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Chelsea Kellner of Midtown Raleigh News wrote Sunday about the exciting news of a small urban farm possibly joining the ranks of new downtown highlights. The location in question is a vacant lot at the corner of Blount and Franklin Street (in red above - the homes shown have since been removed). The proposal, by local startup Raleigh City Farm along with the Triangle Land Conservancy, explains the social and economic advantages of the urban community garden:
"It would go from being a completely unused parcel of land to one of the best-used in the entire city," Raleigh City Farm spokesman Joshua Whiton said. "We want to be a demo site where people can come by and see how much food can be grown in a small space."
Restaurants, Other posts by Paul.
Awesome. Please tell me this is going to be funded by my tax dollars. That would make me sleep better at night. With a $14T budget deficit, I can think of no better way to make a certain group of people feel better about themselves than corn and tomatoes growing in the city.
Hopefully we'll see something really useful being grown, like star fruit.
Yea man. Screw vegetables. Let's build a Starbucks fueled solely by conservative bile.
Seriously though, the details are pretty light at this point, but I wish them luck, especially if they can incorporate an educational aspect. Small area farming is a skill that more people are going to find necessary in the coming years.
I'm lovin' the protocol for commenters on New Raleigh: assume the worst, and sass about it! chill out, "renegade." you know nothin'.
If by "conservative bile" you mean "stop stealing my income and spending it on frivolous garbage", then I'll take a grande, please…but I'm sure you would have no such issue if the proposal was to use the land to build a baptist church. By comparison, there is no "let's" when it comes to building a starbucks; it is privately held and doesn't require the city to waste the money I earned and it subsequently took from me by threat of prison.. but at least some small group of really cool bearded people will learn how to farm; after all, you state that is something we will all need soon, so it must therefore be true.
freemarketrenegade: Clearly your desire to hate precludes you from researching what you're hating on. If you took the few seconds to visit the Raleigh City Farm website and the Midtown Raleigh News article, you'd learn that the group is a non-profit startup that hopes to sustain itself from the sales of produce it grows on the farm. The only thing they appear to be asking from the City of Raleigh is the zoning change to use the land in question for their business, which happens to be agriculture.
renegade, you've demonstrated exactly what I was referring to.
Zero facts, unlimited hate, and a few misquotes thrown in for flavor.
Hey "freemarketrenegade".
Why don't you just hope on over to wral.com. You would feel much at home with hateful lunatics that mostly comment on articles posted there.
Well back to the subject and away from the mouth-breathing trolls, I will say I like the idea.
I'm slightly disappointed that the mixed-use development that was originally going on this plot (as well as on the site of the old mini-strip center immediately to the east) never happened. But this could be a good idea nonetheless.
Great idea! I hope it happens.
Small area farming is a skill that more people are going to find necessary in the coming years.
well said Jeff.
Freemarket Renegade making big complaints about a small urban farm while $.50 cents of every dollar earned by big farms come from government subsidies. http://farm.ewg.org/region.php?fips=37000 Way to channel your energy, Sir.
farm subsidies are terrible waster of money; a review of my comments shows I never stated otherwise.. as far as this group not wanting tax money - if it is a non-profit who gets to pay their tax burden?
I look forward to the day when any ninny using the words "my tax dollars" is immediately imprisoned. Not because the world will be any better; I just like seeing ninnies punished.
A review of your statement shows you are complaining about the POSSIBLE use of your tax dollars. A review of my statement suggests that your efforts would be better directed elsewhere. I actively encourage you to write a letter to your reps about billions in subsidies to Big Ag instead of complaining to a blog about some tiny thing you don't even know about.
matt - interesting. For what other reasons might you want people thrown in prison? I am simply stating that I don't want my tax dollars used on a farm. Reason being, there is plenty of food available in numerous locations around the city already; but most importantly, I don't care what anyone does with that land, so long as they pay for the land and they do not receive any subsidy for it in any way, and that includes the liberal's favorite moniker, "non-profit".
If you buy it with your money and pay taxes on it with your money and incur the risks and rewards of that investment, you can grow whatever the hell you want to on that land. Everyone on this forum knows full well that none of the above is true about this project. And yeah, it's a small thing - it doesn't begin to compare to big ag. But you start to add up the stupid little things, like this, and that ridiculous concert venue downtown, and the whatever-whatever center for whatever-special-interest-group that is 'non-profit', and soon enough you start talking about real money.
But let's ask the real question: what will be the real cost per year in tax dollars, or LOST tax dollars, for this thing to operate? Then look at your tax return for 2010, and tell me if you spent a year of your life funding a garden. I bet it takes a half-dozen or more of us to pay for this thing. But, that's just a guess. If you know the real answer, I'd love to hear it.
According to the wake county property tax site, each of the 4 lots pay about $1k per year. The non-profit will be paying payroll tax for any employees and the employees themselves will be subject to income tax. The net result will certainly be an increase in tax collection.
Pretty much any program to "buy local" is a net benefit to the community.
Bill -
Like I said - as long as someone is buying the land with their money, paying their expenses without subsidy, and reaping the benefits or downfall of the investment on their own, I support whatever they are doing. But if any part of this is subsidized in any way, then it's just another feel-good waste of money. I'll keep buying my EVIL TOMATOES from Harris Teeter.
fur trapping is a skill that more people are going to find necessary in the coming years
well said, gspot.
I propose that Moore Square be turned into urban hunting grounds.
Well said, Fur Trapper!
Don't tread on me.
I propose that Moore Square be turned into urban hunting grounds.
well said, Fur Trapper Jim.
Wow that sure is a lot of comments for something so non-threatening. Troll, you raise an interesting point about non-profits in general, but most of them are churches and charities. Not really a liberal/conservative issue. I'm sorry you don't like small farms. I think it sounds like a cool idea. It's not like a lot of revenue is coming out of a vacant lot anyways. Besides, you gotta spend money to make money. If neat things like this help bring people downtown to live or visit, or that's tax revenue right there.
I love when people complain about their ''hard-earned'' tax dollars being used on frivilous things. I find it amusing. We live in America and I'm guessing your quality of life isn't so awful after all especially in respects to other parts of the world. I am so tired of this debate of private vs. public sector and taxes vs. no taxes. It's just old. We live in enough of a civilized country that we have to balance the independent "don't tread on me" spirit of capitalism with the humanistic qualities of socialism. However the problem is no one will ever be satisfied! I know you tea partier types do not want to go down any sort of socialism road but guess what…TO LATE! In fact your whole lifetime you have lived in a semi-socialist society. We have public schools, police departments, public court systems that we all pay for!
That being said the idea of urban farming has been successful in other parts of the country and mabye it will do well here, and mabye it won't. Regardless I find it bold, and creative of enough idea to try and I seriously doubt it will effect one single penny of my tax dollars and if it does I DON'T Care. I trust the government more now than I do greedy corporations who run their companies into the ground and yet run crying to the government wanting a bail out.
And this urban hunting ground idea…Why don't you be more direct? What exactly would you like to hunt there? I wish you crazies would have some nuts and say what you really want to say, that way us people on the side of sanity and humility can just stop reading, roll our eyes and move on to a comment that is on the side of reason.
Uh-oh, ivanscorp…you said the new magic word that makes a certain segment of the population lose their minds: that "s" word.
As for the actual topic: I don't quite get the downtown farm idea, but it seems better than an empty lot, so I say have at it.
Y'all, stop feeding the troll. Ignore him and he'll get bored and go harass some other innocent blog.
I think this is great news. If that location doesn't work out for whatever reason, I would encourage the organizers to look for spots on South Wilmington Street or Rush Street just south of downtown. That's an area that could use some creative development.
It's a small farm. Chill out.
I'm sorry but I really can't stand Conservatives like that hot-head 'renegade' up a few posts. Maybe use their hard-earned dollars and deport them so we can move forward?
well said aaron. i agree that when cooler heads prevail, all conservatives will be deported.
Aaron…if you deport all conservatives, who will pay for your farm?
I'm assuming it would be Raleigh City Farm. How many times shall it be said until it gets through your thickened skull?
This is a great idea. Limbaugh Jr. here repeatedly assumes they're buying the land but that's idiotic. He only assumes that because he's an idiot with no business sense. I'll assume that developers will continue to own the land and this would be leased as a farm until the free market determines the land is more valuable for development. So, let the idiots eat their "Evil Tomatoes" from Harris Teeter, the ones subsidized by the Federal Government, picked by illegal aliens, and shipped on the Federal Interstate system using fuel from big oil. Mr. Free Market Renegade is so contradictory that he seems to have been created by the same performance artist that created Fred Phelps.
I agree Mr Wingnut is contradictory and not the brightest bulb but you should refrain from using insults like "idiot". It only diminishes your argument.
Alton's response, I hope, will be the end of this controversial and heated debate about a small farm. This, ladies and gentlemen, is the state of our country these days wrapped up in a single news post.
bill, i agree the teabagger is an idiot, but i think you should refrain from using insults like "wingnut." it only diminishes your argument.
Doesn't the Farmer's Market already serve this need? I support a city farm concept but I'm concerned it will add to the hardships currently experienced by our local farmers. Seriously, if the idea was that good wouldn't free enterprise have already done it?
Have to agree with freemarketrenegade on this one. Uh, why do libtards always acuse someone of "hating" when they posit a viewpoint opposite their own. Pot, let me introduce you to kettle. I'll admit, I am a hater, I hate liberals and commies but don't NEED to call them names to make them feel small. All I have to do is ask them to explain their positions using reason and logic. It's at this point when a bunch of "uhs" and "ums" and "wells," spew forth with the occasional spittle missile when they finally let loose with invectives like "Nazi" or "teabagger." Where are all the Daniel Patrick Moynihan liberals that actually have a brain and could at least get their ideas across without stuttering? You know, if all the hipster greenies that will be working this place (wearing hemp coolies?) owned their own property they could each build their own garden without any chance of costing the city tax revenue.
P.S. Earth to "Bill," there is no such thing as Wake County income tax.
I don't know b-fuss. Perhaps the same reason you began your post with name-calling and then criticized others for doing the same?
At least you make it easy on us. Posts containing political name-calling never have any content.
Personally, I think it's an encouraging sign that we are now closing, hopefully, the disconnect between us, our food, and where it comes from. I have seen these 'urban farms' at work in places like Detroit. Not only does it provide some greenery in a concrete jungle or on an old, forgotten lot, but it is actually doing something that is renewable: it is providing locally grown food to the city around it. In addition, it should also bring the city and especially the neighborhood together. I believe, as a liberal, that this is a positive and progressive thing to have happen, and I hope to see more of it in the future. I believe that it is good for our country, not only saving us money and trips to supermarkets (where most of the food is actually foreign) and costs related to shipment, it is good that we are buying things not only grown on our soil, but grown on the soil of our city and on the soil of our neighborhood.
you people are really ridiculous.
Yeah, it's good that Detroit was once the third largest city in the country, with an economy bigger than some countries, built half the cars sold in the world, produced some of the greatest music ever heard. But hey, it's on the rebound- growing tomatoes next to the crack house.
b-fuss, don't hate on our urban sharecropping dreams
So excited about this. Can't wait to get involved.
Fantastic idea! I love how the trolls come out whenever something that is a no-brainer is suggested in this universe.
Next, similar farms/gardens need to be started in the poorer neighborhoods so children can grow up eating at least a little healthy, learn where actual food comes from, learn to work as a team with their neighbors, and on and on.
I hope it works out and they can move Raleigh forward a small step.


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Chapter 12: Our Investors Would Expect No Less
Conditions at Monowitz and I.G. Auschwitz were a living nightmare. They were exploited, as one Nazi bigwig put it, "to the highest possible extent at the lowest possible expenditure." (53) Truth be told, it was even worse than that. You could get a lot of work out of a slave over the course of the slave's long life - America did it with black "slaves" before and black "criminals" today. But the "slaves" at I.G. Auschwitz were quickly worked to death. It was not slave labor, it was death labor.
Slave Labor at the Gate of Auschwitz Concentration Camp
Group of women prisoners march to forced labor. (1943 - 1944)
The diet was designed to kill you from exhaustion in three months - less if you were weak or sick. A Buna plant worker and Auschwitz escapee vividly described the work conditions:
"(our working place) was divided into small sectors of 10 x 10 posts, each guarded by an SS man. Whoever stepped outside these squares during working hours was immediately shot without warning for having "attempted to escape." Often it happened that out of pure spite an SS man would order a prisoner to fetch some given object outside his square. If he followed the order, he was shot for having left his assigned place. The work was extremely hard and there were no rest periods. The way to and from work had to be covered at a brisk military trot; anyone falling out of line was shot. ... Very few could bare the strain and although escape seemed hopeless, attempts were made every day. The result was several hangings a week." (54)
Fritz ter Meer
"Forced labor did not inflict any remarkable injury, pain, or suffering on the detainees, particularly since the alternative for these workers would have been death." (55)
Fritz didn't bother to mention the fact that I.G.'s campaign contributions, the anti-Semitic and authoritarian examples they set and prototype concentration camps they conceived in WWI were the main factors in limiting their present "detainees" options so dramatically.
(53) ibid, p 154
(54) ibid, p. 144
(55) www.health4us.org/codex.html, see also: 18.104.22.168/archivsite/Documents/goeson.htm


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American Depositary Receipt
American Depositary Receipt (ADR) is known as a negotiable certificate issued by an american bank stating that a number of stocks in the overseas firm has been deposited with them. receipt can be exchanged in United states stock markets. Instead of having to buy stocks of 'foreign stocks 'of foreign companies in foreign stock markets. People in america can buy them in the united states in the form of ADRs, that are bought and sold (exchanged) in New York Stock Exchange.
Each and every ADR is distributed by a US depository bank and can represent a part of a share, just one share, or several shares of foreign stock. An owner of the ADR has the authority to obtain the foreign share it represents, but United states traders generally find it more convenient simply to own the ADR. The price of an ADR is usually near to the price of the foreign share in its home stock market, modified for the ratio of ADRs to foreign firm stocks.
Depository banks have a number of obligations for an ADR holder and also to the non-US company the ADR represents. The 1st ADR had been released by JPMorgan in 1927, to the Uk retailer Selfridges&Co. The biggest depositary bank is the Bank of New York Mellon.
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and carried a large green stick with which he touched the fish, saying in a terrible voice, ' Fish, fish, are you doing your duty?' To these words the fish lifting up their heads replied, ' Yes, yes. If you reckon, we reckon. If you pay your debts, we pay ours. If you fly, we conquer, and are content.'
The black slave overturned the pan in the middle of the room, and the fish were turned to cinders. Then he stepped proudly back into the wall, which closed round him.
' After having seen this,' said the Sultan, ' I cannot rest. These fish signify some mystery I must clear up.'
He sent for the fisherman. ' Fisherman,' he said, ' the fish you have brought us have caused me some anxiety. Where did you get them from ? '
' Sire,' he answered, 'I got them from a lake which lies in the middle of four hills beyond yonder mounŁtains.'
' Do you know this lake ? ' asked the Sultan of the grand-vizir.
' No; though I have hunted many times round that mountain, I have never even heard of it,' said the vizir.
As the fisherman said it was only three hours' journey away, the Sultan ordered his whole court to mount and ride thither, and the fisherman led them.
They climbed the mountain, and then, on the other side, saw the lake as the fisherman had described. The water was so clear that they could see the four kinds of fish swimming about in it. They looked at them for some time, and then the Sultan ordered them to make a camp by the edge of the water.
When night came the Sultan called his vizir, and said to him, ' I have resolved to clear up this mystery. I am going out alone, and do you stay here in my tent, and when my ministers come to-morrow, say I am not well, and cannot see them. Do this each day till I return.'


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'Is it summer already? Oh no! The warmth now would just be unbearable.' Is this what your response is when summer season knocks the doorway? Nicely, it's not just you! Individuals generally do not like the summer season time because of the severe heat. So what's the resolution to this? Is there a way to preserve your self as well as your family away in the tough heat? Or is there at least any retreat to assist you endure the sunlight?
Nicely there is certainly! There's a thing to cool you down; to create you as well as your family members to possess entertaining, specially inside the summer season. Your kids will really like it towards the core. It's none aside from water slides. The slides are a fantastic solution to awesome during the summer season. Kids appreciate to engage in with it; to get on from a single aspect then slide down the other. No party seems complete within the summer season, devoid of the h2o slides in presence.
On the other hand, you can find several issues in regards to the materials of h2o slides. H2o slides created from metal or concrete will for certain come to be warm as well as your youngsters could possibly get the burn up. So, these are a no-no. What exactly is the choice then? Well, what you need could be the inflatable drinking water slides. These usually are not only warmth resistant, but can also be uncomplicated on your kids. They are delicate to engage in with; for the children to go up and down. There's no likelihood that your children will get harm taking part in on an inflatable water slide (that is a significant issue with steel or concrete ones).
The permanent slides are created from fiberglass or metal and there is a great likelihood that your kid could get hurt. The inflatable slides, on the other hand, are produced up of vinyl, that is hard sufficient for your kids to climb on, but is smooth adequate that they can't get hurt. Bounce houses are created from exactly the same material, so you can come up with a mental calculation.
Now, the question that arises is, really should you get a drinking water slide or really should you lease it? Nicely, renting is undoubtedly the solution. There are many advantages to renting a h2o slide than purchasing. The lease, even if you lease it year soon after calendar year, would nevertheless be more affordable than the price of the water slide. You may argue that 1 can acquire it at discount stores, but individuals are not of incredibly great top quality and you certainly do not desire to compromise on anything for your youngsters. That is just a single cause to lease. The top portion is however to come back!
The moonwalk rental organization, as soon as the rental time period is more than, will just take again all the equipment with them, and thus you are going to not must thoroughly clean it or anything. Also, the biggest benefit is that, you do not have to retailer it. You will not need to have your garage blocked or your basement packed mainly because there is certainly an additional slide to take care of.
Which means you see, there's absolutely nothing stopping you from experiencing the water slides within the summer season, not even room problems. Just rent 1 now, and return it following the summers. Happy Sliding!
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You may refer your patient to our practice by calling and asking for our referral specialist at 541-618-4400 or toll free at 877-261-8074
between 8:30 a.m. to 12 p.m. and 1:00 p.m. to 5 p.m., Monday through Friday. Our receptionists are trained to triage to the appropriate specialist.
If you know the specific physician you wish to refer your patient, please ask for him or her directly.
After receiving your referral, our referral specialist will call your patient to schedule an appointment. We will make every effort to see your
patient within a week or two of your referral. Urgent cases will be scheduled within 24 hours.
Please contact the appropriate physician by telephone, fax, or e-mail in advance of your patient's appointment to provide any necessary background information.
Toll free: 877-261-8074
Before your patient's first visit to Renal Care Consultants, we need to review his or her records and any relevant diagnostic test results.
These include past hospitalization summaries, previous laboratory and radiology evaluations,
and summaries of consultations and outpatient visits. Click here to visit our Medical Records section.
When referring a patient to us, provide at least twelve months of chart notes and labs for all of our Nephrologists.
If a renal or abdominal ultrasound has been performed, please also send these results.
Please send these records prior to making the appointment for your patient, as it will considerably decrease
the calls we make to your office requesting such records. If that isn't possible due to dictation time frames,
we request records be here three days prior to the patient's first appointment.
If you have seen your patient for less than six months, please indicate this on your cover letter to us.
Otherwise, our staff will make unnecessary calls to your office.
If we are unable to obtain the records from the referring physician by the day before the appointment,
we will need to reschedule the patient's appointment for a time when records can be made available to the consulting physician.
Click here to visit our Medical Records section.
The Patients section of our website has helpful information to assist your
patient in preparing for his or her appointment. As soon as your patient's first appointment is scheduled, we will send him or her
our "New Patient" packet, which includes directions to our office. You can print maps by clicking here.
Your patient can download our forms here
We want to ensure you continue to be an active participant in your patient's care.
We will provide frequent and complete feedback to referring physicians on patients' progress.
Unless other arrangements are made, your patients will return to you for continuing management after the renal problem has been treated.
If at any time you have questions about your patient's treatment or would like a consultation,
please do not hesitate to call or e-mail the doctor supervising his or her care.
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Eldad Hagar, who has a passion for our four-legged friends and their well-being, started rescuing animals off the streets at an early age. When he moved to Los Angeles, he quickly became aware of the pet overpopulation problem and founded Hope for Paws, a nonprofit organization dedicated to help save the lives of homeless animals. http://www.HopeForPaws.org
"We rescue dogs and all other animals who are suffering on the streets and in the shelters," said Hagar. "Our goal is to change the lives of these animals, place them in loving forever homes, and educate people on the importance of companion animals in our society."
One of his latest rescues is of Houdini, a Chihuahua Rat Terrier mix who was living on the docks at the Port of San Pedro for years before Hope for Paws stepped in to save him. Once a helpless dog, living on scraps and afraid of people, Houdini is now loving life, and awaiting a forever home. http://bit.ly/HoudiniRescue1
Abandoned in rivers, thrown out on highways, or discarded in dumpsters… these are some of the stories Hope for Paws receives daily. Without a minute's notice, Hagar is out the door and off on his rescue mission. No matter what time of day or night, he's saving the lives of others, one paw at a time.
This holiday season, let's all give some hope and joy to these often forgotten creatures by supporting Hope for Paws.


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Tips For A Perfect Bathroom Remodel
A bathroom remodel can be one of the most challenging yet rewarding projects you'll ever undertake as a home owner. With any remodel planning is key, researching your remodel is the obvious first step. One of the essential questions to ask yourself when starting a remodel is "can I adapt to change", being flexible is incredibly important at this stage.
First and foremost you should analyze your budget. This project will have a huge impact on your wallet in the form of materials, labor and time. When you understand the details you can set limits for spending and try to maintain your budget. It will also help you determine just what you can afford.
Plan to have everything ordered and on site before you begin your project. Large things such as the can take weeks to get there and patience is key before you've even swung a hammer. Fixtures may take an especially long time to get there so keep in mind when ordering and if an item is custom, figure that into your arrival times as well.
Once your materials have arrived you can consider the choices available to you. There are a multitude of designs, materials, patterns, countertops and other fixtures at your disposal. The big box stores will have standardized options, so keep that in mind, if you want custom work that may be a special order item or take a trip to a more specialized outlet. Shopping online can be another option, the internet can connect you to a variety of artists who do amazing work.
Modern options include built-ins for shower storage – these are increasingly popular in bathrooms today. A storage built-in is a nook that is made into the wall of the shower, it is designed to hold shampoos and toiletries and these replace the cheaper plastic options. If storage is your main goal for your remodel consider adding shelving to your bathroom as well.
If you run into a wall, so to speak, your best bet will be to consult a professional. You shouldn't under estimate an expert opinion and it may be worth the expense to hire a contractor to work on a portion of your remodel. While the upfront cost may be more than you want to spend you will save yourself the headache and time of an imperfect remodel.
Keep in mind the nature of your project, if your budget is cause for concern you can also work on the remodel in stages. You'll want to keep in mind the use of the bathroom, will you be replacing essential fixtures like the toilet or shower? If you do replace these items you will need to do so quickly to get them back into service quickly especially if you only have one bathroom to use.
Ultimately when you take on a remodel project it will become all-consuming project that dominates your life while you're undertaking it. You must be prepared for your life to be turned a bit upside down during the process however if you stick with it and see it through the result will be worthwhile.


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Nothing in cancer makes sense except…
Mel Greaves
BMC Biology 201816:22
https://doi.org/10.1186/s12915-018-0493-8 © Greaves et al. 2018
Published: 21 February 2018
Source/Fonte: Cancer Research UK
Paraphrasing Dobzhansky's famous dictum, I discuss how interrogating cancer through the lens of evolution has transformed our understanding of its development, causality and treatment resistance. The emerging picture of cancer captures its extensive diversity and therapeutic resilience, highlighting the need for more innovative approaches to control.
FREE PDF GRATIS: BMC Biology


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With Pitsford Water hosting the Old Town Canoes and Kayaks Pitsford Kayak Grand Slam later this year, part of the Lowrance Grand Slam series I thought it would be good to have a practice day at the mini meet organised by fellow team member Dane.
The trip's aim was to go after the predators that the reservoir is well known for. A 38lb pike is reputed to live there. It's fantastic that Anglian Water, have the foresight to welcome kayak anglers on this water allowing us to show that we are responsible anglers and demonstrating what a forward thinking management they have there. After the obligatory kayak wash at the gate, payment of fees and the unavoidable addition of just a few extra shiny things from their well stocked shop it was time to kit up right next to the water.
To comply with Anglian Water's biosecurity policy nets and drogues should be washed prior to fishing and again after, at the venue, to ensure you don't bring or take anything away. The prevention of non native invasive species is the aim.
It wasn't the trial I had been hoping to give the Railblaza Sandtrakz wheels but it was a chance to show then off and try them with both a stripped and loaded kayak on. I wondered if it was just my imagination that they were easier to pull even on the gravel and grass but it was confirmed by one of the Hobie team fisherman too.
I kitted the Old Town Predator 13, realised I'd left my cameras at home and paddled out under the causeway bridge, remembering to lay my rods down. With a stiff breeze across the reservoir I decided to paddle up to the Dam wall and then drift the full length back. It seems this was the plan of the only other member of the group who paddled, Simon Adams, the rest having pedals or motors. Stopping on the way to throw lures into the margins or chat with the others.


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The muddle of my life...
Love these images . . . and the saying!!
Thanks Lindsey, it's a Chico Marx quote that I love. It's just the right balance of humour and sweetness.
The title for this post made me laugh. And I've never seen Australia (nor do I intend to) but that photo of Nicole and Hugh gives me that swoony, kicked in the gut, Mills and Boons feeling :)


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Skiing in Singapore
Sometimes it's nice to take a break and code up a solution to a small, fun problem. Here is one some of our engineers enjoyed recently. It's called Skiing In Singapore.
Well you can't really ski in Singapore. But let's say you hopped on a flight to the Niseko ski resort in Japan. Being a software engineer you can't help but value efficiency, so naturally you want to ski as long as possible and as fast as possible without having to ride back up on the ski lift. So you take a look at the map of the mountain and try to find the longest ski run down.
In digital form the map looks like the number grid below.
4 4
4 8 7 3
2 5 9 3
6 3 2 5
4 4 1 6
The first line (4 4) indicates that this is a 4x4 map. Each number represents the elevation of that area of the mountain. From each area (i.e. box) in the grid you can go north, south, east, west - but only if the elevation of the area you are going into is less than the one you are in. I.e. you can only ski downhill. You can start anywhere on the map and you are looking for a starting point with the longest possible path down as measured by the number of boxes you visit. And if there are several paths down of the same length, you want to take the one with the steepest vertical drop, i.e. the largest difference between your starting elevation and your ending elevation.
On this particular map the longest path down is of length=5 and it's highlighted in bold below: 9-5-3-2-1.
4 4
4 8 7 3
2 5 9 3
6 3 2 5
4 4 1 6
There is another path that is also length five: 8-5-3-2-1. However the tie is broken by the first path being steeper, dropping from 9 to 1, a drop of 8, rather than just 8 to 1, a drop of 7.
Your challenge is to write a program in your favorite programming language to find the longest (and then steepest) path on this map specified in the format above. It's 1000x1000 in size, and all the numbers on it are between 0 and 1500.
Send your code or a github link (and a resume if you like) to [?????? at redmart dot com], replacing "??????" with the concatenation of the length of the longest path with the largest drop, and the size of the drop. So in the simple example above length=5, drop=8, so the email address would be [58 at redmart dot com]. If your e-mail gets through - you got the right answer.
Good luck and have fun!


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Substantial Presence Test vs. 330 Day Rule (SFOP) – Streamlined Foreign Offshore
- 1 A Few Key Points
- 2 Streamlined Foreign Offshore Procedures (SFOP)
- 3 Benefits of SFOP
- 4 Qualifying as a Foreign Resident
- 5 Understanding Substantial Presence Test. (SPT)
- 6 Who Qualifies under the Substantial Presence Test?
- 7 Summary of Substantial Presence Test
- 8 Tax Liability – Substantial Presence Test
- 9 Substantial Presence Test – Exception
- 10 330-Day Foreign Resident Rule
- 11 Applying the 330-day Non-Resident Rule
- 12 What if the Years were Staggered?
- 13 BOTH Spouses Must Meet the requirements
- 14 SFOP Blog — (Part 1 of 2)
- 15 Want to Learn More about Offshore Disclosure?
- 16 When Do I Need to Use Voluntary Disclosure?
- 17 Golding & Golding – Offshore Disclosure
- 18 The Devil is in the Details…
- 19 What if You Never Report the Money?
- 20 Getting into Compliance
- 22 2. Streamlined Domestic Offshore Disclosure
- 23 3. Streamlined Foreign Offshore Disclosure
This post is designed to be the first in a two-part series Re: Streamlined Foreign Offshore Procedures involving some of the key nuances involved in meeting the requirements as a foreign resident vs. non-resident.
Before discussing the ambiguity of the current vs. former U.S. Citizen description in the 14653 (IRS Streamlined Foreign), it is important to understand the two different tests being used to evaluate non-residence: 330-Day Non-Resident vs. Substantial Presence Test (SPT).
A Few Key Points
The requirements for showing you are a Non-Resident under the Substantial Presence Test are different than showing that you are a U.S. Person who meets the "Non-Resident" test for the Streamlined Foreign Offshore Procedures (SFOP) – aka lived abroad for at least 330-days in any one tax year.
The 330-day Foreign Earned Income Exclusion (FEIE) Physical Presence Test is not the same as the 330-day U.S. Non-Resident Rule under Streamlined Filing Compliance Procedures. And, just because you meet the FEIE Physical Presence Test does not mean you will necessarily meet the U.S. Non-Resident Rule Under Streamlined Filing Compliance Procedures.
Streamlined Foreign Offshore Procedures (SFOP)
We write about SFOP often, because it is a great program. In fact, out of all the different options an individual may have when they have not properly reported or disclosed their offshore accounts, offshore investments, offshore income, foreign retirement, and/or other non-US-based assets – the Streamlined Foreign Offshore Procedures may be the best possible option.
Why? First, it is one of the approved "Streamlined Programs," which means there are much more lenient requirements in terms of the reporting the tax responsibilities for the applicant than there are under traditional OVDP. Moreover, the penalties are waived, and the submission process is relatively less stressful than a full blown OVDP — or even Streamlined Domestic.
Benefits of SFOP
Some of the benefits of SFOP are the following:
3 Years of Tax Returns
Unlike traditional OVDP in which a person must amend or file original returns for eight years (8), under the Streamlined Foreign Offshore Procedures a person is only required to amend or file original returns for three (3) years.
**Under Streamlined Domestic Offshore Procedures, a person must have filed timely (including extensions) tax returns to qualify for the program, but under streamlined foreign that is not required. In other words, a person may file original returns using the Streamlined Foreign Offshore Procedures.
6 Years of FBARs
Under the Streamlined Foreign Offshore Procedures, a person must only file six (6) years FBARs instead of eight (8) years. The reason for requiring six years is because — short of the IRS proving fraud," the IRS is limited to a six year statue limitations to go back and audit a person for Tax and FBAR related matters.
All Penalties Waived
This is the best part of the program – there is no penalty. That means there is no penalty on the outstanding balance and there is no penalty on the taxes that are due each year. Under the Streamlined Domestic Offshore Procedures the penalties are 5%, and under traditional OVDP, the penalties can reach as high as 50% – along with an annual penalty for each year there is unreported tax.
Qualifying as a Foreign Resident
Aside from the requirement that a person prove he or she is non-willful — which is entirely different discussion for another day — (Click Here for a Comprehensive article on Willful vs. Non-Willful) – a person must prove they resided outside of the United States in order to qualify. Depending on whether a person is considered to be a US resident or nonresident will make the difference between which test they must meet, in which elements they must prove.
The first test as for nonresidents and that is called the Substantial Presence Test. (SPT)
Understanding Substantial Presence Test. (SPT)
The United States is one of the only countries in the world the practices Citizen-Based Taxation (CBT). In other words, the United States taxes US persons on their worldwide income.
When a person is a U.S. Citizen, Legal Permanent Resident ("Green Card Holder"), or long-term Legal Permanent Resident who did not properly relinquish their Green Card, a person will be taxed on all of the income they earn worldwide. It does not matter if they earned the income while living in the United States or abroad. It also does not matter whether the income is sourced in the United States or outside the United States – it must be reported on the US tax return.
Who Qualifies under the Substantial Presence Test?
The Substantial Presence Test takes the matter one step further, in order to tax individuals who are neither a U.S. Citizen, Legal Permanent Resident ("Green Card Holder"), or long-term Legal Permanent Resident who did not properly relinquish their Green Card. Even if a person does not meet one of the aforementioned U.S. Citizen/Resident categories, but meets a certain "Resident Test "- he or she will have to pay tax on their worldwide income in the United States just as it they were a U.S. Person
Usually, it will involve individuals who are in the United States on a work visa. For example, David was transferred to the United States by his company on an L-1 visa. As a result, even though David may have no intention of trying to obtain U.S. Legal Permanent Residency, if he meets the substantial presence test that you will have to pay tax on his worldwide income.
For David, the tax results will be catastrophic. Why? Because in David's home country of Hong Kong, the country does not tax individuals on their passive income. David has amassed a significant nest egg abroad, and is earning upwards of 8% on $2 million he has saved in his bank account. While that money cannot be taxed by Hong Kong, the United States can tax his "worldwide income" which would include the hundred and $160,000 a year he is earning in interest income.
**Since Hong Kong does not tax this category of income, David would have no tax credits to apply to reduce his tax liability – as opposed to Australia for example where individuals are tax similar to the United States.
Summary of Substantial Presence Test
As a non-US citizen and non-US green card holder, you are generally only required to pay tax on your "US Effectively Connected Income" (money you earn while working in the United States). However, if you qualify for the Substantial Presence Test, then the IRS will tax you on your WORLDWIDE income.
IRS Substantial Presence Test generally means that you were present in the United States for at least 30 days in the current year and a minimum total of 183 days over 3 years, using the following equation:
- 1 day = 1 day in the current year
- 1 day = 1/3 day in the prior year
- 1 day = 1/6 day two years prior
Example A: If you were here 100 days in 2016, 30 days in 2015, and 120 days in 2014, the calculation is as follows:
- 2016 = 100 days
- 2015 = 30 days/3= 10 days
- 2014 = 120 days/6 = 20 days
- Total = 130 days, so you would not qualify under the substantial presence test and NOT be subject to U.S. Income tax on your worldwide income (and you will only pay tax on money earned while working in the US).
Example B: If you were here 180 days in 2016, 180 days in 2015, and 180 days in 2014, the calculation is as follows:
- 2016 = 180 days
- 2015 = 180 days/3= 60 days
- 2014 = 180 days/6 = 30 days
- Total = 270 days, so you would qualify under the substantial presence test and will be subject to U.S. Income tax on your worldwide income, unless another exception applies.
Tax Liability – Substantial Presence Test
Once a person meets the substantial presence test, they are required to report their worldwide income in the United States on a 1040 instead of at 1040 NR. Depending on any tax treaties the United States has with any particular country, the foreigner may find himself or herself under heavy tax scrutiny by the United States.
Substantial Presence Test – Exception
There is an exception to this filing rule, depending on the purpose of the foreigner being in the United States and what role/job the person is doing in the United States.
The IRS provides the following involving the substantial presence exception:
Exempt Individual
Do not count days for which you are an exempt individual. The term "exempt individual" does not refer to someone exempt from U.S. tax, but to anyone in the following categories:
- An individual temporarily present in the U.S. as a foreign government-related individual under an "A" or "G" visa, other than individuals holding "A-3" or "G-5" class visas.
- A teacher or trainee temporarily present in the U.S. under a "J" or "Q" visa, who substantially complies with the requirements of the visa.
- A student temporarily present in the U.S. under an "F," "J," "M," or "Q" visa, who substantially complies with the requirements of the visa.
- A professional athlete temporarily in the U.S. to compete in a charitable sports event.
If you exclude days of presence in the U.S. for purposes of the substantial presence test because you were an exempt individual or were unable to leave the U.S. because of a medical condition or medical problem, you must include Form 8843, Statement for Exempt Individuals and Individuals With a Medical Condition, with your income tax return. If you do not have to file an income tax return, send Form 8843 to the address indicated in the instructions for Form 8843 by the due date for filing an income tax return.
If you do not timely file Form 8843, you cannot exclude the days you were present in the U.S. as an exempt individual or because of a medical condition that arose while you were in the U.S. This does not apply if you can show, by clear and convincing evidence that you took reasonable actions to become aware of the filing requirements and significant steps to comply with those requirements.
Closer Connection Exception to the Substantial Presence Test
Even if you passed the substantial presence test you can still be treated as a nonresident alien if you qualify for one of the following exceptions;
- The closer connection exception available to all aliens. Please refer to Conditions for a Closer Connection to a Foreign Country.
- The closer connection exception available only to students. Please refer to The Closer Connection Exception to the Substantial Presence Test for Foreign Students and Sample Letter.
330-Day Foreign Resident Rule
Unlike the Substantial Presence Test, the Streamlined Foreign Offshore Procedures "Non-Resident Test" for U.S. Persons is much different – and much more stringent. Why? Because the United States government does provide as much deference to individuals who are considered citizens or permanent residence and therefore "should have known the rules."
Under these circumstances, the person must meet a very strict 330-day rule.
Applying the 330-day Non-Resident Rule
It is almost as simple as it sounds – a person must have resided outside the United States (in either one country or multiple countries) for at least 330 days in any one of the three years being included in the tax submission, and without having a U.S. Abode.
Example: Scott is originally from California but was transferred to Singapore for five (5) years by his company to run research operations for his company. He brought his family with him, and therefore did not come back to the United States at all during the five-year time period. This would be an example of someone who lived outside the United States for at least 330 days.
What if the Years were Staggered?
Without getting too complicated, the 330-Day rule for the Streamlined Foreign Offshore Procedures is not the same as the 330-Day rule for the Foreign Earned Income Exclusion.
To qualify under the streamlined foreign, a person must have been outside of the United States for at least 330 days in any one or more of the most recent three years for which the tax return due date has already passed – and there must not be any abode in the United States.
In other words, it includes a full tax year. So for the example above, Scott would have no issue. On the other hand, let's say Peter lived outside of the United States for 330 days, but the years were staggered so that he was outside United States from May 2014 to April 2015. Even though he was outside the United States the 330 days it was not in one of the most recent three taxes – rather, it was staggered over to tax years and generally will not qualify.
**With that said, each individual has different circumstances and the IRS has been known to bend or lean in certain situations and so it never hurts to contact the IRS and ask them (anonymously, through your counsel) whether the IRS may allow for a variance.
BOTH Spouses Must Meet the requirements
Under either circumstance, both spouses must meet the requirement to qualify for streamlined foreign. Therefore, using the 330-day rule, if one spouse lived outside the United States for 340 days, and the other spouse only lived outside for 320 days, they would not meet the test as to the spouse who lived outside the United States for only 320 days.
Rather, the spouse who did not meet the residence requirement would have to submit under a different program, and if she used the Streamlined Domestic Offshore Procedures, she would have to submit under the streamlined domestic offshore procedures and could be subject 5% penalty.
**Important to note, is that only the person who has interest in the money is penalized. Therefore, if all of the money belongs to the one spouse who lives outside of the United States and meets the foreign resident requirement than that spouse would have no penalty on that money.
Example: Dean lived outside the United States for 340 days. He earned significant income abroad, and has a foreign account with $3 million. His spouse is not identified on the account and none of the money belongs to her (also, they do not live in a community property state). Therefore, even though his spouse does not meet the foreign resident requirement, the penalty may still be waived as to Peter.
SFOP Blog — (Part 1 of 2)
This is part one of a two-part posting on the Streamlined Foreign Offshore Procedures. The next part of this post will deal specifically with the ambiguity regarding whether a person is currently a US person, but was not a US person during the first one or two years of the three year tax reporting requirement — (such as an F-1 who is now a U.S. Person)
Want to Learn More about Offshore Disclosure?
Offshore Voluntary Disclosure Tax law is very complex. There are many aspects that go into any particular tax calculation, including the legal status, marital status, business status and residence status of the taxpayer.
When Do I Need to Use Voluntary Disclosure?
Voluntary Disclosure is for individuals, estates, and businesses who are out of compliance with the IRS and the Department of Treasury. What does that mean? It means that if you are required to file a U.S. tax return and you don't do so timely, then you are out of compliance.
If the IRS discovers that you are out of compliance, you may become subject to extensive fines and penalties – ranging from a warning letter all the way up to tax liens, tax levies, seizures, and criminal investigations. To combat this, you can take the proactive approach and submit to Voluntary Disclosure.
Golding & Golding – Offshore Disclosure
At Golding & Golding, we limit our entire practice to offshore disclosure (IRS Voluntary Disclosure of Foreign and U.S. Assets). The term offshore disclosure is a bit of a misnomer, because the term "offshore" generally connotes visions of hiding money in secret places such as the Cayman Islands, Bahamas, Malta, or any other well-known tax haven jurisdiction – but that is not the case.
In fact, any money that is outside of the United States is considered to be offshore; the term offshore is not a bad word. In other words, merely because a person has money offshore (a.k.a. overseas or in a foreign country) does not mean that money is the result of ill-gotten gains or that the money is being "hidden." It just means it is not in the United States. Many of our clients have assets and bank accounts in their homeland countries and these are considered offshore assets and offshore bank accounts.
The Devil is in the Details…
If you do have money offshore, then it is very important to ensure that the money has been properly reported to the U.S. government. In addition, it is also very important to ensure that if you are earning any foreign income from that offshore money, that the earnings are being reported on your U.S. tax return.
It does not matter whether your money is in a country that does not tax a particular category of income (for example, many Asian countries do not tax passive income). It also does not matter if you are a dual citizen and/or if that money has already been taxed in the foreign country.
Rather, the default position is that if you are required to file a U.S. tax return and you meet the minimum threshold requirements for filing a U.S. tax return, then you have to include all of your foreign income. If you already paid foreign tax on the income, you may qualify for a Foreign Tax Credit. In addition, if the income is earned income – as opposed to passive income – and you meet either the Bona-Fide Resident Test or Physical-Presence Test, then you may qualify for an exclusion of that income; nevertheless, the money must be included on your tax return.
What if You Never Report the Money?
If you are in the unfortunate position of having foreign money or specified foreign assets that should have been reported to the U.S. government, but which you have not reported — then you are in a bit of a predicament, which you will need to resolve before it is too late.
As we have indicated numerous times on our website, there are very unscrupulous CPAs, Attorneys, Accountants, and Tax Representatives who would like nothing more than to get you to part with all of your money by scaring you into believing you are automatically going to be arrested, jailed, or deported because you have unreported money. While that is most likely not the case (depending on the facts and circumstances of your specific situation), you may be subject to extremely high fines and penalties.
Moreover, if you knowingly or willfully hid your foreign accounts, foreign money, and offshore assets overseas, then you may become subject to even higher fines and penalties…as well as a criminal investigation by the special agents of the IRS and/or DOJ (Department of Justice).
Getting into Compliance
There are five main methods people/businesses use to get into compliance. Four of these methods are perfectly legitimate as long as you meet the requirements for the particular mechanism of disclosure. The fifth alternative, which is called a Quiet Disclosure a.k.a. Silent Disclosure a.k.a. Soft Disclosure, is ill-advised as it is illegal and very well may result in criminal prosecution.
We are going to provide a brief summary of each program below. We have also included links to the specific programs. If you are interested, we have also prepared very popular "FAQs from the Trenches" for FBAR, OVDP and Streamlined Disclosure reporting. Unlike the technical jargon of the IRS FAQs, our FAQs are based on the hundreds of different types of issues we have handled over the many years that we have been practicing international tax law and offshore disclosure in particular.
After reading this webpage, we hope you develop a basic understanding of each offshore disclosure alternative and how it may benefit you to get into compliance. We do not recommend attempting to disclose the information yourself as you may become subject to an IRS investigation insofar as you will have to answer questions directly to the IRS, which you can avoid with an attorney representative.
If you retain an attorney, then you will get the benefit of the attorney-client privilege which provides confidentiality between you and your representative. With a CPA, there is a relatively small privilege which does provide some comfort, but the privilege is nowhere near as strong as the confidentiality privilege you enjoy with an attorney.
Since you will be dealing with the Internal Revenue Service and they are not known to play nice or fair – it is in your best interest to obtain an experienced Offshore Disclosure Attorney.
OVDP is the Offshore Voluntary Disclosure Program — a program designed to facilitate taxpayer compliance with IRS, DOT, and DOJ International Tax Reporting and Compliance. It is generally reserved for individuals and businesses who were "Willful" (aka intentional) in their failure to comply with U.S. Government Laws and Regulations.
The Offshore Voluntary Disclosure Program is open to any US taxpayer who has offshore and foreign accounts and has not reported the financial information to the Internal Revenue Service (restrictions apply). There are some basic program requirements, with the main one being that the person/business who is applying under this amnesty program is not currently under IRS examination.
The reason is simple: OVDP is a voluntary program and if you are only entering because you are already under IRS examination, then technically, you are not voluntarily entering the program – rather, you are doing so under duress.
Any account that would have to be included on either the FBAR or 8938 form as well as additional income generating assets such as rental properties are accounts that qualify under OVDP. It should be noted that the requirements are different for the modified streamlined program, in which the taxpayer penalties are limited to only assets that are actually listed on either an FBAR or 8938 form; thus the value of a rental property would not be calculated into the penalty amount in a streamlined application, but it would be applicable in an OVDP submission.
An OVDP submission involves the failure of a taxpayer(s) to report foreign and overseas accounts such as: Foreign Bank Accounts, Foreign Financial Accounts, Foreign Retirement Accounts, Foreign Trading Accounts, Foreign Insurance, and Foreign Income, including 8938s, FBAR, Schedule B, 5741, 3520, and more.
What is Included in the Full OVDP Submission?
The full OVDP application includes:
- Eight (8) years of Amended Tax Return filings;
- Eight (8) Years of FBAR (Foreign Bank and Account Reporting Statements);
- Penalty Computation Worksheet; and
- Various OVDP specific documents in support of the application.
Under this program, the Internal Revenue Service wants to know all of the income that was generated under these accounts that were not properly reported previously. The way the taxpayer accomplishes this is by amending tax returns for eight years.
Generally, if the taxpayer has not previously reported his accounts, then there are common forms which were probably excluded from the prior year's tax returns and include 8938 Forms, Schedule B forms, 3520 Forms, 5471 Forms, 8621 Forms, as well as proof of filing of FBARs (Foreign Bank and Financial Account Reports).
OVDP Penalties
The taxpayer is required to pay the outstanding tax liability for the eight years within the disclosure period – as well as payment of interest along with another 20% penalty on that amount (for nonpayment of tax). To give you an example, let's pick one tax year during the compliance period. If the taxpayer owed $20,000 in taxes for year 2014, then they would also have to include in the check the amount of $4,000 to cover the 20% penalty, as well as estimated interest (which is generally averaged at about 3% per year). This must be done for each year during the compliance period.
Then there is the "FBAR/8938" Penalty. The Penalty is 27.5% (or 50% if any of the foreign accounts are held at an IRS "Bad Bank") on the highest year's "annual aggregate total" of unreported accounts (accounts which were previously reported are not calculated into the penalty amount).
For OVDP, the annual aggregate total is determined by adding the "maximum value" of each unreported account for each year, in each of the last 8 years. To determine what the maximum value is, the taxpayer will add up the highest balances of all of their accounts for each year. In other words, for each tax year within the compliance period, the application will locate the highest balance for each account for each year, and total up the values to determine the maximum value for each year.
Thereafter, the OVDP applicant selects the highest year's value, and multiplies it by either 27.5%, or possibly 50% if any of the money was being held in what the IRS considers to be one of the "bad banks." When a person is completing the penalty portion of the application, the two most important things are to breathe and remember that by entering the program, the applicant is seeking to avoid criminal prosecution!
2. Streamlined Domestic Offshore Disclosure
The Streamlined Domestic Offshore Disclosure Program is a highly cost-effective method of quickly getting you into IRS (Internal Revenue Service) or DOT (Department of Treasury) compliance.
What am I supposed to Report?
There are three main reporting aspects: (1) foreign account(s), (2) certain specified assets, and (3) foreign money. While the IRS or DOJ will most likely not be kicking in your door and arresting you on the spot for failing to report, there are significantly high penalties associated with failing to comply.
In fact, the US government has the right to penalize you upwards of $10,000 per unreported account, per year for a six-year period if you are non-willful. If you are determined to be willful, the penalties can reach 100% value of the foreign accounts, including many other fines and penalties… not the least being a criminal investigation.
Reporting Specified Foreign Assets – FATCA Form 8938
Not all foreign assets must be reported. With that said, a majority of assets do have to be reported on a form 8938. For example, if you have ownership of a foreign business interest or investment such as a limited liability share of a foreign corporation, it may not need to be reported on the FBAR but may need to be disclosed on an 8938.
The reason why you may get caught in the middle of whether it must be filed or not is due largely to the reporting thresholds of the 8938. For example, while the threshold requirements for the FBAR is when the foreign accounts exceed $10,000 in annual aggregate total – and is not impacted by marital status and country of residence – the same is not true of the 8938.
The threshold requirements for filing the 8938 will depend on whether you are married filing jointly or married filing separate/single, or whether you are considered a US resident or foreign resident.
Other Forms – Foreign Business
While the FBAR and Form 8938 are the two most common forms, please keep in mind that there are many other forms that may need to be filed based on your specific facts and circumstances. For example:
- If you are the Beneficiary of a foreign trust or receive a foreign gift, you may have to file Form 3520.
- If you are the Owner of a foreign trust, you will also have to file Form 3520-A.
- If you have certain Ownerships of a foreign corporation, you have to file Form 5471.
- And (regrettably) if you fall into the unfortunate category of owning foreign mutual funds or any other Passive Foreign Investment Companies then you will have to file Form 8621 and possibly be subject to significant tax liabilities in accordance with excess distributions.
Reporting Foreign Income
If you are considered a US tax resident (which normally means you are a US citizen, Legal Permanent Resident/Green-Card Holder or Foreign National subject to US tax under the substantial presence test), then you will be taxed on your worldwide Income.
It does not matter if you earned the money in a foreign country or if it is the type of income that is not taxed in the country of origin such as interest income in Asian countries. The fact of the matter is you are required to report this information on your US tax return and pay any differential in tax that might be due.
In other words, if you earn $100,000 USD in Japan and paid 25% tax ($25,000) in Japan, you would receive a $25,000 tax credit against your foreign earnings. Thus, if your US tax liability is less than $25,000, then you will receive a carryover to use in future years against foreign income (you do not get a refund and it cannot be used against US income). If you have to pay the exact same in the United States as you did in Japan, it would equal itself out. If you would owe more money in the United States than you paid in Japan on the earnings (a.k.a. you are in a higher tax bracket), then you have to pay the difference to the U.S. Government.
3. Streamlined Foreign Offshore Disclosure
What do you do if you reside outside of the United States and recently learned that you're out of US tax compliance, have no idea what FATCA or FBAR means, and are under the misimpression that you are going to be arrested and hauled off to jail due to irresponsible blogging by inexperienced attorneys and accountants?
If you live overseas and qualify as a foreign resident (reside outside of the United States for at least 330 days in any one of the last three tax years or do not meet the Substantial Presence Test), you may be in for a pleasant surprise.
Even though you may be completely out of US tax and reporting compliance, you may qualify for a penalty waiver and ALL of your disclosure penalties would be waived. Thus, all you will have to do besides reporting and disclosing the information is pay any outstanding tax liability and interest, if any is due. (Your foreign tax credit may offset any US taxes and you may end up with zero penalty and zero tax liability.)
*Under the Streamlined Foreign, you also have to amend or file 3 years of tax returns (and 8938s if applicable) as well as 6 years of FBAR statements just as in the Streamlined Domestic program.
Call Today, Let us Help.
International Tax Lawyers - Golding & Golding, A PLC
Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver, and has also earned the prestigious Enrolled Agent credential. Mr. Golding is also a Board Certified Tax Law Specialist Attorney (A designation earned by Less than 1% of Attorneys nationwide.)
Latest posts by International Tax Lawyers - Golding & Golding, A PLC (see all)
- Courts Reject Kovel – No Attorney-Client Privilege for the Accountant - April 14, 2019
- Numbered Accounts Offshore – FBAR & FATCA Civil & Criminal Penalty - April 12, 2019
- Voluntary Disclosure Lawyer Scam Warning "Flat-Fee without Tax Prep" - April 9, 2019


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Nuno Mendes on Portugal's finest under‑the‑radar restaurants
The A-list London chef reveals where he books a table when he's feeling hungry in his native country
Portugal is a country of regions, each with a completely different cuisine. Spices, techniques, ingredients, all change dramatically as you travel from north to south, from interior to coast. It's a diversity that belies the compact nature of the country (it takes less than eight hours to drive from north to south, about three from the coast to the Spanish border). Don't sample these regional dishes anywhere other than in their home locations. Here are six of my favourite, relatively unheralded restaurants that all offer a fantastic introduction to Portuguese cooking.
Adega Velha, Mourao
A great old-school place in the district of Evora, where you can get amazing Alentejo food and drink. The owner is always around and he provides good entertainment. It serves talha…


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She's about to become a single mother.
He's about to have an empty nest.
But love is about to change all their options.
Having it all is a fantasy, right?
The amazing romance by Julia Kent and Elisa Reed
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Her home study's done, and she's about to adopt, a thirty-something single mother by choice. Who needs to put her life on hold for the right guy when the right baby is waiting for her?
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And then in walks Nick Grafton, with those commanding sapphire eyes and wavy blonde hair and a sophisticated mouth that only smiles for her.
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But the last thing Nick wants is to start fresh with a new baby as his college-age kids fly the coop. A single father for more than fifteen years after his wife walked out on her family, Nick finally tastes freedom.
But he likes the taste of Chloe more.
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Our Options Have Changed is a full-length standalone contemporary romance, the first in the On Hold series by New York Times and USA Today bestselling author Julia Kent and journalist-turned-fiction-writer Elisa Reed. It is a loose spinoff from Julia Kent's Shopping for a Billionaire series, with cameo appearances from favorite characters.
"An utterly charming celebration of the messiness of love, life, and motherhood… every woman deserves a Nick." — Laurelin Paige, New York Times bestselling author
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Launch of Joya – the combination of the words "Enjoy Soy" characterizes the brand's vitality even today.
Sale of milk production and focus on soy products – as the first and only dairy in Europe, Mona Naturprodukte GmbH operates on a strictly vegan basis.
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Mona generated 45 million in sales and continues to experience double-digit growth. Joya is already available in more than 30 countries.
Joya redefined vitality and rethought its core competencies: tasty vegan dairy alternatives.


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My viewed hotels
- Rex Vung Tau Hotel
1 Le Quy Don Street, Vung Tau city, Vietnam
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Rex Vung Tau Hotel
Address: 1 Le Quy Don Street, Vung Tau city, Vietnam (View Map)
Rex Hotel Vung Tau was built in 1972 to combine the highest international standards with heart-felt Vietnamese hospitality. Rex hotel is located in the most convenient area in Vung Tau city. It is very easy to walk to entertainment spots as well as local attractions. It is also close enough to get to the office building or Industrial park within short time by taxi.
Situated directly opposite front beach, the Rex Hotel Vung Tau commands beautiful ocean views and is adorned with a large flower garden and modern beachfront swimming pool. The 8-storey Rex Hotel is one of the few big hotels in the resort city of Vung Tau and comprises 77 luxurious and well-appointed guest rooms with stunning view over the sea, mountain and downtown of Vung Tau city. All the rooms are featured with a traditional and sleek design with warm furnishing. Guest can enjoy the fresh air and sea breeze from every private balcony.
For those travelers who look forward to a combination of convenience and comfort, the Rex Hotel Vung Tau has all of the amenities, facilities and levels of comfort you would expect from a boutique hotel of this class, and maintains the meticulous standards required by travel and tour operators worldwide. Booking a room online with us to get special discount rates and write hotel reviews after your stay.
Facilities of Rex Vung Tau Hotel
- 24/7 Room Service
- Baggage Store
- Bar/Pub
- Buffet Breakfast
- Car Park
- Designated Smoking Area
- Disabled Facilities/Rooms
- Express Check-In/Out
- Family Rooms
- Garden
- Gay Friendly
- Newspapers
- Non-Smoking Rooms
- Poolside Bar
- Restaurant
- Restaurant (buffet)
- Safety Deposit Box
- Sun Terrace
- WiFi Internet
Leisures of Rex Vung Tau Hotel
- Children's Playground
- Cycling
- Gym/Fitness Centre
- Massage
- Outdoor Swimming Pool
- Playground
- Sauna
- Spa & Health Club
- Tennis Court
Services of Rex Vung Tau Hotel
- Babysitting/Child Services
- Bicycle Rental
- Business Facilities
- Car Rental
- Concierge Service
- Currency Exchange
- Doctor on Call
- Fax/Photocopying
- Hotel/Airport Transfer
- Ironing Service
- Laundry & Dry-cleaning
- Meeting/Banquet Facilities
- Motobike Rental
- Postal/Courier Service
- Shoe Shine
- Shuttle Service (surcharge)
- Souvenirs/Gift Shop
- Special Diet Meals (request)
- Ticket Service
- Tour Desk & Information
- Wedding Service
|Free! Wifi internet is available in the rooms / hotel area and is free of charged when using.
|Free! Parking is possible on site (reservation is not needed)
|The Rex restaurant offers the best Vietnamese, Chinese, Asian and Western cuisines with a formal and informal style of serving such as opening parties, wedding party. Divided into six functional dining rooms accommodated from ten up to hundreds guests. You have a wide choice of dining and enjoying fresh drink in any of our luxurious and quite venues mentioned.
|An extensive menu of body and beauty treatments is available. All massage and spa services provide a safe, effective treatment and recovery process.
|Conference Facilities:
|Our meeting rooms have all been specially designed to provide a comfortable and functional working environment, equipped all with video, sound and lighting equipments required for every event. At Rex Hotel we are at your service and ready to propose new customer services and programs specially designed to satisfy your needs.
These are general hotel policies for Rex Vung Tau Hotel, as they may vary per room type, please also check the room description.
|Check-in date:
|from 14:00 until later. Sooner subject to room availability.
|Check-out date:
|until 12:00 or sooner
|Late check-out until 15:00 will be charged 30% of room rate.
|Late check-out until 18:00 will be charged 50% of room rate.
|Free! If cancelled or modified up to 15 days before date of arrival, NO fee will be charged.
|If cancelled or modified up to 14 days before date of arrival, 100% of the reservation will be charged.
|If cancelled or modified after 7 days before date of arrival, 100% of the reservation will be charged.
|In case of no-show, 100% of the first night will be charged.
|Child & Baby-cot:
|Free! 1 child(ren) under 10 years old stay free of charge when using existing beds.
|Free! 1 child(ren) under 2 years old stay free of charge in a baby-cot.
|Child (age of 5 - 10) will be charged US$ 5 /child for an extra breakfast.
|Pets Policy:
|Pets are not allowed
|Room rates:
|All rates are subject to change without notice if booking is still not confirmed. These rates are available only for bookings made with TUN TRAVEL and NOT available from the hotel directly. Supplements will not be calculated automatically in the total costs and have to be paid separately in the hotel.
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Youth for Justice, the national coordinated law- related education consortium funded by the Office of Juvenile Justice and Delinquency Prevention of the U.S. Department of Justice, invites 100 middle and high school classes across the United States to teach others about the fundamental ideas of American democracy through the third annual National Teach-In celebration of National Youth Service Day and National Law Day. The first 100 classes to register will receive a mini-grant of $200, which may be used to buy materials to conduct their teach-in, provide law-related education resources for their class or school library, host a teach-in conference with another school, or donate to a school club or charity.
$200 and a teach-in to help students learn about democracy
By eSchool News
January 13th, 2006