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New IRS guidance fills in several more pieces of the Code Sec. 199A passthrough deduction puzzle. Taxpayers can generally rely on all of these new final and proposed rules.
Final Regulations
The final regulations in T.D. 98xx_1 largely adopt the proposed regulations in NPRM REG-107892-18 (August 16, 2018), but with substantial modifications.
Taxpayers are likely to be disappointed in one thing that did not change: all items treated as capital gain or loss, including Section 1231 gains and losses, are still excluded from qualified business income (QBI). Taxpayers should continue to apply the Section 1231 netting and recapture rules when calculating the Code Sec. 199A deduction.
However, the final regulations drop the rule that treated an incidental non-specified services trade or business (SSTB) as part of an SSTB if the businesses were commonly owned and shared expenses, and the non-SSTB's gross receipts were no more than five percent of the business's combined gross receipts.
The final regulations make several adjustments to the proposed regulations for estates and trusts. Most significantly, the final regulations remove the definition of "principal purpose" under the anti-abuse rule that allows the IRS to aggregate multiple trusts. The IRS is taking this issue under advisement. Also, in determining if a trust or estate has taxable income that exceeds the threshold amount, distributions are no longer excluded. Instead, the entity's taxable income is determined after taking into account any distribution deduction under Code Sec. 651 or Code Sec. 661.
The final regulations retain the presumption that an employee continues to be an employee while doing the same work for the same employer. However, the regulations provide a new three-year look back rule, and allow the worker to rebut the presumption by showing records (such as contracts or partnership agreements) that corroborate the individual's status as a non-employee.
Other changes of note include:
Proposed Regs for QBI, RICs, Trusts, Estates
Taxpayers may rely on the proposed regulations in NPRM REG-134652-18, which cover three broad topics.
First, in calculating QBI, previously disallowed losses are treated as losses from a separate trade or business. If the losses relate to a publicly traded partnership (PTP), they must be treated as losses from a separate PTP. Attributes of the disallowed loss are determined in the year the loss is incurred.
Second, a RIC that receives qualified REIT dividends may pay Section 199A dividends. The IRS continues to consider permitting conduit treatment for qualified PTP income received by a RIC, and seeks public comment on this issue.
Finally, the proposed regulations also provide rules for charitable remainder unitrusts (and their beneficiaries), split-interest trusts, and separate shares.
Rental Real Estate Enterprise
The proposed revenue procedure set forth in Notice 2019-7 provides a safe harbor for a rental real estate enterprise to be treated as a trade or business for purposes of Section 199A. RPEs can also use the safe harbor.
A rental real estate enterprise must satisfy three conditions to qualify for the safe harbor:
Relevant items include hours of all services performed, description of all services performed, dates on which such services were performed, and who performed the services.
W-2 Wages
Rev. Proc. 2019-11 allows taxpayers to use one of three methods to calculate W-2 wages for the passthrough deduction:
These methods were proposed in Notice 2018-64, I.R.B. 2018-35, 347. The unmodified Box method is simplest, but the other two methods are more accurate.
Comments Requested
The IRS requests comments on the proposed regulations and the proposed safe harbor. The IRS must receive the comments and any requests for public hearing within 60 days after the proposed regulations are published in the Federal Register.
The IRS has issued interim guidance on the excise tax payable by exempt organizations on remuneration in excess of $1 million and any excess parachute payments made to certain highly compensated current and former employees in the tax year. The excise tax imposed by Code Sec. 4960 is equal to the maximum corporate tax rate on income (currently 21 percent).
Q&A on Section 4960
The current guidance is contained in a Question-and-Answer format. The interim guidance addresses:
The IRS intends to issue proposed regulations under Code Sec. 4960 which will incorporate the interim guidance. Until future guidance is issued, taxpayers may rely on the rules in the interim guidance from December 22, 2017. Any future guidance will be prospective and will not apply to tax years beginning before the guidance is issued. Until additional guidance is issued, taxpayers may base their positions upon a good faith, reasonable interpretation of the statute and legislative history, where appropriate. Specifically, the positions reflected in the guidance constitute a good faith and reasonable interpretation.
The IRS and Treasury Department request comments on the topics addressed in the interim guidance and any other issues arising under Code Sec. 4960. Comments should be submitted no later than April 2, 2019.
The IRS has provided safe harbors for business entities to deduct certain payments made to a charitable organization in exchange for a state or local tax (SALT) credit. A business entity may deduct the payments as an ordinary and necessary business expenses under Code Sec. 162 if made for a business purpose. Proposed regulations that limit the charitable contribution deduction do not affect the deduction as a business expense.
Charitable Contributions and SALT Limit
An individual's itemized deduction of SALT is limited to $10,000 ($5,000 if married filing separately). Some states and local governments have adopted or considered adopting laws that allowed individuals to receive a tax credit for contributions to funds controlled by the state and local government.
Under proposed regulations, however, an individual, estate, and trust generally must reduce the amount of any charitable contribution deduction by the amount of any SALT credit he or she receives or expects to receive for the transfer. A de minimis exception allows a taxpayer to disregard up to 15 percent of the payment or transfer to the charitable organization.
C Corporations
If a C corporation makes the charitable payment in exchange for a state and local tax credit, it may deduct the payment as an ordinary and necessary business expense to the extent of any SALT credit received or expected to receive.
Specified Pass-Through Entity
A specified pass-through entity may also deduct the payment as an ordinary and necessary business expense, but only if the SALT credit applies or is expected to apply to offset a SALT other than an income tax. A specified pass-through entity for this purpose is any business entity other than a C corporation that is regarded as separate from its owner for all federal income tax purposes (i.e., disregarded entity). The entity also must operate a trade or business within the meaning of Code Sec. 162 and be subject to SALT incurred in carrying on that trade or business that is imposed directly on the entity.
Effective Date
The safe harbors apply to any payments made to a charitable organization in exchange for a SALT credit paid on or after January 1, 2018.
The Treasury and IRS have issued final regulations for determining the inclusion under Code Sec. 965 of a U.S. shareholder of a foreign corporation with post-1986 accumulated deferred foreign income. Code Sec. 965 imposes a "transition tax" on the inclusion. The final regulations retain the basic approach and structure of the proposed regulations, with certain changes.
The final regulations generally apply beginning the last tax year of the foreign corporation that begins before January 1, 2018, and with respect to a U.S. person, beginning the tax year in or with which such tax year of the foreign corporation ends.
Note: The final regulations were published without a T.D. number. According to the IRS, a T.D. number will be assigned after the IRS resumes normal operations.
Controlled Domestic Partnerships
Certain controlled domestic partnerships may be treated as foreign partnerships for determining the section 958(a) U.S. shareholders of a specified foreign corporation owned by the controlled domestic partnership and the section 958(a) stock owned by the shareholders. The definition of controlled domestic partnership is revised to not be defined only with respect to a U.S. shareholder, so that the controlled foreign partnership is clearly treated as a foreign partnership for all partners if the rule applies.
Pro Rata Share
The definitions of pro rata share and section 958(a) U.S. shareholder inclusion year are modified. The final regulations will require a section 965(a)inclusion by a section 958(a) U.S. shareholder if the specified foreign corporation, whether or not it is a CFC, ceases to be a specified foreign corporation during its inclusion year.
Downward Attribution Rule
A special rule applies when determining downward attribution from a partner to a partnership where the partner has a de minimis interest in the partnership. The threshold for applying the special attribution rule for partnerships is increased from five to 10 percent, and is extended to trusts.
Basis Election Rules
The final regulations allow a taxpayer elect to increase its basis in the stock of its deferred foreign income corporations (DFICs) by the lesser of its section 965(b) previously taxed earnings and profits or the amount it can reduce the stock basis of its E&P deficit foreign corporations without recognizing gain. Within limits, a taxpayer may designate which stock of a DFIC is increased and by how much.
Exception from Anti-Abuse Rules
The final regulations provide an exception from the anti-abuse rules for certain incorporation transactions. The rules will not apply to disregard a transfer of stock of a specified foreign corporation by U.S. shareholder of a domestic corporation, if certain requirements are met. The section 965(a) inclusion amount with respect to the transferred stock of the specified foreign corporation must not be reduced, and the aggregate foreign cash position of both the transferor and the transferee is determined as if each had held the transferred stock of the specified foreign corporation owned by the other on each of the cash measurement dates.
Cash Position
Code Sec. 965 taxes foreign earnings of a domestic corporate U.S. shareholder at a 15.5-percent rate if held in cash, but only an 8-percent rate if held otherwise. Cash includes cash and cash equivalents. The final regulations provide a narrow exception from the definition of cash position for certain commodities held by a specified foreign corporation in the ordinary course of its trade or business, as well as for certain privately negotiated contracts to buy and sell these assets.
Election and Payment Rules
Under the final regulations, the signature requirement on an election statement is satisfied if the unsigned copy is attached to a timely-filed return of the person making the election, provided that the person retains the signed original in the manner specified.
Transition rules for filing transfer agreements have also been updated. If a triggering event or acceleration event occurs on or before December 31, 2018, the transfer agreement must be filed by January 31, 2019. Rules are added to address the death of an S corporation shareholder transferor. The final regulations also include modifications to certain requirements for the terms of a transfer agreement.
The final regulations provide that in the case of an additional liability reported on a return or amended return, any amount that is prorated to an installment, the due date of which has already passed, will be due with the return reporting the additional amount. The rule on deficiencies remains the same, and payment for a deficiency prorated to an installment, the due date of which has already passed, is due on notice and demand.
Total Net Tax Liability
A taxpayer may elect to defer the payment of its total net tax liability under Code Sec. 965(h) and (i). Total net tax liability under Code Sec. 965, which defines the portion of a taxpayer's income tax eligible for deferral, is equal to the difference between a taxpayer's net income tax with and without the application of Code Sec. 965. The final regulations will disregard effective repatriations taxed similarly to dividends under Code Sec. 951(a)(1)(B) resulting from investments in U.S. property under Code Sec. 956 when determining net income tax liability without the application of Code Sec. 965.
Consolidated Groups
The consolidated group aggregate foreign cash position is determined under the final regulations as if all members of the consolidated group that are section 958(a) U.S. shareholders of a specified foreign corporation are a single section 958(a) U.S. shareholder.
Obsolete Guidance
The following previous guidance is obsolete:
The IRS has issued its annual revisions to the general procedures for ruling requests, technical memoranda, determination letters, and user fees, as well as areas on which the Associate Chief Counsel offices will not rule. The revised procedures are generally effective January 2, 2019.
Rev. Proc. 2019-1
This procedure explains how the IRS provides advice to taxpayers in the form of letter rulings, closing agreements, determination letters and information letters, and orally on issues under the jurisdiction of the various Associate Chief Counsel offices. It supersedes Rev. Proc. 2018-1, I.R.B. 2018-1, 1. In addition to changes made throughout the guidance, significant changes in the new procedure include:
Rev. Proc. 2019-2
This procedure explains when and how an Associate Office provides technical advice conveyed in a technical advice memorandum (TAM), as well as a taxpayer's rights when a field office requests a TAM regarding a tax matter. It supersedes Rev. Proc. 2018-2, I.R.B. 2018-1, 106. Significant changes in the new procedure include:
Rev. Proc. 2019-3
This procedure provides a revised list of areas under the jurisdiction of certain Associate Chief Counsel offices for which letter rulings or determination letters will not be issued. (Lists of areas of nonissuance under the jurisdiction of the Associate Chief Counsel (International) and the Commissioner, Tax Exempt and Government Entities Division (relating to plans or plan amendments) are presented in separate revenue procedures.) It supersedes Rev. Proc. 2018-3, I.R.B. 2019-1, 130.
The following have been added to the list of issues for which advance rulings will not be issued:
The following issues have been modified:
Rev. Proc. 2019-4
This procedure explains how the IRS provides advice to taxpayers on issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division (TE/GE) Employee Plans Rulings and Agreements Office, and details the types of advice available to taxpayers, and the manner in which the advice is requested and provided. The new procedure supersedes Rev. Proc. 2018-4, I.R.B. 2018-1, 146. In addition to minor non-substantive changes, the following changes are made:
Rev. Proc. 2019-5
This procedure updates the procedures for organizations applying for, and the issuing of determination letters on, exempt status under Code Secs. 501and 521. These apply to exempt organizations other than those relating to pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans. The procedures also apply to revocation or modification of determination letters. In addition, the procedure provides guidance on the exhaustion of administrative remedies for declaratory judgment under Code Sec. 7428. Finally, new procedure provides guidance on applicable user fees for requesting determination letters. The new procedure supersedes Rev. Proc. 2018-5, I.R.B. 2018-1, 233. Notable changes include:
Rev. Proc. 2019-7
This procedure provides an updated list of subject areas under the jurisdiction of the Associate Chief Counsel (International) for which it will not issue advance letter rulings or determination letters, or will issue letters only if justified by unique and compelling circumstances. Section 4.01(01) related to Code Sec. 367(a) has been removed as obsolete. There are no other changes except renumbering to reflect the foregoing and updates to cross references and citations. The new procedure supersedes Rev. Proc. 2018-7, I.R.B. 2018-1, 271
Shortly after resuming operations post-government shutdown, the IRS told taxpayers that the start of the 2014 filing season will be delayed by one to two weeks. The delay will largely impact taxpayers who want to file their 2013 returns early in the filing season. At the same time, the White House clarified on social media that no penalty under the Affordable Care Act's (ACA) individual mandate would be imposed during the enrollment period for obtaining coverage through an ACA Marketplace.
IRS shutdown
On October 1, many IRS employees in Washington, D.C. and nationwide were furloughed after Congress failed to approve funding for the government's fiscal year (FY 2014). During the shutdown, only 10 percent of the IRS' approximately 90,000 employees remained on the job, most engaged in criminal investigations and infrastructure support. Employees on furlough, including revenue agents assigned to exams and hearing officers assigned to collection due process cases, were expressly prohibited from doing any work, including checking email and voice messages.
Employees return to work
The IRS reopened on October 17. The previous day, Congress had passed legislation to fund the government through mid-January 2014. The IRS immediately cautioned taxpayers to expect longer wait times and limited service as it would take time for employees to resume work and process backlogged inventory. Upon their return to work, IRS employees began reviewing email, voice messages and their files as well as completing administrative tasks to reopen operations. The IRS reported that it received 400,000 pieces of correspondence during the furlough period in addition to nearly one million items already being processed before the shutdown.
Returns and refunds
The 16-day furlough overlapped with the October 15 deadline for taxpayers on extension to file 2012 returns. The IRS reported that during the shutdown it continued as many automated processes as possible, including accepting returns and processing payments. The Free File system also was open during the furlough period. However, refunds were not issued while the IRS was closed. Refunds are now being processed. If you have any questions about a refund or payment, please contact our office.
Filing season
The start of the 2014 filing season will be delayed approximately one to two weeks so the IRS can program and test tax processing systems following the 16-day federal government closure. The IRS had anticipated opening the 2014 filing season on January 21. With a one- to two-week delay, the IRS would start accepting and processing 2013 individual tax returns no earlier than January 28, 2014 and no later than February 4, 2014. The IRS reported it will make a final determination on the start of the 2014 filing season in mid-December.
The IRS explained that the government shutdown took place during the peak period for preparing its return processing systems for the 2014 filing season. The IRS must program, test and deploy more than 50 systems to handle processing of nearly 150 million tax returns.
"Readying our systems to handle the tax season is an intricate, detailed process, and we must take the time to get it right," Acting Commissioner Daniel Werfel said in a statement. "The adjustment to the start of the filing season provides us the necessary time to program, test and validate our systems so that we can provide a smooth filing and refund process for the nation's taxpayers. We want the public and tax professionals to know about the delay well in advance so they can prepare for a later start of the filing season."
Affordable Care Act
Beginning January 1, 2014, the Affordable Care Act generally requires individuals - unless exempt - to carry health insurance or make a shared responsibility payment (also known as a penalty). Individuals exempt from the payment include individuals covered by most employer-sponsored health plans, Medicare, Medicaid, and other government programs. The penalty is $95 in 2014 or the flat fee of one percent of taxable income, $325 in 2015 or the flat fee of two percent of taxable income, $695 in 2016 or 2.5 percent of taxable income (the $695 amount is indexed for inflation after 2016).
The Obama administration launched individual Marketplaces (formerly known as Exchanges) on October 1 in all 50 states and the District of Columbia. The enrollment period for coverage for 2014 began on October 1 and is scheduled to end March 31, 2014, which is after the January 1 effective date of the individual mandate. In late October, the Obama administration clarified on social media that individuals who enroll in coverage through a Marketplace at anytime during the enrollment period will not be responsible for a penalty.
Because of technical problems, some applications on HealthCare.gov have not been running at 100 percent, the U.S. Department of Health and Human Services (HHS) reported. Individuals can, however, enroll and obtain insurance at in-person assistance centers. Marketplace customer call centers are also open, HHS explained.
A child with earned income above a certain level is generally required to file a separate tax return as a single taxpayer. However, a child with a certain amount of unearned income (from investments, including dividends, interest, and capital gains) may find that this income becomes subject to tax at his or her parent's highest marginal tax rate. This is referred to as the "kiddie tax," and it is designed to prevent parents from transferring income-producing investments to their children, who would generally be taxed at a lower rate.
Does the kiddie tax apply to my situation?
The kiddie tax applies if:
Computing the kiddie tax
If the kiddie tax applies to a child, the child's tax is calculated as the greater of one of two items:
The allocable parent tax is the amount of the increase in the parent's tax liability that results from adding to the parent's taxable income the net unearned income of the parent's children who are subject to the kiddie tax. If a parent has more than one child with unearned income subject to the kiddie tax, then each child's share of the allocable parental tax would be assigned pro rata according to the ratio that its net unearned income bears to the aggregate net unearned income subject to the kiddie tax.
Which tax form should I use?
A parent with a child or children whose unearned income is subject to the kiddie tax must generally complete and file Form 8615, Tax for Certain Children Who Have Investment Income of More Than $1,900, along with his or her tax return. However, if the child's interest and dividend income (including capital gain distributions) total less than $9,500 for 2013 ($10,000 for 2014), the parent may be able to elect to include that income on the parent's return rather than file a separate return for the child. In this case, the parents should complete Form 8814, Parents Election To Report Child's Interest and Dividends. However, the IRS cautions that the federal income tax owed on a child's income may be lower if the parent files a separate tax return for the child, which would enable him or her to take certain tax benefits that cannot be taken on the parents' return.
Divorced, separated, or unmarried parents
The kiddie tax is based on a parent's tax return, but what happens when parents do not file joint returns? Several special rules determine what should happen. If the parents are married, but file separate returns, then the child should use the return of the parent with the largest taxable income to figure the kiddie tax.
If the parents are married, but do not live together, and the custodial parent is considered unmarried then generally the custodial parent's return would be used. However, if the custodial parent is not considered unmarried, the child should use the return of the parent with the largest amount of taxable income.
If the child's parents are divorced or legally separated, and the custodial parent has not remarried, the child should use the custodial parent's return. If the custodial parent has remarried, the child's stepparent, rather than the noncustodial parent, is treated as the child's other parent. Similarly, if the child's parent is a widow or widower who has remarried, the new spouse is treated as the child's other parent.
If the child's parents never married each other, but lived together all year, the child should use the return of the parent with the greater taxable income. If the parents were never married and did not live together all year, the rules are the same as the rules for parents who are divorced.
Calculating the kiddie tax can become confusing as a taxpayer attempts to sort through the numerous rules governing who is subject to the tax, which income is subject to the tax, and how to report it properly. Please do not hesitate to contact our offices with any questions.
The IRS has issued much-anticipated final "repair" regulations that provide guidance on the treatment of costs to acquire, produce or improve tangible property. These regulations take effect January 1, 2014. They affect virtually any business with tangible assets. The IRS has estimated that about 4 million businesses must comply.
At a length of over 200 pages, the regulations remain complex. Taxpayers will need to devote significant time and effort to study these regulations and to address their impact on their tax accounting. Taxpayers must decide whether they can deduct costs as repairs and maintenance or must capitalize the costs and recover their costs over a period of years. Every business, especially those with significant fixed assets, must develop an understanding of the regulations and their requirements.
Effective dates, decisions and opportunities
The final regulations retain the basic structure of the temporary and proposed regulations issued in December 2011 (the 2011 regulations). The IRS is not expected to delay these effective dates, since taxpayers were informed of the impending changes in many of the rules almost two years ago. Moreover, taxpayers will have the decision of whether to apply the regulations (either the temporary or the final) to the 2012 or 2013 tax years.
The IRS must provide additional guidance for taxpayers to change their methods of accounting to elect to apply either set of regulations retroactively and to comply with the 2014 effective date. Some accounting method changes will require taxpayers to make adjustments under Code Sec. 481(a), in effect, applying the regulations to past years and calculating the impact on income.
The final regulations make significant changes that can benefit most taxpayers if applied correctly. The changes include new and revised safe harbors, as well as new relief provisions for small business. The regulations will provide simplification and reduce controversy by allowing taxpayers to follow their financial accounting ("book") policies in some areas.
The IRS did not finalize every portion of the 2011 regulations. To address some problems with the temporary regulations on the disposition of depreciable property, the IRS issued new proposed regulations that ease the requirements for taxpayers to deduct the cost of building components that they replace.
Significant provisions in the final regulations include the following:
Materials and supplies - The threshold for deducting materials and supplies was increased from $100 to $200 and generally applies to items expected to be consumed in 12 months or less, or that have an economically useful life of 12 months or less.
De minimis safe harbor - The final regulations eliminate a controversial ceiling on the use of this safe harbor. Taxpayers with applicable financial statements can apply the safe harbor to an item that is $5,000 or less. The regulations extend the safe harbor to taxpayers without a financial statement, but only for property that costs $500 or less. Taxpayers must have written book policies in place at the beginning of the year to apply the safe harbor.
Routine maintenance and improvements - The final regulations retain controversial unit of property rules that apply the rules for real property to eight separate building systems. However, the rules do extend the routine maintenance safe harbor to real property and provide a new safe harbor for small taxpayers. The safe harbor for real property limits the period for recurring maintenance to 10 years, which many practitioners believe is too short.
Capitalization election - The final regulations allow taxpayers to capitalize repair and maintenance costs if these costs are capitalized for financial accounting purposes. This provides significant simplification over the temporary regulations, although the tax impact is contrary to what taxpayers normally want.
If you have any questions regarding the compliance obligations that your business now must face, and the opportunities that many of these new rules present, please do not hesitate to call this office.
In 2014, individual taxpayers will receive some relief by way of the mandatory upward inflation-adjustments called for under the Tax Code, according to CCH, a part of Wolters Kluwer. CCH has released projected income ranges for each of the 2014 tax brackets as well as a growing number of other inflation-sensitive tax figures, such as the personal exemption and the standard deduction.
When there is an upward adjustment for inflation, the indexing of brackets can lower tax bills by including more of taxpayers' incomes in lower brackets-in the existing 15-percent rather than the existing 25-percent bracket, for example. The formula used in indexing showed relatively low inflation throughout 2013. Nevertheless, many 2014 figures therefore have increased.
In addition, tax planners will have more certainty moving into 2014. By enacting the American Taxpayer Relief Act of 2012 (ATRA) at the beginning of 2013, Congress permanently extended several of the formerly temporary provisions whose fate often hinged on end-of-the-year legislation. This ensures that in 2014 taxpayers will know for certain that the Alternative Minimum Tax exemptions and other important figures will be adjusted for inflation.
Tax Rates
The current tax rates, as enacted under ATRA, are: 10, 15, 25, 33, 35, and 39.6-percent. CCH projects that inflation during 2013 will raise the 2014 rate brackets for individuals as follows:
Joint returns. For married taxpayers filing jointly and surviving spouses, the maximum taxable income for the 10% bracket is $18,150 (up from $17,850 in 2013); for the 15% tax bracket $73,800 (up from $72,500 in 2013); for the 25% tax bracket $148,850 (up from $146,400 in 2013); for the 28% tax bracket $226,850 (up from $223,050 in 2013); for the 33% tax bracket $405,100 (up from $398,350 in 2013); and for the 35% tax bracket $457,600 (up from $450,000 in 2013). Above the 35% threshold, taxpayers will fall within the top 39.6% tax bracket.
Heads of Household. For heads of household, the maximum taxable income for the 10% bracket is $12,950 (up from $12,750 in 2013); for the 15% tax bracket $49,400 (up from $48,600 in 2013); for the 25% tax bracket $127,550 (up from $125,450 in 2013); for the 28% tax bracket $206,600 (up from $203,150 in 2013); for the 33% tax bracket $405,100 (up from $398,350 in 2013); and for the 35% tax bracket $432,200 (up from $425,000 in 2013). Above the 35% threshold, taxpayers will fall within the top 39.6% tax bracket.
Single filers. For unmarried single filers who are not heads of household or surviving spouses, the maximum taxable income for the 10% bracket is $9,075 (up from $8,925 in 2013); for the 15% tax bracket $36,900 (up from $36,250 in 2013); for the 25% tax bracket $89,350 (up from $87,850 in 2013); for the 28% tax bracket $186,350 (up from $183,250 in 2013); for the 33% tax bracket $405,100 (up from $398,350 in 2013); and for the 35% tax bracket $406,750 (up from $400,000 in 2013). Above the 35% threshold, taxpayers will fall within the top 39.6% tax bracket.
Married filing separately. For married taxpayers filing separately, the maximum taxable income for the 10% bracket is $9,075 (up from $8,925 in 2013); for the 15% tax bracket $36,900 (up from $36,250 in 2013); for the 25% tax bracket $74,425 (up from $73,200 in 2013); for the 28% tax bracket $113,425 (up from $111,525 in 2013); for the 33% tax bracket $202,550 (up from $199,175 in 2013); and for the 35% tax bracket $228,800 (up from $225,000 in 2013). Above the 35% threshold, taxpayers will fall within the top 39.6% tax bracket.
Estates and trusts. For estates and trusts, the maximum taxable income for the 15% tax bracket is $2,500 (up from $2,450 in 2013); for the 25% tax bracket $5,800 (up from $5,700 in 2013); for the 28% tax bracket $8,900 (up from $8,750 in 2013); and for the 33% tax bracket $12,150 (up from $11,950 in 2013). Above the 33% threshold, taxpayers will fall within the top 39.6% tax bracket. There is no 35% tax bracket for estates and trusts.
Standard deduction
The 2014 standard deduction will be $6,200 for single taxpayers; $12,400 for married joint filers; $9,100 for heads of household; and $6,200 for married separate filers.
2014 personal exemption
The 2014 personal exemption is projected to increase by $50, to $3,950, up from $3,900 in 2013. The phase out of the personal exemption for higher income taxpayers will begin after taxpayers pass the same income thresholds set forth for the limitation on itemized deductions.
Limitation on Itemized Deductions
For higher income taxpayers who itemize their deductions, there is a limitation on the amount of itemized deductions that can claim. This limitation was not in effect for several years, but was reinstated by ATRA for tax years beginning on or after January 1, 2013. The limitation will be imposed at income above the following levels:
For married couples filing joint returns or surviving spouses, the income threshold will be $305,050, up from $300,000 in 2013. For heads of household, the threshold will be $279,650 in 2014, up from $275,000 in 2013. For single taxpayers, the threshold will be $254,200, up from $250,000 in 2013. For married taxpayers filing separate returns, the 2014 threshold will be $152,525, up from $150,000 in 2013.
AMT Exemptions
ATRA provided for the annual inflation adjustment of the exemption from AMT income. Previously, this inflation adjustment had to be enacted by Congress each year. CCH projects that, for 2014, the AMT exemption for married joint filers and surviving spouses will be $82,100 (up from $80,800 in 2013). For heads of household and unmarried single filers, the exemption will be $52,800 (up from $51,900 in 2013).
If you have any questions about these or other inflation adjustments, please contact our office.
Despite the passage of the American Tax Relief Act of 2012 - which its supporters argued would bring greater certainty to tax planning - many taxpayers have questions about the tax rates on qualified dividends and capital gains.
Before ATRA, the maximum tax rate on net capital gains and qualified dividends was 15 percent for taxpayers in the 25, 28, 33, or 35 percent individual income tax brackets (the 35 percent rate was the highest individual tax bracket before ATRA). For 2008 through 2012, taxpayers in the 10 and 15 percent individual income tax brackets enjoyed a zero percent tax rate on net capital gains and qualified dividends. Generally, the 15 and zero percent rates applied to long-term capital gains (resulting from the sale of an asset held for longer than one year) and qualified dividends (such as dividends received from a domestic corporation and certain foreign corporations).
ATRA's rates
Under ATRA, the 15 percent rate on net capital gains and qualified dividends is made permanent for taxpayers in the 25, 28, 33, or 35 percent individual income tax brackets. This treatment applies for 2013 and all subsequent years unless modified by Congress in the future. ATRA also made permanent the zero percent tax rate on net capital gains and qualified dividends for taxpayers in the 10 and 15 percent income tax brackets. This treatment applies for 2013 and all subsequent years unless modified by Congress.
Additionally, ATRA created a 20 percent tax rate on net capital gains and qualified dividends intended to apply to higher income taxpayers. The 20 percent tax rate applies to qualified capital gains and dividends of taxpayers subject to the revived 39.6 percent income tax bracket. Taxpayers are subject to the 39.6 percent income tax bracket to the extent their taxable income exceeds certain thresholds: $450,000 for married couples filing joint returns and surviving spouses, $425,000 for heads of households, $400,000 for single filers, and $225,000 for married couples filing separate returns. These threshold amounts are projected to be slightly higher in 2014 as indexed for inflation.
Collectibles and unrecaptured Code Sec. 1250 gain
The Tax Code has special tax rates for collectibles and unrecaptured Code. Sec. 1250 gain. These tax rates were not changed by ATRA or other legislation. A 28 percent tax rate applies to collectibles, and a 25 percent tax rate applies to unrecaptured Code Sec. 1250 gain.
Short-term capital gains
The tax rates are significantly different for short-term capital gains than for long-term capital gains. Short-term capital gains are taxed at ordinary income tax rates. This means that the tax rate on short-term capital gains can range from 10 percent to 39.6 percent, depending on the taxpayer's situation. Income generated from non-capital assets are also subject to these rates.
Net investment income surtax
Unrelated to ATRA's changes is a new 3.8 percent surtax imposed by the Patient Protection and Affordable Care Act (PPACA) on individuals, estates and trusts that have certain investment income above threshold amounts including $250,000 for married couples filing jointly and $200,000 for single filers. These amounts are not subject to an annual adjustment for inflation. The 3.8 percent surtax took effect January 1, 2013 and therefore will be reflected on 2013 returns filed in 2014.
Timing the recognition of capital gain and offsetting losses when possible can frequently lower overall tax liability. Year-end tax planning can be a particularly advantageous in this regard. If you have any questions about the capital gains and dividends tax rates, please contact our office.
The Patient Protection and Affordable Care Act (PPACA)-the Obama administration's health care reform law-was enacted in 2010 and many of its provisions have taken effect. But other important provisions will first take effect in 2014 and 2015. These provisions of the law will require affected parties to take action-or at least to be aware of the law's impact-in 2013 and 2014. These provisions affect individuals, families, employers, and health insurers, among others.
Individual mandate
The individual mandate will apply beginning in 2014. The mandate applies separately for each month. Individuals and their dependents must either carry health insurance or pay a penalty, known as the individual shared responsibility payment. The health insurance must qualify as minimum essential coverage (MEC). Most employer-offered plans, as well as Medicare and Medicaid, qualify as MEC. Certain groups are exempt from the individual mandate, including members of a health sharing ministry, taxpayers without an income tax filing requirement, members of federally-recognized Indian tribes, and persons for whom coverage is unaffordable (more than eight percent of the individual's household income).
Affordable health insurance marketplaces (exchanges) are ramping up and will be open for business October 1, 2013. Exchanges will provide an open enrollment season during which individuals and families without health insurance can sign up for an insurance policy offered through the exchange, effective January 1, 2014. Anyone needing insurance, or looking for cheaper insurance, can use an exchange. Persons who obtain coverage through an exchange will avoid owing a penalty under the individual mandate. Employers have to start notifying existing employees about the existence of exchanges by October 1, 2013, and must notify new employees when hired.
Low-income individuals and families who purchase insurance through an exchange may qualify for the health insurance premium tax credit for 2014 if their household income falls between 100 percent and 400 percent of the federal poverty level for 2013. Individuals who do not have a filing requirement for 2013 do not need to file a return to qualify for the credit. Individuals will generally self-certify as to their eligibility for the credit. Based on this information, the exchange will determine whether the insured person qualifies for the credit. Taxpayers may qualify for an advanced credit; in this case, the exchange will pay the credit directly to the insurer during 2014 to offset a portion of the health insurance premium.
Small employer credit
Small employers may be able to claim the maximum small employer health insurance credit, if the employer has 10 or fewer employees and average wages per employee of $25,000 or less. While the credit has been around since 2010, the amount of the credit increases for 2014 and 2015 to 50 percent of premiums paid for taxable employers, and 35 percent for nonprofit employers.
Employer mandate
The employer mandate (the employer shared responsibility payment) was scheduled to take effect in 2014, but the IRS postponed it until 2015. Nevertheless, during 2014 employers will want to start paying attention to whether they would qualify as an "applicable large employer" (ALE), since status as an ALE for 2015 depends on 2014 employees. An employer who has 50 or more full-time equivalent employees is an ALE. New employers will be treated as an ALE if they "reasonable expect" to have 50 employees. Employers that are members of an affiliated group of companies under Code Sec. 414 must determine their status as ALEs based on the number of employees in the group.
Employers will also want to look at their health insurance offerings. Once the employer mandate applies, employers must offer MEC to 95 percent of their full-time employees. The coverage must also be affordable and must provide minimum value. Employers should look at whether they need to redesign their plan offerings or change the employees' share of the cost to comply with these requirements. If the employer's coverage does not satisfy these requirements, if the employee purchases insurance through an exchange, and if an employee qualifies for the insurance premium tax credit, the employer may be responsible for the employer mandate and owe a penalty.
Employer reporting. The requirements for employers and insurers to report health insurance coverage provided to employees and others were also postponed until 2015. Nevertheless, the IRS is encouraging health insurer issuers to experiment with the requirements by filing the necessary reports for 2014. Larger employers also have to report the value of their health insurance coverage on the employee's Form W-2. The amount reported is not taxable.
Wellness programs. Beginning in 2014, employers may offer wellness programs as part of their health care benefits offered to employees. Employers may offer benefits, such as premium reductions, to employees who satisfy certain health-related requirements.


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Houses of Blessing
Where the Spirit of the Lord is, there is freedom...
Welcome in the digital living Room
Sit down, take a cup of coffee or tea and perhaps have a biscuit. Feel at home!
We are still working hard here, as you can see. There is still work and remodeling, the dust has to descend and a thorough cleaning is certainly necessary, but that should not spoil the fun anyway?
Here in the house we know that we can be safe, secure.
We do not gossip with each other or about each other, but we talk to each other. We laugh with each other and we cry with each other. We meet in the here and now and embrace each other with compassion and mercy.
Above all, as a household of God, we also enjoy each other!
Once again, feel welcome, within the frameworks set by Christ.
There is a place of commanded blessing
Perhaps I can first take you to that 'old' song: "there is a place of commanded blessing".
There is a place where the Lord blessus us, where brethren in unity dwell, a place where anoiting oil is flowing, and we live as one.
Can I ask a question to you? Do you know such a place, a place where the Lord wants to bless you, where unity is and love reigns? Where God's joy and oil can flow? Without obstacles, without regard to the person?
You have called us to be a body. You have calles us as friends. Joined together in the bond of the Spirit. Unto the end.
Do you have such a place where you are bound to the body of Christ, one as a family? Inserted, as a member, each separately, but together one body? To be friends through the Spirit of Jesus, strong to the end?
Father we join with the prayer of Jesus. As you are so let us be one. Joined together in unity and purpose. All for the love of your son.
A place where you can come together to pray as he taught us, to be one together as He is, A desire to be bound together in unity and striving, strong in the Love of Him?
We will break dividing walls. We will break dividing walls. We will break dividing walls in the name of the Son. We will break dividing walls. We will break dividing walls and we will be one.
A place where yu dare to be yourself, where you dare to break down the wall that you may have built around youself? To bring down that wall to become one together in te love of Christ?
Or as the following text says:
"And where the Spirit of the Lord is, there is freedom......." ~2 Cor 3:17b
Freedom. Are we not all looking for it? Are we not all looking for a place where we can be ourselves? A place where nothing is necessary and yet (within the frameworks of the decent) everything is allowed?
Where there are no tightly defined frames of 'as it should be', where there is no fixed structure. A place where freedom is in the broadest sense of the word.
Let's be honest that many fellow believers, from RKK to Free Reformed, from Baptist to Evangelical, have liked their place within those structures and perhaps even within that system. And that is good! If you feel 'happy' there, you know how to 'maneuver' within those frameworks and hove found your place there, I'm really happy for you!
But what is you do not know how to stay inside?
If that space is too limited for you?
We would like to offer you that place. A place to BE. A place where you (perhaps for a moment) can drop your wall and really dare to 'expose'. A place where there are no fixed boundaries with service, liturgy and all other 'Bells and wistles'.
If you are looking for that place or a different form, then we want to help you find that place.
You can always come to the coffee!
You can always be here without apologizing for who you really are.
In the house of God there is always peace!
You can always come to the coffee
A pilgrim song. From David. Behold, how good and sweet it is when brothers also live together. It is like the precious oil on the head, falling down on the beard, the beard of Aaron, who wave down on the hem of his clothes. It is like the dew of the Hermon, who descends on the mountains of Zion. For that is where the Lord blesses, life for all eternity.
Psalm 133
Are you looking for a house where you can come for a moment, just to BE you? And BE with capital letters. Just as you really are.
Maybe you need some compagny. A listening ear. Maybe you want to share your story. Perhaps you would like someone to pray for you, for the situation in which you are or want to recieve a piece of education from the Word of God, the Bible. That is possible!
But also, as said, just that listening ear. Or maybe you want to watch a movie together, play a game, just have a cup of coffee together and just do NOT do anything else. In other words, just be there, no matter who or what you are and to experience that you are welcome and of value.
It is all possible. The people who are connected to this site all have an open heart to recieve you as you are!
Feel free to contact one of them. There is probably 1 in your area and otherwise we are looking for someone in your area. If we do not have anyone in our network, we will go over the church walls and knock on a local pastor or preachers door and if you wish one of them will contact you.
Houses of Blessing Winnipeg Manitoba.
We are Hilde and Marc pranger and we work with the team at Living Word Temple in Winnipeg Manitoba, Canada. After that Marc was carrying a vision for ministry in Canada since 1995 and made several trips over the years, did we move to Winnipeg in August 2018. This was and is a leap of faith as we got the invitation to go in June that year and moved fast and swiftly after that with three young children. We are already for a longer time connected with houses of blessings when we lived in Veenendaal the Netherlands.
Even though our meeting are not in our house, we hope to make other people's houses and all the place we meet at, places of blessing, as we go there to pray, or to open the Bible, or to listen and be there.
Gilbert Park Church Plant
On September 16, 2018 we began to gather in Gilbert Park Winnipeg as a new church plant in Winnipeg. God has opened up many new doors for us to share the love of Jesus with the community. The team has also seen the beginning of the Light of the World sharing circle gathering. We now meet every Saturday at the Gilbert Park community gy at 2 p.m we welcome everyone in the circle to share their story and to meet each other and Creator and His son Jesus. Marc as community pastor works together with pastor Cameron in this simple church setting. This church should be as a warm place, a house of blessing. Where possible do we also try to embrace Indigenous culture and ceremonies in honoring the stewarts of the Land and showing Jesus the Way, Life and Truth through their culture too. Hilde recently started to do children's ministry for children coming to the gatherings
If you live in the Winnipeg area or come here as visitor and recognize yourself in what the home page says - Are you looking for a place where you can come for a moment, just to BE you? And BE with capital letters. Just as you really are. Maybe you need some company. A listening ear. Maybe you want to share your story. Perhaps you would like someone to pray for you, for the situation in which you are or want to receive a piece of education from the Word of God, the Bible. That is possible.
For contact send an email to email@example.com
Our ministry is without salary your support is appreciated https://goo.gl/j9PtjX C4013 Marc Pranger
Thank You! Hilde and Marc

subset: commoncrawl


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Mastering an online article rewriter tool can prove quite tricky. When paraphrasing or rewriting any text or paragraph, many writers and students tend to get hold of the technology that enables them to rewriter any written piece of content into a fresh piece, yet keeping the original meaning of the text same. This approach is usually used to simplify a piece of writing, minimize the use of quotes or target an alternative audience. When article spinner tool is used correctly, paraphrasing turns out to be much more concise than the original text, covering all the main points while preventing the risk of plagiarism. Whether you are a student or writer, you can use this free article rewriter online to rewrite any text to save time and get a different version.
It is a widespread technique in SEO and SMM, involving the rewording and rephrasing of article. As a result, user will get a unique and original content based on the sample article. With the help of any paraphrasing tool, this technique can be used to create original articles which can then be used for posting online or any other purpose without being identified as a duplicate content.
By the way, I check all these spins and compare them using DiffChecker in order to easily see what has changed. And as you can see, the "Turing" spinner of WordAI really focuses on rewriting the structure and flow of the sentences of the content as opposed to focusing on exchanging words with synonyms, which is of course why the result content is extremely human readable.
Anyone will can this, all you want is a fabulous computer and the flexibility to sequence a post title together. You can generate original article content and submit them to story lookup directories and receive paid for. You possess to apply to these web pages and may or may never get transformed down. If you should materialize to receive transformed down subsequently just hold plugging apart until you obtain person to "work with" you.
Not so long ago there lived a boy. He blue eyes with blond hair as yellow as gold. The young boy was smaller than average fragile, but his mind was swift much like the wind. He could calculate the outcome from a situation within the blink of the eye. But that was not his biggest talent. No. His biggest talent was perception. The son could understand and perceive anything quicker than anyone he'd ever met. Then, he fell crazy about a lovely princess. She'd magnetic green eyes and light brown hair. He loved her quite definitely and then she loved him back even more. There were only 1 problem – the young lad was the son of your blacksmith. The princess's father would never allow her to marry an easy son of a blacksmith. On the other hand love was too strong. In a single fell swoop, the young boy raised an army of undead and commenced a rebellion to overthrow the evil king who didn't trust soul mates. After months of struggling with the armies of his beloved's father, the young lad was assassinated as well as the war was over. No songs were sang.
If you have not used a spinner before then I would suggest that you first use something that require more human imput like The Best Spinner or Spinner Chief in order to understand the basic principles. However if you must go fully auto then I would suggest you go for Wicked Article Creator. I have it and understand it is similar to wordAI but a one off fee of $47.
https://www.inetsolutions.org/wp-content/uploads/2016/03/WordAI-Ultimate-Tutorial-And-Honest-Review-Innovative-Content-Spinning-Software.jpg 1200 1920 root https://www.inetsolutions.org/wp-content/uploads/2015/07/Inet-Solutions-Symbol-Plain18-80x80.png root2016-03-03 15:51:322016-03-03 21:58:36WordAI Ultimate Tutorial & Honest Review - Innovative Content Spinning Software
Customer Testimonials — Disclaimer: The testimonials displayed on this website were sent to us by our actual customers and were not altered in any way. Some of the testimonials also display a photo of our customer who sent us that particular testimonial — we always obtained our customer's full permission to use their photo as part of their testimonial. With this in mind, of course every user is different so we want to point out that while these results are possible, they are not guaranteed by us (as the product vendor). The results described are not typical and not experienced by every one of our customers.
If you already have some blog or website content that you want to turn into fresh, rewritten content in a matter of seconds you should use our article rewriter tool. This free paraphrasing tool is available to you 24/7 to rewrite the text. Most of the text created by our article spinner is human readable and 100% unique which makes it suitable for creating mass blog posts and web content.
Now, remember that the above example was using the "Very Readable" setting of WordAI. Let's see what content will be generated if we use the "Readable" setting. Just a quick note here that this time it took about 20 seconds for WordAI to finish the spin, so the setting we are playing with definitely has some effect and is not there just for marketing purposes:
A long time ago right now there lived a boy. He had blue eyes with blond hair as yellowish as gold. The young boy was small and fragile, but his mind was swift just like the wind. He could calculate the outcome of any situation in the blink of an eye. But that had not been his biggest talent. No. His biggest skill was perception. The young boy could understand and perceive anything quicker than anyone he previously ever met. Then, he fell in love with a beautiful princess. She acquired magnetic green eye and light brown locks. He loved her quite definitely and she loved him back more even. There was only 1 problem – the young boy was the son of a blacksmith. The princess's father could not allow her to marry a straightforward child of a blacksmith. But their love was too strong. In one fell swoop, the young boy raised an army of undead and began a rebellion to overthrow the evil king who did not believe in true love. After months of fighting against the armies of his beloved's father, the youthful boy was assassinated and the battle was over. No songs were sang.
If you are a blogger or content writer or perhaps even an SEO specialist, then looking for unique artistic content that focus your product or services as online identity. You know most of the Search engine looks unique content. To be in good state of the web world, you must have to ensure exorcism data in your site or blog, that attract your visitor to visit you regularly also it present acceptance to the search engine. As an online marketer you need content regular basis, but to write or create a brand new article concept and its composition is not an easy task!
So you are still doing it? I have stopped using spin content after panda update way couple of years ago. As content become king and the user expereince the key to earn website authority, I started focusing on writing more meaningful and engaging content. I never cam across any spinner that time which makes total sense after spinning. The spin content either looked very bad or it needed manual review. I forgot the name of the spinner tool as well. Looking forward for replied from more experts here as it could be an eye opener for me if spinning still works.
If you already have some blog or website content that you want to turn into fresh, rewritten content in a matter of seconds you should use our article rewriter tool. This free paraphrasing tool is available to you 24/7 to rewrite the text. Most of the text created by our article spinner is human readable and 100% unique which makes it suitable for creating mass blog posts and web content.
4. Tier 2 content (content that is keyword rich and relevant to your niche. Doesn't have to be all that readable, it just has to be indexable by a search engine.)– Here put same options as with the Tier 1 content situation with the only difference that you set the 1st input to "Regular." It is important that lower tiers have a lower quality of content compared to upper tiers.
There are lots of reviews about the product, and many people here are writers that experienced a wonderful time doing their job with the aid of the tool. Most of these people usually say that you dont need to rely on the tool completely to get the job done because that will fail at most times. What you need to do according to the reviewers is that you should learn how to edit the article a bit so that it wont look completely spun since there are some clients that hate this tool.
Does your website need quality content in numbers? The truth is; producing articles restrict the amount of content that is written on your site if you're the only one writing on your website and can take any author hours. Hiring a writer can get expensive. Have you ever considered using an article spinner? Spinning content is a excellent way to keep your website fresh and relevant . Needless to say, not all article spinner applications is great. Therefore it's important to do your homework first. We propose Spin Rewriter 9.0. You can rewrite your articles using their Rewrite system. In addition, you have a Bulk Rewrite option that lets your rewrite articles with one click. You break it up into several terrific pieces of content and may take one article. The choices are endless.
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From personal experience Spin Rewriter is the best! like I still use it today. Its so easy to use (Just copy paste and the program do everything) Because of this tool I managed to schedule content and articles for 3 years, do you know how much time and money I've saved?!?! A LOT!!! Also i high recommend you pick their mothly plan if you are still in doubt
4. Tier 2 content (content that is keyword rich and relevant to your niche. Doesn't have to be all that readable, it just has to be indexable by a search engine.)– Here put same options as with the Tier 1 content situation with the only difference that you set the 1st input to "Regular." It is important that lower tiers have a lower quality of content compared to upper tiers.
Millions of people who also have the internet at their fingertips are wondering exactly the same thing as you right now: How can I make money online? How can I get search engine exposure for my website (or blog)? What will give me a leg up on the competition? Thankfully you have already arrived at the answer to all these questions. Article Rewriter Tool is available for free to make your online business as successful as possible, with minimal effort on your part.
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If you have not used a spinner before then I would suggest that you first use something that require more human imput like The Best Spinner or Spinner Chief in order to understand the basic principles. However if you must go fully auto then I would suggest you go for Wicked Article Creator. I have it and understand it is similar to wordAI but a one off fee of $47.
Millions of individuals who likewise have the internet on their fingertips are usually wondering exactly a similar thing as you at this time: How can I make money online? How do i get internet search engine exposure for my web site (or blog)? Exactly what will provide me a leg through to your competition? Thankfully you have previously arrived at the solution to all or any these questions. Post Rewriter Tool can be acquired to make your website as profitable as possible, with reduced work on your own part.
There is a major drive emulsifying the online business that roots back to the very need of writing articles. To get top quality visitors as well as one way links, one of the best techniques is usually to submit posts in order to stretch internet directories and target websites. There may also be a number of disadvantages in tapping for the WordAI for document syndication.
Imo it is not possible for google to detect properly spun content, it is not worth computing power it requires. They can do this using ngrams for example, but it is uses a lot of queries. And for example article spinner I coded beats this algo, so google cant detect that the content is spun. Manual spinning is also good but it takes more than 30 minutes per article.
Cross Platform – Being a Mac user I prefer when I can fire up a program locally. WordAi is web based and therefore works on Windows & Macs without issue (Linux as well). SpinnerChief III Ultimate has a Web Api that allows spinning from the web, but we did not have much luck with it, so at this time we consider SpinnerChief a Windows only application and therefore requires me to run it in a virtual Windows Machine using VMWare Fusion. This one is a hard one to call because clearly WordAi wins cross platform, but it doesn't have all the extras that SpinnerChief offers.
Some writers research for batches of affordable private brand rights articles and spin them before submitting them. These PLR content articles may not really become the greatest high quality but anything can become enhanced upon by the rewriting. These PLR content articles are utilized credited to the truth that actually though the high quality is mediocre, they nevertheless have assisted attract in visitors.
I'm new on this of online business thing, and English is not my native language. In spite of that, I have written my first pages and posts by myself. I totally agree with what you say here. There is nothing more satisfactory than to produce your own content, even if it is not perfect or excellent in the beginning, but with time and practice, it will surely improve.


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This recipe may frustrate some of you.
Once I learn how to cook something, with the exception of baked goods of course, I start making it from memory and all exact measurements go out the window. It's more fun that way. Baking is chemistry and you must have everything exactly right, but cooking is art. This is also why I rarely type up my own recipes to share here, and why I say this one may frustrate you. Don't worry. Just keep an eye on things, taste test every now and then, and it'll all turn out fine. This recipe is pretty hard to mess up.
Every time I've had gulash made by a different person, the dish was very different. It seems to me there's no consensus on what gulash is, exactly, although there are basics that carry over to each one. My grandmother taught to me to make this one when I was around thirteen, and she called it gulash. Who am I to say she's wrong?
Grandma's Gulash:
- A pound of hamburger meat (omit to make this a vegetarian meal)
- One small yellow onion, diced
- A couple carrots, peeled and diced
- A red (or orange, or yellow) bell pepper, diced
- A stalk of celery, diced
- Three or four cloves of garlic, minced
- A can of diced tomatoes (undrained)
- Two cups or so of beef broth. Maybe three. It really depends. (or vegetable broth if making this vegetarian)
- A big handful or two of elbow pasta. Eyeball it.
- V8 juice
- Basil and oregano, preferably fresh
- Salt, pepper, and chili powder
In a large pot, cook the hamburger meat until it's starting to get fairly browned. Add in the onions, carrots, bell pepper, and celery. Continue cooking until the meat is fully cooked and the vegetables start to soften.
Add in the undrained can of diced tomatoes, the garlic, herbs, and some seasonings. Stir it all together. Add in the broth, plus more if you feel you need to. Bring this to a boil, cover, and let that cook for a couple minutes.
Next, add in the elbow pasta. Obviously that pasta is going to absorb all that broth as it cooks. This is what the V8 juice is for. Keep it boiling for the amount of time it takes to cook the pasta (whatever it says on the package), adding in V8 juice as needed to keep enough liquid in the pot to cook it without letting it get too thin. You will need to keep a close eye on it, and taste it every now and then to make sure it's still seasoned well. Bland food is no good. Don't be shy with your herbs and seasonings.
Once the pasta is fully cooked, your meal is finished. If you ended up with a little too much liquid, just let it go a little longer to let some of that cook off.
And there you have it! Enjoy.


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Flintstones-themed amusement park in Arizona closes after nearly half a century Bedrock City opened in 1972 near the Grand Canyon. Posted: January 30, 2019, 8:56AM
The Love Boat is one the few hour-long TV shows ever to feature a laugh track Now that's what we call hearty har-hars. Posted: January 29, 2019, 4:30PM
Wait. Did they forget to stencil this one letter in the M*A*S*H opening credits? Looks like M*A*S*H forgot to cross some Ts. Posted: January 28, 2019, 4:14PM
Jack Larson from Adventures of Superman almost joined the cast of Gomer Pyle, U.S.M.C. Jimmy Olsen almost became Private Tommy permanently. Posted: January 28, 2019, 9:38AM
Krispy Kreme is making conversation heart doughnuts to fill the void of missing Sweethearts candies These unexpected Valentine's treats are "So Extra." Posted: January 25, 2019, 1:46PM
Saved by the Bell star who played Zack Morris confirms he dated Jessie Spano co-star Elizabeth Berkley Don't tell Kelly or Slater. Posted: January 24, 2019, 11:15AM
HGTV teased that they might give away The Brady Bunch house to a fan That's the way you could become The Brady Bunch homeowner. Posted: January 24, 2019, 11:03AM
The Star Trek universe recycled a planet from Buck Rogers in the 25th Century Hey, that space colony sure looks familiar… Posted: January 23, 2019, 1:14PM
You can kiss Sweethearts candies goodbye this Valentine's Day The popular candy is unavailable after the manufacturer went bankrupt. Posted: January 23, 2019, 11:20AM
Dennis Weaver explained why he regretted giving Chester that limp on Gunsmoke "I had to take yoga lessons to do some of that stuff." Posted: January 22, 2019, 3:18PM
R.I.P. Kaye Ballard of 'The Mothers-in-Law' and 'Freaky Friday' The Sixties sitcom star died at the age of 93. Posted: January 22, 2019, 1:20PM
The music by the Honeybees from Gilligan's Island turned up twice on Perry Mason You can hear the instrumental of "You Need Us" in two of Perry's season nine cases. Posted: January 21, 2019, 2:15PM
Scooby Doo once spoofed The Andy Griffith Show with the help of Don Knotts The Mystery Machine met Dandy Griffith in Juneberry. Posted: January 21, 2019, 10:34AM
This painting from I Love Lucy decorated walls on The Andy Griffith Show, too This farm scene is a through line connecting Andy and Lucy's worlds. Posted: January 18, 2019, 3:38PM
The M*A*S*H episode ''Lend A Hand'' was an Alda family affair Alan Alda's father and brother lent a hand to Hawkeye in season eight. Posted: January 18, 2019, 1:05PM
5 overlooked Betty White TV roles that further prove she is the queen The beloved legend continually pioneered the role of women on TV. Posted: January 17, 2019, 10:55AM
Carol Channing maybe invented hip-hop fashion in a 1966 Corn Flakes commercial with Gomer Pyle She was rocking gold chains and clocks before anyone else. Posted: January 16, 2019, 11:33AM
This is the ''simple logic'' that convinced Leonard Nimoy to stay on as Spock on Star Trek The fascinating origin of how "Fascinating" helped define Mr. Spock. Posted: January 16, 2019, 10:38AM
8 cringe-worthy original reviews of hit TV shows that completely got it wrong Which show "as a whole, is not as well cast as it could be"?! Posted: January 15, 2019, 10:26AM
R.I.P. Carol Channing, the bubbly Broadway star turned TV darling The actress died at the age of 97. Posted: January 15, 2019, 9:33AM
Confirmed: The next Perry Mason will be The Americans star Matthew Rhys They finally cast the new Perry Mason. Posted: January 14, 2019, 11:17AM


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This is a heavily revised version of one of 2016's prompts, which asked students to describe a transition from childhood to adulthood. The purview of the inquiry has been expanded to ask about personal growth in general, leaving the lessons and timing of an applicant's transformation more open-ended. Students are also now free to reflect on a "realization" in addition to an "event" or "occurrence." While a realization that changes your understanding of the world will likely be sparked by a concrete marker (i.e., an event or accomplishment), we are happy to receive the added flexibility from you, Common App. Thank you very much.
"I wake up to the sounds of chickadees singing outside my bedroom window and the delicious smell of breakfast cooking downstairs. A feeling of contentment washes over me as I slip out of bed and into my slippers. I saunter downstairs and sit at the kitchen bar as I rub the sleepy dirt from my eyes and wait to taste my mom's delicious cooking. I love my laid back mornings. No alarms are jolting me out of a deep sleep followed by a mad rush to get ready and catch a bus like the other children in the neighborhood.
IIE's scholarship and fellowship program are in place to recognize graduate and undergraduate industrial engineering students for academic excellence and campus leadership. The Society for Health Systems Scholarship is available to undergraduate students enrolled full-time, who have a minimum 3.4 GPA and who are active Society for Health Systems student members. For more information or to apply, [...] More
The goal of these revisions is to help all applicants, regardless of background or access to counseling, see themselves and their stories within the prompts. They are designed to invite unencumbered discussions of character and community, identity, and aspiration. To this end, we will be creating new educational resources to help students both understand and approach the opportunities the essay presents for them.
Our Incight Scholarship Program is a long-term commitment to students with disabilities entering and attending college. It functions to help reduce the barriers of education advancement and completion by providing the necessary skills for youth with disabilities. We believe that this will enable young people to become self-supporting participants in their communities. Scholarship recipients are [...] More
Read your essay backwards. This may sound a bit silly, but when reading in sequential order, your brain has a tendency to piece together missing information, or fill in the blanks, for you. Reading each sentence on its own and backwards can help you realize not only typos and mistakes in grammar, but that you may have forgotten an article here and there, such as "a" or "the."
CCSD male seniors who are of European descent may apply for the Josef Princ Memorial Scholarship. Applicants must also have a minimum 3.5 GPA, demonstrate financial need and planning to attend an accredited post-secondary college or university majoring in engineering, mathematics or science. Up to four scholarships in the amount of $2,000 each will be awarded. Must write a 400-500 essay on [...] More
Three scholarships of $600 will be awarded to outstanding students who are pursuing careers in the beef industry. Fields of study may include education, communications, production, research or any other area involved in the beef industry. The purpose of this program is to identify and encourage talented and thoughtful students who will emerge as industry leaders.
In 2015, the city of Melbourne, Australia created a "tree-mail" service, in which all of the trees in the city received an email address so that residents could report any tree-related issues. As an unexpected result, people began to email their favorite trees sweet and occasionally humorous letters. Imagine this has been expanded to any object (tree or otherwise) in the world, and share with us the letter you'd send to your favorite.
If my father had a life insurance policy, we would not have to work ourselves to the bone and sacrifice our physical and emotional well-being to keep up with expenses. I would not have to worry so intensely about the future of my education on top of the crippling grief that I have felt over the last five months. If this devastating experience has taught me anything, it is this: financial planning for these situations is absolutely invaluable. I will not soon forget the stress and despair that I have experienced, and I now realize that to have a life insurance policy is to throw your surviving family members a crucial lifeline. Though no one can ever prepare you for the trauma of losing a parent, life insurance allows you to grieve without the constant stress of financial burden, and for that reason, it is an absolutely essential precaution.
Now, I cherish the chance to act based on what I hear. Through teaching at Kumon and church and leading volunteer organizations, I've worked to develop and implement my style of listening to benefit others. Listening is a skill that I feel is often under appreciated in leadership. People usually flock to the figure in the center of the room, not the person on the side listening. But from my experience, it's clear that I can guide others by harnessing my observations to benefit the inspirations and passions of those around me. My college plans are only avenues to further explore this ideology, as I'll have the unique perspectives of thousands of other students, and professors to listen to.
The Mercatus MA Fellowship is a two-year, competitive, full-time fellowship program for students pursuing a master's degree in economics at George Mason University who are interested in gaining an advanced degree in applied economics in preparation for a career in public policy. The Mercatus Center's MA Fellowship program is targeted toward students with an interest in gaining advanced training [...] More
Even at first, when the whole research group sat there doing rote calculations and others felt like they were staring down the barrel of defeated purpose, I remained enthusiastic. Time and time again I reminded myself of that famous phrase "great effort leads to great rewards," and sure enough, soon my aspirations began to be met. This shift in attitude also coincided with a shift in location: from the computer desk to the laser lab. It was finally time to get my hands dirty.
The Jordan & Cara Odo Scholarship Foundation will award a $1,000 scholarship to a bright and talented high school senior seeking to further his or her education. Applicants must be a high school senior currently attending a high school in Hawaii; plan to attend a two- or four-year college; and have a minimum 2.5 GPA. A 500-word essay will be part of the application.
There is no objection that studying process is hard and it strongly affects a student's life and because of it many young people lean toward buying the finished essay using internet resource. When there are tons of homework you risk to lose things, which are more valuable – your friends and relatives. Don't allow it happen with you! You have to be in touch with people, who care about your life, but on the other hand solving the academic questions is not of less importance. When you strike a snag with that researching process and have no time to accomplish everything, our helping hand is just what you need. Do you know the phrase, that two heads are better than one? We don't want you to work like a horse for this writing tasks, we are able to help writing a paper for you. Our site is a magic tool, that will not let the most important things to slip your mind. When dealing with our company you can be sure that everything is legal and that you will be pleased with the result.
You may have heard the phrase "holistic" admissions thrown around—many universities follow this model, which means they don't necessarily have an ACT or SAT cutoff score, nor do they require a certain number of AP/IB/Honors courses. Instead, they're trying to get to know candidates as humans. Admissions officers are people—people who would be horribly bored if their job came down just to numbers, statistics, cutoffs, and counting up your AP and SAT and ACT scores.
Now that you are well-known of all the features that we have in store, ensuring flawless online essay help in U.S.A, you must be wondering who's going to assist you with essay writing at MyAssignmenthelp.com, then we would like to mention that the diligent essay assistants of our firm are always there to cover almost any subject matter, and challenging topic. Here's a list of sample topics that you can expect our team of online essay assistance providers to help you with.
Essay Prompt: Please explain a personal hardship or catastrophic life event that you have experienced. How did you manage to overcome this obstacle? What did you learn and how did you grow from it? This answer is critical to your application as Change a Life Foundation's vision is to assist individuals who have persevered and overcome a hardship/catastrophic life event.
State University and I possess a common vision. I, like State University, constantly work to explore the limits of nature by exceeding expectations. Long an amateur scientist, it was this drive that brought me to the University of Texas for its Student Science Training Program in 2013. Up to that point science had been my private past time, one I had yet to explore on anyone else's terms. My time at UT, however, changed that. Participating for the first time in a full-length research experiment at that level, I felt more alive, more engaged, than I ever had before. Learning the complex dynamics between electromagnetic induction and optics in an attempt to solve one of the holy grails of physics, gravitational-waves, I could not have been more pleased. Thus vindicated, my desire to further formalize my love of science brings me to State University. Thanks to this experience, I know now better than ever that State University is my future, because through it I seek another, permanent, opportunity to follow my passion for science and engineering.


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Ombudsman Office in Lodi, CA
YP - The Real Yellow PagesSM - helps you find the right local businesses to meet your specific needs. Search results are sorted by a combination of factors to give you a set of choices in response to your search criteria. These factors are similar to those you might use to determine which business to select from a local Yellow Pages directory, including proximity to where you are searching, expertise in the specific services or products you need, and comprehensive business information to help evaluate a business's suitability for you. "Preferred" listings, or those with featured website buttons, indicate YP advertisers who directly provide information about their businesses to help consumers make more informed buying decisions. YP advertisers receive higher placement in the default ordering of search results and may appear in sponsored listings on the top, side, or bottom of the search results page.
1. US Army Recruiting Office - CLOSED
2533 W Kettleman LnLodi, CA 95242
2. Corrections Department Parole Office
612 Carlton AveStockton, CA 95203
3. San Joaquin Sheriff's Office
7000 Michael Canlis WayFrench Camp, CA 95231
From Business: Established in 1849, the San Joaquin County Sheriff s Department is a full-service law enforcement agency. It has a patrol division that responds to complaints fi…
4. Merced County Office Education
2707 Transworld DrStockton, CA 95206
5. Agricultural Commissioner Office
14177 State Highway 160Walnut Grove, CA 95690
6. Traffic Safety Office
2208 Kausen Dr Ste 300Elk Grove, CA 95758
From Business: Established in 1967, the Office of Traffic Safety designs and administers traffic safety programs to deaths, injuries and economic losses resulting from traffic c…
7. U S Government Offices Land Reclamation Bureau
38563 Netherlands RdClarksburg, CA 95612
8. California State Government Offices District 4
9899 Elder Creek RdSacramento, CA 95829
9. Tracy Clerk's Office
333 Civic Center PlzTracy, CA 95376
10. Sacramento County Office of Education
3535 65th StSacramento, CA 95820
11. United States Government Offices District 7
8950 Cal Center Dr Ste 100Sacramento, CA 95826
12. Molina Healthcare Regional Office
300 University Ave Ste 100Sacramento, CA 95825
From Business: Molina in Sacramento,CA has been serving the needs of low-income families and individuals with high quality health care.
13. Office Of Inspector General
10111 Old Placerville RdSacramento, CA 95827
14. Emergency Services Office
3650 Schriever AveMather, CA 95655
15. Controllers Office
3301 C St Ste 712Sacramento, CA 95816
16. Government Offices State Job Service - CLOSED
1783 W Yosemite AveManteca, CA 95337
17. Lodi City Animal Service
1345 E Kettleman LnLodi, CA 95240
I adopted the most awesome cat here! I have combat ptsd and he's my care cat! I wish that I could register him as my "service animal" but cats don't…
18. Lodi Street Div
1331 S Ham LnLodi, CA 95242
From Business: The City of Lodi Street Division offers street cleaning and sweeping services. The division oversees the maintenance of sidewalks and landscaped areas. The City o…
19. Lodi Municipal Service Center
1331 S Ham LnLodi, CA 95242
From Business: The City of Lodi Public Works Department operates through water and fleet services and engineering divisions. The department also operates a water pollution contr…
20. Lodi Wine & Visitor Center
2545 W Turner RdLodi, CA 95242
21. M V Transportation Inc
24 S Sacramento StLodi, CA 95240
22. Lodi Chamber of Commerce
35 S School StLodi, CA 95240
23. Lodi Dial-A-Ride
24 S Sacramento StLodi, CA 95240
24. City Business Licenses
221 W Pine StLodi, CA 95240
25. Lodi City Manager
221 W Pine StLodi, CA 95240
26. San Joaquin County Lodi
121 W Elm StLodi, CA 95240
27. Lodi Parks & Recreation
125 N Stockton StLodi, CA 95240
28. San Joaquin County Superior Ct
217 W Elm StLodi, CA 95240
29. City of Lodi
125 N Stockton StLodi, CA 95240
30. Hicap Services
125 S Hutchins StLodi, CA 95240


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Composer | Actor | Soundtrack
Host of radio show, "State of Trance".
[on the future of EDM (electronic dance music)] I don't know. Everything is going so fast now. There are so many new talents on the horizon. What is happening right now is a thing I like to call 'diversification' because you have all these little ...
Armin Joseph Daniel Jacobus van Buuren
Leiden, Zuid-Holland, Netherlands
Don't miss these picks: Daniel Radcliffe and Steve Buscemi as a divine duo, a superhero family facing the apocalypse, and two new joints from Jordan Peele. Presented by M&M's.
Check out our guide to the Academy Awards, our coverage of the 2019 awards season, and more.


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Barbara Turkeltaub, a Jewish girl who was hidden by Catholic nuns during the war, describes witnessing a Nazi massacre.
In this graphic testimony, Holocaust survivor Zvi Michaeli describes realizing that he survived after the Jewish community of Eishyshok, Lithuania was murdered by the Nazis.
Consider the experiences of Jewish prisoners who were forced to help German guards murder other prisoners.
Deepen your understanding of the Nazis' persecution of Sinti and Roma people during World War II.
Learn how the Germans tried to hide evidence of their mass murder toward the end of World War II by evacuating prisoners from camps.


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