He said that we who are evil know how to give good gifts.
That’s certainly confused. Is there any solution?
It’s no solution to pretend everything is alright. There are drugs in pro sport. And there is failure in our lives.
It’s no solution to give up. Drug testing should continue. And we still admire those able to say sorry.
Jesus’ words point us to the real solution, prayer to God our Father. He’s the one who gives the good gifts of life and forgiveness.
This entry was posted in Christianity & culture and tagged Luke 11:11-13, Prayer, Reflections column, Sin on 15 January, 2013 by Chris.
← Most-clicked posts of 2012 Sport will let us down → | 2023-14/0000/en_head.json.gz/1374 | {"url": "https://www.littlepeople.id.au/2013/01/were-a-mixed-up-bunch/", "partition": "head_middle", "language": "en", "source_domain": "www.littlepeople.id.au", "date_download": "2023-03-20T09:42:32Z", "digest": "sha1:AOIIDBZOKNRQJ25NACBRQLJ447WSZHZN"} | {"ccnet_length": [[0, 2513, 2513.0]], "ccnet_original_length": [[0, 2513, 3555.0]], "ccnet_nlines": [[0, 2513, 17.0]], "ccnet_original_nlines": [[0, 2513, 67.0]], "ccnet_language_score": [[0, 2513, 0.96]], "ccnet_perplexity": [[0, 2513, 321.5]], "ccnet_bucket": [[0, 2513, 0.0]], "rps_doc_curly_bracket": [[0, 2513, 0.0]], "rps_doc_ldnoobw_words": [[0, 2513, 0.0]], "rps_doc_lorem_ipsum": [[0, 2513, 0.0]], "rps_doc_stop_word_fraction": [[0, 2513, 0.39646018]], "rps_doc_ut1_blacklist": [[0, 2513, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2513, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2513, 0.00903614]], "rps_doc_frac_chars_top_3gram": [[0, 2513, 0.01004016]], "rps_doc_frac_chars_top_4gram": [[0, 2513, 0.01506024]], "rps_doc_frac_all_caps_words": [[0, 2513, 0.02123894]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2513, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2513, 0.18053097]], "rps_doc_frac_unique_words": [[0, 2513, 0.60356347]], "rps_doc_mean_word_length": [[0, 2513, 4.43652561]], "rps_doc_symbol_to_word_ratio": [[0, 2513, 0.0]], "rps_doc_unigram_entropy": [[0, 2513, 5.284102]], "rps_doc_word_count": [[0, 2513, 449.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 23, 0.0], [23, 340, 1.0], [340, 456, 1.0], [456, 652, 1.0], [652, 902, 1.0], [902, 1076, 1.0], [1076, 1225, 1.0], [1225, 1297, 1.0], [1297, 1575, 0.0], [1575, 1655, 1.0], [1655, 1921, 1.0], [1921, 1971, 1.0], [1971, 2087, 1.0], [2087, 2191, 1.0], [2191, 2324, 1.0], [2324, 2460, 1.0], [2460, 2513, 0.0]], "rps_lines_javascript_counts": [[0, 23, 0.0], [23, 340, 0.0], [340, 456, 0.0], [456, 652, 0.0], [652, 902, 0.0], [902, 1076, 0.0], [1076, 1225, 0.0], [1225, 1297, 0.0], [1297, 1575, 0.0], [1575, 1655, 0.0], [1655, 1921, 0.0], [1921, 1971, 0.0], [1971, 2087, 0.0], [2087, 2191, 0.0], [2191, 2324, 0.0], [2324, 2460, 0.0], [2460, 2513, 0.0]], "rps_lines_num_words": [[0, 23, 5.0], [23, 340, 51.0], [340, 456, 22.0], [456, 652, 38.0], [652, 902, 41.0], [902, 1076, 35.0], [1076, 1225, 25.0], [1225, 1297, 13.0], [1297, 1575, 50.0], [1575, 1655, 15.0], [1655, 1921, 50.0], [1921, 1971, 7.0], [1971, 2087, 21.0], [2087, 2191, 19.0], [2191, 2324, 25.0], [2324, 2460, 21.0], [2460, 2513, 11.0]], "rps_lines_numerical_chars_fraction": [[0, 23, 0.0], [23, 340, 0.0], [340, 456, 0.0], [456, 652, 0.0], [652, 902, 0.0], [902, 1076, 0.0], [1076, 1225, 0.02797203], [1225, 1297, 0.0], [1297, 1575, 0.0], [1575, 1655, 0.0], [1655, 1921, 0.00772201], [1921, 1971, 0.0], [1971, 2087, 0.0], [2087, 2191, 0.0], [2191, 2324, 0.0], [2324, 2460, 0.0952381], [2460, 2513, 0.07692308]], "rps_lines_start_with_bulletpoint": [[0, 23, 0.0], [23, 340, 0.0], [340, 456, 0.0], [456, 652, 0.0], [652, 902, 0.0], [902, 1076, 0.0], [1076, 1225, 0.0], [1225, 1297, 0.0], [1297, 1575, 0.0], [1575, 1655, 0.0], [1655, 1921, 0.0], [1921, 1971, 0.0], [1971, 2087, 0.0], [2087, 2191, 0.0], [2191, 2324, 0.0], [2324, 2460, 0.0], [2460, 2513, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 23, 0.04347826], [23, 340, 0.02523659], [340, 456, 0.03448276], [456, 652, 0.04591837], [652, 902, 0.012], [902, 1076, 0.05747126], [1076, 1225, 0.02684564], [1225, 1297, 0.02777778], [1297, 1575, 0.02877698], [1575, 1655, 0.0125], [1655, 1921, 0.02255639], [1921, 1971, 0.04], [1971, 2087, 0.02586207], [2087, 2191, 0.02884615], [2191, 2324, 0.03007519], [2324, 2460, 0.05882353], [2460, 2513, 0.03773585]], "rps_doc_ml_palm_score": [[0, 2513, 0.06821233]], "rps_doc_ml_wikipedia_score": [[0, 2513, null]], "rps_doc_ml_wikiref_score": [[0, 2513, 0.00564873]], "rps_doc_books_importance": [[0, 2513, -137.49046847]], "rps_doc_openwebtext_importance": [[0, 2513, 51.67791709]], "rps_doc_wikipedia_importance": [[0, 2513, -237.16667716]], "rps_doc_num_sentences": [[0, 2513, 40.0]]} |
Home / Self-Improvement Tips / Anger Management Techniques for Teens: 3 Great Tips To Deal With Anger
Anger Management Techniques for Teens: 3 Great Tips To Deal With Anger
These days, there is a great need for people to learn about anger management techniques for teens. Teenagers today deal with so many personal issues and yet know very little about handling them the right way.
Unfortunately, this lack of knowledge gets them into all sorts of trouble. Teens have the tendency to release all their negative energy onto other people (and even themselves) and do things they later regret.
However, there are better ways to deal with anger, and these three anger management techniques for teens will show you how.
1) Learn to relax.
When you’re angry, everything about you is agitated. Tense. Feeding this agitation will only serve to make you angrier.
In order to prevent the situation from getting worse, calm yourself down. Think of the people who make you happy and feel your body muscles relax.
2) Focus on solving the problem.
One of the most important anger management techniques for teens is to divert the focus on the solution, not the problem.
Don’t let your emotions get the better of you. Instead of focusing on the negative feeling, focus on the possible solutions to the problem. Look at it from a different point of view and try to figure out what you can do to make things better. Do this one step at a time.
3) Find a creative outlet.
If there’s nothing you can do to solve the problem at the moment, find a creative outlet. This is one of the most effective anger management techniques for teens because it does not only help you release aggression in a healthy way; it also paves the way for the discovery of new skills and hobbies. You can try drawing or writing in a journal for starters.
There’s nothing wrong with being angry or even letting it all out. What is important is that you don’t get yourself into trouble for it, and that you express your anger in a healthy way. Hopefully, these three anger management techniques for teens will help you achieve that.
Now you can easily become your own psychiatrist. Discover breakthrough anger management tips to transform the deadly effects of your anger into a stimulating experience at http://www.20daypersuasion.com/ripping-loose.htm | 2023-14/0000/en_head.json.gz/1375 | {"url": "https://www.livinginwellbeing.org/anger-management-techniques-for-teens-3-great-tips-to-deal-with-anger/", "partition": "head_middle", "language": "en", "source_domain": "www.livinginwellbeing.org", "date_download": "2023-03-20T10:04:09Z", "digest": "sha1:BOGPPKENODJ7CSRNAKHS2WLZMOWK2WCF"} | {"ccnet_length": [[0, 2307, 2307.0]], "ccnet_original_length": [[0, 2307, 11629.0]], "ccnet_nlines": [[0, 2307, 15.0]], "ccnet_original_nlines": [[0, 2307, 368.0]], "ccnet_language_score": [[0, 2307, 0.93]], "ccnet_perplexity": [[0, 2307, 293.9]], "ccnet_bucket": [[0, 2307, 0.0]], "rps_doc_curly_bracket": [[0, 2307, 0.0]], "rps_doc_ldnoobw_words": [[0, 2307, 0.0]], "rps_doc_lorem_ipsum": [[0, 2307, 0.0]], "rps_doc_stop_word_fraction": [[0, 2307, 0.47084233]], "rps_doc_ut1_blacklist": [[0, 2307, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2307, 0.06243272]], "rps_doc_frac_chars_dupe_5grams": [[0, 2307, 0.16630786]], "rps_doc_frac_chars_dupe_6grams": [[0, 2307, 0.11302476]], "rps_doc_frac_chars_dupe_7grams": [[0, 2307, 0.11302476]], "rps_doc_frac_chars_dupe_8grams": [[0, 2307, 0.11302476]], "rps_doc_frac_chars_dupe_9grams": [[0, 2307, 0.06243272]], "rps_doc_frac_chars_top_2gram": [[0, 2307, 0.06458558]], "rps_doc_frac_chars_top_3gram": [[0, 2307, 0.0941873]], "rps_doc_frac_chars_top_4gram": [[0, 2307, 0.10548977]], "rps_doc_frac_all_caps_words": [[0, 2307, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2307, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2307, 0.13606911]], "rps_doc_frac_unique_words": [[0, 2307, 0.4605598]], "rps_doc_mean_word_length": [[0, 2307, 4.72773537]], "rps_doc_symbol_to_word_ratio": [[0, 2307, 0.0]], "rps_doc_unigram_entropy": [[0, 2307, 4.78535128]], "rps_doc_word_count": [[0, 2307, 393.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 102, 0.0], [102, 173, 0.0], [173, 382, 1.0], [382, 591, 1.0], [591, 715, 1.0], [715, 734, 1.0], [734, 854, 1.0], [854, 1001, 1.0], [1001, 1034, 1.0], [1034, 1155, 1.0], [1155, 1426, 1.0], [1426, 1453, 1.0], [1453, 1811, 1.0], [1811, 2087, 1.0], [2087, 2307, 0.0]], "rps_lines_javascript_counts": [[0, 102, 0.0], [102, 173, 0.0], [173, 382, 0.0], [382, 591, 0.0], [591, 715, 0.0], [715, 734, 0.0], [734, 854, 0.0], [854, 1001, 0.0], [1001, 1034, 0.0], [1034, 1155, 0.0], [1155, 1426, 0.0], [1426, 1453, 0.0], [1453, 1811, 0.0], [1811, 2087, 0.0], [2087, 2307, 0.0]], "rps_lines_num_words": [[0, 102, 15.0], [102, 173, 12.0], [173, 382, 36.0], [382, 591, 34.0], [591, 715, 21.0], [715, 734, 4.0], [734, 854, 19.0], [854, 1001, 26.0], [1001, 1034, 6.0], [1034, 1155, 21.0], [1155, 1426, 53.0], [1426, 1453, 5.0], [1453, 1811, 66.0], [1811, 2087, 48.0], [2087, 2307, 27.0]], "rps_lines_numerical_chars_fraction": [[0, 102, 0.01052632], [102, 173, 0.01449275], [173, 382, 0.0], [382, 591, 0.0], [591, 715, 0.0], [715, 734, 0.0625], [734, 854, 0.0], [854, 1001, 0.0], [1001, 1034, 0.03333333], [1034, 1155, 0.0], [1155, 1426, 0.0], [1426, 1453, 0.04166667], [1453, 1811, 0.0], [1811, 2087, 0.0], [2087, 2307, 0.00947867]], "rps_lines_start_with_bulletpoint": [[0, 102, 0.0], [102, 173, 0.0], [173, 382, 0.0], [382, 591, 0.0], [591, 715, 0.0], [715, 734, 0.0], [734, 854, 0.0], [854, 1001, 0.0], [1001, 1034, 0.0], [1034, 1155, 0.0], [1155, 1426, 0.0], [1426, 1453, 0.0], [1453, 1811, 0.0], [1811, 2087, 0.0], [2087, 2307, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 102, 0.1372549], [102, 173, 0.14084507], [173, 382, 0.00956938], [382, 591, 0.00956938], [591, 715, 0.00806452], [715, 734, 0.05263158], [734, 854, 0.025], [854, 1001, 0.01360544], [1001, 1034, 0.03030303], [1034, 1155, 0.00826446], [1155, 1426, 0.01476015], [1426, 1453, 0.03703704], [1453, 1811, 0.00837989], [1811, 2087, 0.01086957], [2087, 2307, 0.00909091]], "rps_doc_ml_palm_score": [[0, 2307, 0.01614797]], "rps_doc_ml_wikipedia_score": [[0, 2307, null]], "rps_doc_ml_wikiref_score": [[0, 2307, 0.00957662]], "rps_doc_books_importance": [[0, 2307, -129.78664164]], "rps_doc_openwebtext_importance": [[0, 2307, -8.5334967]], "rps_doc_wikipedia_importance": [[0, 2307, -203.31925413]], "rps_doc_num_sentences": [[0, 2307, 29.0]]} |
Home / Addiction & It's Management / Smoking Addiction & Life
Smoking Addiction & Life
Nicotine addiction or cigarette smoking is considered by many california drug rehab center across the state as one of the hardest addiction to cure. This is because cigarettes are as much available as alcohols are in most parts of the world, thus every people, and every age, have access to buy a pack of cigarette from a nearby store. Though not as harmful as other illicit drugs such as heroin, cocaine, and amphetamines, long-term and abusive use of nicotines can have its adverse effects. Technically, nicotine is not significantly addictive, as nicotine administered alone does not produce significant reinforcing properties. However, only after coadministration with an MAOI, such as those found in tobacco, nicotine produces significant behavioral sensitization, a measure of addiction potential. This is similar in effect to amphetamine.
Addictive Effects
Modern research shows that nicotine acts on the brain to produce a number of effects. Specifically, its addictive nature has been found to show that nicotine activates reward pathways-the circuitry within the brain that regulates feelings of pleasure and euphoria. Dopamine is one of the key neurotransmitters actively involved in the brain. According to california drug rehab center researchers, by increasing the levels of dopamine within the reward circuits in the brain, nicotine acts as a chemical with intense addictive qualities.
In many studies it has been shown to be more addictive than cocaine and heroin, though chronic treatment has an opposite effect on reward thresholds. Like other physically addictive drugs, nicotine causes down-regulation of the production of dopamine and other stimulatory neurotransmitters as the brain attempts to compensate for artificial stimulation. In addition, the sensitivity of nicotinic acetylcholine receptors decreases. A study found that nicotine exposure in adolescent mice retards the growth of the dopamine system, thus increasing the risk of substance abuse during adolescence.
Nicotine Addiction Treatments
According to california drug rehab center therapists, various drugs have been used as treatments for nicotine addiction such as bupropion, mecamylamine and the more recently developed varenicline.
* Bupropion - Is an atypical antidepressant that acts as a norepinephrine and dopamine reuptake inhibitor, and nicotinic antagonist. Initially researched and marketed as an antidepressant, bupropion was subsequently found to be effective as a smoking cessation aid.
* Mecamylamine - Is a voltage dependant non-competitive antagonist at nicotinic receptors. Mecamylamine is used to help people stop smoking tobacco, and is now more widely used for this application than it is for lowering blood pressure.
* Varenicline - Is a prescription medication used to treat smoking addiction. As a partial agonist, it both reduces cravings for and decreases the pleasurable effects of cigarettes and other tobacco products, and through these mechanisms it can assist some patients in stopping smoking.
Posted on September 1, 2013 by Dr.Purushothaman Kollam in Addiction & It's Management, Uncategorised / Miscellaneous | 2023-14/0000/en_head.json.gz/1376 | {"url": "https://www.livinginwellbeing.org/smoking-addition-life/", "partition": "head_middle", "language": "en", "source_domain": "www.livinginwellbeing.org", "date_download": "2023-03-20T10:13:18Z", "digest": "sha1:ONNHBJD2J24YHJQQWNSNP6E7KA3ONCQ2"} | {"ccnet_length": [[0, 3217, 3217.0]], "ccnet_original_length": [[0, 3217, 12001.0]], "ccnet_nlines": [[0, 3217, 12.0]], "ccnet_original_nlines": [[0, 3217, 341.0]], "ccnet_language_score": [[0, 3217, 0.94]], "ccnet_perplexity": [[0, 3217, 317.2]], "ccnet_bucket": [[0, 3217, 0.0]], "rps_doc_curly_bracket": [[0, 3217, 0.0]], "rps_doc_ldnoobw_words": [[0, 3217, 0.0]], "rps_doc_lorem_ipsum": [[0, 3217, 0.0]], "rps_doc_stop_word_fraction": [[0, 3217, 0.37523105]], "rps_doc_ut1_blacklist": [[0, 3217, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3217, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3217, 0.0269562]], "rps_doc_frac_chars_dupe_6grams": [[0, 3217, 0.0269562]], "rps_doc_frac_chars_dupe_7grams": [[0, 3217, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 3217, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3217, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3217, 0.00935979]], "rps_doc_frac_chars_top_3gram": [[0, 3217, 0.02134032]], "rps_doc_frac_chars_top_4gram": [[0, 3217, 0.02807937]], "rps_doc_frac_all_caps_words": [[0, 3217, 0.00369686]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3217, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3217, 0.13123845]], "rps_doc_frac_unique_words": [[0, 3217, 0.49247312]], "rps_doc_mean_word_length": [[0, 3217, 5.74408602]], "rps_doc_symbol_to_word_ratio": [[0, 3217, 0.0]], "rps_doc_unigram_entropy": [[0, 3217, 4.998297]], "rps_doc_word_count": [[0, 3217, 465.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 62, 0.0], [62, 87, 0.0], [87, 933, 1.0], [933, 951, 0.0], [951, 1488, 1.0], [1488, 2083, 1.0], [2083, 2113, 0.0], [2113, 2310, 1.0], [2310, 2576, 1.0], [2576, 2814, 1.0], [2814, 3101, 1.0], [3101, 3217, 0.0]], "rps_lines_javascript_counts": [[0, 62, 0.0], [62, 87, 0.0], [87, 933, 0.0], [933, 951, 0.0], [951, 1488, 0.0], [1488, 2083, 0.0], [2083, 2113, 0.0], [2113, 2310, 0.0], [2310, 2576, 0.0], [2576, 2814, 0.0], [2814, 3101, 0.0], [3101, 3217, 0.0]], "rps_lines_num_words": [[0, 62, 7.0], [62, 87, 3.0], [87, 933, 130.0], [933, 951, 2.0], [951, 1488, 81.0], [1488, 2083, 85.0], [2083, 2113, 3.0], [2113, 2310, 27.0], [2310, 2576, 36.0], [2576, 2814, 35.0], [2814, 3101, 42.0], [3101, 3217, 14.0]], "rps_lines_numerical_chars_fraction": [[0, 62, 0.0], [62, 87, 0.0], [87, 933, 0.0], [933, 951, 0.0], [951, 1488, 0.0], [1488, 2083, 0.0], [2083, 2113, 0.0], [2113, 2310, 0.0], [2310, 2576, 0.0], [2576, 2814, 0.0], [2814, 3101, 0.0], [3101, 3217, 0.0462963]], "rps_lines_start_with_bulletpoint": [[0, 62, 0.0], [62, 87, 0.0], [87, 933, 0.0], [933, 951, 0.0], [951, 1488, 0.0], [1488, 2083, 0.0], [2083, 2113, 0.0], [2113, 2310, 0.0], [2310, 2576, 0.0], [2576, 2814, 0.0], [2814, 3101, 0.0], [3101, 3217, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 62, 0.11290323], [62, 87, 0.12], [87, 933, 0.01182033], [933, 951, 0.11111111], [951, 1488, 0.00744879], [1488, 2083, 0.00672269], [2083, 2113, 0.1], [2113, 2310, 0.00507614], [2310, 2576, 0.0112782], [2576, 2814, 0.01260504], [2814, 3101, 0.01045296], [3101, 3217, 0.0862069]], "rps_doc_ml_palm_score": [[0, 3217, 0.35797906]], "rps_doc_ml_wikipedia_score": [[0, 3217, null]], "rps_doc_ml_wikiref_score": [[0, 3217, 0.2818169]], "rps_doc_books_importance": [[0, 3217, -69.15897098]], "rps_doc_openwebtext_importance": [[0, 3217, 19.35905256]], "rps_doc_wikipedia_importance": [[0, 3217, 20.69017555]], "rps_doc_num_sentences": [[0, 3217, 23.0]]} |
Tecolotes held to 2 hits by Rieleros in Fermin’s first game
Jason Mack, LMTonline.com / Laredo Morning Times
May 8, 2018 Updated: May 9, 2018 12:25 a.m.
The Tecolotes were held to two hits Tuesday as they lost 12-1 in their series opener at Aguascalientes.Christian Alejandro Ocampo /Laredo Morning Times file
The Felix Fermin era got off to an inauspicious start for the Tecolotes Dos Laredos on Tuesday as they were held to a pair of hits and opened a six-game road trip with a 12-1 loss at Rieleros de Aguascalientes.
Fermin was announced as the new manager Monday as the Tecolotes moved on from Eddy Castro with three weeks remaining in the regular season. The Tecos sat 5 ½ games back of the fourth and final playoff spot in the Mexican League’s North division when they made the change at the top. Castro finished 206-273 in his career managing the Tecolotes and Rojos del Águila.
The Tecolotes (15-25) didn’t lose any ground Tuesday but missed out on a chance to inch closer in the playoff race. Fourth-place Monclova (20-19) lost 15-6 at Laguna, and fifth-place Durango (17-22) was lost 4-2 at Saltillo. The Tecos could have climbed within a game of fifth place and 4 ½ games of fourth with a victory. Instead, they dropped into seventh place at half a game behind Saltillo (15-24). The third-place Rieleros (23-17) moves into second place as Monterrey (27-13) extended its division lead with a 2-1 win over Tijuana (22-17).
Entering the week ranked 14th out of 16 teams with a .274 team batting average, the Tecolotes failed to help their cause Tuesday. They finished just four over the minimum hitting 2-for-29 with two walks and six strikeouts. Balbino Fuenmayor and Enrique Osorio previously had hit streaks of 16 and 14 games, respectively, and both were kept off the board combining to go 0-for-6 with two strikeouts.
Yeison Asencio had the only hit until the ninth inning when Carlos Munoz replaced Fuenmayor and picked up his third hit of the season. Ivan Bellazetin and Josh Rodriguez each added a walk.
Alexis Candelario (0-3, 4.82 ERA) had his second shortest outing of the season giving up seven hits and a walk in 2.2 innings. He allowed six runs with only two of them earned. Gerardo Gutierrez pitched 2.1 scoreless innings to keep the Tecolotes within striking distance, but four runs scored on Norman Elenes and Luis Enrique Rodriguez in the sixth inning to put the game out of reach. Yohan Flande (3-0, 4.66 ERA) earned the win holding the Tecos to one hit and an unearned run with five strikeouts in six innings.
The Tecolotes briefly gave Fermin a lead early in his first game as manager, but it didn’t last long. Asencio lined a single into center field to lead off the second inning and moved to second on a wild pitch. He was nearly stranded there with consecutive strikeouts, but a fielding error in right field allowed Juan Martinez to reach and Asencio to score for a 1-0 lead.
The Rieleros broke through in the bottom of the third inning as an error on a sacrifice bunt loaded the bases with no outs. After a single from Cristhian Presichi drove in two runs, the Tecolotes turned a double play setting up a chance to limit the damage. Instead, an error in the next at bat was followed by five straight hits allowing Aguascalientes to take a 6-1 lead and chase Candelario.
Following the run off the error in the second inning, the Tecolotes had 17 straight batters retired before Bellazetin and Rodriguez drew consecutive walks in the eighth. Aguascalientes extended the lead to 10-1 in the sixth inning. An RBI single chased Elenes, and two pitches into his relief appearance Rodriguez gave up a three-run home run to Michael Wing. It was Wing’s sixth homer of the season. Marc Flores hit his fourth home run with two outs in the eighth for a 12-1 advantage.
Carlos Munoz pinch hit for Fuenmayor and broke up the one-hitter with a single into left field in the ninth inning, but Alan Espinoza grounded into a double play on the next pitch to end the game.
The Tecolotes will attempt to avoid locking up a sixth straight series loss as they continue at 7:30 p.m. Wednesday at Aguascalientes.
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Jason Mack is the Deputy Editor at the Laredo Morning Times | 2023-14/0000/en_head.json.gz/1377 | {"url": "https://www.lmtonline.com/sports/article/Tecolotes-held-to-2-hits-by-Rieleros-in-12899262.php", "partition": "head_middle", "language": "en", "source_domain": "www.lmtonline.com", "date_download": "2023-03-20T09:55:04Z", "digest": "sha1:EKG243PQDK4ODTZ7UHELC37FSACNQACP"} | {"ccnet_length": [[0, 4249, 4249.0]], "ccnet_original_length": [[0, 4249, 6938.0]], "ccnet_nlines": [[0, 4249, 20.0]], "ccnet_original_nlines": [[0, 4249, 117.0]], "ccnet_language_score": [[0, 4249, 0.96]], "ccnet_perplexity": [[0, 4249, 331.3]], "ccnet_bucket": [[0, 4249, 0.0]], "rps_doc_curly_bracket": [[0, 4249, 0.0]], "rps_doc_ldnoobw_words": [[0, 4249, 0.0]], "rps_doc_lorem_ipsum": [[0, 4249, 0.0]], "rps_doc_stop_word_fraction": [[0, 4249, 0.36092715]], "rps_doc_ut1_blacklist": [[0, 4249, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 4249, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 4249, 0.03890363]], "rps_doc_frac_chars_top_3gram": [[0, 4249, 0.01591512]], "rps_doc_frac_chars_top_4gram": [[0, 4249, 0.00943118]], "rps_doc_frac_all_caps_words": [[0, 4249, 0.00331126]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4249, 0.0]], "rps_doc_frac_no_alph_words": [[0, 4249, 0.20640177]], "rps_doc_frac_unique_words": [[0, 4249, 0.46153846]], "rps_doc_mean_word_length": [[0, 4249, 4.57894737]], "rps_doc_symbol_to_word_ratio": [[0, 4249, 0.0]], "rps_doc_unigram_entropy": [[0, 4249, 5.26547537]], "rps_doc_word_count": [[0, 4249, 741.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 60, 0.0], [60, 109, 0.0], [109, 153, 1.0], [153, 310, 0.0], [310, 521, 1.0], [521, 887, 1.0], [887, 1433, 1.0], [1433, 1832, 1.0], [1832, 2021, 1.0], [2021, 2539, 1.0], [2539, 2911, 1.0], [2911, 3306, 1.0], [3306, 3793, 1.0], [3793, 3990, 1.0], [3990, 4125, 1.0], [4125, 4145, 0.0], [4145, 4164, 0.0], [4164, 4175, 0.0], [4175, 4190, 0.0], [4190, 4249, 0.0]], "rps_lines_javascript_counts": [[0, 60, 0.0], [60, 109, 0.0], [109, 153, 0.0], [153, 310, 0.0], [310, 521, 0.0], [521, 887, 0.0], [887, 1433, 0.0], [1433, 1832, 0.0], [1832, 2021, 0.0], [2021, 2539, 0.0], [2539, 2911, 0.0], [2911, 3306, 0.0], [3306, 3793, 0.0], [3793, 3990, 0.0], [3990, 4125, 0.0], [4125, 4145, 0.0], [4145, 4164, 0.0], [4164, 4175, 0.0], [4175, 4190, 0.0], [4190, 4249, 0.0]], "rps_lines_num_words": [[0, 60, 11.0], [60, 109, 6.0], [109, 153, 9.0], [153, 310, 24.0], [310, 521, 40.0], [521, 887, 65.0], [887, 1433, 92.0], [1433, 1832, 67.0], [1832, 2021, 33.0], [2021, 2539, 92.0], [2539, 2911, 68.0], [2911, 3306, 72.0], [3306, 3793, 84.0], [3793, 3990, 37.0], [3990, 4125, 22.0], [4125, 4145, 1.0], [4145, 4164, 2.0], [4164, 4175, 2.0], [4175, 4190, 3.0], [4190, 4249, 11.0]], "rps_lines_numerical_chars_fraction": [[0, 60, 0.01694915], [60, 109, 0.0], [109, 153, 0.37837838], [153, 310, 0.01960784], [310, 521, 0.01449275], [521, 887, 0.02209945], [887, 1433, 0.07240705], [1433, 1832, 0.04134367], [1832, 2021, 0.0], [2021, 2539, 0.028], [2539, 2911, 0.00547945], [2911, 3306, 0.00515464], [3306, 3793, 0.01680672], [3793, 3990, 0.0], [3990, 4125, 0.02307692], [4125, 4145, 0.0], [4145, 4164, 0.0], [4164, 4175, 0.0], [4175, 4190, 0.0], [4190, 4249, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 60, 0.0], [60, 109, 0.0], [109, 153, 0.0], [153, 310, 0.0], [310, 521, 0.0], [521, 887, 0.0], [887, 1433, 0.0], [1433, 1832, 0.0], [1832, 2021, 0.0], [2021, 2539, 0.0], [2539, 2911, 0.0], [2911, 3306, 0.0], [3306, 3793, 0.0], [3793, 3990, 0.0], [3990, 4125, 0.0], [4125, 4145, 0.0], [4145, 4164, 0.0], [4164, 4175, 0.0], [4175, 4190, 0.0], [4190, 4249, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 60, 0.05], [60, 109, 0.16326531], [109, 153, 0.06818182], [153, 310, 0.06369427], [310, 521, 0.04265403], [521, 887, 0.03825137], [887, 1433, 0.02930403], [1433, 1832, 0.02005013], [1832, 2021, 0.04761905], [2021, 2539, 0.03861004], [2539, 2911, 0.02150538], [2911, 3306, 0.02278481], [3306, 3793, 0.0349076], [3793, 3990, 0.02538071], [3990, 4125, 0.02962963], [4125, 4145, 0.0], [4145, 4164, 0.05263158], [4164, 4175, 0.18181818], [4175, 4190, 0.13333333], [4190, 4249, 0.11864407]], "rps_doc_ml_palm_score": [[0, 4249, 0.24979597]], "rps_doc_ml_wikipedia_score": [[0, 4249, null]], "rps_doc_ml_wikiref_score": [[0, 4249, 0.95477968]], "rps_doc_books_importance": [[0, 4249, -247.84988165]], "rps_doc_openwebtext_importance": [[0, 4249, 20.01922867]], "rps_doc_wikipedia_importance": [[0, 4249, 11.18881964]], "rps_doc_num_sentences": [[0, 4249, 44.0]]} |
Map Atlas of Battista Agnese. Atlas de Battista Agnese
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Atlas of Battista Agnese.
Atlas de Battista Agnese
Battista Agnese (circa 1500--1564) was an Italian cartographer, born in Genoa, who worked in Venice between 1536 and 1564 and became one of the most important figures in Renaissance cartography. He created approximately 100 manuscript atlases, of which more than 70 are extant, either with his signature or attributed to his school. His atlases, which are considered works of art for their high quality and beauty, are mostly portolan, or nautical, atlases printed on vellum for high-ranking officials or wealthy merchants. This 1544 atlas contains 15 full-page illuminated plates, with detailed maps and geographic figures, in bright colors, decorated with cherubs on clouds. Some of the maps are decorated with traces of gold. The oval mappa mundi has cherubs, or wind heads, in blue and gold clouds, which represent the classical 12 wind points out of which evolved the modern compass points. The most detailed maps show complete coasts, ports, and rivers and were the navigation aids of the day, but they do not generally represent inland features other than towns and cities. The atlas includes an armillary sphere and a finely drawn zodiac chart.
Agnese, Battista, 1514-1564 Cartographer.
[place of publication not identified] : [publisher not identified], 1544.
- Geography, Medieval
- Illuminations
- Mappae mundi
- World maps
- Original resource extent: 16 sheets, parchment: 20 x 14 centimeters.
- Original resource at: National Library of Spain.
- Content in Latin.
National Library of Spain (47)
Agnese, Battista
Geography, Medieval
Mappae Mundi
Agnese, Battista, Cartographer. Atlas of Battista Agnese . [Place of Publication Not Identified: Publisher Not Identified, 1544] Map. https://www.loc.gov/item/2021668456/.
Agnese, B. (1544) Atlas of Battista Agnese . [Place of Publication Not Identified: Publisher Not Identified] [Map] Retrieved from the Library of Congress, https://www.loc.gov/item/2021668456/.
Agnese, Battista, Cartographer. Atlas of Battista Agnese . [Place of Publication Not Identified: Publisher Not Identified, 1544] Map. Retrieved from the Library of Congress, <www.loc.gov/item/2021668456/>.
Nautical Atlas of Battista Agnese. Battista Agnese (1514-64) was a masterful geographer and mapmaker. Born in Genoa, he worked in Venice from 1536 to 1564 and became one of the most important figures in Renaissance cartography. Researchers...
Contributor: Agnese, Battista
Mappamundi. Little is known about the 15th-century Venetian geographer and cosmographer Giovanni Leardo, beyond the fact that three of his world maps have survived from late-medieval times, signed by their creator. This is...
Contributor: Leardo, Giovanni, Flourished 1440
Atlas of Joan Martines.
Atlas de Joan Martines This manuscript atlas by Joan Martines, cosmographer to King Philip II of Spain, dated 1587, represents the combination of two cartographic schools that existed at the time of its creation. The older...
Contributor: Martines, Joan
Nautical Atlas of the World, Circular World Map of the Portuguese Hemisphere and Title Page. The map presented here is from the Miller Atlas in the collections of the National Library of France. Produced for King Manuel I of Portugal in 1519 by cartographers Pedro Reinel, his...
Contributor: Homem, Lopo, Flourished - Manuel I, King of Portugal - Reinel, Jorge, Active 16th Century - Reinel, Pedro, Born Approximately 1464 - Holanda, António De
Portolan Atlas of Battista Agnese.
Portolano This portolan atlas is attributed to Battista Agnese (1514-64), one of the most important Italian Renaissance cartographers. Of Genoese origin, Agnese was active in Venice from 1536 until his death. He is...
Contributor: Agnese, Battista - Victor Emmanuel II, King of Italy - Sforza DI Santa Fiora, Guido Ascanio
The Excursion of the One Who Yearns to Penetrate the Horizons, by al-Idrisi. Muhammad ibn Muhammad al-Idrisi (circa 1100--1166) was an Arab geographer and adviser to Norman king Roger II of Sicily. He was born into a family of Andalusian and Maghreb princes and sharif...
Contributor: Roger II, King of Sicily - Idrīsī
Etymology.
Etymologiae Etymologiae (Etymology) is the best known work by Saint Isidore of Seville (circa 560--636), a scholar and theologian considered the last of the great Latin Church Fathers. It takes its name from...
Contributor: Isidore, of Seville, Saint, Died 636
Compendium of Cosmography.
Suma de cosmographia Pedro de Medina (1493--1567) was a cartographer, author, and a founder of marine science. He lived in Seville, the center of the Spanish ocean-going commerce and the starting point for ships headed...
Contributor: Zutman, Lambert - Medina, Pedro De
Seven-Part Code.
Siete partidas This illuminated manuscript of the Siete partidas (Seven-part code), on parchment in Gothic script, dates from the 13th--15th centuries. The codex is important for several reasons. It was written in one scriptorium...
Contributor: Alfonso X, King of Castile and Leon
The Meadows of Gold and Mines of Gems. Abu al-Hasan Ali ibn al-Husayn ibn Ali al-Mas'udi (circa 896--956 AD, 283--345 AH) was an Arab historian and geographer, known as the "Herodotus of the Arabs." He was one of the first...
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MITSUBISHI FORKLIFT TRUCKS INTRODUCES ELECTRIC WALKIE END RIDER TRUCKS FOR LATIN AMERICA
HOUSTON (September 3, 2014) – Mitsubishi Forklift Trucks, manufacturer of reliable and affordable forklift trucks for hardworking applications, today introduced the new series of 10,000 – 15,000 kg. capacity diesel pneumatic tire forklift trucks for Mexico, the Caribbean, and Central and South America. The FD100NM – FD150NM series features a powerful 6D16 7.5L engine that delivers exceptional performance and a newly-designed operator compartment, allowing operators to work comfortably and efficiently.
“This series of large pneumatic tire forklifts are designed to handle heavy-duty applications such as lumber, steel, pipe, concrete and fabricated metals” said Lucas Dumdie, product line manager at Mitsubishi Forklift Trucks. “The addition of the FD100NM – FD150NM series to the Mitsubishi forklift truck product line-up allows us to be more flexible with customers looking for large-capacity forklifts that help reduce operator fatigue and increase productivity.”
The FD100NM – FD150NM series provides customers with several features and benefits, including:
• Productivity-Enhancing Engine. This series is equipped with a 6D16 7.5L turbo, in-line six-cylinder diesel engine with a turbocharger. The powerful engine increases operator productivity by consistently delivering a high performance – even when the forklift truck is operating in outdoor applications where there are extreme weather conditions and rough and uneven surfaces.
• High-Performance Transmission. These FD100NM-FD150NM models often operate on rugged terrain, making the powerful transmission a key component for better performance and increased efficiency. The forklift’s drivetrain is equipped with an automatic transmission that converts the power of the engine into torque, resulting in controlled, rapid response and amplified acceleration.
• Excellent Operator Comfort. Operators can comfortably handle and maneuver heavy loads, up to 15,000 kg., while easily maintaining control of the forklift. A full-suspension seat, built for operators of various sizes, and a three-section hydraulic control valve with seat side levers help reduce stress and fatigue during long shifts. Additionally, rubber mounted components, helical transmission gears, closed wheel wells and a fully-insulated engine hood help reduce the loud noise and vibration commonly associated with operating large forklift trucks.
• Reduced Downtime. These forklifts require less downtime and reduced preventative maintenance as a result of the easy-to-access engine and 500-hour service intervals. The Mitsubishi forklift truck dealer network is manned with trained and qualified technicians, who are capable of thoroughly servicing the forklift truck.
For more information on the new FD100NM – FD150NM series of forklift trucks or other Mitsubishi forklift trucks, visit www.logisnextamericas.com/en/mit.
About Mitsubishi Forklift Trucks
Mitsubishi Forklift Trucks Deliver Exceptional Value
Mitsubishi Forklift Trucks provides customers with quality and reliable forklifts that deliver exceptional value – making them ideal for today’s fast-moving material handling applications. Ranging in capacity from 2,200 to 15,500 pounds, Mitsubishi forklift trucks are manufactured and distributed by Mitsubishi Caterpillar Forklift America Inc., a leading manufacturer of forklifts in North, Central and South America and the Caribbean. Parts are supplied from five distribution centers located in California, Indiana, Michigan, Pennsylvania and Texas, for reliable customer support. For more information on Mitsubishi Forklift Trucks, please visit Mitsubishi Forklift Trucks, Mitsubishi Forklift Trucks on Facebook, Mitsubishi Forklift Trucks on Twitter, Mitsubishi Forklift Trucks on YouTube and Mitsubishi Forklift Trucks on LinkedIn. | 2023-14/0000/en_head.json.gz/1379 | {"url": "https://www.logisnextamericas.com/en/logisnext/news/articles/mit/2014/MFT-PWR30-EndRider", "partition": "head_middle", "language": "en", "source_domain": "www.logisnextamericas.com", "date_download": "2023-03-20T09:20:35Z", "digest": "sha1:FXKTECFYSP2EOYOKC44V3EAMWAHI353D"} | {"ccnet_length": [[0, 3871, 3871.0]], "ccnet_original_length": [[0, 3871, 6537.0]], "ccnet_nlines": [[0, 3871, 12.0]], "ccnet_original_nlines": [[0, 3871, 127.0]], "ccnet_language_score": [[0, 3871, 0.89]], "ccnet_perplexity": [[0, 3871, 321.3]], "ccnet_bucket": [[0, 3871, 0.0]], "rps_doc_curly_bracket": [[0, 3871, 0.0]], "rps_doc_ldnoobw_words": [[0, 3871, 0.0]], "rps_doc_lorem_ipsum": [[0, 3871, 0.0]], "rps_doc_stop_word_fraction": [[0, 3871, 0.25]], "rps_doc_ut1_blacklist": [[0, 3871, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3871, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3871, 0.05166052]], "rps_doc_frac_chars_dupe_6grams": [[0, 3871, 0.0295203]], "rps_doc_frac_chars_dupe_7grams": [[0, 3871, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 3871, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3871, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3871, 0.07749077]], "rps_doc_frac_chars_top_3gram": [[0, 3871, 0.10332103]], "rps_doc_frac_chars_top_4gram": [[0, 3871, 0.02583026]], "rps_doc_frac_all_caps_words": [[0, 3871, 0.04294479]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3871, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3871, 0.18404908]], "rps_doc_frac_unique_words": [[0, 3871, 0.50566038]], "rps_doc_mean_word_length": [[0, 3871, 6.13584906]], "rps_doc_symbol_to_word_ratio": [[0, 3871, 0.0]], "rps_doc_unigram_entropy": [[0, 3871, 5.0603901]], "rps_doc_word_count": [[0, 3871, 530.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 89, 0.0], [89, 596, 1.0], [596, 1061, 1.0], [1061, 1156, 0.0], [1156, 1533, 1.0], [1533, 1914, 1.0], [1914, 2471, 1.0], [2471, 2794, 1.0], [2794, 2947, 1.0], [2947, 2980, 0.0], [2980, 3033, 0.0], [3033, 3871, 1.0]], "rps_lines_javascript_counts": [[0, 89, 0.0], [89, 596, 0.0], [596, 1061, 0.0], [1061, 1156, 0.0], [1156, 1533, 0.0], [1533, 1914, 0.0], [1914, 2471, 0.0], [2471, 2794, 0.0], [2794, 2947, 0.0], [2947, 2980, 0.0], [2980, 3033, 0.0], [3033, 3871, 0.0]], "rps_lines_num_words": [[0, 89, 12.0], [89, 596, 70.0], [596, 1061, 67.0], [1061, 1156, 13.0], [1156, 1533, 53.0], [1533, 1914, 50.0], [1914, 2471, 79.0], [2471, 2794, 45.0], [2794, 2947, 20.0], [2947, 2980, 4.0], [2980, 3033, 6.0], [3033, 3871, 111.0]], "rps_lines_numerical_chars_fraction": [[0, 89, 0.0], [89, 596, 0.05295316], [596, 1061, 0.01318681], [1061, 1156, 0.06521739], [1156, 1533, 0.01358696], [1533, 1914, 0.01612903], [1914, 2471, 0.00925926], [2471, 2794, 0.00952381], [2794, 2947, 0.04109589], [2947, 2980, 0.0], [2980, 3033, 0.0], [3033, 3871, 0.01098901]], "rps_lines_start_with_bulletpoint": [[0, 89, 0.0], [89, 596, 0.0], [596, 1061, 0.0], [1061, 1156, 0.0], [1156, 1533, 1.0], [1533, 1914, 1.0], [1914, 2471, 1.0], [2471, 2794, 1.0], [2794, 2947, 0.0], [2947, 2980, 0.0], [2980, 3033, 0.0], [3033, 3871, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 89, 0.86516854], [89, 596, 0.05325444], [596, 1061, 0.0344086], [1061, 1156, 0.09473684], [1156, 1533, 0.01856764], [1533, 1914, 0.03412073], [1914, 2471, 0.01077199], [2471, 2794, 0.01547988], [2794, 2947, 0.06535948], [2947, 2980, 0.12121212], [2980, 3033, 0.11320755], [3033, 3871, 0.0548926]], "rps_doc_ml_palm_score": [[0, 3871, 0.17567384]], "rps_doc_ml_wikipedia_score": [[0, 3871, null]], "rps_doc_ml_wikiref_score": [[0, 3871, 0.15301913]], "rps_doc_books_importance": [[0, 3871, -240.09033029]], "rps_doc_openwebtext_importance": [[0, 3871, -31.52111552]], "rps_doc_wikipedia_importance": [[0, 3871, -34.37539115]], "rps_doc_num_sentences": [[0, 3871, 29.0]]} |
unfiltered water
How Unfiltered Water Can Make You Sick
Leave a Comment / Health / By Gael
Clean and safe drinking water is a necessity for every human being. There are many ways to make water safe to drink like water softener and water filtration systems. And it needs to be done if you want to prevent the diseases which occur from consuming unsafe and unfiltered water. Here are some of the …
How Unfiltered Water Can Make You Sick Read More » | 2023-14/0000/en_head.json.gz/1380 | {"url": "https://www.lolozi.com/tag/unfiltered-water/", "partition": "head_middle", "language": "en", "source_domain": "www.lolozi.com", "date_download": "2023-03-20T10:21:09Z", "digest": "sha1:JCVC3B3NBUBJOJS2BRATWMR2CITXLKR6"} | {"ccnet_length": [[0, 446, 446.0]], "ccnet_original_length": [[0, 446, 1299.0]], "ccnet_nlines": [[0, 446, 5.0]], "ccnet_original_nlines": [[0, 446, 74.0]], "ccnet_language_score": [[0, 446, 0.95]], "ccnet_perplexity": [[0, 446, 339.5]], "ccnet_bucket": [[0, 446, 0.0]], "rps_doc_curly_bracket": [[0, 446, 0.0]], "rps_doc_ldnoobw_words": [[0, 446, 0.0]], "rps_doc_lorem_ipsum": [[0, 446, 0.0]], "rps_doc_stop_word_fraction": [[0, 446, 0.34883721]], "rps_doc_ut1_blacklist": [[0, 446, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 446, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 446, 0.17827298]], "rps_doc_frac_chars_dupe_6grams": [[0, 446, 0.17827298]], "rps_doc_frac_chars_dupe_7grams": [[0, 446, 0.17827298]], "rps_doc_frac_chars_dupe_8grams": [[0, 446, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 446, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 446, 0.16713092]], "rps_doc_frac_chars_top_3gram": [[0, 446, 0.10027855]], "rps_doc_frac_chars_top_4gram": [[0, 446, 0.11699164]], "rps_doc_frac_all_caps_words": [[0, 446, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 446, 0.2]], "rps_doc_frac_no_alph_words": [[0, 446, 0.08139535]], "rps_doc_frac_unique_words": [[0, 446, 0.66666667]], "rps_doc_mean_word_length": [[0, 446, 4.43209877]], "rps_doc_symbol_to_word_ratio": [[0, 446, 0.01162791]], "rps_doc_unigram_entropy": [[0, 446, 3.78251337]], "rps_doc_word_count": [[0, 446, 81.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 17, 0.0], [17, 56, 0.0], [56, 91, 0.0], [91, 396, 0.0], [396, 446, 0.0]], "rps_lines_javascript_counts": [[0, 17, 0.0], [17, 56, 0.0], [56, 91, 0.0], [91, 396, 0.0], [396, 446, 0.0]], "rps_lines_num_words": [[0, 17, 2.0], [17, 56, 7.0], [56, 91, 6.0], [91, 396, 56.0], [396, 446, 10.0]], "rps_lines_numerical_chars_fraction": [[0, 17, 0.0], [17, 56, 0.0], [56, 91, 0.0], [91, 396, 0.0], [396, 446, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 17, 0.0], [17, 56, 0.0], [56, 91, 0.0], [91, 396, 0.0], [396, 446, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 17, 0.0], [17, 56, 0.17948718], [56, 91, 0.14285714], [91, 396, 0.01311475], [396, 446, 0.18]], "rps_doc_ml_palm_score": [[0, 446, -1.001e-05]], "rps_doc_ml_wikipedia_score": [[0, 446, null]], "rps_doc_ml_wikiref_score": [[0, 446, -6.44e-06]], "rps_doc_books_importance": [[0, 446, -26.24208314]], "rps_doc_openwebtext_importance": [[0, 446, -13.12649712]], "rps_doc_wikipedia_importance": [[0, 446, -37.65236766]], "rps_doc_num_sentences": [[0, 446, 4.0]]} |
Entry Series
Tower Series
Pre Amplifiers, Sources
Active Amplifier Modules
MUTEC Master Clocks
Mike Wells Mastering
Las Vegas, NV – January 2013 – Mastering engineer Mike Wells has installed a new pair of ATC SCM150ASL PRO three-way active reference monitor speakers – purchased from Brad Lunde, president of U.S. distributor TransAudio Group in Las Vegas – at his studio in North Hollywood, CA. Wells almost immediately discovered how accurately mixes mastered at his new facility translated outside his studio while working with Vance Powell on an album that he engineered and mixed for up-and-coming indie rock band The Young Things.
From winning a shoot-out against other prospective mastering houses to completing the album master took only days, Wells reports. “The whole thing happened in four days, and I really think a lot of that had to do with the seamlessness of translation coming from the mix to the master. Vance’s perspective and the producer’s perspective on the mixes all felt very similar to what I was hearing. When I sent them tracks back they said, ‘Yes, this is what we want!’ I’m doing better work with the ATCs – I’m making better, faster decisions, I’m making less revisions and clients are happier.”
Wells recently moved into a room in the famed former Kingsound Studios complex in North Hollywood, now owned by production music company Megatrax, after relocating from San Francisco to the Los Angeles area over a year ago. The new ATC SCM150 monitors replaced a pair of Dunlavy SC-V passive monitors, which Wells had been using for the past eight years, but which were not suited to his new facility. “You need a lot of space and a long throw to be able to run the Dunlavys,” he explains.
“I didn’t want to lose the performance and the fidelity that I was getting, but I clearly needed a smaller format speaker,” he continues. During his research, Wells found a review in Stereophile magazine comparing the ATC SCM150 speakers with the Dunlavys, which are no longer manufactured. “The reviewer wrote that it’s so hard to find a speaker that can perform like the Dunlavy, because of its legend and its reputation. The ATC 150 was the only speaker he’d heard in a long time that not only came close but also that he felt would be a wonderful next-generation speaker. So I got in touch with Brad at TransAudio.”
Changing over to the SCM150s offered a number of advantages, according to Wells. “I’ve reduced the crossover count and I’ve got a smaller footprint. There are so many crossovers in the Dunlavy system that I always felt I had to double-check crossover count. But most people don’t listen on large array systems, so I wanted to get onto a system that was at most a three-way. Plus, because most systems today are active, I wanted to represent what’s happening in the marketplace better. So the ATCs met all of my criteria – and the price point was great,” says Wells.
He also notes, “I didn’t even have to play with the positioning. We put them down, turned them on, and…that’s what I was looking for! We fine-tuned them from there.”
He concludes, “I feel like I’ve been doing better work since I got the ATCs. It’s the sum of all the parts: this rig is the best that it’s ever been and I’m in this awesome, acoustically correct room. My revision list from every client has been greatly reduced, which I attribute to the ATCs and this room. It’s everything that you want to hear from a results standpoint.” | 2023-14/0000/en_head.json.gz/1381 | {"url": "https://www.lonemountainaudio.com/2013/06/mike-wells-mastering/", "partition": "head_middle", "language": "en", "source_domain": "www.lonemountainaudio.com", "date_download": "2023-03-20T08:56:37Z", "digest": "sha1:N32ZJ6624IN5NX2H53WXHDZDCRORVGKP"} | {"ccnet_length": [[0, 3441, 3441.0]], "ccnet_original_length": [[0, 3441, 4032.0]], "ccnet_nlines": [[0, 3441, 13.0]], "ccnet_original_nlines": [[0, 3441, 52.0]], "ccnet_language_score": [[0, 3441, 0.98]], "ccnet_perplexity": [[0, 3441, 266.4]], "ccnet_bucket": [[0, 3441, 0.0]], "rps_doc_curly_bracket": [[0, 3441, 0.0]], "rps_doc_ldnoobw_words": [[0, 3441, 0.0]], "rps_doc_lorem_ipsum": [[0, 3441, 0.0]], "rps_doc_stop_word_fraction": [[0, 3441, 0.41815681]], "rps_doc_ut1_blacklist": [[0, 3441, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3441, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3441, 0.01009737]], "rps_doc_frac_chars_top_3gram": [[0, 3441, 0.01153985]], "rps_doc_frac_chars_top_4gram": [[0, 3441, 0.0]], "rps_doc_frac_all_caps_words": [[0, 3441, 0.0522696]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3441, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3441, 0.14718019]], "rps_doc_frac_unique_words": [[0, 3441, 0.53846154]], "rps_doc_mean_word_length": [[0, 3441, 4.63712375]], "rps_doc_symbol_to_word_ratio": [[0, 3441, 0.00137552]], "rps_doc_unigram_entropy": [[0, 3441, 5.33286585]], "rps_doc_word_count": [[0, 3441, 598.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 13, 0.0], [13, 26, 0.0], [26, 50, 0.0], [50, 75, 0.0], [75, 95, 0.0], [95, 116, 0.0], [116, 637, 1.0], [637, 1227, 1.0], [1227, 1717, 1.0], [1717, 2337, 1.0], [2337, 2903, 1.0], [2903, 3069, 1.0], [3069, 3441, 1.0]], "rps_lines_javascript_counts": [[0, 13, 0.0], [13, 26, 0.0], [26, 50, 0.0], [50, 75, 0.0], [75, 95, 0.0], [95, 116, 0.0], [116, 637, 0.0], [637, 1227, 0.0], [1227, 1717, 0.0], [1717, 2337, 0.0], [2337, 2903, 0.0], [2903, 3069, 0.0], [3069, 3441, 0.0]], "rps_lines_num_words": [[0, 13, 2.0], [13, 26, 2.0], [26, 50, 3.0], [50, 75, 3.0], [75, 95, 3.0], [95, 116, 3.0], [116, 637, 84.0], [637, 1227, 102.0], [1227, 1717, 88.0], [1717, 2337, 109.0], [2337, 2903, 100.0], [2903, 3069, 30.0], [3069, 3441, 69.0]], "rps_lines_numerical_chars_fraction": [[0, 13, 0.0], [13, 26, 0.0], [26, 50, 0.0], [50, 75, 0.0], [75, 95, 0.0], [95, 116, 0.0], [116, 637, 0.01372549], [637, 1227, 0.0], [1227, 1717, 0.00625], [1717, 2337, 0.00986842], [2337, 2903, 0.00543478], [2903, 3069, 0.0], [3069, 3441, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 13, 0.0], [13, 26, 0.0], [26, 50, 0.0], [50, 75, 0.0], [75, 95, 0.0], [95, 116, 0.0], [116, 637, 0.0], [637, 1227, 0.0], [1227, 1717, 0.0], [1717, 2337, 0.0], [2337, 2903, 0.0], [2903, 3069, 0.0], [3069, 3441, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 13, 0.15384615], [13, 26, 0.15384615], [26, 50, 0.125], [50, 75, 0.12], [75, 95, 0.35], [95, 116, 0.14285714], [116, 637, 0.07485605], [637, 1227, 0.02542373], [1227, 1717, 0.04897959], [1717, 2337, 0.03870968], [2337, 2903, 0.03533569], [2903, 3069, 0.03012048], [3069, 3441, 0.04032258]], "rps_doc_ml_palm_score": [[0, 3441, 0.78746313]], "rps_doc_ml_wikipedia_score": [[0, 3441, null]], "rps_doc_ml_wikiref_score": [[0, 3441, 0.86943853]], "rps_doc_books_importance": [[0, 3441, -172.41211044]], "rps_doc_openwebtext_importance": [[0, 3441, 115.24031036]], "rps_doc_wikipedia_importance": [[0, 3441, -282.25019035]], "rps_doc_num_sentences": [[0, 3441, 30.0]]} |
The Real Reason Colin Trevorrow Left The Rise Of Skywalker
Lucasfilm / Disney
By Mike Floorwalker/Dec. 11, 2019 11:09 am EST
It turns out that big-budget, blockbuster filmmaking is a bit of an inexact science.
In a recent interview with io9, Lucasfilm President Kathleen Kennedy and Star Wars: The Rise of Skywalker producer Michelle Rejwan discussed the circumstances which led to writer/director Colin Trevorrow's exit from the project.
Trevorrow, the mastermind behind the Jurassic World franchise, had made a significant amount of headway on Rise of Skywalker before he and his writing partner Derek Connolly departed in September 2017. The filmmaker's contributions were substantial enough for him to receive a story credit on the upcoming film, but according to Kennedy, he basically started out behind the 8-ball through no real fault of his own.
This was due to two factors: the fact that Trevorrow had not been involved in either Star Wars: The Force Awakens or Star Wars: The Last Jedi, and simple time constraints. "I wouldn't say [Trevorrow's version] didn't work," Kennedy explained. "Colin was at a huge disadvantage not having been a part of Force Awakens and [a] part of those early conversations, because we had a general sense of where the story was going."
Kennedy went on to elaborate that Trevorrow's vision just wasn't meshing quite right with the story elements that the creative team already had in mind, and that while it might have gotten there eventually, time was a factor. "Like any development process, it was only in the development that we're looking at a first draft and realizing that it was perhaps heading in a direction that many of us didn't feel was really quite where we wanted it to go," she said. "And we were on a schedule, as we often are with these movies, and had to make a tough decision as to whether or not we thought we could get there in time or not. And as I said, Colin was at a disadvantage because he hadn't been immersed in everything that we all had [been] starting out with [The Force Awakens]."
This makes perfect sense, and as Force Awakens director J.J. Abrams was involved in the process of putting together the sequel trilogy's story from the very beginning, it also makes sense that the best way to get Rise of Skywalker into theaters on time was to bring him back on to replace Trevorrow. As it so happens, Trevorrow himself has credited Abrams with finding the "key" to the whole story: the return of Emperor Palpatine, which was one of Abrams' first contributions to Rise of Skywalker's story upon being brought back into the fold.
How did Rise of Skywalker's story come together?
As it happened, though, it took a meeting of the minds between Abrams, co-writer Chris Terrio, Kennedy, and Rejwan to come up with the perfect ending to the Skywalker Saga. Rejwan related that Palpatine's big comeback in Rise of Skywalker, for example, was a plot point which all four agonized over for quite some time — the Emperor having seemingly met his decisive end at the conclusion of Star Wars: Return of the Jedi.
"I think there was a feeling of inevitability that Palpatine had been a part of all three [trilogies] and in the biggest picture of nine movies, he has been there from the very beginning," she explained. "And his presence in this movie, we will not spoil that, but... the ending of where we left him last, in Return of the Jedi, was very important to J.J. and Chris and to all of us. We discussed it at great length... I think it definitely feels as though it is in the DNA of the [Skywalker Saga]. And it felt appropriate to have [Palpatine] be in this movie."
Kennedy elaborated that the creatives weren't sure that they'd hit upon that perfect ending to the saga until shooting was already well underway. "There was a point in the shooting where there was an epiphany moment," she said. "Where all of us very clearly said, 'Yes, this feels right.' The how, getting there, the details in that? We were [working on them] right up until the end."
She went on to explain that this wouldn't have been possible without a degree of brutal honesty on the part of everyone involved — especially in regards to Terrio, who had no prior Star Wars credits on his resume, and therefore could offer an outsider's perspective.
"I think the great thing about the dialogue that happened consistently with J.J., Michelle, Chris, and myself was that because we all know each other pretty well — Chris was really the only person we didn't know super well — but there was a very free, confident, honest dialogue that could happen," Kennedy said. "Nobody was being overly polite. If you didn't think something made sense, If you couldn't follow it, if you thought, from a fan's point of view, that you're stepping outside the lines and it was a bogus kind of thinking, no one was afraid to say that because we knew how important this was to get right."
Important, indeed; it's not every day that filmmakers are tasked with crafting a satisfying conclusion to one of the most beloved film series of all time. Fortunately, we don't have long to wait before we can finally feast our eyes on the fruits of their labor: Star Wars: The Rise of Skywalker hits the big screen on December 20. | 2023-14/0000/en_head.json.gz/1382 | {"url": "https://www.looper.com/178752/the-real-reason-colin-trevorrow-left-the-rise-of-skywalker/", "partition": "head_middle", "language": "en", "source_domain": "www.looper.com", "date_download": "2023-03-20T09:23:26Z", "digest": "sha1:UUCBGWFP2RQ3FM4MP5MGMNFQZUR6ZVNX"} | {"ccnet_length": [[0, 5234, 5234.0]], "ccnet_original_length": [[0, 5234, 5702.0]], "ccnet_nlines": [[0, 5234, 16.0]], "ccnet_original_nlines": [[0, 5234, 35.0]], "ccnet_language_score": [[0, 5234, 0.99]], "ccnet_perplexity": [[0, 5234, 220.1]], "ccnet_bucket": [[0, 5234, 0.0]], "rps_doc_curly_bracket": [[0, 5234, 0.0]], "rps_doc_ldnoobw_words": [[0, 5234, 0.0]], "rps_doc_lorem_ipsum": [[0, 5234, 0.0]], "rps_doc_stop_word_fraction": [[0, 5234, 0.48694869]], "rps_doc_ut1_blacklist": [[0, 5234, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 5234, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 5234, 0.01256342]], "rps_doc_frac_chars_dupe_6grams": [[0, 5234, 0.01256342]], "rps_doc_frac_chars_dupe_7grams": [[0, 5234, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 5234, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 5234, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 5234, 0.011597]], "rps_doc_frac_chars_top_3gram": [[0, 5234, 0.02174438]], "rps_doc_frac_chars_top_4gram": [[0, 5234, 0.01304663]], "rps_doc_frac_all_caps_words": [[0, 5234, 0.01170117]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 5234, 0.0]], "rps_doc_frac_no_alph_words": [[0, 5234, 0.15571557]], "rps_doc_frac_unique_words": [[0, 5234, 0.41420765]], "rps_doc_mean_word_length": [[0, 5234, 4.52349727]], "rps_doc_symbol_to_word_ratio": [[0, 5234, 0.00180018]], "rps_doc_unigram_entropy": [[0, 5234, 5.28990184]], "rps_doc_word_count": [[0, 5234, 915.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 59, 0.0], [59, 78, 0.0], [78, 125, 0.0], [125, 210, 1.0], [210, 439, 1.0], [439, 854, 1.0], [854, 1276, 0.0], [1276, 2054, 0.0], [2054, 2599, 1.0], [2599, 2648, 1.0], [2648, 3071, 1.0], [3071, 3633, 0.0], [3633, 4018, 0.0], [4018, 4285, 1.0], [4285, 4904, 0.0], [4904, 5234, 1.0]], "rps_lines_javascript_counts": [[0, 59, 0.0], [59, 78, 0.0], [78, 125, 0.0], [125, 210, 0.0], [210, 439, 0.0], [439, 854, 0.0], [854, 1276, 0.0], [1276, 2054, 0.0], [2054, 2599, 0.0], [2599, 2648, 0.0], [2648, 3071, 0.0], [3071, 3633, 0.0], [3633, 4018, 0.0], [4018, 4285, 0.0], [4285, 4904, 0.0], [4904, 5234, 0.0]], "rps_lines_num_words": [[0, 59, 10.0], [59, 78, 2.0], [78, 125, 8.0], [125, 210, 14.0], [210, 439, 33.0], [439, 854, 66.0], [854, 1276, 73.0], [1276, 2054, 144.0], [2054, 2599, 94.0], [2599, 2648, 8.0], [2648, 3071, 74.0], [3071, 3633, 106.0], [3633, 4018, 67.0], [4018, 4285, 46.0], [4285, 4904, 111.0], [4904, 5234, 59.0]], "rps_lines_numerical_chars_fraction": [[0, 59, 0.0], [59, 78, 0.0], [78, 125, 0.23809524], [125, 210, 0.0], [210, 439, 0.0044843], [439, 854, 0.01231527], [854, 1276, 0.0], [1276, 2054, 0.0], [2054, 2599, 0.0], [2599, 2648, 0.0], [2648, 3071, 0.0], [3071, 3633, 0.0], [3633, 4018, 0.0], [4018, 4285, 0.0], [4285, 4904, 0.0], [4904, 5234, 0.00623053]], "rps_lines_start_with_bulletpoint": [[0, 59, 0.0], [59, 78, 0.0], [78, 125, 0.0], [125, 210, 0.0], [210, 439, 0.0], [439, 854, 0.0], [854, 1276, 0.0], [1276, 2054, 0.0], [2054, 2599, 0.0], [2599, 2648, 0.0], [2648, 3071, 0.0], [3071, 3633, 0.0], [3633, 4018, 0.0], [4018, 4285, 0.0], [4285, 4904, 0.0], [4904, 5234, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 59, 0.16949153], [59, 78, 0.10526316], [78, 125, 0.14893617], [125, 210, 0.01176471], [210, 439, 0.06113537], [439, 854, 0.02409639], [854, 1276, 0.04265403], [1276, 2054, 0.01285347], [2054, 2599, 0.03119266], [2599, 2648, 0.06122449], [2648, 3071, 0.04018913], [3071, 3633, 0.03024911], [3633, 4018, 0.01558442], [4018, 4285, 0.01498127], [4285, 4904, 0.01615509], [4904, 5234, 0.02424242]], "rps_doc_ml_palm_score": [[0, 5234, 0.84196365]], "rps_doc_ml_wikipedia_score": [[0, 5234, null]], "rps_doc_ml_wikiref_score": [[0, 5234, 0.8949883]], "rps_doc_books_importance": [[0, 5234, 147.91007121]], "rps_doc_openwebtext_importance": [[0, 5234, 157.02521493]], "rps_doc_wikipedia_importance": [[0, 5234, -174.217171]], "rps_doc_num_sentences": [[0, 5234, 40.0]]} |
$900B COVID relief bill passed by Congress, sent to Trump
WASHINGTON (AP) — Congress passed a $900 billion pandemic relief package Monday night that would finally deliver long-sought cash to businesses and individuals and resources to vaccinate a nation confronting a frightening surge in COVID-19 cases and deaths.
Lawmakers tacked on a $1.4 trillion catchall spending bill and thousands of pages of other end-of-session business in a massive bundle of bipartisan legislation as Capitol Hill prepared to close the books on the year. The bill goes to President Donald Trump for his signature, which is expected in the coming days.
The relief package, unveiled Monday afternoon, sped through the House and Senate in a matter of hours. The Senate cleared the massive package by a 92-6 vote after the House approved the COVID-19 package by another lopsided vote, 359-53. The tallies were a bipartisan coda to months of partisanship and politicking as lawmakers wrangled over the relief question, a logjam that broke after President-elect Joe Biden urged his party to accept a compromise with top Republicans that is smaller than many Democrats would have liked.
The bill combines coronavirus-fighting funds with financial relief for individuals and businesses. It would establish a temporary $300 per week supplemental jobless benefit and a $600 direct stimulus payment to most Americans, along with a new round of subsidies for hard-hit businesses, restaurants, and theaters and money for schools, health care providers and renters facing eviction.
The 5,593-page legislation — by far the longest bill ever — came together Sunday after months of battling, posturing and postelection negotiating that reined in a number of Democratic demands as the end of the congressional session approached. Biden was eager for a deal to deliver long-awaited help to suffering people and a boost to the economy, even though it was less than half the size that Democrats wanted in the fall.
“This deal is not everything I want — not by a long shot,” said Rules Committee Chairman Jim McGovern, D-Mass., a longstanding voice in the party’s old-school liberal wing. “The choice before us is simple. It’s about whether we help families or not. It’s about whether we help small businesses and restaurants or not. It’s about whether we boost (food stamp) benefits and strengthen anti-hunger programs or not. And whether we help those dealing with a job loss or not. To me, this is not a tough call.”
The Senate, meanwhile, was also on track to pass a one-week stopgap spending bill to avert a partial government shutdown at midnight and give Trump time to sign the sweeping legislation.
Treasury Secretary Steven Mnuchin, a key negotiator, said on CNBC Monday morning that the direct payments would begin arriving in bank accounts next week.
Democrats promised more aid to come once Biden takes office, but Republicans were signaling a wait-and-see approach.
The measure would fund the government through September, wrapping a year’s worth of action on annual spending bills into a single package that never saw Senate committee or floor debate.
The legislation followed a tortured path. Democrats played hardball up until Election Day, amid accusations that they wanted to deny Trump a victory that might help him prevail. Democrats denied that, but their demands indeed became more realistic after Trump’s loss and as Biden made it clear that half a loaf was better than none.
The final bill bore ample resemblance to a $1 trillion package put together by Senate Republican leaders in July, a proposal that at the time was scoffed at by House Speaker Nancy Pelosi, D-Calif., as way too little.
Majority Leader Mitch McConnell, R-Ky., took a victory lap after blocking far more ambitious legislation from reaching the Senate floor. He said the pragmatic approach of Biden was key.
“The president-elect suggesting that we needed to do something now was helpful in moving both Pelosi and Schumer into a better place,” McConnell told The Associated Press. “My view about what comes next is let’s take a look at it. Happy to evaluate that based upon the needs that we confront in February and March.”
Vice President-elect Kamala Harris, D-Calif., came to the Senate to cast her vote for the bill. “The American people need relief and I want to be able to do what I can to help them,” she said.
On direct payments, the bill provides $600 to individuals making up to $75,000 per year and $1,200 to couples making up to $150,000, with payments phased out for higher incomes. An additional $600 payment will be made per dependent child, similar to the last round of relief payments in the spring.
“I expect we’ll get the money out by the beginning of next week — $2,400 for a family of four,” Mnuchin said. “So much needed relief just in time for the holidays.”
The $300 per week bonus jobless benefit was half the supplemental federal unemployment benefit provided under the $1.8 billion CARES Act in March. That more generous benefit and would be limited to 11 weeks instead of 16 weeks. The direct $600 stimulus payment was also half the March payment.
The CARES Act was credited with keeping the economy from falling off a cliff during widespread lockdowns in the spring, but Republicans controlling the Senate cited debt concerns in pushing against Democratic demands.
“Anyone who thinks this bill is enough hasn’t heard the desperation in the voices of their constituents, has not looked into the eyes of the small-business owner on the brink of ruin,” said Senate Democratic leader Chuck Schumer, a lifelong New Yorker who pushed hard for money helping his city’s transit systems, renters, theaters and restaurants.
Progress came after a bipartisan group of pragmatists and moderates devised a $908 billion plan that built a middle-ground position that the top four leaders of Congress — the GOP and Democratic leaders of both the House and Senate — used as the basis for their talks. The lawmakers urged leaders on both sides to back off of hardline positions.
“At times we felt like we were in the wilderness because people on all sides of the aisle didn’t want to give, in order to give the other side a win,” said freshman Rep. Elssa Slotkin, D-Mich. “And it was gross to watch, frankly.”
Republicans were most intent on reviving the Paycheck Protection Program with $284 billion, which would cover a second round of PPP grants to especially hard-hit businesses. Democrats won set-asides for low-income and minority communities.
The sweeping bill also contains $25 billion in rental assistance, $15 billion for theaters and other live venues, $82 billion for local schools, colleges and universities, and $10 billion for child care.
The governmentwide appropriations bill was likely to provide a last $1.4 billion installment for Trump’s U.S.-Mexico border wall as a condition of winning his signature. The Pentagon would receive $696 billion. Democrats and Senate Republicans prevailed in a bid to use bookkeeping maneuvers to squeeze $12.5 billion more for domestic programs into the legislation.
The bill was an engine to carry much of Capitol Hill’s unfinished business, including an almost 400-page water resources bill that targets $10 billion for 46 Army Corps of Engineers flood control, environmental and coastal protection projects. Another addition would extend a batch of soon-to-expire tax breaks, such as one for craft brewers, wineries and distillers.
It also would carry numerous clean-energy provisions sought by Democrats with fossil fuel incentives favored by Republicans, $7 billion to increase access to broadband, $4 billion to help other nations vaccinate their people, $14 billion for cash-starved transit systems, $1 billion for Amtrak and $2 billion for airports and concessionaires. Food stamp benefits would temporarily be increased by 15%.
The Senate Historical Office said the previous record for the length of legislation was the 2,847-page tax reform bill of 1986 — about one-half the size of Monday’s behemoth. | 2023-14/0000/en_head.json.gz/1383 | {"url": "https://www.lootpress.com/900b-covid-relief-bill-passed-by-congress-sent-to-trump/", "partition": "head_middle", "language": "en", "source_domain": "www.lootpress.com", "date_download": "2023-03-20T09:56:01Z", "digest": "sha1:GB5ZEY323QDLDBBKALI4SQ23R3J7Q5MN"} | {"ccnet_length": [[0, 8024, 8024.0]], "ccnet_original_length": [[0, 8024, 18743.0]], "ccnet_nlines": [[0, 8024, 29.0]], "ccnet_original_nlines": [[0, 8024, 402.0]], "ccnet_language_score": [[0, 8024, 0.96]], "ccnet_perplexity": [[0, 8024, 296.8]], "ccnet_bucket": [[0, 8024, 0.0]], "rps_doc_curly_bracket": [[0, 8024, 0.0]], "rps_doc_ldnoobw_words": [[0, 8024, 0.0]], "rps_doc_lorem_ipsum": [[0, 8024, 0.0]], "rps_doc_stop_word_fraction": [[0, 8024, 0.36580767]], "rps_doc_ut1_blacklist": [[0, 8024, null]], 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Chief Justice Tim Armstead Takes Oath of Office for New Term
Tuesday, March 2, 2021 11:46 am
CHARLESTON, WV (LOOTPRESS) – Supreme Court Chief Justice Tim Armstead began his first full 12-year-term on the Supreme Court of Appeals of West Virginia on Tuesday by pledging to continue to work to restore public confidence in the state court system.
“I feel deeply honored and deeply privileged to be a member of this Court,” Chief Justice Armstead said. “It is important that the people of our state have respect for their Court.”
Chief Justice Tim Armstead was appointed to the Supreme Court by Governor Jim Justice in September 2018. He was elected November 6, 2018, to retain the seat until the end of the term on December 31, 2020, and was re-elected June 9, 2020, to a 12-year term that will begin on January 1, 2021.
He has served as Chief Justice since January 1, 2020, and has led the judiciary through the COVID pandemic with the same integrity, hard work and attention to detail that he brought to other jobs in this career, said speakers at the investiture ceremony in the Supreme Court Courtroom.
“Two things stand out when I think of Tim: His character and his life of principle,” said Senior Judge David A. Faber of the U.S. District Court for the Southern District of West Virginia, who delivered the oath of office.
“I look at your colleagues on the Court and I am convinced this court will be one of the finest this state has seen in its history,” Judge Faber said.
Judge Faber and Chief Justice Armstead worked at the same law firm when Judge Faber was appointed to the federal bench. Chief Justice Armstead became one of Judge Faber’s first law clerks.
“His public service has reflected his personality,” Judge Faber said. “Tim is the epitome of what I consider to be a Christian gentleman.”
Chief Justice Armstead’s daughter, Katie Armstead Ferrari, introduced her father before he took the oath of office, saying he was a man of integrity, responsibility, loyalty and leadership.
Justices Margaret Workman, Beth Walker, Evan Jenkins and John Hutchison thanked Chief Justice Armstead for his work leading the court system through the COVID pandemic this year.
“I can’t think of anybody who would have been a better Chief this year,” Justice Beth Walker said.
The past year “has been the hardest year I can recall us ever having to face,” Justice Workman said. “I have gotten to know Tim Armstead pretty well. In Tim Armstead I have seen an excellent work ethic. I have seen a person who is thoughtful, who is open and willing to listen to other people’s ideas. . . . He is a really kind, caring person.”
Before he was appointed to the Supreme Court, Chief Justice Armstead was Speaker of the West Virginia House of Delegates. He was a member of the House from 1998 to 2018. He became Minority Leader in 2006 and Speaker in 2015.
He previously worked as Executive Assistant to the Chief of Staff of Governor Cecil Underwood.
He is a graduate of the University of Charleston and West Virginia University College of Law. He lives in Elkview with his wife, Anna, and they have one daughter and two grandchildren. | 2023-14/0000/en_head.json.gz/1384 | {"url": "https://www.lootpress.com/chief-justice-tim-armstead-takes-oath-of-office-for-new-term/", "partition": "head_middle", "language": "en", "source_domain": "www.lootpress.com", "date_download": "2023-03-20T09:20:13Z", "digest": "sha1:ERLHS6J73ILUC6UDYYWLZHDBJPFLGS4Z"} | {"ccnet_length": [[0, 3124, 3124.0]], "ccnet_original_length": [[0, 3124, 13776.0]], "ccnet_nlines": [[0, 3124, 17.0]], "ccnet_original_nlines": [[0, 3124, 389.0]], "ccnet_language_score": [[0, 3124, 0.98]], "ccnet_perplexity": [[0, 3124, 163.4]], "ccnet_bucket": [[0, 3124, 0.0]], "rps_doc_curly_bracket": [[0, 3124, 0.0]], "rps_doc_ldnoobw_words": [[0, 3124, 0.0]], "rps_doc_lorem_ipsum": [[0, 3124, 0.0]], "rps_doc_stop_word_fraction": [[0, 3124, 0.37558685]], "rps_doc_ut1_blacklist": [[0, 3124, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3124, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 3124, 0.02314445]], "rps_doc_frac_chars_dupe_6grams": [[0, 3124, 0.02314445]], "rps_doc_frac_chars_dupe_7grams": [[0, 3124, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 3124, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 3124, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 3124, 0.04788508]], "rps_doc_frac_chars_top_3gram": [[0, 3124, 0.03990423]], "rps_doc_frac_chars_top_4gram": [[0, 3124, 0.02753392]], "rps_doc_frac_all_caps_words": [[0, 3124, 0.02816901]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 3124, 0.0]], "rps_doc_frac_no_alph_words": [[0, 3124, 0.16901408]], "rps_doc_frac_unique_words": [[0, 3124, 0.44751381]], "rps_doc_mean_word_length": [[0, 3124, 4.61510129]], "rps_doc_symbol_to_word_ratio": [[0, 3124, 0.0]], "rps_doc_unigram_entropy": [[0, 3124, 4.9638561]], "rps_doc_word_count": [[0, 3124, 543.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 61, 0.0], [61, 93, 0.0], [93, 345, 1.0], [345, 527, 1.0], [527, 819, 1.0], [819, 1105, 1.0], [1105, 1328, 1.0], [1328, 1479, 1.0], [1479, 1668, 1.0], [1668, 1807, 1.0], [1807, 1997, 1.0], [1997, 2176, 1.0], [2176, 2275, 1.0], [2275, 2620, 1.0], [2620, 2845, 1.0], [2845, 2940, 1.0], [2940, 3124, 1.0]], "rps_lines_javascript_counts": [[0, 61, 0.0], [61, 93, 0.0], [93, 345, 0.0], [345, 527, 0.0], [527, 819, 0.0], [819, 1105, 0.0], [1105, 1328, 0.0], [1328, 1479, 0.0], [1479, 1668, 0.0], [1668, 1807, 0.0], [1807, 1997, 0.0], [1997, 2176, 0.0], [2176, 2275, 0.0], [2275, 2620, 0.0], [2620, 2845, 0.0], [2845, 2940, 0.0], [2940, 3124, 0.0]], "rps_lines_num_words": [[0, 61, 11.0], [61, 93, 6.0], [93, 345, 41.0], [345, 527, 32.0], [527, 819, 54.0], [819, 1105, 49.0], [1105, 1328, 40.0], [1328, 1479, 30.0], [1479, 1668, 32.0], [1668, 1807, 23.0], [1807, 1997, 28.0], [1997, 2176, 27.0], [2176, 2275, 18.0], [2275, 2620, 64.0], [2620, 2845, 41.0], [2845, 2940, 15.0], [2940, 3124, 32.0]], "rps_lines_numerical_chars_fraction": [[0, 61, 0.0], [61, 93, 0.32142857], [93, 345, 0.00816327], [345, 527, 0.0], [527, 819, 0.09642857], [819, 1105, 0.01785714], [1105, 1328, 0.0], [1328, 1479, 0.0], [1479, 1668, 0.0], [1668, 1807, 0.0], [1807, 1997, 0.0], [1997, 2176, 0.0], [2176, 2275, 0.0], [2275, 2620, 0.0], [2620, 2845, 0.07272727], [2845, 2940, 0.0], [2940, 3124, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 61, 0.0], [61, 93, 0.0], [93, 345, 0.0], [345, 527, 0.0], [527, 819, 0.0], [819, 1105, 0.0], [1105, 1328, 0.0], [1328, 1479, 0.0], [1479, 1668, 0.0], [1668, 1807, 0.0], [1807, 1997, 0.0], [1997, 2176, 0.0], [2176, 2275, 0.0], [2275, 2620, 0.0], [2620, 2845, 0.0], [2845, 2940, 0.0], [2940, 3124, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 61, 0.14754098], [61, 93, 0.0625], [93, 345, 0.13095238], [345, 527, 0.03846154], [527, 819, 0.05136986], [819, 1105, 0.04195804], [1105, 1328, 0.07623318], [1328, 1479, 0.03311258], [1479, 1668, 0.06349206], [1668, 1807, 0.04316547], [1807, 1997, 0.03157895], [1997, 2176, 0.09497207], [2176, 2275, 0.05050505], [2275, 2620, 0.03768116], [2620, 2845, 0.07555556], [2845, 2940, 0.08421053], [2940, 3124, 0.05978261]], "rps_doc_ml_palm_score": [[0, 3124, 0.70406783]], "rps_doc_ml_wikipedia_score": [[0, 3124, null]], "rps_doc_ml_wikiref_score": [[0, 3124, 0.97868031]], "rps_doc_books_importance": [[0, 3124, -66.61256302]], "rps_doc_openwebtext_importance": [[0, 3124, 110.95583321]], "rps_doc_wikipedia_importance": [[0, 3124, -5.88165822]], "rps_doc_num_sentences": [[0, 3124, 29.0]]} |
Common Types of Storm Damage Seen in Palo Alto
by David | Sep 8, 2018 | Roofing
Palo Alto has a Mediterranean climate, common to the San Francisco Bay Area. Annual rainfall is quite low and measurable snowfall is very rare. Most storms happen during the winter and may be several days in length, but typically they are not severely damaging.... | 2023-14/0000/en_head.json.gz/1385 | {"url": "https://www.losgatosroofing.com/tag/storm-damage-repair/", "partition": "head_middle", "language": "en", "source_domain": "www.losgatosroofing.com", "date_download": "2023-03-20T09:01:21Z", "digest": "sha1:5K5DFMTANQVDQD7JL4FVNHEAL6J43GCS"} | {"ccnet_length": [[0, 344, 344.0]], "ccnet_original_length": [[0, 344, 1833.0]], "ccnet_nlines": [[0, 344, 3.0]], "ccnet_original_nlines": [[0, 344, 44.0]], "ccnet_language_score": [[0, 344, 0.96]], "ccnet_perplexity": [[0, 344, 217.9]], "ccnet_bucket": [[0, 344, 0.0]], "rps_doc_curly_bracket": [[0, 344, 0.0]], "rps_doc_ldnoobw_words": [[0, 344, 0.0]], "rps_doc_lorem_ipsum": [[0, 344, 0.0]], "rps_doc_stop_word_fraction": [[0, 344, 0.34328358]], "rps_doc_ut1_blacklist": [[0, 344, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 344, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 344, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 344, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 344, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 344, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 344, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 344, 0.05860806]], "rps_doc_frac_chars_top_3gram": [[0, 344, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 344, 0.0]], "rps_doc_frac_all_caps_words": [[0, 344, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 344, 0.33333333]], "rps_doc_frac_no_alph_words": [[0, 344, 0.14925373]], "rps_doc_frac_unique_words": [[0, 344, 0.88135593]], "rps_doc_mean_word_length": [[0, 344, 4.62711864]], "rps_doc_symbol_to_word_ratio": [[0, 344, 0.01492537]], "rps_doc_unigram_entropy": [[0, 344, 3.91306184]], "rps_doc_word_count": [[0, 344, 59.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 47, 0.0], [47, 80, 0.0], [80, 344, 1.0]], "rps_lines_javascript_counts": [[0, 47, 0.0], [47, 80, 0.0], [80, 344, 0.0]], "rps_lines_num_words": [[0, 47, 9.0], [47, 80, 6.0], [80, 344, 44.0]], "rps_lines_numerical_chars_fraction": [[0, 47, 0.0], [47, 80, 0.18518519], [80, 344, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 47, 0.0], [47, 80, 0.0], [80, 344, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 47, 0.14893617], [47, 80, 0.09090909], [80, 344, 0.03409091]], "rps_doc_ml_palm_score": [[0, 344, 0.06222612]], "rps_doc_ml_wikipedia_score": [[0, 344, null]], "rps_doc_ml_wikiref_score": [[0, 344, 0.00040418]], "rps_doc_books_importance": [[0, 344, -8.90893635]], "rps_doc_openwebtext_importance": [[0, 344, -3.82263117]], "rps_doc_wikipedia_importance": [[0, 344, 4.56180479]], "rps_doc_num_sentences": [[0, 344, 3.0]]} |
Ways to Add More Plant Ingredients to Your Meals
Ways to Add More Plant Ingredients to Your Meals I’ve always been interested in healthier cooking, but a few years ago, I did a deeper dive into the topic. There were a variety of reasons but overall, I wanted to know that the meals I was making at home... | 2023-14/0000/en_head.json.gz/1386 | {"url": "https://www.loveandcraftkitchen.com/tag/addmoreplants/", "partition": "head_middle", "language": "en", "source_domain": "www.loveandcraftkitchen.com", "date_download": "2023-03-20T09:01:08Z", "digest": "sha1:PXRXTHKMU62IWGMEGANHPEKTY67R5XU7"} | {"ccnet_length": [[0, 305, 305.0]], "ccnet_original_length": [[0, 305, 4141.0]], "ccnet_nlines": [[0, 305, 2.0]], "ccnet_original_nlines": [[0, 305, 88.0]], "ccnet_language_score": [[0, 305, 0.99]], "ccnet_perplexity": [[0, 305, 274.2]], "ccnet_bucket": [[0, 305, 0.0]], "rps_doc_curly_bracket": [[0, 305, 0.0]], "rps_doc_ldnoobw_words": [[0, 305, 0.0]], "rps_doc_lorem_ipsum": [[0, 305, 0.0]], "rps_doc_stop_word_fraction": [[0, 305, 0.38461538]], "rps_doc_ut1_blacklist": [[0, 305, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 305, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 305, 0.33195021]], "rps_doc_frac_chars_dupe_6grams": [[0, 305, 0.33195021]], "rps_doc_frac_chars_dupe_7grams": [[0, 305, 0.33195021]], "rps_doc_frac_chars_dupe_8grams": [[0, 305, 0.33195021]], "rps_doc_frac_chars_dupe_9grams": [[0, 305, 0.33195021]], "rps_doc_frac_chars_top_2gram": [[0, 305, 0.04979253]], "rps_doc_frac_chars_top_3gram": [[0, 305, 0.0746888]], "rps_doc_frac_chars_top_4gram": [[0, 305, 0.10788382]], "rps_doc_frac_all_caps_words": [[0, 305, 0.06153846]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 305, 0.5]], "rps_doc_frac_no_alph_words": [[0, 305, 0.09230769]], "rps_doc_frac_unique_words": [[0, 305, 0.68965517]], "rps_doc_mean_word_length": [[0, 305, 4.15517241]], "rps_doc_symbol_to_word_ratio": [[0, 305, 0.01538462]], "rps_doc_unigram_entropy": [[0, 305, 3.56001103]], "rps_doc_word_count": [[0, 305, 58.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 49, 0.0], [49, 305, 1.0]], "rps_lines_javascript_counts": [[0, 49, 0.0], [49, 305, 0.0]], "rps_lines_num_words": [[0, 49, 9.0], [49, 305, 49.0]], "rps_lines_numerical_chars_fraction": [[0, 49, 0.0], [49, 305, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 49, 0.0], [49, 305, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 49, 0.14285714], [49, 305, 0.046875]], "rps_doc_ml_palm_score": [[0, 305, -3.46e-06]], "rps_doc_ml_wikipedia_score": [[0, 305, null]], "rps_doc_ml_wikiref_score": [[0, 305, 0.00033045]], "rps_doc_books_importance": [[0, 305, -9.02397108]], "rps_doc_openwebtext_importance": [[0, 305, 1.89648688]], "rps_doc_wikipedia_importance": [[0, 305, -27.62634507]], "rps_doc_num_sentences": [[0, 305, 2.0]]} |
Everything we know about Paris Jackson’s reported attempted suicide
Photo credit: Featureflash Photo Agency / Shutterstock.com
Over the weekend, the internet was flooded with reports that Paris Jackson was hospitalized after attempting to take her own life.
The attempted suicide comes just weeks after HBO’s Leaving Neverland documentary aired, in which two men spoke of the alleged sexual abuse they suffered as children at the hands of her father, the late Michael Jackson.
“Today at about 7:28 in the morning, Hollywood units responded for a radio call of an ambulance attempt suicide. The victim was transported to a local hospital,” a source for the LAPD told E! News, possibly in relation to Paris Jackson.
Paris was seen outside her home later that day (Saturday) wearing a blue jacket that read, ‘Puppies, Wine And I’m Fine’ on the back – with the word ‘wine’ covered up with tape.
Regardless of whether there is any truth in the hospitalization reports, Paris is keen to put it behind her…
She called the reports of her attempted suicide “lies lies lies omg and more lies” on Twitter, and also posted a selfie on her Instagram story with the caption, “f–k you I’m chillen like Bob Dylan.”
She also posted about getting KFC with her boyfriend Gabriel Glenn later that day.
Despite initially wanting to keep a dignified silence, Paris has addressed the documentary several times on social media. A fan recently asked her if she would “trade the wealth for the freedom from disgusting press” to which she replied:
“I have the same moral compass as my father, but not the level of patience. I’ll fight for love n peace in the same way, but I am more aggressively driven.
“I don’t sit by idly when i see injustices happen, especially when they’re directed towards me or my family. F–k that noise.”
“There’s nothing I can say that hasn’t already been said in regards to defense,” she continued.
“My cousin Taj Jackson is doing a perfect job on his own. And I support him. But that’s not my role. I’m just tryna get everyone to chill out and go with the flow, be mellow and think about the bigger picture. That’s me.”
Her close friends have been worried about Paris since the documentary aired…
“Paris is a sensitive soul and this has affected her deeply,” a close friend reportedly said.
“She’s been very upset about all the hateful things she’s been reading about her father on social media.”
The 20-year-old model was previously hospitalized back in 2013 after attempting suicide – an attempt which has since been revealed wasn’t her first.
“It was just self-hatred. Low self-esteem, thinking that I couldn’t do anything right, not thinking I was worthy of living anymore,” she told Rolling Stone back in 2017 about her 2013 attempt, adding that she had attempted suicide “multiple times”.
We sincerely hope that Paris Jackson is surrounding herself with the right people right now, and is being taken care of during this understandably difficult time.
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“You’ve got a friend in me” – Tom Hanks gifts his typewriter to 8-year-old bullied Australian boy named Corona | 2023-14/0000/en_head.json.gz/1387 | {"url": "https://www.loveisallcolors.com/everything-we-know-about-paris-jacksons-reported-attempted-suicide/", "partition": "head_middle", "language": "en", "source_domain": "www.loveisallcolors.com", "date_download": "2023-03-20T08:51:49Z", "digest": "sha1:V5CLLEDAJHLEKTHAY67VEZHS7353OREG"} | {"ccnet_length": [[0, 3421, 3421.0]], "ccnet_original_length": [[0, 3421, 4926.0]], "ccnet_nlines": [[0, 3421, 26.0]], "ccnet_original_nlines": [[0, 3421, 96.0]], "ccnet_language_score": [[0, 3421, 0.97]], "ccnet_perplexity": [[0, 3421, 311.6]], "ccnet_bucket": [[0, 3421, 0.0]], "rps_doc_curly_bracket": [[0, 3421, 0.0]], "rps_doc_ldnoobw_words": [[0, 3421, 2.0]], "rps_doc_lorem_ipsum": [[0, 3421, 0.0]], "rps_doc_stop_word_fraction": [[0, 3421, 0.41234222]], "rps_doc_ut1_blacklist": [[0, 3421, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 3421, 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Local Media Covers the Distribution of Nearly 100 Free Chromebooks to Kids in Flint
On Friday, October 29, 2021 The Loyalty Foundation returned to Flint, Michigan for the third time to distribute Chromebooks to children in need, this time in conjunction with Tauzzari Robinson, CEO of the Boys & Girls Club of Flint. Popular Publicity reached out to local media, including Local reporters Carmen Nesbitt of Flint Beat and Dylan Goetz of M LIVE who both came down to cover the big day.
Thank you to Carmen Nesbitt from Flint Beat. Below is an excerpt from her story:
Flint, MI—When Tiffany Webb, a mother of two teenagers, arrived at The Boys and Girls Club of Greater Flint to pick up a care package, she didn’t expect to be handed a free laptop. “I was like, ‘What? Are you serious? Is this a prank?’” Webb said. She, along with 49 other families in need, come to The Boys and Girls Club of Flint each month for “Club At-Home Packages” stocked with board games, cleaning supplies, toilet paper, masks, and other items. But this month’s distribution included a special surprise: a Chromebook. “This is such a blessing because we have been struggling especially since the pandemic. And I’ve been very sick with kidney failure and not able to afford a lot of things. I used to be a nurse and I’m just really down because I can’t work. So, to receive something like this is a big help,” Webb said. The laptops were donated by The Loyalty Foundation, a New York-based nonprofit that aims to narrow the digital divide by getting technology into the hands of underserved youth. This is the second year they’ve partnered with the Boys and Girls Club of Greater Flint, a nonprofit that provides afterschool programs to 1,000 Flint-area youths. Read the full story here.
Thank you to Dylan Goetz from M LIVE. Here is an excerpt from his story:
FLINT, MI — Flint families were surprised with new Chromebooks for their children during a Friday morning distribution at the Boys and Girls Club of Greater Flint. Boys and Girls Clubs of Greater Flint received a donation from The Loyalty Foundation, a New York-based organization, of 100 Chromebooks to distribute to children that the club serves. This 100 Chromebook donation comes after a 50 Chromebook donation from the foundation last year. Loyalty Foundation Founder and Chairman David Neeman was at the Flint club this morning to watch distribution and tour the facilities. Neeman said he believes every child should have access to technology. “It’s the future and the present,” he said. “When you open technology to someone, if you think about it, they now have access to everything we know about the universe. … You can build yourself a future, a very lucrative future, and it doesn’t matter where you are.” Read the full story here. | 2023-14/0000/en_head.json.gz/1388 | {"url": "https://www.loyaltyfoundation.org/post/local-media-covers-the-distribution-of-nearly-100-free-chromebooks-to-kids-in-flint", "partition": "head_middle", "language": "en", "source_domain": "www.loyaltyfoundation.org", "date_download": "2023-03-20T10:14:06Z", "digest": "sha1:WNGCA4HKCZCZDSXJM7BXO3CC6JVZNSXH"} | {"ccnet_length": [[0, 2777, 2777.0]], "ccnet_original_length": [[0, 2777, 3572.0]], "ccnet_nlines": [[0, 2777, 6.0]], "ccnet_original_nlines": [[0, 2777, 42.0]], "ccnet_language_score": [[0, 2777, 0.95]], "ccnet_perplexity": [[0, 2777, 227.8]], "ccnet_bucket": [[0, 2777, 0.0]], "rps_doc_curly_bracket": [[0, 2777, 0.0]], "rps_doc_ldnoobw_words": [[0, 2777, 0.0]], "rps_doc_lorem_ipsum": [[0, 2777, 0.0]], "rps_doc_stop_word_fraction": [[0, 2777, 0.38986014]], "rps_doc_ut1_blacklist": [[0, 2777, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2777, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2777, 0.10290828]], "rps_doc_frac_chars_dupe_6grams": [[0, 2777, 0.08501119]], "rps_doc_frac_chars_dupe_7grams": [[0, 2777, 0.04608501]], "rps_doc_frac_chars_dupe_8grams": [[0, 2777, 0.04608501]], "rps_doc_frac_chars_dupe_9grams": [[0, 2777, 0.03131991]], "rps_doc_frac_chars_top_2gram": [[0, 2777, 0.01565996]], "rps_doc_frac_chars_top_3gram": [[0, 2777, 0.0246085]], "rps_doc_frac_chars_top_4gram": [[0, 2777, 0.02684564]], "rps_doc_frac_all_caps_words": [[0, 2777, 0.02272727]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2777, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2777, 0.16083916]], "rps_doc_frac_unique_words": [[0, 2777, 0.49895178]], "rps_doc_mean_word_length": [[0, 2777, 4.68553459]], "rps_doc_symbol_to_word_ratio": [[0, 2777, 0.00174825]], "rps_doc_unigram_entropy": [[0, 2777, 4.99940677]], "rps_doc_word_count": [[0, 2777, 477.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 84, 0.0], [84, 485, 1.0], [485, 566, 0.0], [566, 1762, 1.0], [1762, 1835, 0.0], [1835, 2777, 1.0]], "rps_lines_javascript_counts": [[0, 84, 0.0], [84, 485, 0.0], [485, 566, 0.0], [566, 1762, 0.0], [1762, 1835, 0.0], [1835, 2777, 0.0]], "rps_lines_num_words": [[0, 84, 14.0], [84, 485, 68.0], [485, 566, 15.0], [566, 1762, 209.0], [1762, 1835, 15.0], [1835, 2777, 156.0]], "rps_lines_numerical_chars_fraction": [[0, 84, 0.03614458], [84, 485, 0.01538462], [485, 566, 0.0], [566, 1762, 0.00516796], [1762, 1835, 0.0], [1835, 2777, 0.00865801]], "rps_lines_start_with_bulletpoint": [[0, 84, 0.0], [84, 485, 0.0], [485, 566, 0.0], [566, 1762, 0.0], [1762, 1835, 0.0], [1835, 2777, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 84, 0.10714286], [84, 485, 0.0798005], [485, 566, 0.07407407], [566, 1762, 0.04264214], [1762, 1835, 0.12328767], [1835, 2777, 0.04352442]], "rps_doc_ml_palm_score": [[0, 2777, 0.5347662]], "rps_doc_ml_wikipedia_score": [[0, 2777, null]], "rps_doc_ml_wikiref_score": [[0, 2777, 0.8500967]], "rps_doc_books_importance": [[0, 2777, -121.28409517]], "rps_doc_openwebtext_importance": [[0, 2777, 55.14539316]], "rps_doc_wikipedia_importance": [[0, 2777, -126.51548436]], "rps_doc_num_sentences": [[0, 2777, 27.0]]} |
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Deep Learning for RAPID classification of the transient Universe
Astronomical transients are stellar objects that become temporarily brighter on various timescales and have led to some of the most significant discoveries in astrophysics and cosmology. Some of these transients are exploding stars called supernovae, which are critical for measuring the expansion and composition of the universe. Kilonovae, a newly discovered class of transients, are the visible-light signatures of gravitational-wave sources caused by neutron star mergers, responsible for creating most of the universe's heavy elements. With new surveys, astronomers are discovering rare, exotic, or entirely new kinds of stellar explosions, which teach us about the diverse pathways of stellar evolution and death.
New wide-field telescope surveys, such as the current Zwicky Transient Facility (ZTF), are producing hundreds of thousands of transient alerts per night, and the upcoming Large Synoptic Survey Telescope (LSST) is expected to observe tens of millions of transients, recording in excess of 20 Terabytes of images each night. To meet this demand, Daniel Muthukrishna and colleagues (Muthukrishna et al 2019) have developed a novel machine learning approach, RAPID (Real-time Automated Photometric IDentification), that uses deep recurrent neural networks (RNNs) to automatically classify transients as a function of time. Variants of RNNs have achieved state-of-the-art performance in several time-series applications. In particular, they revolutionized speech recognition, outperforming traditional methods, and have very recently been used in the trigger word detection algorithms popularised by Apple's Siri, Amazon's Echo, Google's voice assistant, and Microsoft's Cortana. Interestingly, the recording of different frequencies of sound waves as someone says "Okay Google" to their Google Home device, looks extraordinarily similar to the early part of a supernova exploding as we record it in different frequencies of light waves. The success of RNNs in trigger word detection algorithms inspired us to apply them to classifying different types of transients. They have adapted this technique to deal with noisy, multi-channel, sparse, astronomical time-series data. RAPID is the first method designed to quickly classify transient data streams in real-time, and identifies 12 different astrophysical types. An example of a supernova explosion's brightness as a function of time is shown in the top panel of Figure 1, and the classification accuracies from our RNN-based algorithm are plotted in the bottom panel.
This strategy is well-suited to classifying these events very shortly after their explosion. This early classification allows them to alert the global astronomical community to follow up interesting transients with more detailed measurements to probe their underlying physics, before they fade away. In preparation for LSST, they have deployed RAPID to classify the real-time ZTF data stream, and it is currently classifying over 5000 extragalactic transients each night. It is enabling astronomers to make best use of their precious telescope time by prioritizing the most interesting events to follow up with further observations.
Figure: The brightness of a transient measured in two different frequencies (g and r) is shown in the top panel. The classification probabilities of 12 different transient types as predicted by our machine learning-based algorithm are plotted in the bottom panel. The correct transient type is predicted as the most probable type within just a few days of the explosion. The confidence in this prediction improves as more data is taken.
Last updated: 21 Jan 2020 at 13:07
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This project is funded by the Science and Technology Facilities Council (STFC) through ST/S006206/1 and related grants. | 2023-14/0000/en_head.json.gz/1389 | {"url": "https://www.lsst.ac.uk/science-spotlight/deep-learning-rapid-classification-transient-universe", "partition": "head_middle", "language": "en", "source_domain": "www.lsst.ac.uk", "date_download": "2023-03-20T09:08:58Z", "digest": "sha1:LTDSVHNFHYG62PGN2KPFKGLRCGHMEQ4R"} | {"ccnet_length": [[0, 4348, 4348.0]], "ccnet_original_length": [[0, 4348, 4530.0]], "ccnet_nlines": [[0, 4348, 20.0]], "ccnet_original_nlines": [[0, 4348, 31.0]], "ccnet_language_score": [[0, 4348, 0.92]], "ccnet_perplexity": [[0, 4348, 337.0]], "ccnet_bucket": [[0, 4348, 0.0]], "rps_doc_curly_bracket": [[0, 4348, 0.0]], "rps_doc_ldnoobw_words": [[0, 4348, 0.0]], "rps_doc_lorem_ipsum": [[0, 4348, 0.0]], "rps_doc_stop_word_fraction": [[0, 4348, 0.33762887]], "rps_doc_ut1_blacklist": [[0, 4348, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 4348, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 4348, 0.03997779]], "rps_doc_frac_chars_dupe_6grams": [[0, 4348, 0.03053859]], "rps_doc_frac_chars_dupe_7grams": [[0, 4348, 0.01943365]], "rps_doc_frac_chars_dupe_8grams": [[0, 4348, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 4348, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 4348, 0.00832871]], "rps_doc_frac_chars_top_3gram": [[0, 4348, 0.00610772]], "rps_doc_frac_chars_top_4gram": [[0, 4348, 0.00721821]], "rps_doc_frac_all_caps_words": [[0, 4348, 0.03994845]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 4348, 0.0]], "rps_doc_frac_no_alph_words": [[0, 4348, 0.15206186]], "rps_doc_frac_unique_words": [[0, 4348, 0.53364632]], "rps_doc_mean_word_length": [[0, 4348, 5.63693271]], "rps_doc_symbol_to_word_ratio": [[0, 4348, 0.0]], "rps_doc_unigram_entropy": [[0, 4348, 5.32286214]], "rps_doc_word_count": [[0, 4348, 639.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 32, 0.0], [32, 40, 0.0], [40, 96, 0.0], [96, 114, 0.0], [114, 128, 0.0], [128, 148, 0.0], [148, 193, 0.0], [193, 242, 0.0], [242, 274, 0.0], [274, 296, 0.0], [296, 306, 0.0], [306, 318, 0.0], [318, 383, 0.0], [383, 1103, 1.0], [1103, 2919, 1.0], [2919, 3552, 1.0], [3552, 3989, 1.0], [3989, 4024, 0.0], [4024, 4229, 1.0], [4229, 4348, 1.0]], "rps_lines_javascript_counts": [[0, 32, 0.0], [32, 40, 0.0], [40, 96, 0.0], [96, 114, 0.0], [114, 128, 0.0], [128, 148, 0.0], [148, 193, 0.0], [193, 242, 0.0], [242, 274, 0.0], [274, 296, 0.0], [296, 306, 0.0], [306, 318, 0.0], [318, 383, 0.0], [383, 1103, 0.0], [1103, 2919, 0.0], [2919, 3552, 0.0], [3552, 3989, 0.0], [3989, 4024, 0.0], [4024, 4229, 0.0], [4229, 4348, 0.0]], "rps_lines_num_words": [[0, 32, 5.0], [32, 40, 1.0], [40, 96, 10.0], [96, 114, 2.0], [114, 128, 2.0], [128, 148, 3.0], [148, 193, 6.0], [193, 242, 6.0], [242, 274, 5.0], [274, 296, 4.0], [296, 306, 2.0], [306, 318, 2.0], [318, 383, 9.0], [383, 1103, 102.0], [1103, 2919, 262.0], [2919, 3552, 93.0], [3552, 3989, 71.0], [3989, 4024, 7.0], [4024, 4229, 30.0], [4229, 4348, 17.0]], "rps_lines_numerical_chars_fraction": [[0, 32, 0.0], [32, 40, 0.0], [40, 96, 0.0], [96, 114, 0.0], [114, 128, 0.0], [128, 148, 0.0], [148, 193, 0.0], [193, 242, 0.0], [242, 274, 0.13333333], [274, 296, 0.0], [296, 306, 0.0], [306, 318, 0.0], [318, 383, 0.0], [383, 1103, 0.0], [1103, 2919, 0.00511654], [2919, 3552, 0.00642055], [3552, 3989, 0.0046729], [3989, 4024, 0.3125], [4024, 4229, 0.0], [4229, 4348, 0.06140351]], "rps_lines_start_with_bulletpoint": [[0, 32, 0.0], [32, 40, 0.0], [40, 96, 0.0], [96, 114, 0.0], [114, 128, 0.0], [128, 148, 0.0], [148, 193, 0.0], [193, 242, 0.0], [242, 274, 0.0], [274, 296, 0.0], [296, 306, 0.0], [306, 318, 0.0], [318, 383, 0.0], [383, 1103, 0.0], [1103, 2919, 0.0], [2919, 3552, 0.0], [3552, 3989, 0.0], [3989, 4024, 0.0], [4024, 4229, 0.0], [4229, 4348, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 32, 0.21875], [32, 40, 0.75], [40, 96, 0.10714286], [96, 114, 0.11111111], [114, 128, 0.5], [128, 148, 0.4], [148, 193, 0.06666667], [193, 242, 0.08163265], [242, 274, 0.125], [274, 296, 0.31818182], [296, 306, 0.5], [306, 318, 0.41666667], [318, 383, 0.12307692], [383, 1103, 0.00555556], [1103, 2919, 0.03579295], [2919, 3552, 0.02527646], [3552, 3989, 0.01144165], [3989, 4024, 0.05714286], [4024, 4229, 0.03902439], [4229, 4348, 0.10084034]], "rps_doc_ml_palm_score": [[0, 4348, 0.22979748]], "rps_doc_ml_wikipedia_score": [[0, 4348, null]], "rps_doc_ml_wikiref_score": [[0, 4348, 0.55701262]], "rps_doc_books_importance": [[0, 4348, -178.46486328]], "rps_doc_openwebtext_importance": [[0, 4348, -3.85296418]], "rps_doc_wikipedia_importance": [[0, 4348, 3.07582739]], "rps_doc_num_sentences": [[0, 4348, 23.0]]} |
Museums and Questions of Donor Morality: The Sackler Case
susan July 12, 2022 July 12, 2022
By Susan J. Lutzker
In an earlier Insight, we discussed the issue of renaming by public and private educational institutions in situations where naming honors previously bestowed are now considered inconsistent with the institution’s goals of diversity, inclusion and other questions of morality. We have explored the renaming of public spaces for similar reasons. We have also noted that denaming and renaming should be two separate processes. Here we look at issues surrounding denaming in the context of an increased focus by museums on ethics in philanthropy.
In our insight on educational institution name issues, we referenced removal by Tufts University of the Sackler name from several buildings.
The Sacklers are the owners of Purdue Pharma, the maker of OxyContin, which was blamed for fueling the U.S. opioid epidemic. Before the fall from grace, the family was known as a generous patron of arts institutions. However, starting several years ago, artists began demanding removal of the Sackler name from museums. Leading this campaign has been artist Nan Goldin, a former OxyContin addict, who formed a group called PAIN (Prescription Addiction Intervention Now).
Starting in 2019 several major museums announced they would not accept any further donations from the Sackler family, but large-scale removal of the family name from museum facilities is a more recent development.
In March 2022 a $6 billion settlement was reached between Purdue Pharma and a consortium of U.S. attorneys general to resolve a host of civil lawsuits filed against the company. (The settlement still needs final court approval.) One term of the settlement requires the Sackler family to allow institutions to remove the family name from buildings, scholarships and fellowships without penalty, as long as any statement announcing the name change does not “disparage the Sacklers."
The Sackler name has already been removed, or is committed to be removed, by numerous major museums. The National Gallery in London has removed the Sackler name from its walls, and the Tate announced in February that it would remove references to Sackler philanthropy from its two London museums. The Serpentine Gallery and the British Museum had previously done the same. The Louvre in Paris has removed the Sackler name from a major wing. The Metropolitan Museum of Art in New York has removed the Sackler name from the gallery housing the Temple of Dendur and six other exhibition spaces. In May 2022 the Guggenheim Museum erased the family name from an educational center. Some of these actions have been publicly announced, while others have been more quietly implemented or explained in other ways (such as expiration of a term-limited agreement).
The Victoria and Albert Museum remains one of the last holdouts, with its entrance named the Sackler Courtyard. It is unclear whether that will change. The Smithsonian claims it does not have the legal right to change the name of the Arthur M. Sackler Gallery because the naming agreement was in perpetuity.
Activism by artists, among other factors, has increasingly led museums to rethink their policies on accepting donations. To protect themselves from Sackler-like situations in the future, some museums are adding “morals clauses” to donation documents. These clauses are commonly found in entertainment and sports contracts and are generally enforced by courts. According to Terri Lynn Helge, a law professor at Texas A&M University School of Law, morals clauses “… allow an institution to protect themselves in the event of a donor falling from grace.”
But, according to Helge, they are not easy to draft because it is difficult to balance the needs of donor and institution and tricky to anticipate what should constitute a trigger event for disassociation. A premature rush to judgment, as well as a delay in termination, can be disastrous. Some very large donors have the leverage to reject morals clauses altogether (for example, Jeff Bezos’s 50-year naming rights deal with the Smithsonian does not include one). Morals clauses fall into the larger category of termination rights in philanthropic agreements, and there are practical reasons, unrelated to morals, that museums may not want to enter into “forever” contracts. For example, they can discourage other donations and eliminate competition for naming rights.
The Sackler family has not been the only target of artist activism, nor has denaming been the sole issue. In 2019 Warren B. Kanders, the vice-chairman of the board of the Whitney and a major donor to the museum, resigned his position after months of protests by artists over Kanders’s ownership of the Safariland Group, a manufacturer of tear gas, used at the U.S.-Mexico border. In June 2021 Leon Black resigned as chairman of the Museum of Modern Art in New York because of revelations about his association with convicted sex offender Jeffrey Epstein. Increasingly, artists are demanding a seat at the table where decisions are made as to leadership and patronage of the cultural institutions that display their works. We will continue to follow these and related developments in this rapidly evolving area.
Stamping Out Uyghur Culture: The Winter Olympics Shine a Light on Misappropriation of Traditions — Addendum
A Joint Study by the USPTO and the Copyright Office on NFTs and Intellectual Property | 2023-14/0000/en_head.json.gz/1390 | {"url": "https://www.lutzker.com/museums-and-questions-of-donor-morality-the-sackler-case/", "partition": "head_middle", "language": "en", "source_domain": "www.lutzker.com", "date_download": "2023-03-20T09:48:13Z", "digest": "sha1:Z35K5BLG3SISQXCSADPIMHDEJCCVVXP3"} | {"ccnet_length": [[0, 5451, 5451.0]], "ccnet_original_length": [[0, 5451, 7500.0]], "ccnet_nlines": [[0, 5451, 15.0]], "ccnet_original_nlines": [[0, 5451, 115.0]], "ccnet_language_score": [[0, 5451, 0.97]], "ccnet_perplexity": [[0, 5451, 247.7]], "ccnet_bucket": [[0, 5451, 0.0]], "rps_doc_curly_bracket": [[0, 5451, 0.0]], "rps_doc_ldnoobw_words": [[0, 5451, 1.0]], "rps_doc_lorem_ipsum": [[0, 5451, 0.0]], "rps_doc_stop_word_fraction": [[0, 5451, 0.3937247]], "rps_doc_ut1_blacklist": [[0, 5451, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 5451, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 5451, 0.02768475]], "rps_doc_frac_chars_dupe_6grams": [[0, 5451, 0.01875419]], "rps_doc_frac_chars_dupe_7grams": [[0, 5451, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 5451, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 5451, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 5451, 0.02455905]], "rps_doc_frac_chars_top_3gram": [[0, 5451, 0.01875419]], "rps_doc_frac_chars_top_4gram": [[0, 5451, 0.02009377]], "rps_doc_frac_all_caps_words": [[0, 5451, 0.01518219]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 5451, 0.0]], "rps_doc_frac_no_alph_words": [[0, 5451, 0.12145749]], "rps_doc_frac_unique_words": [[0, 5451, 0.47580645]], "rps_doc_mean_word_length": [[0, 5451, 5.16013825]], "rps_doc_symbol_to_word_ratio": [[0, 5451, 0.00101215]], "rps_doc_unigram_entropy": [[0, 5451, 5.37770934]], "rps_doc_word_count": [[0, 5451, 868.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 58, 0.0], [58, 92, 0.0], [92, 112, 0.0], [112, 656, 1.0], [656, 797, 1.0], [797, 1268, 1.0], [1268, 1482, 1.0], [1482, 1963, 0.0], [1963, 2817, 1.0], [2817, 3125, 1.0], [3125, 3677, 1.0], [3677, 4447, 1.0], [4447, 5258, 1.0], [5258, 5366, 0.0], [5366, 5451, 0.0]], "rps_lines_javascript_counts": [[0, 58, 0.0], [58, 92, 0.0], [92, 112, 0.0], [112, 656, 0.0], [656, 797, 0.0], [797, 1268, 0.0], [1268, 1482, 0.0], [1482, 1963, 0.0], [1963, 2817, 0.0], [2817, 3125, 0.0], [3125, 3677, 0.0], [3677, 4447, 0.0], [4447, 5258, 0.0], [5258, 5366, 0.0], [5366, 5451, 0.0]], "rps_lines_num_words": [[0, 58, 9.0], [58, 92, 7.0], [92, 112, 4.0], [112, 656, 83.0], [656, 797, 21.0], [797, 1268, 74.0], [1268, 1482, 33.0], [1482, 1963, 75.0], [1963, 2817, 141.0], [2817, 3125, 52.0], [3125, 3677, 84.0], [3677, 4447, 120.0], [4447, 5258, 134.0], [5258, 5366, 16.0], [5366, 5451, 15.0]], "rps_lines_numerical_chars_fraction": [[0, 58, 0.0], [58, 92, 0.38709677], [92, 112, 0.0], [112, 656, 0.0], [656, 797, 0.0], [797, 1268, 0.0], [1268, 1482, 0.01904762], [1482, 1963, 0.01066098], [1963, 2817, 0.00476758], [2817, 3125, 0.0], [3125, 3677, 0.0], [3677, 4447, 0.00265957], [4447, 5258, 0.01007557], [5258, 5366, 0.0], [5366, 5451, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 58, 0.0], [58, 92, 0.0], [92, 112, 0.0], [112, 656, 0.0], [656, 797, 0.0], [797, 1268, 0.0], [1268, 1482, 0.0], [1482, 1963, 0.0], [1963, 2817, 0.0], [2817, 3125, 0.0], [3125, 3677, 0.0], [3677, 4447, 0.0], [4447, 5258, 0.0], [5258, 5366, 0.0], [5366, 5451, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 58, 0.12068966], [58, 92, 0.05882353], [92, 112, 0.2], [112, 656, 0.00919118], [656, 797, 0.02836879], [797, 1268, 0.05095541], [1268, 1482, 0.00934579], [1482, 1963, 0.02079002], [1963, 2817, 0.03981265], [2817, 3125, 0.04220779], [3125, 3677, 0.02536232], [3677, 4447, 0.01168831], [4447, 5258, 0.03205919], [5258, 5366, 0.11111111], [5366, 5451, 0.17647059]], "rps_doc_ml_palm_score": [[0, 5451, 0.90458268]], "rps_doc_ml_wikipedia_score": [[0, 5451, null]], "rps_doc_ml_wikiref_score": [[0, 5451, 0.86833262]], "rps_doc_books_importance": [[0, 5451, -161.92913466]], "rps_doc_openwebtext_importance": [[0, 5451, 89.14595683]], "rps_doc_wikipedia_importance": [[0, 5451, 95.27027346]], "rps_doc_num_sentences": [[0, 5451, 47.0]]} |
MACAO, March 17 (Xinhua) -- Macao's total population at the end of December 2022 decreased by 10,400 year-on-year to 672,800, the special administrative region's (SAR) statistic service said on Friday.
Information from the Statistics and Census Service (DSEC) showed that the female population accounted for 53.2 percent of the total.
A total of 4,344 live births were delivered in 2022, down by 682 year-on-year. The median age of mothers who gave birth to their first baby was 31.0 years, up by 0.9 year-on-year.
Mortality rose by 684 year-on-year to 3,004 in 2022. The top three underlying causes of death were malignant neoplasms, hypertension and pneumonia, said the report.
In 2022, new arrivals from the mainland with one-way permits went down by 324 year-on-year to 2,303. There were 154,912 non-resident workers at the end of 2022, a drop of 16,186 year-on-year.
The report also showed that marriage registrations totaled 2,727 in 2022, down by 550 year-on-year. | 2023-14/0000/en_head.json.gz/1391 | {"url": "https://www.macaunews.net/news/273637995/macaos-population-decreases-to-672800-in-2022", "partition": "head_middle", "language": "en", "source_domain": "www.macaunews.net", "date_download": "2023-03-20T10:17:27Z", "digest": "sha1:SYQ6EFR2KF2ULTX6ZPPXX2EEZJBVHERH"} | {"ccnet_length": [[0, 971, 971.0]], "ccnet_original_length": [[0, 971, 7939.0]], "ccnet_nlines": [[0, 971, 6.0]], "ccnet_original_nlines": [[0, 971, 186.0]], "ccnet_language_score": [[0, 971, 0.98]], "ccnet_perplexity": [[0, 971, 131.5]], "ccnet_bucket": [[0, 971, 0.0]], "rps_doc_curly_bracket": [[0, 971, 0.0]], "rps_doc_ldnoobw_words": [[0, 971, 0.0]], "rps_doc_lorem_ipsum": [[0, 971, 0.0]], "rps_doc_stop_word_fraction": [[0, 971, 0.29535865]], "rps_doc_ut1_blacklist": [[0, 971, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 971, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 971, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 971, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 971, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 971, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 971, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 971, 0.03149606]], "rps_doc_frac_chars_top_3gram": [[0, 971, 0.02099738]], "rps_doc_frac_chars_top_4gram": [[0, 971, 0.02624672]], "rps_doc_frac_all_caps_words": [[0, 971, 0.01687764]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 971, 0.0]], "rps_doc_frac_no_alph_words": [[0, 971, 0.36708861]], "rps_doc_frac_unique_words": [[0, 971, 0.64285714]], "rps_doc_mean_word_length": [[0, 971, 4.94805195]], "rps_doc_symbol_to_word_ratio": [[0, 971, 0.0]], "rps_doc_unigram_entropy": [[0, 971, 4.31391489]], "rps_doc_word_count": [[0, 971, 154.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 202, 1.0], [202, 335, 1.0], [335, 515, 1.0], [515, 680, 1.0], [680, 872, 1.0], [872, 971, 1.0]], "rps_lines_javascript_counts": [[0, 202, 0.0], [202, 335, 0.0], [335, 515, 0.0], [515, 680, 0.0], [680, 872, 0.0], [872, 971, 0.0]], "rps_lines_num_words": [[0, 202, 29.0], [202, 335, 20.0], [335, 515, 33.0], [515, 680, 25.0], [680, 872, 32.0], [872, 971, 15.0]], "rps_lines_numerical_chars_fraction": [[0, 202, 0.09189189], [202, 335, 0.0234375], [335, 515, 0.0952381], [515, 680, 0.07006369], [680, 872, 0.14606742], [872, 971, 0.11702128]], "rps_lines_start_with_bulletpoint": [[0, 202, 0.0], [202, 335, 0.0], [335, 515, 0.0], [515, 680, 0.0], [680, 872, 0.0], [872, 971, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 202, 0.06435644], [202, 335, 0.06015038], [335, 515, 0.01111111], [515, 680, 0.01212121], [680, 872, 0.01041667], [872, 971, 0.01010101]], "rps_doc_ml_palm_score": [[0, 971, 0.95952636]], "rps_doc_ml_wikipedia_score": [[0, 971, null]], "rps_doc_ml_wikiref_score": [[0, 971, 0.78983009]], "rps_doc_books_importance": [[0, 971, -90.2990673]], "rps_doc_openwebtext_importance": [[0, 971, 15.31208746]], "rps_doc_wikipedia_importance": [[0, 971, 34.35671526]], "rps_doc_num_sentences": [[0, 971, 12.0]]} |
Digital Performer 8 100: What's New In DP8
3. The Improved Plug-in Chooser (04:42)
Sep 21st, 2022, 08:45 by Student499960 | 2023-14/0000/en_head.json.gz/1392 | {"url": "https://www.macprovideo.com/video/digitalperformer8100-what-s-new-in-dp8/3-3-the-improved-plug-in-chooser", "partition": "head_middle", "language": "en", "source_domain": "www.macprovideo.com", "date_download": "2023-03-20T10:41:54Z", "digest": "sha1:I7GVGG6PLUBYEGB2GP4JZAVGDFFRIKSR"} | {"ccnet_length": [[0, 121, 121.0]], "ccnet_original_length": [[0, 121, 2665.0]], "ccnet_nlines": [[0, 121, 3.0]], "ccnet_original_nlines": [[0, 121, 116.0]], "ccnet_language_score": [[0, 121, 0.81]], "ccnet_perplexity": [[0, 121, 308.3]], "ccnet_bucket": [[0, 121, 0.0]], "rps_doc_curly_bracket": [[0, 121, 0.0]], "rps_doc_ldnoobw_words": [[0, 121, 0.0]], "rps_doc_lorem_ipsum": [[0, 121, 0.0]], "rps_doc_stop_word_fraction": [[0, 121, 0.08823529]], "rps_doc_ut1_blacklist": [[0, 121, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 121, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 121, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 121, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 121, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 121, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 121, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 121, 0.0]], "rps_doc_frac_chars_top_3gram": [[0, 121, 0.0]], "rps_doc_frac_chars_top_4gram": [[0, 121, 0.0]], "rps_doc_frac_all_caps_words": [[0, 121, 0.02941176]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 121, 0.0]], "rps_doc_frac_no_alph_words": [[0, 121, 0.52941176]], "rps_doc_frac_unique_words": [[0, 121, 1.0]], "rps_doc_mean_word_length": [[0, 121, 4.6]], "rps_doc_symbol_to_word_ratio": [[0, 121, 0.0]], "rps_doc_unigram_entropy": [[0, 121, 2.99573227]], "rps_doc_word_count": [[0, 121, 20.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 43, 0.0], [43, 83, 0.0], [83, 121, 0.0]], "rps_lines_javascript_counts": [[0, 43, 0.0], [43, 83, 0.0], [83, 121, 0.0]], "rps_lines_num_words": [[0, 43, 8.0], [43, 83, 6.0], [83, 121, 6.0]], "rps_lines_numerical_chars_fraction": [[0, 43, 0.125], [43, 83, 0.14705882], [83, 121, 0.45714286]], "rps_lines_start_with_bulletpoint": [[0, 43, 0.0], [43, 83, 0.0], [83, 121, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 43, 0.1627907], [43, 83, 0.1], [83, 121, 0.05263158]], "rps_doc_ml_palm_score": [[0, 121, 0.01352352]], "rps_doc_ml_wikipedia_score": [[0, 121, null]], "rps_doc_ml_wikiref_score": [[0, 121, -1.001e-05]], "rps_doc_books_importance": [[0, 121, -25.99458907]], "rps_doc_openwebtext_importance": [[0, 121, -10.8583676]], "rps_doc_wikipedia_importance": [[0, 121, -6.51409155]], "rps_doc_num_sentences": [[0, 121, 2.0]]} |
Second time charm for Mississippi test of moon shot rocket
NASA conducts a hot fire test Jan. 16, 2021, of the core stage for the agency’s Space Launch System rocket on the B-2 Test Stand at Stennis Space Center near Bay St. Louis. The hot fire test of the stage’s four RS-25 engines generated a combined 1.6 million pounds of thrust, just as will occur during an actual launch. The hot fire is the final test of the Green Run test series, a comprehensive assessment of the SLS core stage prior to launching the Artemis I mission to the Moon. NASA photo by Danny Nowlin
NASA completed an engine test firing of its moon rocket Thursday in Mississippi, after the first attempt in January ended prematurely.
This time, the four main engines of the rocket’s core stage remained ignited for the full eight minutes. Applause broke out in the control room at Mississippi’s Stennis Space Flight Center once the engines shut down on the test stand.
NASA officials called it a major milestone in sending astronauts back to the moon, but declined to say when that might occur or even whether the first test flight without a crew would occur by year’s end as planned.
John Honeycutt, NASA’s program manager for the Space Launch System or SLS rocket, said everything seemed to go well in Thursday’s test firing. “The core stage … got an A-plus today,” he told reporters.
During the first test, the engines fired for just a minute, automatically cut short by strict test limits that were relaxed for the redo. Valve issues also had to be resolved prior to Thursday’s countdown.
With this critical test finally finished — and assuming everything went well — NASA can now send the rocket segment to Florida’s Kennedy Space Center to prepare it for launch.
Noting they’re taking it one step at a time, officials declined to say whether this first SLS launch will occur by year’s end as had been planned or will bump into 2022. The SLS rocket will send an empty Orion capsule to the moon and back.
The four engines tested Thursday actually flew into orbit on NASA’s space shuttles and were upgraded for the more powerful SLS system. The orange core stage is reminiscent of the shuttle’s external fuel tank, which held the liquid hydrogen and oxygen that fed the main engines.
Boeing built the core stage, which stands 212 feet (65 meters.)
The Trump administration had pressed for a moon landing by astronauts by 2024, a deadline increasingly difficult if not impossible to achieve at this point. The current White House has yet to issue a revised timeline.
NASA Acting Administrator Steve Jurczyk said the space agency is conducting an internal study to determine a schedule for the astronaut moon landings — “what we can optimally do” based on budgets. The review will take a few months, he noted. | 2023-14/0000/en_head.json.gz/1393 | {"url": "https://www.magnoliastatelive.com/2021/03/18/second-time-charm-for-mississippi-test-of-moon-shot-rocket/", "partition": "head_middle", "language": "en", "source_domain": "www.magnoliastatelive.com", "date_download": "2023-03-20T09:09:00Z", "digest": "sha1:RLCOGGTOWFWEVNFRT2QWV5QRWZ7WRTAL"} | {"ccnet_length": [[0, 2781, 2781.0]], "ccnet_original_length": [[0, 2781, 3604.0]], "ccnet_nlines": [[0, 2781, 13.0]], "ccnet_original_nlines": [[0, 2781, 44.0]], "ccnet_language_score": [[0, 2781, 0.94]], "ccnet_perplexity": [[0, 2781, 337.8]], "ccnet_bucket": [[0, 2781, 0.0]], "rps_doc_curly_bracket": [[0, 2781, 0.0]], "rps_doc_ldnoobw_words": [[0, 2781, 0.0]], "rps_doc_lorem_ipsum": [[0, 2781, 0.0]], "rps_doc_stop_word_fraction": [[0, 2781, 0.37010676]], "rps_doc_ut1_blacklist": [[0, 2781, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2781, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2781, 0.01598579]], "rps_doc_frac_chars_dupe_6grams": [[0, 2781, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2781, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2781, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2781, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2781, 0.01332149]], "rps_doc_frac_chars_top_3gram": [[0, 2781, 0.01198934]], "rps_doc_frac_chars_top_4gram": [[0, 2781, 0.01420959]], "rps_doc_frac_all_caps_words": [[0, 2781, 0.03024911]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2781, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2781, 0.13345196]], "rps_doc_frac_unique_words": [[0, 2781, 0.52892562]], "rps_doc_mean_word_length": [[0, 2781, 4.65289256]], "rps_doc_symbol_to_word_ratio": [[0, 2781, 0.00177936]], "rps_doc_unigram_entropy": [[0, 2781, 5.07286197]], "rps_doc_word_count": [[0, 2781, 484.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 59, 0.0], [59, 570, 0.0], [570, 705, 1.0], [705, 940, 1.0], [940, 1156, 1.0], [1156, 1358, 1.0], [1358, 1564, 1.0], [1564, 1740, 1.0], [1740, 1980, 1.0], [1980, 2258, 1.0], [2258, 2322, 0.0], [2322, 2540, 1.0], [2540, 2781, 1.0]], "rps_lines_javascript_counts": [[0, 59, 0.0], [59, 570, 0.0], [570, 705, 0.0], [705, 940, 0.0], [940, 1156, 0.0], [1156, 1358, 0.0], [1358, 1564, 0.0], [1564, 1740, 0.0], [1740, 1980, 0.0], [1980, 2258, 0.0], [2258, 2322, 0.0], [2322, 2540, 0.0], [2540, 2781, 0.0]], "rps_lines_num_words": [[0, 59, 10.0], [59, 570, 95.0], [570, 705, 21.0], [705, 940, 40.0], [940, 1156, 39.0], [1156, 1358, 34.0], [1358, 1564, 35.0], [1564, 1740, 30.0], [1740, 1980, 46.0], [1980, 2258, 46.0], [2258, 2322, 11.0], [2322, 2540, 36.0], [2540, 2781, 41.0]], "rps_lines_numerical_chars_fraction": [[0, 59, 0.0], [59, 570, 0.02208835], [570, 705, 0.0], [705, 940, 0.0], [940, 1156, 0.0], [1156, 1358, 0.0], [1358, 1564, 0.0], [1564, 1740, 0.0], [1740, 1980, 0.01694915], [1980, 2258, 0.0], [2258, 2322, 0.08474576], [2322, 2540, 0.01869159], [2540, 2781, 0.0]], "rps_lines_start_with_bulletpoint": [[0, 59, 0.0], [59, 570, 0.0], [570, 705, 0.0], [705, 940, 0.0], [940, 1156, 0.0], [1156, 1358, 0.0], [1358, 1564, 0.0], [1564, 1740, 0.0], [1740, 1980, 0.0], [1980, 2258, 0.0], [2258, 2322, 0.0], [2322, 2540, 0.0], [2540, 2781, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 59, 0.03389831], [59, 570, 0.06849315], [570, 705, 0.05185185], [705, 940, 0.02978723], [940, 1156, 0.01851852], [1156, 1358, 0.07425743], [1358, 1564, 0.01456311], [1564, 1740, 0.05113636], [1740, 1980, 0.0375], [1980, 2258, 0.03597122], [2258, 2322, 0.015625], [2322, 2540, 0.02293578], [2540, 2781, 0.0373444]], "rps_doc_ml_palm_score": [[0, 2781, 0.86797905]], "rps_doc_ml_wikipedia_score": [[0, 2781, null]], "rps_doc_ml_wikiref_score": [[0, 2781, 0.88683283]], "rps_doc_books_importance": [[0, 2781, -160.20117391]], "rps_doc_openwebtext_importance": [[0, 2781, 63.82920854]], "rps_doc_wikipedia_importance": [[0, 2781, -78.33039927]], "rps_doc_num_sentences": [[0, 2781, 24.0]]} |
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Digital Realty Trust ESG Rating & Sustainability Data
Adding Digital Realty Trust, Inc.
Key ESG Takeaways for Digital Realty Trust
Learn about the key takeaways.
The keytakeaways are AI-generated and highlight the main contributors behind the net impact scores of Digital Realty Trust. The insights are based on millions of scientific articles, along with the company-specific product and service portfolio.
Digital Realty seems to create the most significant positive value in categories
Knowledge Infrastructure
. The positive contribution in the
impact category is mostly driven by its Data center services, Cloud management tools, and Hosted database services products.
On the other hand, these positive outcomes are achieved by using resources or causing negative impacts in categories
Scarce Human Capital
, and Non-
. The negative contribution in the
impact category seems to be driven mostly by its Data center services, Data center control services, and Hosted database services products.
To improve its net impact, a company can either grow its positive impacts, or reduce its negative impacts. For example, by doubling its General data protection regulation compliance consulting business, Digital Realty would improve its net impact ratio by 2 percentage points.
DLR Impact Ratio
Learn about the net impact ratio.
Net impact ratio represents the net impact of a company. It is defined as the (positive impacts - negative impacts) / positive impacts. The maximum value for net impact ratio is 100%, representing a theoretical company with no negative impacts. The minimum value is -∞. Net scores depend on the value sets that determine the importance of different impact categories.
The default value set, where each category is given the same weight.
Value Sets Value sets can be used to assess how different stakeholder values or emphasis on certain values might affect the net impact ratio.
Value set of millennials (b. 1980 - 1999), based on Upright's annual Impact at Work survey.
Most Wanted Workforce
Value set of the most wanted workforce, based on Upright's annual Impact at Work survey.
Society First
Value set that emphasizes society impacts over other impacts.
Knowledge First
Value set that emphasizes knowledge impacts over other impacts.
Value set that emphasizes health impacts over other impacts.
Digital Realty Trust ESG Score + Net Impact Profile
Societal Infrastructure
Societal Stability
Equality & Human Rights
Creating Knowledge
Distributing Knowledge
Physical Diseases
Meaning & Joy
Non-GHG Emissions
Scarce Natural Resources
Jobs: What Does This Impact Category Mean?
Negative Impacts
(No negative impacts are considered for this impact category.)
Positive Impacts
Employing people and thus enabling them to gain financial actorship and identity in society. In this impact, we take into account people employed both directly by the company, as well as indirectly by its suppliers and customers.
Example: a company employs 700 people.
Taxes: What Does This Impact Category Mean?
Contributing to joint resources via taxes paid directly by the company or indirectly by its suppliers and customers.
Example: a company pays its corporate taxes.
Societal Infrastructure: What Does This Impact Category Mean?
Contributing to or forming basic societal infrastructure, such as roads, sewage systems, electricity network, hospitals, schools, and pension systems. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company builds sewer systems.
Societal Stability: What Does This Impact Category Mean?
Decreasing understanding among people or inciting or enabling armed conflict. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces firearms that are used in armed conflicts.
Increasing understanding among people or inciting or enabling peace. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company offers translation services that help people with no common language understand each other.
Equality & Human Rights: What Does This Impact Category Mean?
Decreasing racial, economic or gender equality, or violating human rights. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company uses conflict minerals to produce consumer electronics.
Increasing racial, economic or gender equality, or enforcing human rights. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company provides microloans to women in developing countries, enabling them to start a business.
Knowledge Infrastructure: What Does This Impact Category Mean?
Contributing to knowledge infrastructure and thus enabling the effective and safe creation, distribution, and maintenance of knowledge, information, and data. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces base stations.
Creating Knowledge: What Does This Impact Category Mean?
Enabling, encouraging or practicing the creation of data, information or knowledge. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company providing preclinical research services.
Distributing Knowledge: What Does This Impact Category Mean?
Distributing untrue or misleading information, or spreading spam content that takes up space from trustworthy information and burdens human cognitive capacity. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company running fake news websites.
Distributing already existing data, information or knowledge. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company broadcasts television programs.
Scarce Human Capital: What Does This Impact Category Mean?
The opportunity cost of employing people with scarce skills and capabilities. This impact reflects the fact that oftentimes, the workforce is a company's most valuable resource. If a company reserves or utilized scarce human capital, it needs to put these resources into use and achieve something on the positive side in order to be considered net positive. In this impact, we take into account people employed both directly by the company, as well as indirectly by its suppliers and customers.
Example: a company employs 140 highly skilled programmers.
(No positive impacts are considered for this impact category.)
Physical Diseases: What Does This Impact Category Mean?
Causing or contributing towards the development or occurrence of physical diseases, injuries or fatalities. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces cigarettes which have been proven to cause lung cancer.
Treating, preventing or contributing towards the treatment or prevention of physical diseases, injuries or fatalities. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company develops and produces vaccines.
Mental Diseases: What Does This Impact Category Mean?
Causing or contributing towards the development of mental health problems. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces slot machines that cause addiction.
Treating, preventing or contributing towards the treatment and prevention of mental health problems. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company offers psychotherapy services for the treatment of depression.
Nutrition: What Does This Impact Category Mean?
Encouraging, enabling or providing healthy nutrition or contributing to food security. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company sells legumes, which have been proven to be a healthy source of protein and various other nutrients.
Relationships: What Does This Impact Category Mean?
Worsening the quality of human relationships and connection. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces alcohol that causes aggression and violence.
Improving the quality of human relationships and connection. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company offers couple therapy services that help individuals establish and maintain healthy relationships.
Meaning & Joy: What Does This Impact Category Mean?
Decreasing experiences of joy and sense of meaning. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces fashion advertisements that enforce beauty standards causing anxiety and loss of self-esteem.
Increasing experiences of joy and sense of meaning. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces chocolate, which makes some people feel enjoyment.
GHG Emissions: What Does This Impact Category Mean?
Creating greenhouse gas emissions. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company runs a factory that causes GHG emissions.
Removing or contributing towards the reduction of greenhouse gas emissions, or producing or enabling products and services that create fewer GHG emissions compared to their most common alternatives. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company creates carbon-capture technology, or produces wind power.
Non-GHG Emissions: What Does This Impact Category Mean?
Creating non-GHG emissions, such as land, water and air pollution. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces fertilizers that contain ammonia which can seep into lakes, or diesel-powered passenger cars that create particulate emissions.
Removing or contributing towards the reduction of non-GHG emissions, such as land, water and air pollution, or producing or enabling products and services that create less non-GHG emissions compared to their most common alternatives. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces oil spill clean-up technology.
Scarce Natural Resources: What Does This Impact Category Mean?
The use of highly scarce natural resources, such as fresh water, or scarce minerals and metals. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company runs an industrial process that uses large amounts of fresh water, or produces solar panels with rare earth metal components.
Saving or increasing the amount of highly scarce natural resources, such as fresh water, and scarce minerals and metals. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company produces water desalination systems, which increase the amount of fresh drinking water available.
Biodiversity: What Does This Impact Category Mean?
Destroying biodiversity or harming animal welfare. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company cuts down forests to produce palm oil, or utilises intensive animal farming to produce dairy products.
Protecting or increasing biodiversity or animal welfare. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company breeds bees which help pollinate surrounding flora.
Waste: What Does This Impact Category Mean?
Creating all types of waste. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company manufactures disposable plastic cups.
Treating waste and encouraging, enabling or practicing recycling or the re-use of materials. This can occur either directly through the company's core products and services, indirectly through its suppliers' operations or when its products and services are used by customers.
Example: a company treats hazardous waste, or runs a platform on which customers can sell used goods.
Upright Model Version 0.4.0
ESG Data Last Updated: April 1, 2022
About Upright's Net Impact Model
Upright's Net Impact Data quantifies the holistic value creation and impact of companies. It details both the negative and positive impacts a company has on the environment, health of people, society and knowledge, and forms a net sum of these costs and gains based on the economic costs of each impact category. The data is produced by Upright's Net Impact model, which is a mathematical model of the economy that produces continuously updated estimates of the net impact of companies by means of an information integration algorithm. The data is primarily sourced from the CORE open access database, which contains over 200 million scientific papers. Other sources of data include open databases published by the World Bank, IMF, WHO, OECD, IPCC, CDC and USDA.
Digital Realty Trust ESG Rating - Frequently Asked Questions
How is Digital Realty Trust doing in terms of sustainability?
According to The Upright Project, which measures holistic value creation and impact of companies, Digital Realty Trust has a net impact ratio of 21.0%, indicating an overall positive sustainability impact. Digital Realty seems to create the most significant positive value in the categories of Taxes, Knowledge infrastructure, and Jobs. On the other hand, these positive outcomes are achieved by using resources or causing negative impacts in the categories of Scarce human capital, GHG emissions, and Non-GHG emissions. Learn more on the sustainability of Digital Realty Trust.
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Writing your way to the White House
Nancy Marshall-Genzer May 14, 2015
https://www.marketplace.org/2015/05/14/writing-your-way-white-house/
Walk into about any bookstore in Washington and they are hard to miss – all the books by presidential hopefuls.
James Webb has a book called “I Heard My Country Calling.” Ben Carson’s is “One Nation.” Then of course there’s “God, Guns, Grits and Gravy” from Mike Huckabee.
“This is where we put the newest books that were released in paperback – so you can see right at the front is Hillary Clinton’s paperback: just came out last week,” says Mark Laframboise, the book buyer for the Politics and Prose Bookstore in Washington, D.C.
He points out other books, by Senator Marco Rubio, and Congressman Paul Ryan.
“Paul Ryan’s around sometimes,” he says. “He was down in the coffee shop a couple weeks ago.”
This is ground-zero for political books, a hangout for politicians and political junkies. But Lafromboise says even here, the presidential campaign book usually has a short shelf life.
“A month, three weeks,” he says.
So why write them?
“Candidates feel a lot of pressure to get their message out there in their words with their ideas, without the filters of lots and lots of other people,” says Lissa Muscatine, a former chief speechwriter for Hillary Clinton, who worked on most of Clinton’s books.
Now Muscatine owns Politics and Prose with her husband, Bradley Graham. Muscatine says the candidates’ books take many forms. Memoirs, or manifestos, laying out what they would do as president. Who buys these books? People like Gordon Mantler, a historian at George Washington University.
Mantler is browsing in the political section. He bought one of President Obama’s books: “Dreams from my Father.”
“I didn’t feel like this was the typical memoir that’s setting up a presidential or national campaign,” Mentler says.
And that’s key.
“I think the most important thing is to write a book that the reader will find authentic,” says longtime publisher Peter Osnos, founder and editor-at-large of the PublicAffairs publishing company.
He says political writers should open up about their lives. And say something original. And it doesn’t hurt if people are really interested in you. “Dreams from my Father” was published in 1995, but sales didn’t take off until after Barack Obama’s speech at the 2004 Democratic National Convention.
And candidates shouldn’t worry if their book is a total bomb — we’ve had some pretty bad writers win the White House.
The Mueller Report is an overnight bestseller
Bookstores see surge in sales of works about race
Everybody falls in love: diversity in the romance industry
The villain in James Patterson’s new book seems strangely familiar…
What’s it like publishing your first book in a pandemic?
Indie booksellers innovate to survive the age of Amazon | 2023-14/0000/en_head.json.gz/1395 | {"url": "https://www.marketplace.org/2015/05/14/writing-your-way-white-house/", "partition": "head_middle", "language": "en", "source_domain": "www.marketplace.org", "date_download": "2023-03-20T10:47:25Z", "digest": "sha1:UVYRNWAQH2TRCDRUPEGLNPF27JYKRM72"} | {"ccnet_length": [[0, 2831, 2831.0]], "ccnet_original_length": [[0, 2831, 5930.0]], "ccnet_nlines": [[0, 2831, 25.0]], "ccnet_original_nlines": [[0, 2831, 186.0]], "ccnet_language_score": [[0, 2831, 0.95]], "ccnet_perplexity": [[0, 2831, 266.1]], "ccnet_bucket": [[0, 2831, 0.0]], "rps_doc_curly_bracket": [[0, 2831, 0.0]], "rps_doc_ldnoobw_words": [[0, 2831, 0.0]], "rps_doc_lorem_ipsum": [[0, 2831, 0.0]], "rps_doc_stop_word_fraction": [[0, 2831, 0.37353434]], "rps_doc_ut1_blacklist": [[0, 2831, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2831, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2831, 0.0]], "rps_doc_frac_chars_dupe_6grams": 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CBS MarketWatch.com
Not your father's go-cart
Published: Aug. 21, 2003 at 4:20 p.m. ET
, Medill News Service
Consumer group calls for age limits for all-terrain vehicles
WASHINGTON (CBS.MW) -- Citing increasing injuries among young users of all-terrain vehicles, consumer and conservation advocates are calling for a mandatory federal law banning the sale of adult-size ATVs for use by children younger than age 16.
Between 1997 and 2001, serious injuries involving ATVs requiring emergency room treatment more than doubled to almost 112,000, and ATV-related injuries among children between ages 12 and 15 increased by 76 percent nationally, according to a report released this week by the Consumer Federation of America, Natural Trails & Waters Coalition, and Bluewater Network.
The proposal pits the groups against ATV users and the industry. ATV users in June urged the Consumer Product Safety Commission to abolish voluntary minimum age limits, calling them ineffective. Likewise, manufacturers and distributors said states -- not the federal government -- should enact a tiered age/size policy for young drivers.
"This report documents that the industry's approach to safety has led to more injuries, more deaths and bigger and more powerful ATVs on the market," said Consumer Federation attorney Rachel Weintraub, a co-author of the report. "[The commission] must act now by issuing a rule to protect all consumers, especially children, from what continues to be a hidden epidemic."
The report was based on data from the commission, an independent regulatory agency that issues both voluntary and mandatory product safety standards and bans particularly troublesome products.
Spurred by a Consumer Federation petition, the three-member commission will consider making mandatory a voluntary ban on the sale of adult-sized off-road vehicles to children younger than age 16.
The potential policy change could require that a retailer "must explicitly know that if a parent is purchasing an ATV for someone younger than 16, that the vehicle is of the appropriate size for that rider," said commission spokesman Scott Wolfson, "A mandatory regulation gives us enforcement authority."
In addition to the voluntary ban, the safety commission now bans the sale of three-wheeled ATVs, requires dealers to offer consumers financial incentives for training, and requires manufacturers to post warning labels on new vehicles.
Three states have banned the sale of off-road vehicles to children, laws that legally supercede the safety commission's voluntary policy.
Still, the Consumer Federation said, a national policy is needed.
Sales of ATVs have risen steadily during the past decade. An estimated 847,000 ATVs were sold in 2002, up from 802,000 in 2001 and 169,000 in 1992, according to the Specialty Vehicle Institute of America, the industry's main trade group. Leading manufacturers include Artic Cat, Bombadier, Honda, John Deere, Kawasaki and Yamaha. The median age of an ATV owner is 40, and 90 percent are male, according to the institute.
In 2001, about 97 percent of children younger than 16 involved in ATV-related accidents were injured by off-road vehicles larger than those recommended for their age group, up from 95 percent in 1997, according to the study. The commission recommends that children younger than age 16 use ATVs with engines no larger than 90 cubic centimeters.
And while about 1.4 million children in the nation's 8.6 million ATV-owning households are younger than 16, a full 82 percent of these young drivers are using off-road vehicles with engines larger than 90 cc, according to the safety commission.
"Just because a child has the physical stature to sit comfortably on an ATV, it doesn't mean he has the maturity and judgment to operate an adult-sized ATV," said Dr. Rebecca Brown, a pediatric trauma nurse from Morgantown, West Virginia.
The size-versus-maturity argument directly challenges a proposal by ATV manufacturers and sellers who argue that machine size limits based on a child's age are misguided.
Rather than alter the voluntary federal policy, the Specialty Vehicle Institute of America, the main lobbyist group for ATV manufacturers and distributors, is proposing model legislation for states.
The proposal recommends that children younger than 6 may operate off-road vehicles with engines that are 70 cc and smaller. Riders age 12-15 may operate vehicles with engines 70-90 cc, and riders age 16 and older may operate vehicles with engines 90 cc and larger.
States would be responsible for ensuring that sellers and buyers adhere to the policy, said Michael Mount, a Specialty Vehicle Institute spokesman.
"The key to this whole issue is parental responsibility," Mount added. "You may have a 6-year-old who's fine to ride and a 12-year-old who's not -- parents need to make that call."
But the Consumer Federation's Weintraub said a mandatory federal law is necessary to ensure safer rides in all states.
"If we just rest all responsibility on parents, nothing is going to change," Weintraub added. 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Removing the Restrainer
THE past month has been one of palpable sorrow as the Lord continues to warn that there is So Little Time Left. The times are sorrowful because mankind is about to reap what God has begged us not to sow. It is sorrowful because many souls do not realize that they are on the precipice of eternal separation from Him. It is sorrowful because the hour of the Church’s own passion has come when a Judas will rise up against her. [1]cf. The Seven Year Trial-Part VI It is sorrowful because Jesus is not only being neglected and forgotten throughout the world, but abused and mocked once again. Hence, the Time of times has come when all lawlessness will, and is, breaking forth across the globe.
Before I go on, ponder for a moment the truth-filled words of a saint:
Do not fear what may happen tomorrow. The same loving Father who cares for you today will care for you tomorrow and everyday. Either he will shield you from suffering or He will give you unfailing strength to bear it. Be at peace then and put aside all anxious thoughts and imaginings. —St. Francis de Sales, 17th century bishop
Indeed, this blog is not here to scare or frighten, but to confirm and prepare you so that, like the five wise virgins, the light of your faith will not be snuffed out, but glow ever brighter when the light of God in the world is fully dimmed, and darkness fully unrestrained. [2]cf. Matt 25:1-13
Therefore, stay awake, for you know neither the day nor the hour. (Matt 25:13)
THE RESTRAINER…
In 2005, I wrote in The Restrainer (under the urging of a Canadian bishop) how I was driving alone in British Columbia, Canada, making my way to my next concert, enjoying the scenery, drifting in thought, when suddenly I heard within my heart the words:
I have lifted the restrainer.
I felt something in my spirit that is hard to explain. It was as if a shock wave traversed the earth—as if something in the spiritual realm had been released.
That night in my motel room, I asked the Lord if what I heard was in the Scriptures, since the word “restrainer” was unfamiliar to me. I grabbed my Bible which opened straight to 2 Thessalonians 2:3. I began to read:
…[do not be] shaken out of your minds suddenly, or… alarmed either by a “spirit,” or by an oral statement, or by a letter allegedly from us to the effect that the day of the Lord is at hand. Let no one deceive you in any way. For unless the apostasy comes first and the lawless one is revealed…
That is, the “apostasy” (rebellion) and “the lawless one” (Antichrist) essentially usher in “the day of the Lord,” says St. Paul, a day of both vindication and justice [3]cf. The Vindication of Wisdom (the Day of the Lord being, not a 24 hour period, but what could rightly be called the final era before the end of the world. See Two More Days). How can one not recall at this point the startling words of the popes in this regard?
Apostasy, the loss of the faith, is spreading throughout the world and into the highest levels within the Church. —POPE PAUL VI, Address on the Sixtieth Anniversary of the Fatima Apparitions, October 13, 1977
In fact, Pope Pius X—in an encyclical, no less—suggested that both the apostasy and the Antichrist may already be present:
Who can fail to see that society is at the present time, more than in any past age, suffering from a terrible and deep-rooted malady which, developing every day and eating into its inmost being, is dragging it to destruction? You understand, Venerable Brethren, what this disease is—apostasy from God… When all this is considered there is good reason to fear lest this great perversity may be as it were a foretaste, and perhaps the beginning of those evils which are reserved for the last days; and that there may be already in the world the “Son of Perdition” of whom the Apostle speaks. —E Supremi, Encyclical On the Restoration of All Things in Christ, n. 3, 5; October 4th, 1903
But there is something “restraining” the appearance of this Antichrist. For, with my jaw wide open that night, I went on to read:
And you know what is restraining him now so that he may be revealed in his time. For the mystery of lawlessness is already at work; only he who now restrains it will do so until he is out of the way. And then the lawless one will be revealed…
Now, this April 2012 [March 2014], I hear new words which I have pondered for weeks, spoken about several times with my spiritual director, and which I write now in obedience: that the Lord is going to remove the restrainer altogether.
WHAT IS THE RESTRAINER?
Theologians are divided about the meaning of these mysterious words of St. Paul. “What” is it that restrains? And who is “he who now restrains?“ The Early Church Fathers often held that the restrainer was the Roman Empire, based on Daniel 7:24:
Out of this kingdom ten kings shall arise, and another shall arise after them; he shall be different from the former ones, and shall put down three kings. (Dan 7:24)
Now this restraining power [is] generally admitted to be the Roman empire… I do not grant that the Roman empire is gone. Far from it: the Roman empire remains even to this day. —Blessed Cardinal John Henry Newman (1801-1890), Advent Sermons on Antichrist, Sermon I
And yet, St. Paul also refers to “he who restrains,” as in a person or possibly angelic entity. From the Navarre biblical commentary:
Although it is not altogether clear what St. Paul means here (commentators ancient and modern have offered all kinds of interpretations), the general thrust of his remarks seems clear enough: he is exhorting people to persevere in doing good, because that is the best way to avoid doing evil (evil being the “mystery of lawlessness”). However, it is difficult to say precisely what this mystery of lawlessness consists in or who is restraining it.
Some commentators think that the mystery of lawlessness is the activity of the man of lawlessness, which is being restrained by the rigid laws enforced by the Roman Empire. Others suggest that St. Michael is the one who is holding lawlessness back (cf. Rev 12:1; Rev 12:7-9; 20:1-3, 7)… which show him combating Satan, restraining him or letting him free… others think that the curb on the man of lawlessness is the active presence of Christians in the world, who through word and example bring Christ’s teaching and grace to many. If Christians let their zeal grow cold (this interpretation says), then the curb on evil will cease to apply and the rebellion will ensue. —The Navarre Bible commentary on 2 Thess 2:6-7, Thessalonians and Pastoral Epistles, p. 69-70
The original Roman Empire collapsed, though not completely some historians argue, essentially because of political and moral corruption. Speaking to the Roman Curia, Pope Benedict XVI said:
The disintegration of the key principles of law and of the fundamental moral attitudes underpinning them burst open the dams which until that time had protected peaceful coexistence among peoples. The sun was setting over an entire world. Frequent natural disasters further increased this sense of insecurity. There was no power in sight that could put a stop to this decline. All the more insistent, then, was the invocation of the power of God: the plea that he might come and protect his people from all these threats. —POPE BENEDICT XVI, Address to the Roman Curia, December 20th, 2010
I believe few realize the prophetic thrust of Pope Benedict’s words that were carefully chosen on the eve of the winter solstice—the darkest day of the year in the northern hemisphere. [4]cf. On the Eve He was comparing the decline of Rome with our generation. He was underlining how “the key principles of law and of the fundamental moral attitudes underpinning” our society, are beginning to collapse:
…our world is at the same time troubled by the sense that moral consensus is collapsing, consensus without which juridical and political structures cannot function… Only if there is such a consensus on the essentials can constitutions and law function. This fundamental consensus derived from the Christian heritage is at risk… In reality, this makes reason blind to what is essential. To resist this eclipse of reason and to preserve its capacity for seeing the essential, for seeing God and man, for seeing what is good and what is true, is the common interest that must unite all people of good will. The very future of the world is at stake. —Ibid.
Essentially, the world is on the brink of lawlessness. Now, this does not necessarily mean to be without laws, but rather to embrace, codify, and promote falsehoods as though they were truths. For to abandon objective truth, which under-girds the principles of just law, is to allow the whole structure to collapse.
Therefore, God handed them over to impurity through the lusts of their hearts for the mutual degradation of their bodies. They exchanged the truth of God for a lie and revered and worshiped the creature rather than the creator, who is blessed forever. (Rom 1:24-25)
The voice of truth that restrains men from their passions by calling them to repentance and back to the right path, has been entrusted to the Church…
THE CHURCH RESTRAINS
Jesus promised the Apostles “when he comes, the Spirit of truth, he will guide you to all truth.” [5]cf. John 16:13 But they were not to hide this truth beneath a bushel basket; rather, they were commissioned to:
Go, therefore, and make disciples of all nations… teaching them to observe all that I have commanded you. (Matt 28:19-20)
…sinful man needs grace and revelation so moral and religious truths may be known “by everyone with facility, with firm certainty and with no admixture of error.” The natural law provides revealed law and grace with a foundation prepared by God and in accordance with the work of the Spirit. —Catechism of the Catholic Church, n. 1960
With the French Revolution, [6]1789-99 A.D. the division between Church and state became systematized and human rights began to be defined, no longer by the natural and moral law, but by the state. Henceforth, the Church’s moral authority has continually been eroded, such that today:
…the Christian faith is no longer allowed to express itself visibly… in the name of tolerance, tolerance is being abolished. —POPE BENEDICT XVI, Light of the World, A Conversation with Peter Seewald, p. 52-53
The illusive concept of “tolerance“, [7]eg. http://radio.foxnews.com/ while creating an illusion of “freedom”, has led to the rejection of inspired truth thus leading mankind to a new kind of slavery:
The Church invites political authorities to measure their judgments and decisions against this inspired truth about God and man: Societies not recognizing this vision or rejecting it in the name of their independence from God are brought to seek their criteria and goal in themselves or to borrow them from some ideology. Since they do not admit that one can defend an objective criterion of good and evil, they arrogate to themselves an explicit or implicit totalitarian power over man and his destiny, as history shows. —POPE JOHN PAUL II, Centesimus annus, n. 45, 46
With tragic consequences, a long historical process is reaching a turning-point. The process which once led to discovering the idea o f “human rights”—rights inherent in every person and prior to any Constitution and State legislation—is today marked by a surprising contradiction… the very right to life is being denied or trampled upon… the original and inalienable right to life is questioned or denied on the basis of a parliamentary vote or the will of one part of the people—even if it is the majority. This is the sinister result of a relativism which reigns unopposed: the “right” ceases to be such, because it is no longer firmly founded on the inviolable dignity of the person, but is made subject to the will of the stronger part. In this way democracy, contradicting its own principles, effectively moves towards a form of totalitarianism. —POPE JOHN PAUL II, Evangelium Vitae, “The Gospel of Life”, n. 18, 20
A totalitarianism that is now global in nature, thanks to the phenomenon of globalization. Add to this the repeated calls for a global currency and a “new world order”, [8]cf. The Writing on the Wall as the world economy as we know it continues to disintegrate. [9]cf. The Collapse of Babylon But it is not merely an economic or political dictatorship forming, but a religious one controlled by “those with the power to “create” opinion and impose it on others.” [10]POPE JOHN PAUL II, Cherry Creek State Park Homily, Denver, Colorado, 1993
…an abstract, negative religion is being made into a tyrannical standard that everyone must follow. —POPE BENEDICT XVI, Light of the World, A Conversation with Peter Seewald, p. 52
A new world order in itself is not necessarily evil; but if truth is rejected—and the Church who proclaims it—it will ultimately lead to the acceptance of the one whom Jesus calls a “liar and the father of lies”. [11]cf. John 8:44 For…
…without the guidance of charity in truth, this global force could cause unprecedented damage and create new divisions within the human family… humanity runs new risks of enslavement and manipulation… —Caritas in Veritate, n.33, 26
…enslavement to the one whom “the manipulator” gives his power to: a Judas, [12]cf. John 13:27 the lawless one, the “son of perdition”, the Antichrist or beast:
To it the dragon gave its own power and throne, along with great authority. (Rev 13:2)
He comes to power when that which is “restraining” him is removed.
THE ROCK AND THE RESTRAINER
When still a cardinal, Pope Benedict XVI wrote:
Abraham, the father of faith, is by his faith the rock that holds back chaos, the onrushing primordial flood of destruction, and thus sustains creation. Simon, the first to confess Jesus as the Christ… now becomes by virtue of his Abrahamic faith, which is renewed in Christ, the rock that stands against the impure tide of unbelief and its destruction of man. —POPE BENEDICT XVI (Cardinal Ratzinger), Called to Communion, Understanding the Church Today, Adrian Walker, Tr., p. 55-56
The Pope, Simon Peter’s successor, by virtue of his divine office as “rock” and custodian of the “keys of the kingdom”, [13]cf. Matt 16:18-19 holds back the “mystery of lawlessness” in its fullness. The Pope, however, is not alone; there are “living stones” [14]cf. 1 Pet 2:5 built with him upon the foundation who is Christ, the cornerstone, [15]cf. 1 Cor 3:11 who leads the whole Church into all truth through His Spirit.
The whole body of the faithful… cannot err in matters of belief. This characteristic is shown in the supernatural appreciation of faith (sensus fidei) on the part of the whole people, when, from the bishops to the last of the faithful, they manifest a universal consent in matters of faith and morals. —Catechism of the Catholic Church, n. 92
Thus, the entire body of Christ shares in the Petrine ministry insofar as they remain in communion with him. So then, is that which restrains unbridled lawlessness—indeed, the Antichrist—the moral witness and voice of the Church, in communion with the Holy Father?
The Church is always called upon to do what God asked of Abraham, which is to see to it that there are enough righteous men to repress evil and destruction. —POPE BENEDICT XVI, Light of the World, A Conversation with Peter Seewald, p. 166
When Christians cease to shine [16]cf. A Sliver of His Light, or when that light has been dulled by sin and corruption, that authoritative “voice” loses its moral force and credence. Then the future is determined no longer by absolutes, but by what Pope Benedict calls “a dictatorship of relativism”….
…which leaves as the ultimate measure only one’s ego and desires… —Cardinal Ratzinger (POPE BENEDICT XVI) pre-conclave Homily, April 18th, 2005
We can better understand, then, why now, at this hour, the restrainer is being removed, particularly in light of the widespread sexual scandals in the priesthood. Regarding these sins, Pope Benedict has not been vague:
As a result, the faith as such becomes unbelievable, and the Church can no longer present herself credibly as the herald of the Lord. —POPE BENEDICT XVI, Light of the World, A Conversation with Peter Seewald, p. 25
Even St. Michael the Archangel, as protector of the Church, is himself bound by the free will of its members if they so choose to slide into apostasy.
What of the Roman Empire? Western civilization is built in part upon principles of the Roman Empire, particularly the Judaeo-Christian principles that it adopted. Under Emperor Constantine, Rome became Christian and from there, Catholicism spread throughout Europe and beyond. The collapse of the Roman Empire, hence, could be understood, in part, as the collapse of those Christian morals that supported it.
This revolt [apostasy], or falling off, is generally understood, by the ancient fathers, of a revolt from the Roman empire, which was first to be destroyed, before the coming of Antichrist. It may, perhaps, be understood also of a revolt of many nations from the Catholic Church which has, in part, happened already, by the means of Mahomet, Luther, etc. and it may be supposed, will be more general in the days of the Antichrist. —footnote on 2 Thess 2:3, Douay-Rheims Holy Bible, Baronius Press Limited, 2003; p. 235
Today, the Roman Empire is believed to subsist in some form through the European Union, which embraced the Treaty of Rome in forming its economic union. America, I might add, finds its roots in the European people, and through a nearly constant history of war, has built an empire of sorts throughout the Middle East and beyond. Others believe the Roman Empire has yet to rise in its final form before it falls for good. The point, however, is this: Western civilization is in a collapse, says Pope Benedict.
God is disappearing from the human horizon, and, with the dimming of the light which comes from God, humanity is losing its bearings, with increasingly evident destructive effects. —Letter of His Holiness Pope Benedict XVI to All the Bishops of the World, March 10, 2009; Catholic Online
The dam of lawlessness is about to burst open upon a world whose future, he warned, “is at stake.”
WHAT WOULD HE SAY?
If Pope Pius X were alive today… walking through our malls on Sunday, noting our empty and closed churches, [17]nb. there are places, such as in Africa and parts of India where the Church is thriving; I am speaking here of the Western world that, for the most part, dominates the political and economic future of the world, for better or worse… watching a sampling of evening sitcoms and Hollywood movies, spending a day browsing the internet, listening to our radio shock jocks, watching pagan parades, comparing plump North Americans to starving Africans, and counting the number of unborn who are decimated in the womb by the thousands each and every day… I am almost certain we would hear him shouting… [18]cf. Why Aren’t the Popes Shouting?
…there may be already in the world the “Son of Perdition” of whom the Apostle speaks. —E Supremi, Encyclical On the Restoration of All Things in Christ, n. 5; October 4th, 1903
In our rationalism, and in the face of the rising power of dictatorships, God shows us the humility of the Mother, who appears to little children and speaks to them of the essentials: faith, hope, love, penance. —POPE BENEDICT XVI, Light of the World, A Conversation with Peter Seewald, p. 164
In the end, my Immaculate Heart will triumph. The Holy Father will consecrate Russia to me, and she shall be converted, and a period of peace will be granted to the world. —Our Lady of Fatima to the three children of Portugal; Message of Fatima, www.vatican.va
First published April 27th, 2012.
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Does the Antichrist come before or after the “era of peace”… or both? Read The Last Two Eclipses and On Heresies and More Questions
Dream of the Lawless One
Like a Thief
The Coming Refuges and Solitudes
Global Revolution!
Quest for Freedom
The Great Revolution
The Seven Seals of Revolution
Living the Book of Revelation
Understanding the Final Confrontation
The Great Vacuum
A Short Story of the Anti-Christ by Vladimir Solovëv
The end of Antichrist and beginning of a new era: The End of the Age
The Popes, and the Dawning Era
Watch: The Big Picture & The Big Picture – Part II
Watch: We Were Warned
Watch: The Prophecy at Rome series
cf. The Seven Year Trial-Part VI
cf. Matt 25:1-13
cf. The Vindication of Wisdom
cf. On the Eve
cf. John 16:13
1789-99 A.D.
eg. http://radio.foxnews.com/
cf. The Writing on the Wall
cf. The Collapse of Babylon
POPE JOHN PAUL II, Cherry Creek State Park Homily, Denver, Colorado, 1993
cf. John 8:44
cf. Matt 16:18-19
cf. 1 Pet 2:5
cf. 1 Cor 3:11
cf. A Sliver of His Light
nb. there are places, such as in Africa and parts of India where the Church is thriving; I am speaking here of the Western world that, for the most part, dominates the political and economic future of the world, for better or worse…
cf. Why Aren’t the Popes Shouting?
Spread The Now Word!
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← Be Merciful
Who Am I to Judge? → | 2023-14/0000/en_head.json.gz/1397 | {"url": "https://www.markmallett.com/blog/removing-the-restrainer/", "partition": "head_middle", "language": "en", "source_domain": "www.markmallett.com", "date_download": "2023-03-20T09:19:28Z", "digest": "sha1:5IZCI5RUTB6QUEEBLYJ6VPRNIJL5UR52"} | {"ccnet_length": [[0, 21445, 21445.0]], "ccnet_original_length": [[0, 21445, 27514.0]], "ccnet_nlines": [[0, 21445, 113.0]], "ccnet_original_nlines": [[0, 21445, 302.0]], "ccnet_language_score": [[0, 21445, 0.95]], "ccnet_perplexity": [[0, 21445, 284.7]], "ccnet_bucket": [[0, 21445, 0.0]], "rps_doc_curly_bracket": [[0, 21445, 0.0]], "rps_doc_ldnoobw_words": [[0, 21445, 1.0]], "rps_doc_lorem_ipsum": [[0, 21445, 0.0]], "rps_doc_stop_word_fraction": [[0, 21445, 0.39196311]], "rps_doc_ut1_blacklist": [[0, 21445, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 21445, 0.065178]], "rps_doc_frac_chars_dupe_5grams": [[0, 21445, 0.08318232]], "rps_doc_frac_chars_dupe_6grams": [[0, 21445, 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Search Results: Brain
Refined Results
Type All Post Investigator Page
Visualizing the Mind: How We See the Brain Through Functional MRI
Last year, Harvard College senior Kelsey Ichikawa (shown in the photo above) interviewed the Martinos Center’s Bruce Rosen and Bruce Fischl for a general audience article about functional MRI, which she was writing for a science journalism course. Earlier this year, the article won the Harvard Bo...
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Risk, Resiliency in Aging Brain Focus of $33 Million Grant
A large study that investigates just what keeps our brains sharp as we age and what contributes to cognitive decline has been launched by Martinos Center researchers in collaboration with colleagues from Washington University School of Medicine in St. Louis, the University of Minnesota Medical Sc...
Uncovering ‘Covert Consciousness’ in Brain Injury Patients
In a paper published in the journal Brain last month Brian Edlow and colleagues reported a study in which they used the imaging techniques functional MRI and EEG to detect ‘covert consciousness’ in the intensive care unit. We checked in with Edlow, associate director of the Center for Neurotechno...
Nutrition and Brain Growth in the Developing World
The aging pickup truck bounces along a dirt road somewhere outside Bissora, one of the larger towns in the Oio region of the West African nation of Guinea-Bissau. The road, a major thoroughfare in the region, is pocked with holes. The rest of the year these would be deep and dusty. But it’s July ...
Publications Updates
May 11, 2020 The presubiculum links incipient amyloid and tau pathology to memory function in older persons Jacobs HIL, Augustinack JC, Schultz AP, Hanseeuw BJ, Locascio J, Amariglio RE, Papp KV, Rentz DM, Sperling RA, Johnson KA. Neurology. 2020 May 5;94(18):e1916-e1928. doi: 10.1212/WNL.00...
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20 Years of FreeSurfer
It’s a sunny day in Southern California and the developers of FreeSurfer—a suite of software tools for the analysis of neuroimaging data—are preparing for a training session to introduce scientists to the many benefits of the package. To help the scientists find the classroom they have hung “Free...
Ken Kwong and the Introduction of Noninvasive fMRI
In the early months of 1992 the neuroscience community was flush with excitement. Jack Belliveau, a graduate student with the MGH-NMR Center (now the MGH Martinos Center for Biomedical Imaging), had recently published in Science his pioneering work with functional MRI, and the possibilities of th...
Machine Learning Model Identified Alzheimer’s Disease-Like Structural Brain Patterns in Younger, Asymptomatic Adults
Human Whole-Brain Diffusion MRI Dataset Available Online
Reported by Fuyixue Wang and colleagues, it is the first publicly available reference dataset acquired in vivo at submillimeter resolution.
Are Pandemic-Related Stressors Impacting Uninfected People’s Brain Health?
Early Details of Brain Damage in COVID-19 Patients
Acupuncture Yields Improved Outcomes in Carpal Tunnel Syndrome
Though the practice of acupuncture predates current understanding of physiology by several millennia, it often provides measureable improvements in health outcomes, particularly in the area of chronic pain. Now, in a study reported in the journal Brain, a team of investigators based at the Athino...
Kenneth Kwong
Kenneth Kwong, PhD, has been conducting magnetic resonance imaging (MRI) research for more than 30 years with expertise in diffusion (R.1), functional imaging (R.2) and perfusion imaging (R.3). He was one of the earliest researchers to explore MR diffusion imaging of healthy subjects and patients...
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Tommi Raij
Dr. Raij is a researcher currently serving as the Director of Transcranial Magnetic Stimulation (TMS) Clinical Research at the Martinos Center. He aims to understand the human brain mechanisms and improve the treatment of psychiatric and neurological disease, such as depression, schizophrenia, co...
The Road to MPI
Functional MRI has proved a transformative technology, yielding previously unimaginable insights into the workings of the brain. But what if there were another approach, one with dramatically higher sensitivity, that could shed even more light on these mysteries? What might we learn then? Larry ...
BrainMap
The BrainMap seminar series is offered by and for researchers using neuroimaging to study brain structure and function. Presented by invited speakers from around the world, as well as by investigators who call the Martinos Center home, the talks cover the gamut of topics - with a particular focus...
A New Role for Diffusion MRI in Treating Anxiety and Depression
Anxiety disorders and depression are widespread among adolescents in the U.S., affecting as many as one in four 13 to 18 year olds. Determining the best course of treatment can be difficult, though, as we still don’t fully understand the biology underlying them. Now, using cutting-edge brain i...
Susie Huang
Susie Huang, MD, PhD, is a board-certified neuroradiologist and physician-scientist specializing in the development and translation of novel MRI techniques for investigating structure, function and pathology within the brain. Her doctoral training in physical chemistry and subsequent residency in...
Optics Technologies Could Advance Neuromonitoring During Heart Surgery
A team of researchers at the MGH Martinos Center for Biomedical Imaging has reported an innovative light-based technique that could help reduce the incidence of neurological injury during aortic arch replacement and other cardiac surgeries. Deep hypothermic circulatory arrest (DHCA) is a techn...
Magnetoencephalography Aids Diagnosis and Treatment of Epilepsy, Other Disorders
Originally used only for research purposes, magnetoencephalography (MEG) has been introduced into clinical care in recent decades. 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Pragmatism and Judaism
In an article entitled “Word of the Year” (www.FloridaJewishJournal.com, January 12, 2012, page 34), Rabbi Yaakov Thompson talked about the word “pragmatism” (which Merriam-Webster announced was the “word of the year”–most looked up word– for 2011) and Judaism.
While noting that pragmatism is very apropos to American thinking in general, and to 2011 in particular because of the economic difficulties facing us then, he went on to say:
“It is, however, a word that bothers me as a Jew. Being pragmatic is a great way to approach some things but it is a terrible way to address some aspects of life. While Jews have shown they can be very pragmatic–making the best decisions possible in the most impossible of situations–we are the least pragmatic people in the world. Has there ever been anything about Jewish existence that was pragmatic? Face it, we are a nation of dreamers and we always will be. That has been the key to our role in the human drama. The first Jew in the world, Abraham, did not understand being pragmatic–he believed in a God you couldn’t see, he left his homeland and went on a journey without knowing where he was going, and finally came to a new land that God promised to the children that he did not yet have.
“As a people we have witnessed the worst that humanity could create and yet we affirm our belief in the goodness of man. We have wandered from place to place but still believed in a homeland to which we would return. We have seen how much hatred can come into the world but we have never stopped believing in the power of love. With a resume like that we can hardly be called pragmatic. Pragmatism would have demanded that we abandon our beliefs and values but instead we have tried to reshape the world around them.
“2011 was a year in which we learned to be pragmatic about many things but not everything. In 2012 keep dreaming big and believe in the least pragmatic premises of all time–the God of Israel, the land of Israel and the people of Israel. | 2023-14/0000/en_head.json.gz/1399 | {"url": "https://www.martinvesole.com/pragmatism-and-judaism.html", "partition": "head_middle", "language": "en", "source_domain": "www.martinvesole.com", "date_download": "2023-03-20T10:33:56Z", "digest": "sha1:OMRGVLLMWXDNJQOQLNYTVPFXDDFJUB7V"} | {"ccnet_length": [[0, 2013, 2013.0]], "ccnet_original_length": [[0, 2013, 3172.0]], "ccnet_nlines": [[0, 2013, 6.0]], "ccnet_original_nlines": [[0, 2013, 45.0]], "ccnet_language_score": [[0, 2013, 0.97]], "ccnet_perplexity": [[0, 2013, 231.3]], "ccnet_bucket": [[0, 2013, 0.0]], "rps_doc_curly_bracket": [[0, 2013, 0.0]], "rps_doc_ldnoobw_words": [[0, 2013, 0.0]], "rps_doc_lorem_ipsum": [[0, 2013, 0.0]], "rps_doc_stop_word_fraction": [[0, 2013, 0.52857143]], "rps_doc_ut1_blacklist": [[0, 2013, null]], "rps_doc_frac_chars_dupe_10grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_dupe_5grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_dupe_6grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_dupe_7grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_dupe_8grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_dupe_9grams": [[0, 2013, 0.0]], "rps_doc_frac_chars_top_2gram": [[0, 2013, 0.02164502]], "rps_doc_frac_chars_top_3gram": [[0, 2013, 0.01236858]], "rps_doc_frac_chars_top_4gram": [[0, 2013, 0.0]], "rps_doc_frac_all_caps_words": [[0, 2013, 0.0]], "rps_doc_frac_lines_end_with_ellipsis": [[0, 2013, 0.0]], "rps_doc_frac_no_alph_words": [[0, 2013, 0.13809524]], "rps_doc_frac_unique_words": [[0, 2013, 0.52777778]], "rps_doc_mean_word_length": [[0, 2013, 4.49166667]], "rps_doc_symbol_to_word_ratio": [[0, 2013, 0.0]], "rps_doc_unigram_entropy": [[0, 2013, 4.78640548]], "rps_doc_word_count": [[0, 2013, 360.0]], "rps_lines_ending_with_terminal_punctution_mark": [[0, 23, 0.0], [23, 285, 1.0], [285, 461, 0.0], [461, 1260, 1.0], [1260, 1777, 1.0], [1777, 2013, 1.0]], "rps_lines_javascript_counts": [[0, 23, 0.0], [23, 285, 0.0], [285, 461, 0.0], [461, 1260, 0.0], [1260, 1777, 0.0], [1777, 2013, 0.0]], "rps_lines_num_words": [[0, 23, 3.0], [23, 285, 38.0], [285, 461, 30.0], [461, 1260, 149.0], [1260, 1777, 96.0], [1777, 2013, 44.0]], "rps_lines_numerical_chars_fraction": [[0, 23, 0.0], [23, 285, 0.04819277], [285, 461, 0.02325581], [461, 1260, 0.0], [1260, 1777, 0.0], [1777, 2013, 0.03433476]], "rps_lines_start_with_bulletpoint": [[0, 23, 0.0], [23, 285, 0.0], [285, 461, 0.0], [461, 1260, 0.0], [1260, 1777, 0.0], [1777, 2013, 0.0]], "rps_lines_uppercase_letter_fraction": [[0, 23, 0.08695652], [23, 285, 0.04961832], [285, 461, 0.01136364], [461, 1260, 0.0175219], [1260, 1777, 0.00967118], [1777, 2013, 0.02118644]], "rps_doc_ml_palm_score": [[0, 2013, 0.80694842]], "rps_doc_ml_wikipedia_score": [[0, 2013, null]], "rps_doc_ml_wikiref_score": [[0, 2013, 0.34881747]], "rps_doc_books_importance": [[0, 2013, 2.25608816]], "rps_doc_openwebtext_importance": [[0, 2013, 73.96579164]], "rps_doc_wikipedia_importance": [[0, 2013, -56.3094252]], "rps_doc_num_sentences": [[0, 2013, 17.0]]} |
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