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Wisconsin had no authority to impose its income tax on an out-of-state company licensing IP to its in-state affiliate.
Antidumping duty updates and more
This newsletter covers international tax issues including legislative changes, case law and treaty changes.
Out-of-state IP company subject to NJ tax despite in-state affiliate adding back royalty expense paid to the IP company.
US-parented MNE group must file CbC report if group has entities with operations in a country requiring CbC reporting
Our August edition features final and proposed partnership regulations, and other guidance.
This issue addresses recent tax and legal changes in France, Russia, South Korea, Spain, UK and US.
Pending Congressional review, new DC law would clarify start date of market-based sourcing and enact tax haven expansion.
The Russian Finance Ministry has issued clarification letters on iapplicability of witholding tax to interest.
Recent Japanese Supreme Court decision impacts individuals who hold partnership investments.
August 2015 update for the aircraft industry.
Analysis and insights into state and local tax developments
Ukraine: Introduced amendments to TP legislation are aimed at bringing regulations in line with international practice
The IRS on August 26 released proposed regulations under Section 199 (REG-136459-09) addressing many technical issues.
August 2015 Roundup - Recent state and local tax developments affecting retailers.
Global mobility - United States: New FBAR filing deadline and extension enacted, but questions loom
Canada: CRA's 2015 MAP report reflects an increase in the number of completed foreign-initiated MAP negotiable cases.
In the second half of 2015, amnesty programs will begin in eight different states.
IRS concluded that excess loss policies issued by a captive insurance company did not constitute insurance
Shanghai immigration policies simplified to attract talent.
Canada Revenue Agency's 2015 APA report reflects an increase in the number of APAs completed compared to the prior year.
Illinois extends its sales tax bad debt deduction to purchases made on private label credit cards.
US: New APA procedures require more information and factual development upfront.
When is a taxpayer engaged in an activity that is considered a 'hobby?'
United Kingdom: More details announced for new short term business visitors payment scheme.
The Internal Revenue Service (IRS) on August 20, 2015, updated its website with information about a new feature that will allow sponsoring entity financial institutions to add sponsored entities to the Foreign Account Tax Compliance Act (FATCA) Online Registration System and obtain a global intermediary identification number (GIIN) for each sponsored entity.
Mobility: Hong Kong: Recent changes to immigration policy on talent - consider the practical implications
Universities should continue to be diligent in TIN collection efforts and file complete and accurate Forms 1098-T.
IRS provides a new safe harbor for certain service contracts to be treated as ratably performed.
A Texas Comptroller's letter provides considerations for when a taxpayer may be qualify for the reduced margin tax rate
Chilean executive branch calls for amendments to 2014 tax reform shareholder provisions.
For tax years beginning after 2014, Alabama provides a factor presence nexus standard for income and other taxes.
Data matching of foreign nationals working in Australia by the Australian Tax Office.
IRS to issue regulations limiting deferral of gain on contributions to partnerships with related foreign partners
The Chilean IRS on July 30 issued a Resolution setting forth how to report indirect transfers.
Recent legislation changes eturn filing dates for some returns filed for tax years beginning after Dec. 31, 2015.
The disparate state and local tax treatment of digital streaming services.
A recent 'innovation box' proposal would provide a 10.15% US tax rate on income from certain of intellectual property.
The SEC has finalized rules implementing the pay ratio disclosure requirement of the Dodd-Frank Act.
The purpose of Action 4 is to develop best practice for countries on local interest limitation.
Amendments to the Cyprus tax laws that will enhance the country's tax competitiveness have been published.
Australia is the second country to release draft legislation to implement new OECD standards on TP documentation.
Ukraine: Resolution 504 enables large taxpayers to negotiate and conclude unilateral, bilateral and multilateral APAs
PwC's India Customs and Foreign Trade Policy Newsletter - July Edition.
Altera decision represents a significant development for US taxpayers currently in a cost-sharing arrangement
The Luxembourg government released a tax bill that includes proposed tax measures for corporations.
Companies may have to reflect a liability for penalties under ACA in financial statements if the liability is material.
Altera decision represents a significant development for US taxpayers currently in a cost-sharing arrangement.
Key tax issues potentially affecting companies investing in the USA today.
IRS updated the static mortality tables for defined benefit plans for certain funding and benefit requirements in 2016.
Romania: Results from ANAF TP inspections concluded during the six months to June 2015.
Spain: new TP documentation requirements includes the need for a Country-by-Country Report, Master File and Local File
Federal consolidated tax return regulatory requirement to 'push down' CODI applies in determining New Jersey income.
Texas Franchise Tax is not imposed on income for Compact purposes, the Compact's apportionment election not available.
United States: New social security agreements signed but not yet in force.
Congress today completed action on a three-month extension of federal highway and transit program authorization.
Discussion draft on an 'innovation box' tax regime that would provide a 10.15% effective US federal income tax rate.
CA proposes a change in ownership of real property occurs if a percentage is sold or transferred in a single transaction,
Discusses new sales and use tax legislation in Texas; and a last call for potential 50% bonus depreciation for 2014.
IL proposed changes to income tax regulations include hedging and foreign currency
Companies need to be prepared for an audit, understand their pre-audit filing options, and consider exam strategies.
Our July edition features the 'May Company' regulations, final and proposed regulations, and other recent guidance.
Australia: new APA process applies to all ongoing APA negotiations and future APA requests
5-year remedial amendment cycles to end and new applications to be limited to new and terminating retirement plans.
This issue addresses recent tax and legal changes in France, New Zealand, United Kingdom and the United States.
Thinking past the audit: the bigger picture in unclaimed property compliance.
Equipment located outside generation plants used to process and distribute electricity qualified for sales tax exemption.
Section 707(a)(2)(A) regs address disguised payments for services.
This is the first income tax treaty between the two countries.
Massachusetts - Intercompany loans made by a parent to its subsidiary were bona fide debt, no addback required
These IPUs provide guidance to IRS examiners in addressing a range of issues involving US federal income taxation of cross-border activities.
Oregon updates its tax haven list and excludes tax haven entity factors from an Oregon group's apportionment percentage
Oregon temporarily disallows use of tax credits to offset minimum tax--repeals Con-way.
Alabama retracted a regulatory amendment that would have imposed a rental tax on streaming services
Italy: Taxpayer may bring the action before the Tax Court if access to European Arbitration Convention is denied.
Senate Finance Committee approves renewal of expired tax provisions
On July 17, 2015, Massachusetts eliminated Massachusetts' FAS 109 Deduction and established tax amnesty.
Washington increases the B&O tax rate on royalties, extends economic nexus, and establishes click-through nexus
Taxpayer allowed to adjust his Georgia taxable income for taxes paid in another state on pass-through income
Australia announces plans for BEPS anti-hybrid legislation.
Senate reports include recommendations that would, if adopted, affect tax-exempt organizations.
House approves short-term highway bill with revenue offsets; international tax reforms being discussed as option for long-term bill.
Global mobility - India: Government eases process of e-filing returns using EVC
The OECD's planned revisions to the Transfer Pricing Guidelines and confirmed timeline will have a significant impact.
S. Africa Tax Court has held that a US advisory firm's delivery of consultiing services to an SA client was a PE.
IRS announced that defined benefit plans may not replace an annuity in pay status with an accelerated payment form.
Life insurance: Tax Court applies investor control doctrine to variable life insurance contracts
United Kingdom: Summer Budget 2015 to impact mobile executives and their employers
India: Agreement on social security with Austria comes into force July 1
SEC proposed rules require clawback policies for the recovery of erroneously awarded incentive compensation.
The Trade Preferences Extension Act of 2015 was recently signed into law providing substantial increases in penalties for failure to timely file information returns.
Global mobility-United Kingdom: Updated short term business visitors agreement - new 'payment scheme'
The UK Budget, released July 8, 2015, announced a tax rate cut and focused on tax avoidance and aggressive tax planning
Payments made by corporation to sole executive and shareholder did not constitute reasonable compensation
July 20, 2015, starts the first of three application periods for $200 million of California Competes Tax Credits.
Senate Finance Committee tax reform working groups issue reports
The Portuguese Parliament has approved the new special tax regime for the Madeira International Business Centre (MIBC).
IRS clarifies how a charitable hospital may comply with the requirement to include a list in the FAP of non-employees
Income tax accounting and reporting developments (April - June 2015)
Chicago's Amusement Tax applies to charges paid for electronically delivered amusements
PwC's India Customs and Foreign Trade Policy Newsletter - June Edition
This quarter's technical highlights include Connecticut combined reporting starting in 2016 and Nevada's Commerce Tax.
Future trends CEOs see for their businesses provide clear pressure points for the tax function as well.
The Accounting Methods Spotlight discusses the IRS's request for comments on the new revenue recognition standards.
Our June edition features two revenue rulings, proposed regulations, and other recent guidance
Interactions between the Japanese transfer pricing and donation rules.
NYC - Unincorporated business denied deduction for payments to partner for employee services.
Chicago adopts guidance regarding cloud computing, software, and nonpossessory lease tax exemptions and sourcing.
On June 30, 2015, Connecticut enacted two bills that require combined reporting in 2016 and other changes.
On June 12, 2015, the South Carolina Department of Revenue released alternative apportionment guidance.
Senator Wyden's Offshore Reinsurance Tax Fairness Act would amend the PFIC exception for foreign insurance companies
The IRS on January 16 issued Rev. Proc. 2015-13, modifying the previous rules for requesting accounting method changes.
Discusses mixed-use trip tax treatment and special depreciation election for an aircraft.
Exploring developments affecting high net worth individuals such as cyber security and non US purchase of real property.
This issue addresses recent tax and legal changes in Australia, Belgium and the United States.
VAT News highlights: EC strategy for digital single market in Europe, upcoming indirect tax changes in Puerto Rico
On 8 June 2015, the OECD released a 'Country-by-Country Reporting Implementation Package.'
The European Commission has appointed organisations rather than individuals to the EU Joint Transfer Pricing Forum
OECD guidance on transfer pricing aspects of intangibles: hard-to-value intangibles
Discusses New York state sales/ use tax legislation and a federal case on deductions for business use of an aircraft.
Our May edition features a ruling that helps clarify ambiguity under section 163(l) for convertible debt
On 22 May 2015, the OECD issued a Revised Discussion Draft on BEPS Action 6: Prevention of Treaty Abuse.
Recent legislative updates (May 2015).
The G20 International Tax Symposium provided a platform to discuss the ongoing OECD/G20 BEPS Action Plan.
The OECD has released revised proposals on the Article 5 PE rules in the OECD Model Tax Treaty.
The importance of unclaimed property policies and procedures.
We bring you the latest global immigration updates from across our global network in this spring edition of our global newsletter.
This newsletter covers international tax issues including legislative changes, case law and treaty changes
Multinationals developing and using intangibles under cost contribution arrangements should note the discussion draft.
Discusses application of excise taxes on taxable air transportation to prepaid jet cards and management fees.
This Month in M&A features proposed regulations which would rewrite the 'next-day rule' for consolidated return filers.
Results of the work done by economists and others under Action 11 of BEPS
VAT News highlights: CJEU addresses digital publications in France and Luxembourg, GST in Malaysia, VAT in Costa Rica
Designed to help multinationals stay aware of tax accounting and regulatory developments.
Multinational enterprises (MNEs) will be concerned about the BEPS discussion draft on CFC rules
With analysis and insight on policy changes around the world, these bulletins help you stay up-to-date with the latest developments and explain what these changes mean for you and your business.
International Tax News is a monthly publication that offers updates and analysis on international tax developments worldwide.
Consider the details of the discussion draft published on 31 March on disclosure of tax planning arrangements
This month's issue addresses recent tax and regulatory changes in various jurisdictions.
Key tax issues potentially affecting companies investing in the USA today
Discusses a recent CCA on excise tax exemptions, and the application of the SIFL rules to multi-leg trips by employees.
Recent IRS and court rulings provide guidance on tax accounting issues.
The BEPS Action Plan discussion drafts on profit splits risk, recharacterization and special measures provide evidence of the OECD moving away from the arm's-length principle and towards formulary apportionment.
Fifth Circuit clarifies character of losses on abandonment of certain capital assets.
Economic power balance shifting to developing countries will impact a business's domestic and global incentives function.
Foreign-based multinationals should be up to speed on the current US approach to international tax enforcement for several significant reasons.
Exploring developments affecting high net worth individuals such as tax fraud and international filing requirements.
VAT News highlights: 2016 VAT in Puerto Rico and GST in India, Swiss e-services, Advocate General opinion on warranties.
February 2015 Roundup - Recent state and local tax developments affecting retailers.
This Month in M&A features the IRS respecting taxpayer's 'self-help' measures to avoid adverse basis shift consequences.
Discusses updated SIFL rates for the first half of 2015; and new 2015 federal excise tax rates.
New developments provide guidance on accounting method issues
European Customs & International Trade Communiqué - January 2015
As part of our continued effort to help organizations navigate through the complexity of today's tax accounting issues, we've assembled a compilation of our Tax Accounting Services' publications released between July 2014 and January 2015.
Vol 24: Recent IRS guidance provides safe harbor accounting methods for cable system operators.
Multinational enterprises recently received additional guidance on complying with certain BEPS recommendations.
VAT News highlights: OECD draft guidelines on B2C digital supplies, import VAT deferment simplification in the EU
Michael Danilack, former Deputy Commissioner (international) in the IRS Large Business & International Division (LB&I), joined PwC's Washington National Tax Services. Michael shared his insights in an interview with Amy Elliott from Tax Analysts.
New legislative, IRS and court rulings provide guidance on tax accounting method issues
Our January edition features recent mergers and acquisition tax guidance
IRS denies immediate deduction for ceding commission in an indemnity retrocession of life insurance business
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These alerts provide analysis of the impact of major transfer pricing, tax, and related developments within hours of the news breaking, authored by PwC professionals around the world. Each alert is classified by the country or territory to which it pertains.
India notifies income tax return forms for financial year 2014-15.
Obergefell will require same-sex married couples and opposite-sex couples to be treated the same for state tax purposes.
IRS TE/GE Advisory Committee 2015 recommendations on Form 990
Australia's Tax and Superannuation Laws Amendment (2015 Measures No.1) Bill 2015 received Royal Assent on June 25, 2015.
Today, the Supreme Court ruled that subsidies under the Affordable Care Act (ACA) are available to eligible individuals
Tax-exempt healthcare executives should continue to include tax on list of business and financial considerations.
Goals are to provide fairer and more efficient taxation and to effectively tackle corporate tax avoidance
New foreign investment reporting requirement (Form BE-10)
SEC proposal requires many US registrants to disclose relationship between executive pay and financial performance.
The renegotiated tax treaty between South Africa and Mauritius is expected to enter into force on January 1, 2016.
CCA 201515020 addresses the economic substance doctrine in a transaction with offsetting loan and contractual rights
The draft law introducing amendments to the Russian thin cap rules has passed the first reading in Parliament.
This new stricter approach of the Italian tax authorities is likely to have a broad impact.
FASB released proposed changes to improve accounting for stock compensation that if finalized will have a major impact.
US Country of Origin Labelling: Hot topic for Canadian traders
The Swiss Federal Council has released the draft bill of Swiss Corporate Tax Reform III for parliamentary discussion.
IRS requests comments on tax accounting method impact of new FASB, IASB revenue recognition standard
Turkey: Constitutional Court decision overturns legal provision with respect to third parties for public receivables
Notable tax implications of partnership terminations and structural changes
PwC's India Customs and Foreign Trade Policy Newsletter - May Edition.
The Court of Federal Claims held in Dynetics that research performed by the taxpayer was 'funded' under Section 41.
Global mobility – India announces simplified return forms and extends deadline for filing
Turkish Court of First Instance declares use of secret comparable data violates taxpayer's right to fair trial.
Final Section 7874 regulations on substantial business activities in a foreign country.
Turkey: A recent court case has reignited the discussion on special irregularity penalties
Turkey: Constitutional Court decision addresses as a matter of first impression the standards set forth by the ECHR.
The IRS provided an automatic 90-day extension of time to file Form 8966 to all filers extending the deadline until June 29, 2015.
U.S. Customs and Border Protection will finally start accepting applications from exporters to participate in C-TPAT.
Excise tax: Court of Appeals rules insurance Federal Excise Tax does not apply to wholly foreign retrocessions
Potential tax impacts should be identified and addressed as companies plan and implement their 3D printing strategies.
New FAQs answer questions on health plan gender-specific preventive service requirements.
House approves permanent extension of research credit; tax reform discussions continue.
US Treasury proposes revised model income tax convention, modifying existing provisions and introducing new provisions.
FASB amended retirement benefit accounting rules so employers may elect alternative measurement dates in certain cases.
The approved budget proposals considered concerns raised about certain provisions.
ERISA fiduciaries must manage plan investments prudently and dispose of investments that are no longer appropriate.
The outcomes of the BEPS initiative have the potential to significantly impact effective tax rates, restructuring costs, and—ultimately—enterprise value and market capitalization.
Updated Cayman Island AEOI Portal User Guide provides clarification on notification for sponsored FIs
IRS applies Section 351 to amounts transferred in excess of arms-length indemnity reinsurance
CCA determines captive's loss indemnification isn't insurance.
Adjustment of life insurance reserves treated as a change in basis under Section 807(f).
The IRS LB&I division has issued guidance on whether certain activities qualify as Sec. 199 MPGE
The Cayman Department for International Tax Cooperation recently launched its Automatic Exchange of Information Portal.
New regs provide research credit opportunity for online retailers
A quarterly periodical that provides updates on significant federal and state tax developments or issues that affect individuals, estates and trusts.
Final regs allow some taxpayers to elect the alternative simplified research credit on amended returns.
The IRS released final forms and instructions used to comply with the new ACA information reporting requirements
Insurance tax provisions in Obama's FY 2016 budget.
Transfer of property under a 100% coinsurance transaction may be treated as a tax-free exchange.
FATCA brings significant implementation challenges to industrial products and services multinational companies.
House Ways and Means Committee today voted to permanently extend expired tax provisions
The IRS on January 16 issued two new revenue procedures that update the procedural rules to change an accounting method.
President Obama on February 2 submitted an FY 2016 budget that reaffirms his support for 'business tax reform'.
Release of Paying Taxes 2015, joint study by PwC and the World Bank Group, comes at pivotal time for tax policy.
Distributions to owners of pass-through entities ruled to be included in San Francisco's payroll expense tax base.
Spanish tax reforms to Corporate Income, Personal Income, Non Resident Income and Value Added Tax Act have significant impact.
The key question for US tax policymakers is whether 2015 will be marked by compromise or gridlock.
The IRS on January 16 issued two revenue procedures that update rules to change an accounting method for tax purposes.
The proposed IUS regulations are comprehensive and reflect thoughtful consideration of many complex issues.
IRS issues final regulations with respect to foreign financial assets that do not significantly alter previous guidance.
The IRS today released proposed regs addressing various issues regarding the treatment internal-use software.
The implementation of FATCA has required changes to the existing information reporting for MNCs
President Obama recently signed a law extending the research credit through December 31, 2014.
The Senate late on December 16, 2014 voted 76 to 16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014.
FinCEN on December 10, 2014 issued Notice 2014-1 to further extend the filing date of FBAR
US Department of the Treasury provides FATCA relief to jurisdictions with IGAs treated as in effect.
Charitable diversions: Tax implications and tips for addressing them.
In September, the Internal Revenue Service (IRS) released drafts of the 2014 Form 990, Schedule H and instructions.
Rev. Proc. 2014-54 provides automatic method change procedures for taxpayers to comply with the final disposition regs.
How are budget constraints in the IRS affecting affecting enforcement strategies? What options are available for resolving tax controversies?
Securitas Holdings, Inc. v. Commissioner: Tax Court allows a deduction for premiums paid to a captive insurance company
The IRS will not contest a restaurant's use of a facts-and-circumstances method to allocated kitchen labor to COGS
This briefing on EU State aid answers common questions and answers
Paul DeNard recently spoke with Tax Analysts about his career, the interaction between the domestic and international sides of Large Business & International tax, and his thoughts on the audit selection and personnel challenges facing the Service.
Cencast employment tax decision impact on production companies and employees, REIT rulings and CA film tax credit.
Recently, the OECD published reports on the BEPS Action Plan items dealing with topics relevant to the PLS industry.
California expands and extends its film credit.
Recently released instructions to the 2014 Form 1042-S clarify FATCA reporting requirements for US premiums.
Treasury and the IRS recently issued Notice 2014-52 addressing certain cross-border business combination transactions.
The IRS on August 14 issued final regs that restate and clarify the computation of certain ending inventory values.
A pre-filing agreement (PFA) allows a taxpayer to obtain certainty on an issue before filing its return.
The IRS on August 14 released final regulations regarding disposition of tangible depreciable property.
IRS provides annual domestic asset & liability percentages for foreign insurance companies.
IRS concludes that life insurance company's passive investment activities qualify as insurance business.
The 2014-2015 Priority Guidance Plan includes seven items specific to the insurance industry.
Under the Sec. 263A regs, taxpayers may allocate some royalties to COGS or between prop. sold and ending inventory.
There are areas where it was not appropriate for UK CDOT to exactly mirror US FATCA due to differences in context.
BCBS reorganization ruling includes representation regarding 9010(a) health insurer fee.
In our August 2014 issue, we explore state and local tax issues affecting retailers.
Global Information Reporting: OECD publishes long anticipated Commentary on Common Reporting Standard.
The IRS recently published final regulations allowing filers of certain information returns to use truncated TINs.
IRS directive addressing hedges of variable annuity guarantees.
Final regulations prohibit taxpayers from using identified mixed straddles to recognize built-in capital gains.
Wyden criticizes Treasury and IRS for failure to close hedge fund 'loophole' that uses offshore insurance companies.
Global Green Policy Insights is a bimonthly update on the latest developments in environmental taxes, regulations, and other "green" policies around the world. Written by PwC specialists around the world, they provide timely updates on new tax incentives, credits, and policy issues of interest to multinational organizations.
The IRS recently released the instructions for Form W-8BEN-E for complying with FATCA.
Spectrum auction, Favorable REIT rulings for EMC companies, New York State Corporate Tax Reform.
IPCC's new climate change report; EU's new State aid guidelines; Highlights of country-specific developments
According to our 2014 Assessing tax, average ETRs over the last three years have continued to edge upward.
Taxpayers transferring goods or property between group members must consider Sec. 263A impact on intercompany profit.
IRS Notice 2014-39 clarifies important questions with regards to Treasury Section 1603 grants subject to sequestration.
Financial executives at major organizations are increasingly collaborating with their tax departments and monitoring the expanded use of enforcement actions by the Internal Revenue Service under stricter guidelines for complying with information document requests (IDRs).
Support payments made by manufacturers under 'facility image upgrade programs' are includible in gross income.
Assessing Tax 2014 provides a detailed analysis of tax rate metrics for 324 companies and highlights tax trends for aerospace and defense, automotive, chemicals, engineering and construction, industrial manufacturing and metals, and transportation and logistics companies. This issue includes a special report on the surge in international tax controversy.
The EPA released proposed regulations under the Clean Air Act that would for the first time set carbon emissions reduction targets for existing US electric power plants.
FATCA not only impacts the financial services sector, but many entities outside of the traditional financial services sector with operations in and outside of the US.
With the credits and incentives landscape always changing, this publication on C&I developments will help you stay abreast of issues that may affect your business.
In Revenue Ruling 2014-15, the IRS holds that an arrangement entered into to provide health benefits for retirees of a single employer qualifies as insurance.
New York tax reform contains important tax benefits applicable to manufacturers, some of which are effective in 2014.
The US Treasury and IRS announced in Notice 2014-33 that 2014 and 2015 will be a transition period for IRS enforcement and administration with respect to FATCA.
The PwC Retail and Consumer Roundup - Recent state and local tax issues affecting retailers (April 2014).
This article highlights the Top 10 accounting method changes for pharmaceutical companies.
FATCA and other recently issued US information reporting regulations are effective immediately or apply beginning July 1, affecting many nonfinancial services entities.
Covered entities are required to report their net premiums written information for calendar year 2013 to the Internal Revenue Service by April 15, 2014.
ECJ A-G deems green energy law flawed; China to cut energy intensity further; India to set up environment regulation authority; new Indonesia policy promoting renewables.
IRS expands when a jurisdiction will be treated as having an IGA in effect and extends to May 5, 2014 the time by which FFIs must register with the IRS.
On 3/31/14, the Mississippi governor signed Senate Bill 2933, which provides a new method of apportionment for certain major pharmaceutical and medical product suppliers.
Entertainment, Media, and Communications Tax Newsletter: Vol 21. OECD Action Plan on BEPS and its impact on EMC Companies and more.
Manufacturer not required to capitalize construction support payments made to its retailers.
Insurance tax provisions contained in the Obama Administration FY 2015 Budget Proposal.
The IRS issued final regulations relating to the adjustment to inventory costs for the receipt of certain sales-based vendor allowances, specifically vendor 'chargebacks.'
Treasury and the IRS recently released the last substantial package of regulations necessary to implement FATCA, with varying impacts to insurance companies.
The final IRS regulations provide companies the option of allocating capitalizable sales-based royalties to property sold, or between property sold and ending inventory.
House Ways and Means Chairman Dave Camp released the 'Tax Reform Act of 2014' discussion draft, which would affected Insurance companies dramatically.
Treasury and the IRS recently released FATCA amendments and coordinating regulations.
C Corporations may continue to claim enhanced inventory donation deductions
The US Treasury and the IRS released on February 20 final and temporary regulations for FATCA and coordinating regulations for Chapters 3, 4 and 61.
The OECD recently released the Common Reporting Standard to establish a new global standard for automatic exchange of financial account information.
We explore many state and local tax issues affecting retailers, including a Colorado sales tax credit opportunity and Nebraska's proposed daily sales tax remittance law.
In this issue, we concentrate our state tax credits and incentives review to an in-depth exploration of the new and expanded provisions of certain New York credits.
There are many potential tax risks, obligations, and costs associated with moving employees abroad for foreign assignments.
In Validus Reinsurance, Ltd. v. U.S., the DC District Court held that the insurance FET does not apply to certain retrocession arrangements.
This Tax Insight serves as a high-level primer of information reporting and withholding requirements for 2014 and beyond.
Warsaw Climate Change summit (COP19) summary; EU carbon targets for 2030 and a new OECD report; less emphasis on supporting renewables and greater concern over pricing.
Rent-A-Center, Inc. v. Commissioner: A divided Tax Court allows a deduction for premiums paid to a captive insurance company.
PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress
IRS insight into the Convenience Kit rules and the interpretation of exportation and importation of medical devices and the contract manufacturing rules applied to MDET
Soon to be released 'Common Reporting Standard' promises new FATCA-type obligations around the world.
A listing of PwC webcasts hosted by the US Tax Services team.
Calendar year 2013 has seen considerable activity across the global legislative and regulatory landscapes. We have seen changes to tax laws in several key territories, and certain legislative trends having a significant impact on income tax accounting. These developments, combined with an environment of economic uncertainty, have added to the challenges in accounting for income taxes.
On December 26, 2013, the IRS released the final FFI agreement (to implement FATCA) which contains a number of changes and clarifications to the draft FFI Agreement.
Entertainment. Media & Communications tax newsletter: Section 199 Benefits & Burden determination, communications company tax complexity, goodwill in radio station swaps
For tax years beginning on or after January 1, 2014, retailers will need to evaluate the impact of these new regulations on their businesses.
The IRS concluded that a taxpayer was not entitled to deduct cash bonuses paid to employees until the end of the year in which the bonuses were actually paid
The IRS has issued loss payment patterns and discount factors and salvage discount factors applicable to accident year 2013
Pharmaceutical and Life Sciences ("PLS") companies have traditionally set their transfer pricing strategy by trying to manage the expectations of multiple external stakeholders (regulatory bodies, income tax authorities, and customs authorities) and by staying abreast of industry trends. Nowadays, this task has become even more complex given the recent developments in the international tax and transfer pricing environment and the attention allocated by the media to the international tax practices of multinational companies. This news alert addresses some of the key highlights of the draft documents published by the OECD in the recent months and their anticipated impact for PLS companies.
UN report on climate change; Chile, Portugal, France and Poland renewable energy; developments in the biofuels market; emission in the aviation sector
The IRS issued a proposed update and revision of the revenue procedure governing advance pricing agreements (APAs).
This decision should be of interest to companies that recently have litigated (or may litigate) issues in the Tax Court.
This release follows the international tax reform discussion draft and tax administration reform discussion draft.
The changes made by the Updated Directive should allow more taxpayers to streamline the examination of their Section 199 deductions.
The Finance staff international reform discussion draft ('discussion draft') proposes to repeal or modify the current deferral system.
This release, the second in a series of staff tax reform discussion drafts, follows the November 19, 2013 discussion draft on international tax reform.
Australian Treasurer has issued a media release regarding the fates of previously announced but unlegislated tax measures.
Summarize the new guidance and the impact on foreign investors doing business with India through an entity located in Cyprus
The IRS issued Notice 2013-69 addressing FFI agreements and related issues under FATCA and accompanying regulations.
On October 22, 2013, the START-UP NY program will create tax-free zones to attract and grow new businesses, and incentivize existing businesses, in New York.
The final regulations are intended to ease the administrative burden and complexity of the segregation rules for loss corporations with small shareholders.
The Japanese government recently announced that it will proceed with a planned increase in the consumption tax rate from 5% to 8%, effective April 1, 2014.
The tax accounting items on the new business plan cover a wide range of transactions and therefore should be of interest to many taxpayers.
Missouri bad debt deduction sales tax; New Jersey incentives; New York City commercial rent tax; deductibility of management fees
On October 11, 2013 the Chancellor announced that the UK and Isle of Man had signed an automatic tax information exchange agreement based on FATCA (the US Foreign Account Tax Compliance Act). This Newsbrief provides an update and background information on the agreement.
The sequestration rate applicable to Treasury Section 1603 grant programs will be 7.2%.
This Insight discusses the 2013 proposed regulations.
Chairman Camp has reaffirmed his commitment to plan to overhaul the US tax system in time for a markup in the fall.
China, South Korea, Thailand plan to subsidise solar power; India and the UK plan to support wind energy; and France is increasing its support for biogas power
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
This newsalert summarizes those provisions in the circular that could affect foreign investors in India.
An account receivable established under Rev. Proc. 99-32 may constitute increased related-party indebtedness for purposes of the related-party debt rule
In this issue, our authors explore two different avenues that states may take to offer incentives to businesses.
Discusses in depth the recently issued final regulations regarding the deduction and capitalization of expenditures related to tangible property
Companies that have sold assets which were used to generate FSC commissions or ETI exclusions may be able to restore a portion of the basis of these assets.
Regulations on the exception from the definition of 'qualified research' for internal-use software under Section 41(d)(4)(E).
New guidance for companies beginning construction in 2013 on renewable electricity projects that qualify for the production tax credit.
Tax Court held that the amount of carried loss reserves claimed by an insurance company under Section 832 was fair and reasonable
This Newsbrief describes key changes contained in the technical correction and provides observations.
This is the first in a three-part series that will discuss the recently issued final regulations regarding the deduction and capitalization of expenditures.
Twenty one guidance projects addressing consolidated return issues or other issues relating to corporations and their shareholders.
The IRS released final tangible property 'repair' regulations regarding the deduction and capitalization of expenditures related to tangible property.
IRS announced in Notice 2013-56 that it would be providing penalty relief for incorrect name and taxpayer identification number combinations reported.
IRS concluded that the post-death beneficiary of five annuity contracts could exchange the value of those contracts tax-free for higher payouts.
Newly proposed Section 174 regulations address several long-standing issues related to the deduction for research or experimental (R&E) expenditures
The new regime applies to a wide range of companies across all industries, including industrial products and services companies.
Efforts to advance tax reform legislation move into a critical phase this fall.
On August 29, 2013, the IRS released a new Form W-9, Request for Taxpayer Identification Number and Certification and its instructions. The Form W-9 is one of several forms being revised to conform to the provisions of FATCA. This Newsbrief provides an overview and key observations of the new Form W-9.
IRS has provided domestic asset/liability percentages and domestic investment yields for foreign insurance companies.
Geosyntec Consultants, Inc. v. US, US District Court ruled that research conducted under fixed-price contracts held not 'funded,' eligible for research credit
Insights exploring unclaimed property, credits and incentives, and state income tax reporting for retailers.
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes ("UK Guidance") in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 ("UK Regulations") laid before the UK House of Commons earlier this month.This version of the guidance supersedes any versions previously published. This Newsbrief identifies key changes and certain additions from the draft UK Guidance released in May 2013.
This publication discusses key tax and financial reporting considerations of patent box regimes and other technology incentives.
Deductions for policyholder dividends did not satisfy the 'all-events' test under the principles of Section 461.
The Internal Revenue Service (IRS) announced the opening of the Foreign Account Tax Compliance Act (FATCA) registration system on August 19, 2013. This Global IRW Newsbrief provides background information, important deadlines, key observations, and next steps.
Retailers may have a time sensitive opportunity to qualify for current enterprise zone benefits before the credits expire at the end of 2013
New Mexico and Virginia have enacted special state income tax rules for retailers
Key observations from HM Treasury and HMRC's release of the International Tax Compliance (United States of America) Regulations 2013 to improve international tax compliance and implement FATCA.
Understanding its impact and the path forward for nonfinancial multinational businesses.
These procedural changes are intended to make it easier for FBAR filers to use the e-filing system.
IRS directive for use in determining whether a taxpayer has the benefits and burdens test for purposes of Reg. sec. 199
Final regulations explaining the exception for certain expenditures paid or incurred under a reimbursement or other expense allowance arrangement
The IRS has released guidance (Notice 2013-51) on the procedural requirements related to the branded prescription drug fee ("the fee") for the 2014 calendar year. This annual fee, which applies to companies that manufacture or import branded prescription drugs, was enacted as part of health care legislation in 2010 and applies to each calendar year beginning after 2010. For 2014, the aggregate amount of the fee that is to be allocated proportionally to covered entities is $3.0 billion.
The IRS issued temporary and proposed regulations addressing identified mixed straddle transactions.
China and the United States both launching initiatives in recent months to reduce greenhouse gas emissions and drive sustainable growth.
General overview of elections and accounting methods
The IRS recently issued guidance regarding the deferral of gross income in connection with certain advance payments received from the sale of gift cards.
China and the Netherlands recently entered into a new double taxation agreement (DTA) and protocol.
The monograph provides an overview of developments affecting the taxation of insurance companies in 2012.
Tax code provisions offer relief to taxpayers affected by disasters.
The Obama administration decision to delay reporting and enforcement of employer mandate is welcome relief for all employers that would have been subject to the reporting requirements and shared responsibility payments. Pharmaceutical and Life Sciences companies will now have additional time to determine their coverage responsibilities and to implement the necessary recordkeeping and reporting capabilities.
OECD published an Action Plan that addresses the perceived flaws in the international tax rules that were discussed in the BEPS report
The latest edition of Continuing Developments in the Taxation of Insurance Companies from PwC reviews developments affecting the taxation of insurance companies, with a special focus on legislation, tax accounting, and Federal, international, and multi-state taxation developments.
Australia has enacted new loss carry back rules that will give Australian companies the option to carry back tax losses to a preceding tax year.
CA AB 93 and SB 90 make sweeping changes to the California Enterprise Zone credit program
The IRS recently issued a directive to all LB&I employees that should improve the way that they, and taxpayers, deal with Information Document Requests.
Additional year before the mandatory employer and insurer reporting requirements under the Affordable Care Act
CA AB 93 replaces most of the current program with a new hiring credit, a new sales and use tax exemption, and a negotiable tax credit for certain investments
MO S.B. 287 allows for sponsored captive insurance companies and respective protected cells to be organized and operate in the state
PLR 201323009, the IRS granted an insurance company an extension of time to file an election to be subject to the alternative tax under Section 831(b)
Rev. Proc. 2013-32 will restrict the scope of letter rulings issued under sections 332, 351, 355, 368, and 1036
Senate Finance Committee Chairman Max Baucus and Ranking Member Orrin Hatch issued a letter to all Senators setting forth next steps
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies
Senate Bill 1133 was introduced to permanently extend the New Markets Tax Credit
Litigation between the IRS and Wells Fargo over access to tax accrual workpapers has been resolved by the trial court.
The IRS has recently released drafts of certain FATCA-related forms.
Understanding the effects of the European Commission's proposed amendments to the automatic exchange of information ("AEOI") between EU Member States.
The IRS concluded that a written collaboration agreement constituted a partnership for all federal income tax purposes.
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.
Chinese State Administration of Taxation has clarified how local-level tax bureaus should assess beneficial ownership
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.
Emissions trading, carbon tax, carbon markets, carbon price support, renewable energy, cleantech, subsidy, environmental policy, landfill tax, climate change
A memorandum directing LB&I staff to not challenge the treatment of certain 'eligible milestone payments' paid in the course of a covered transaction.
The Neal Bill would limit deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
Permits taxpayers to elect to treat certain dispositions of a target corporation's stock as a sale of the underlying assets of the target corporation.
The IRS concluded that minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
The Australian 2013 – 2014 federal budget, released on May 14, contains a number of measures aimed at increasing Australian tax revenue.
Determining whether expenditures to maintain, replace, or improve steam or electric power generation property must be capitalized under Section 263(a).
The House Ways and Means Committee May 8 held a meeting covering the work of certain of its 11 bipartisan working groups on tax reform
The RCF case confirms that it is possible to look through an LP to identify the relevant taxpayer for purposes of applying a tax treaty.
LB&I recently issued a memorandum for all staff regarding the treatment of eligible milestone payments paid or incurred in the course of certain transactions.
JCT staff today issued a 568-page report on 'Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups'
The IRS concluded in a field attorney advice (FAA 20124401F) that minimum royalties paid for the use of licensed patents must be capitalized in part to ending inventory under Section 263A.
Pharma and Life Sciences Tax News, Vol.12, No. 6: IRS disallowance of research credit for employee separation payments validates importance of documentation - 30 April, 2013
Important guidance for entities that are classified as FFIs under FATCA and considering applying for qualified intermediary, withholding foreign partnership, or withholding foreign trust status.
A taxpayer can meet the special rule for government contracts under Section 199.
The IRS provided applicable guidance implementing both a physical work standard and providing an economic safe harbor.
A recent PLR permitted the taxpayer to claim 'bonus depreciation' by filing Form 3115, Application for Change in Accounting Method.
US District Court concluded a policyholder had basis in the shares of stock received in connection with the demutualization of five life insurance companies.
A provision that limits deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
President Obama's FY2014 budget proposal includes a permanent extension of the production tax credit and would make the credit refundable.
The IRS recently issued a memorandum for all LB&I staff that provides direction to field examiners on the repair versus capitalization issue.
The President's budget asks Congress to "immediately begin the process of reforming the individual and business tax systems."
Form 8957, when issued in final form, may be used by foreign financial institutions (FFIs) to register for FATCA purposes.
Minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
Planning and development activities did not constitute a MPGE activity for purposes of the Section 199 deduction.
The UK Chancellor of the Exchequer delivered his 2013 Budget on March 20, 2013. The Chancellor reinforced the message that the United Kingdom is 'open for business'.
Payments to certain salaried employees pursuant to a 'voluntary separation program' do not constitute 'wages' eligible for the Section 41 research credit.
In this Newsbrief, we take a closer look at the potential impact of FATCA on the global captive insurance market.
To accelerate use of these credits, an election must be made under Section 168(k)(4).
Development activities held not Section 199 manufacturing activities
There could be a change to the country's thin capitalization regime.
This quarter, our authors explore the benefits, pitfalls, and opportunities of some of the the state and federal tax credits.
The Senate Budget Committee on a party-line vote approved an FY 2014 budget resolution. Senate Finance Committee announced upcoming meetings.
House Ways and Means issued a 'small business' tax reform discussion draft that features proposals affecting large and small partnerships and S corporations.
House Budget Committee Chairman Paul Ryan (R-WI) today released a proposed FY 2014 House budget resolution.
The exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange.In PLR 201304003, the IRS concluded that the exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange under section 1035.
The IRS issued Notice 2013-19, which clarifies deficiency reserves.
IRS released AM 2012-010, a GLAM addressing application of the end-of-the-day rule and the next-day rule of Reg. sec. 1.1502-76(b)
Treasury announced that all awards made under the Treasury 1603 cash grant program will be reduced by 8.7 percent.
Amendment that would change the evidence required to prove tax residency
The budget would defer the introduction of general anti-avoidance rules to April 1, 2015.
The Australian government recently introduced draft amendments to the Australian general antiavoidance rules.
The regulations provide guidance on the key issues that arise when options or convertible partnership interests are issued to investors.
Read this PwC tax insight on new temporary tangible property regulations for general asset account treatment of property subject to Section 168.
The excise tax for offshore medical device manufacturers in Puerto Rico has been set to 4% for taxable periods from January 1, 2013 until December 31, 2017.
The OECD released a related 90-page report, Addressing Base Erosion and Profit Shifting.
The Discussion Draft proposals would most significantly impact taxpayers that execute financial transactions as part of a trading or investment strategy.
Repayment to the DRS is due by February 14, 2013.
The taxpayer had a zero basis in the shares it received as part of a demutualization.
Yesterday, the IRS announced that a second round allocation of $150 million in tax credits will be available for advanced energy manufacturing property.
Companies with manufacturing operations in Puerto Rico (PR) are subject to an excise tax on goods or services provided to offshore-related entities under Act 154 of the Internal Revenue Code. The excise tax is imposed in lieu of the PR income tax that otherwise would apply as a result of the source rule.
Companies that meet certain requirements may elect to pay an alternative tax provided in Section 831(b)
This WNTS Insight will provide updates on important treaties and protocols between the United States and key countries in Europe, Asia, and South America.
The US Department of the Treasury and the Internal Revenue Service provided welcome relief on a number of key issues for the asset management industry.
The final regulations follow last February's release of the proposed regulations.
State assumed interest rates and applicable federal rates for the determination of reserves under Section 807(d) for insurance products.
COP18 UN climate change summit, carbon markets, carbon law, carbon price support, bilateral carbon offset, renewable energy, cleantech, environmental policy
Foreign taxpayers who paid cascading insurance excise tax evaluate filing protective refund claims
The protocol is significant since it provides for exclusive residence State taxation of interest.
Key international tax law changes that could affect US multinational corporations (MNCs).
IRS Large Business and International (LB&I) Commission issued a directive not to challenge qualified research expenditures (QREs) claimed by taxpayers in the pharmaceutical sector during Stage 1 (discovery and preclinical stage) or Stage 2 (clinical trial stage) of the pharmaceutical development process if the taxpayer provides a Certification Statement regarding those QREs.
Related to the insurance industry, these final FATCA regulations contain a number of significant differences from the proposed regulations.
500 pages of guidance in the form of final regulations to implement the provisions of the Foreign Account Tax Compliance Act (FATCA)
House Ways and Means Chairman Dave Camp released for public comment a discussion draft on reforming the tax treatment of financial products.
Final regulations were issued along with a press release on January 17, 2013
The Indian Finance Minister recently announced the government's intent to accept several of the committee's GAAR proposals.
President Obama signed the American Taxpayer Relief Act of 2012 (the Act) which freezes tax rates and retroactively reinstates certain business tax incentives that expired such as the research and development (R&D) tax credit for pharmaceutical and life sciences companies. This Alert provides guidance on accounting for the retroactive reinstatement of the R&D tax credit.
American Taxpayer Relief Act of 2012 extends the research credit for two years and resolves an issue regarding the treatment of qualified research expenditures
A new whitepaper from PwCs cross isciplined Global Information Reporting practice.
Companies now should consider whether to elect general asset account (GAA) treatment for their historic depreciable property.
Proposed regs to implement and expand the application of a voluntary IRS pilot program that permits filers to truncate taxpayer identification numbers (TINs).
The previous deadline of June 30, 2013 has been extended to June 30, 2014 for eligible officers and employees to file their 2010, 2011 and 2012 FBARs.
American Taxpayer Relief Act of 2012, retroactive extensions through 2013 of certain business and energy tax provisions that had expired.
Renewable and alternative energy provisions, including a one-year extension of the production tax credit for wind energy and a one-year extension of bonus depreciation.
The bill extends certain expired and expiring business and individual tax provisions through the end of 2013.
Mass. economic development incentive program, R&D credits, jobs incentives programs
We have prepared this report to assist management teams to identify and understand the areas most frequently commented on by the SEC.
Congress is set to recess for Christmas without a 'fiscal cliff' agreement to avoid scheduled tax increases and spending reductions
This quarterly publication focuses on critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
These modifications should make the program more appealing to employers and enhance options for employers.
The IRS published regulations amending the temporary regulations to delay the effective date.
The IRS revoked an earlier ruling allowing taxpayers to include the value of facility-specific PPAs in the depreciable basis of the project.
LB&I issued a memorandum regarding examination of section 41 research credit claims in the pharmaceutical sector.
OECD recently issued several updates and consultations relevant to transfer pricing that could have important consequences for multinational enterprises.
The Australian 2015-2016 federal budget contains measures to enhance the integrity of the Australian tax system.
The EEOC released a propos to modify employer wellness program rules under the Americans with Disabilities Act.
The IRS issued two new revenue rulings that both address step transaction issues
CCA 201518013 holds that a nonqualified plan's terms violating Section 409A can't be corrected in the year of vesting.
IRS Chief Counsel advises that none of a taxpayer's CFC loans satisfy Notice 88-108 unless all do
Colombia now imposes a net wealth tax on residents and nonresidents with net wealth exceeding certain thresholds
The Australian government has released draft legislation that would amend the Australian tax consolidation regime.
Spain has approved with the agreement of the EU Commission the new Spanish special tax regime for the Canary Islands.
Recent IRS rulings have provided more clarity regarding the assets and activities that may qualify for MLP treatment.
In AM 2015-002 the IRS recently provided the most detailed guidance to date regarding the 'tax rate desparity test.'
The IRS recently released CCA 201505038 clarifying the amount if income to be included by a lessee claiming rehabilitation
Treasury issues proposed regulations on the PFIC exception for foreign insurance companies.
The past year saw a number of important developments relating to tax incentives for research.
The Australian government has released exposure draft legislation for a proposed new Managed Investment Trust regime.
New rules define fiduciary by reason of retirement investment advice and outline exemptions for common transactions.
The final draft of the EU's Union Customs Code was published and creates ambiguity about whether 1st sale will survive.
Updated rules for benefit plans of exempt organizations, including 403(b) plans, 457(b) plans and defined benefit plans.
The multi-step treaty ratification process has been stalled.
Final regulations include rules for stock-based compensation to be performance-based and exempt from deduction limits.
New final regulations allow limited wraparound health coverage during a pilot program.
Final, temporary regs issued April 2 address allocating research credit among controlled group members.
Discusses the bonus depreciation extension and a court case on substantiation requirements for use of business aircraft.
Recent developments on Section 199 and other IRS guidance shed light on tax accounting method issues.
MNEs may be concerned about various aspects of the six Discussion Drafts released last week as part of BEPS
VAT News highlights: HMRC and VAT pension schemes, digital tax audit files in France, real time VAT reporting in Spain
Temporary & final regulations, Second Circuit affirmation: the Barnes Group Tax Court case, and a 'retroactive CTB' CCA.
This month's issue addresses recent tax and regulatory changes in various jurisdictions
We are pleased to share PwC's 2014 Year-End State Tax Review and a Look Ahead to 2015 and Beyond— a brief, interactive summary and collection of Insights focused on the key developments, issues and trends across the state and local tax landscape in 2014 and what we may expect for 2015 and beyond. There was one striking truth about the state and local tax world in 2014: It continued to offer a rich mix of legislative, judicial and administrative actions that altered the state tax landscape.
Tax-related identity theft is an increasingly widespread problem for both business and individual taxpayers. PwC's Beth Tucker explores the risks, effects, warning signs, and how business taxpayers can minimize their chance of becoming a victim.
The IRS is moving towards 'cooperative compliance' in interactions between the IRS and taxpayers, and have updated their process for Information Document Requests for multinational companies.
Global companies investing in the United States face unique opportunities and challenges. Doing business in the US reviews the key tax issues and provides insights to help investors navigate the US business environment.
For foreign-based multinational corporations (MNCs) doing business in the United States, the amount of customs duties paid on goods entering the U.S. often is not a top-level consideration. However, many of those companies might be leaving money on the table by paying more in customs duties than is necessary.
Joel Walters, leader of the U.S. inbound tax practice and the global communications tax practice at PwC shares insight on the overall tax environment, public perception of multinational companies and the OECD/G-20 BEPS project.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on the continually changing HR landscape and what organizations need to do to take control of today's opportunities and tomorrow's decisions.
Explore mandatory tax reporting rules, EU rules for banking, extractive and logging industries, plus US implementation & country-by-country reporting issues.
In the current economic environment, the priority for governments worldwide – and Western governments in particular – is for their tax systems to generate the level of revenues they expect. This focus is reflected in a strong public sentiment that everyone should 'pay their fair share'. Inevitably, 'everyone' is often defined in popular parlance as large corporations. And asked whether corporations are paying their fair share of tax, growing numbers of people appear to believe – rightly or wrongly – that the answer is "no".
PwC US Tax Leader, Mark Mendola recently spoke with Tax Analysts contributing editor Jeremiah Coder on tax uncertainty, accounting firm services, and future tax policy.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Total Rewards, and delve into the challenges employers face of getting their employees' "total rewards" packages right.
Over 1,300 CEOs talked to us about their global talent management issues. The results of these conversations are reflected in this report.
In this release we discuss a variety of accounting and reporting developments and the related tax accounting considerations.
TP to Go is a new mobile application from the PwC global transfer pricing network that brings the best thought leadership from the network directly to your current smart phone. TP to Go is free to download on iOS, Android, and BlackBerry.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Healthcare for Employers, and bring to light where the opportunities and obstacles might lie post-health reform and where different paths might lead.
This publication is focused on the topics we believe will be most relevant to the preparation of 2012 year-end financial statements.
In this special edition of PwC's Perspectives, Anthony Curtis and Ogniana Todorova from PwC US take a detailed look at transfer pricing in Africa.
In this release, we discuss decisions of the International Financial Reporting Interpretations Committee along with other accounting and reporting developments.
On November 8, a group of PwC Global Structuring Partners facilitated an engaging discussion with a group of senior tax professionals on a range of issues impacting the way multinational corporations align global structures to manage their US tax burden.
Learn how and why BRIC countries have made strides as manufacturing and services countries and are now developing into significant end markets for multinationals.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders.
This report looks at the challenges that companies across the world are facing as a result of stringent and diverse transfer pricing requirements.
PwC and the National Association of Stock Plan Professionals (NASPP) are pleased to announce the release of the 2012 Global Equity Incentives Survey (GEIS): "Back to the Basics"— Executive Summary. Our survey is one of the most comprehensive studies available on the design and administration of equity incentive compensation plans for multinational companies.
Our Tax policy Perspectives series provides insight into specific topics influencing global tax policy developments, including in-depth analysis of trends in specific jurisdiction. Drawing on case law, practical experience, and knowledge of tax systems worldwide, we'll provide a global perspective on each subject area, look at how it is currently playing out in a few contrasting territories and suggest the pivotal challenges to come.
Our tax policy trends publication provides analysis and insight into the key global trends influencing the development of tax policy worldwide.
Trends in multinational businesses, unremitted foreign earnings, and recent regulatory trends
This newsletter discusses a recent update to the financial accounting convergence projects and other accounting and reporting developments along with the related tax accounting considerations.
PwC's M&A Asian Tax Guide summarizes jurisdictions of the Asia Pacific area and highlights key tax issues relevant to purchasers and sellers of the mergers and acquisition transaction.
This report provides messages for companies with existing Swiss HQs which are seeking to expand their scope, assure their sustainability or reduce costs, for companies planning to implement a centralised business model but also for the Swiss authorities.
In this release, we discuss some recent updates to the financial accounting convergence projects and other tax accounting developments along with the related tax accounting considerations.
Goodwill impairment testing continues to be a challenging and complex area of practice. As companies perform goodwill assessments, tax considerations can play a critical role in the final conclusions.
This PwC reference guide helps you manage your financial services transfer pricing issues.
Key areas of focus when accounting for income taxes during interim periods
Accounting for income taxes 2011 year-end hot topics
As part of their current workplan, the SEC is analyzing the impact of IFRS on US issuers and whether, when, and how to incorporate IFRS into the US financial reporting system.
This issue of HR Innovation looks at current trends and their implications for meeting organizational goals while cultivating and sustaining an efficient, high-performing workforce in a dynamic organizational culture.
The impact of transfer pricing in financial reporting
2011 Global Equity Incentives Survey: The Rise of Performance-based Equity
Information on corporate and individual tax rates and rules in over 150 countries worldwide.


text:
In between my cartooning chores I try to find the time to do an instructable or two. So I would classify what follows as a minimalist-lazy-butt-speed-instructable with shortcuts taken wherever I can. Actually, a true feat of engineering...
Step 1: It will pan out one day...
No, I do not think IKEA really sells the RACK TWINKEN mold. I just wrote the logo on. By the way, does anyone know if the names of their products are real Swedish words?
I'm not trying to take anything away from your instructable. It's actually a very well done step by step. I just wanted to throw in my two cents:
this is for a twinkie copy cat recipe that I have made before. It's really, really, close to the original. So, basically use what you've done with an actual recipe. I hope you take this as a compliment to your instructable.
Make your own and impress your friends.
Anyways, I don't like cooking :(
+1 rating.
+1 vote.

subset: commoncrawl


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Ghost Train: The Studio B SessionsMore Albums by Marty Stuart
Track Listing
1. Branded
2. Country Boy Rock & Roll
3. Drifting Apart
4. Bridge Washed Out
5. A World Without You
6. Hummingbyrd
7. Hangman
8. Ghost Train Four-Oh-Ten
9. Hard Working Man
10. I Run To You
11. Crazy Arms
12. Porter Wagoner's Grave
13. Little Heartbreaker
14. Mississippi Railroad Blues
With his 14th studio album, Marty Stuart steadily continues to lead the charge in preserving the roots, culture and history of traditional country music.
"What inspires me now, is traditional country music," says Stuart. "It's the music I most cherish, the culture in which I was raised. It's the bedrock upon which the empire of country music is built, the empowering force that provides this genre with lasting credibility. It's beyond trends and it's timeless. With all that being said, I found traditional country music to be on the verge of extinction. It's too precious to let slip away. I wanted to attempt to write a new chapter."


text:
Presenting with iMindMap is a whole new ball game. iMindMap will take you from the early brainstorming stages, through the refining and planning, all the way to an exciting finished presentation with ease and confidence. A refreshing and dynamic alternative to presenting with bullet points and slides, Presentation View animates your map branch by branch and takes your audience on a journey through your ideas.
Build a well-structured argument, in memorable chunks of information, whilst always keeping the bigger picture in sight. Show how all the elements weave together to make the grand design and take advantage of the advanced linking abilities to tie together a variety of other material. Link to files, videos, websites, other Mind Maps or even slides – all from within iMindMap. Plus, customise the transitions, rotate the angles and adjust the zoom for a real visual feast.
View your maps as movable and groupable slides in our advanced presentation builder, so you can choreograph and customise your presentation to play out exactly how you want. Set timers for your presentation so that it can autoplay without you having to control it.
Haven't got time to arrange your presentation? Why not take the quick and easy route with our range of ready-made Presentation Templates. Whether you're in a meeting or teaching a class, you can just select the template and we'll build your presentation for you – it's as easy as that.
Your branch notes will also show up on the presenter screen to prompt you with the facts at key moments, so you can avoid the fearsome mental blank. A good presentation is all about delivering clear information in an exciting and memorable way, and with iMindMap's Presentation View you will struggle to do anything else.
You can add the finishing touches to your presentation by uploading your company logo so it will appear in the corner of every slide. This is particularly useful when presenting to clients or potential customers and to keep your audience captivated, apply a slick background to your slides or present in stunning 3D.
Don't forget, if you want to share your presentation with a wider audience, there are several exporting options available including PDF, Presentation Slides, Video Files or upload straight to YouTube. To learn more, please view our Export as Presentation page.


text:
Compression Clothing
Please try broadening your selection by deselecting or clearing the filters on the left.
Recovery after a tough session or a race is important and can help you to be ready for the next one. The fabric is designed to increase circulation and help remove blood lactate from exercising muscles leading to faster repair. You can choose compression clothing from top brands such as Orca and 2XU that suits you – and there are loads of options, full tights to calf guards and socks as well as race suits which use the technology to help power your muscles when it really matters.


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The Bible is perfect and contains ZERO contradictions
The Bible is perfect and contains ZERO contradictions
A True Christian™ guide to logic
The "problem": contradictions?
Every so often, an arrogant atheist pig will attempt to point out "contradictions" they've apparently found in the Bible using their unholy powers of "logic". Generally they attempt to use this as the basis of an argument denying the existence of God. I'm here to tell you why these people are so wrong that they're "not even wrong" (to borrow a term from their own parlance).
First, let's examine a few simple, oft-cited cases of "contradictions":
The faux Christian resolution to the "problem"
Faux Christians (or foe Christians, if you prefer) are invariably hardline revisionists. The revisionist tactics can be used to make the Bible mean whatever you want it to! You can reinterpret verses to change their meaning and ignore the parts you don't like, effectively transforming God's word into something that isn't God's word. The relevance of this to our overall theme is that revisionists will often try to resolve so-called "contradictions" in the Bible by excluding verses, changing their meanings or by forging a weird hybrid interpretation of multiple verses on the fly. I'm going to explain why this is clearly the wrong way to go.
When confronted with a Bible verse that tickles their conscience or doesn't neatly coincide with their existing worldview, faux Christians resolve the cognitive dissonance by simply discarding the "questionable" verse. They do a similar thing on a massive scale whenever the Bible fails to keep up with the contemporary moral standards for mainstream society (see the progressive attitude towards homosexuality for example). They'll say that the verses about stoning, slavery and submissive wives are anachronisms; that they were a function of the time in which they were written. When asked why God's word isn't perfect and timeless, they'll say the Bible was "inspired by God" but "transcribed by fallible humans". What they're basically saying is that humans can't be trusted to relay the word of God accurately -- yet these same people are absolutely fine with different and equally fallible people relaying a modified version of the message 2000 years later? No, I'm sorry, that's just stupid.
What does this mean? Well, for starters, it means that faux Christians are wrong. They're wrong and they may just end up in hell for it. What they're really doing is holding the Bible to their own moral standards instead of holding their own moral standards to the Bible. Where does God say that it's okay to ignore parts of the Bible that you don't like? Where does God say that some verses have an expiry date? The Bible describes homosex as an abomination, not an abomination until next Tuesday. As soon as you change one little word of God's book, all guarantees are off. By the time you realise that your modified Bible isn't actually what God intended, you'll be in hell.
If you're going to go through the Bible with a marker pen, crossing out what you don't like, why don't you just burn the thing? First, you decide that there's nothing shameful or dirty about a woman's intimate bleeding, next thing you know you're harpooning whales with your penis. Crossing out Bible verses is a slippery slope.
Some of this selective ignorance is actually sanctioned by religious "leaders" and "authorities". The catholic church, for instance, reinterprets the Bible pretty much at will (presumably useful to justify raping altar boys). Don't be fooled, the Bible doesn't give those "leaders" the right to rewrite it either. All humans are fallible and cannot be trusted to reinterpret the Bible without damaging its integrity.
I hope I've shown you that, no matter who is doing the revision, Biblical revisionism is wrong and hypocritical. Frankly, the faux Christians who engage in it are the last people I would want resolving the Bible's so-called "contradictions".
The overarching point of all this is that you can not and should not attempt to resolve contradictions in the Bible, nor should you delegate this responsibility to fallible, self-appointed religious "authorities".
You are stupid, God is not
Although I'm not convinced that quantum mechanics is real (I've never seen a "quibit", have you?), if God did create it, it would certainly help to demonstrate my next point. You see, quantum mechanics makes no sense and physics PhDs can confirm that. God doesn't have to make sense to less intelligent lifeforms like us. In other words: the Bible isn't stupid, you're stupid. What you understand to be "contradictions" using your limited powers of "logic" and "deduction", God does not.
Consider the following: if God limited His actions to only those that you, personally, can understand, he could never have created humanity! Can you create a human from scratch? Because I sure can't! Our contemporary scientists, supposedly some of the brightest minds on the planet, can't even isolate the gene that turns blacks into sub-human savages. How can we have the sheer arrogance to demand that God works in ways understandable to us when our understanding is so limited?
One of atheism's major problems is an inherent superiority complex. I couldn't tell you why this happens, perhaps it's a little game to make their stay in hell's waiting room more pleasant. But have you atheists ever considered that perhaps not everyone is stuck in the same quagmire of "rationality"? That not everyone is as dumb as you?
Take, for example, Stephen Hawking. I'm sure he understands quantum mechanics. I'm sure he understands a lot of things that you don't. Perhaps he doesn't see the "contradictions" in the Bible that you do. Are you really so arrogant as to claim intellectual superiority over him? Now, before you say to me "Elijah, you're wrong, Stephen Hawking is a God-mocking spaz-o-tron" maybe we should stop and consider why he preaches atheism. Isn't it obvious? God made him a degenerate cripple so now he's angry and bitter. And why did God make him a degenerate cripple? Well, probably because God knew what a nasty secuLIAR he would turn out to be.
Challenging the logical paradigm
It's not my job to educate you on the subject of formal logic. Logic, like all things, was created by God. Logic is a great thing sometimes. It can be used for wonderful, Godly purposes. But all too often atheists misunderstand and misuse it to continue oppressing Christians. I see it all the time on this forum unfortunately.
Traditional formal logic (propositional, predicate etc.) deals with binary classifications of true and false. A statement is either true or false. "All atheists are satanists" is either true or false (it's true by the way). "Catholic priest Father Frank is a paedophile" is either true or false (it's actually false -- he's dead). And so on and so forth. In formal logic, a contradiction occurs when there is a conflict between two statements (or propositions, to be precise).
Let's take, for example, the first Biblical "contradiction" listed in this thread. The first proposition is that "God dwells in the light" and the second is that "God dwells in the dark". Since, as I'm sure you'll agree, "dark" implies an absence of light, classical logic would consider this a contradiction. Both propositions cannot simultaneously be true.
Let's represent the two propositions by the letters p and q as follows:
We know this system of propositions is inconsistent; it is contradictory. We know that p and q are incompatible because of our a posteriori knowledge of their semantics.
If we acknowledge that when there is no light, there is darkness then (that is that q is the equivalent of the negation of p).
With this simplification, we can express the system as a conjunction of both propositions (for those who don't know their logical symbols, the identity below simply states that two statements of opposite meaning cannot both be true simultaneously):
Since this compound proposition is always false by the negation law, it is a logical contradiction in its purest form.
I believe I've now established common ground and a shared starting point between us by acknowledging that the traditional paradigm of logic demonstrates "contradictions" in the Bible. I'm not disputing that. What I am disputing is the application of classical logic, which is limited by our human intellect, to God's work. It's fallacious to cry wolf about apparent "contradictions" when we really have no understanding of God's logic.
Why should necessarily be false? After all, God created everything, including logic, so it seems insufferably arrogant to claim that we know better than He does about how it works. Where does this idea that is false even come from? Nowhere in the Bible does it say that this is a contradiction.
Given that we have observed "contradictions" in the Bible using the classical paradigm of logic, it is clear that our classical paradigm is not objectively correct (and I'm surprised that academics aren't more concerned about this). It works for some things, sure, but we need to refine the very foundations of our logic if we are to stand a chance of reasoning about the Bible.
The idea of a "supposition of states" is one of the things that makes quantum mechanics so difficult to understand. But if it exists, God understands it perfectly! Never forget that God can understand things of which we cannot even conceive. Likewise, He is able to see through and think beyond our simplistic categorisation of true/false to create things that are neither.
Enter fuzzy logic
Over time, scholars grew wise to our cognitive errors and black-and-white thinking. What heathens call "fuzzy logic" is probably the closest approximation to God's own logic system that we have achieved to date. If the number 1 represents "true" and 0 represents "false" then fuzzy logic opens up the entire domain of real numbers between 0 and 1 for valuations. Under fuzzy logic, statements like "that's kind of true" suddenly become fair game.
Let's examine how we can apply fuzzy logic to the Bible with our previous example propositions, p and q. Let 1 represent "God dwells in light" and 0 represent "God dwells in darkness" such that a value of 0.5 might represent the statement "God dwells in half-light" (I say "might" because I have no idea what God intended, I'm just trying to expand your mind to see beyond simplistic "contradictions").
How do we work out a single number from two Biblical propositions? Well, that's simple! There's a variadic function, let's call it g (defined g(p, q, ...)), which takes an arbitrary number of Biblical propositions (greater than or equal to 2) and returns an answer. The answer is a number between 0 and 1 indicating God's intended balance between the original propositions.
In cases where the interpretation of the result is not intuitive (i.e. every case because God defies human intuition), there is another analogous function, i, which takes the same arguments as g and returns the semantics of g's valuation.
Since g and i return a number and a single atomic proposition, respectively, there's no way for the results to be contradictory according to the axioms of classical logic. Thus it is trivially seen that there aren't actually any contradictions in the Bible at all.
Under my proposed system, you can use the two functions to resolve ANY so-called "contradiction" in the Bible!
Obviously, the functions are not available to you or I. Why would they be? We should be praying, not questioning God's reasoning. But their existence should be hugely comforting to all real Christians.
Hopefully you're satisfied that I've demonstrated the perfect nature of the Bible and its complete lack of contradictions.
To summarise:
So just follow what the Bible says, to the letter, and look forward to eternal life in Heaven! Praise Jesus!
But they mocked the messengers of God, and despised his words, and misused his prophets, until the wrath of the LORD arose against his people, till there was no remedy. (2 Chronicles 36:16)
Guides and teachings:
The Bible is perfect and contains ZERO contradictions: A True Christian guide to logic
Using a spirit level to identify homosexuals: A guide for those without the "gaydar"
Things that don't anger God:
Landover Baptist Church
Killing For Christ
Re: The Bible is perfect and contains ZERO contradictions
Praise Jesus! What a beautiful explanation, Dr. Mee! Your explanation clearly shows that all atheists, agnostics, and cherry picking false Christians are, indeed, fools in the eyes of God!
God created fossils to test our faith.
* * *
My favorite LBC sermons:
True Christians are Perfect!
True Christian Love.
True Christian Man as a spitting image of God.
You cant be a Christian if you dont believe the Old Testament.
Jesus is impolite. Deal with it.
Sanctity of Life is NOT a Biblical Concept.
The Immorality of the "Universal Declaration of Human Rights."
Geneva Conventions vs. The Holy Bible.
God HATES Rational Thinking!
Re: The Bible is perfect and contains ZERO contradictions
But they mocked the messengers of God, and despised his words, and misused his prophets, until the wrath of the LORD arose against his people, till there was no remedy. (2 Chronicles 36:16)
Guides and teachings:
The Bible is perfect and contains ZERO contradictions: A True Christian guide to logic
Using a spirit level to identify homosexuals: A guide for those without the "gaydar"
Things that don't anger God:
Landover Baptist Church
Killing For Christ
Re: The Bible is perfect and contains ZERO contradictions
My brother! You speak the words of the Lord! From Matthew to Mark to John and Luke you are the words of our saviour Jesus Christ! I cannot thank you enough for your revelation, I too am not worthy to receive your word.
Re: The Bible is perfect and contains ZERO contradictions
Please make a thread of your own in the "Introductions" section of the forum, so that we can properly greet you. Tell us about yourself, your church, and how you came to find Jesus.
And if you're here to flame us, better take a look at THIS before making an even bigger ass out of yourself.
I will pray that the Holy Spirit enter you and chase the demons out of your rectum and let Jesus fill you with His Grace. If you use your God-given free will to reject Christ and His temporary death on the cross for my sins, then you are sending yourself to hellfire.
--Pastor Ezekiel
Who Will Jesus Damn?
Here is a partial list from just a few scripture verses:
Hypocrites (Matthew 24:51), The Unforgiving (Mark 11:26), Homosexuals (Romans 1:26, 27), Fornicators (Romans 1:29), The Wicked (Romans 1:29), The Covetous (Romans 1:29), The Malicious (Romans 1:29), The Envious (Romans 1:29), Murderers (Romans 1:29), The Deceitful (Romans 1:29), Backbiters (Romans 1:30), Haters of God (Romans 1:30), The Despiteful (Romans 1:30), The Proud (Romans 1:30), Boasters (Romans 1:30), Inventors of evil (Romans 1:30), Disobedient to parents (Romans 1:30), Covenant breakers (Romans 1:31), The Unmerciful (Romans 1:31), The Implacable (Romans 1:31), The Unrighteous (1Corinthians 6:9), Idolaters (1Corinthians 6:9), Adulterers (1Corinthians 6:9), The Effeminate (1Corinthians 6:9), Thieves (1Corinthians 6:10), Drunkards (1Corinthians 6:10), Reviler (1Corinthians 6:10), Extortioners (1Corinthians 6:10), The Fearful (Revelation 21:8), The Unbelieving (Revelation 21:8), The Abominable (Revelation 21:8), Whoremongers (Revelation 21:8), Sorcerers (Revelation 21:8), All Liars (Revelation 21:8)
Need Pastoral Advice? Contact me privately at firstname.lastname@example.com TODAY!!
Re: The Bible is perfect and contains ZERO contradictions
No man can serve two masters: for either he will hate the one, and love the other; or else he will hold to the one, and despise the other. Ye cannot serve God and mammon. Matthew 6:24
But they mocked the messengers of God, and despised his words, and misused his prophets, until the wrath of the LORD arose against his people, till there was no remedy. (2 Chronicles 36:16)
Guides and teachings:
The Bible is perfect and contains ZERO contradictions: A True Christian guide to logic
Using a spirit level to identify homosexuals: A guide for those without the "gaydar"
Things that don't anger God:
Landover Baptist Church
Killing For Christ
Re: The Bible is perfect and contains ZERO contradictions
I have been delighted by the lack of atheist response to this thread. I knew you atheists were stupid but I expected at least some kind of incoherent ranting.
But they mocked the messengers of God, and despised his words, and misused his prophets, until the wrath of the LORD arose against his people, till there was no remedy. (2 Chronicles 36:16)
Guides and teachings:
The Bible is perfect and contains ZERO contradictions: A True Christian guide to logic
Using a spirit level to identify homosexuals: A guide for those without the "gaydar"
Things that don't anger God:
Landover Baptist Church
Killing For Christ
Re: The Bible is perfect and contains ZERO contradictions
Isaiah 24:23 KJVThe atheist world is meagre and bleak. Aristotle is reported to have wasted time cooking up arguments about nothing for example. Is a void, empty space, nothing? What if there were no space? What would that be? Nothing. So that's two types of nothing.
WARNING ~ contains gibberish ~ intended For Parental Guidance following the stuff pumped out by television networks these days
These dismal eternities encourage neither present hope nor future delight. Nothing is as good as it gets. The Bible is not like that as every atheist knows and probably that's why they don't respond. Maybe they read the thread and find it too challenging. So if that's the case I would not like them to go away empty handed and will post an easy-to-read tract demonstrating what is available from God, whose Plan offers us the certainty of Redemption and forgiveness. But forgiveness demands a price, which is set out at the end, so without further ado and with Scriptural references throughout..
Jeremiah 17:18 KJV
Re: The Bible is perfect and contains ZERO contradictions
The only bigger waste of time than philosophy is theology. God's word does not require a degree in theology to understand because God takes mercy on the borderline retardeds (but not the full retardeds and illiterates who cannot know His word and will only know hell). Praise Him!
But they mocked the messengers of God, and despised his words, and misused his prophets, until the wrath of the LORD arose against his people, till there was no remedy. (2 Chronicles 36:16)
Guides and teachings:
The Bible is perfect and contains ZERO contradictions: A True Christian guide to logic
Using a spirit level to identify homosexuals: A guide for those without the "gaydar"
Things that don't anger God:
Landover Baptist Church
Killing For Christ
Re: The Bible is perfect and contains ZERO contradictions
Now my head is going peculiar as I think about that, but I was reminded of the dialogue between Democritus and Aristotle just as Paul had been reminded in his epistle to the Corinthians.
Often, in a musical environment, I am required to assess the performance on drums by participants in an educational setting. There is a sliding scale from abysmal to excellent according to such parameters as
The optimum value might be 0 in that case.+2
For example a drummer could be consistent and confident, which would get a good score
but be playing the wrong rhythm
So there'd be a +2 and a 2 resulting in a score of 0 overall but that would be a bad 0, not a good 0.
In the imaginary world of secular logic with its discrete minima and quantum leaps, its "rights" and "wrongs" and "mutuallies exclusive" perhaps a similar system would be useful?
Responses at the extremities of any range are more significant. The greater the folly, as perceived through the lens of atheistic logic, the clearer their delusion becomes. Having established that the atheist's responses have a consistency significantly better than random (random responses merit no further analysis because they are random) we would like to know whether their responses are balanced. In the above example a t test demonstrates that although our drummer was drumming away like billy-o what was being played was no better balanced than random
Consistency? consistent and confident, which would get a good score +2
Balanced? but be playing the wrong rhythm 2
t test says not balanced = bad 0
and it's exactly the same for the atheist, raving in an imaginary number of meaningless propositions all based upon the baseless foundation of disbelief
Consistency? consistent and confident, "Christians are always mad, bad and dangerous to know" +2
Balanced? but although they call us "mad" or "deranged" it's for a different reason every day 2
t test says not balanced = bad 0
We get to hear the atheist drum here quite a lot. There are minor issues such as the taxonomic system for describing creatures with wings or whether the 7th day is Saturday or Sunday and stuff like that of which there's quite a lot and it's all somewhat arbitrary really.
...God has explained the true situation.
......They disagree,
.........Cest la vie.
The more significant matters, such as whether exterminating myriads of heathen babies is an expression of love, are more confronting. So often we read in their posts how God commands murder or rape or whatever distortion of His Inerrant Word they favour on the day when we know that nothing God commands ever disagrees with His commandments.
. These objections from atheists show the devil inside each one of them is at full oven temperature.
By subtracting the number of minor perceived discrepencies as described by the atheist observer from their more significant responses at the extreme end of the range a negative number of observations becomes available.
To see whether theirs is a balanced response the variance is divided by which in this case is an imaginary number since we are dealing with the significant responses (having subtracted their arbitrary objections which are not significantly different from random and amount to just making up stuff to be awkward) thereby aligning our analysis with the imaginary nature of their objections as described by Paul in his comparison with the Greek philosophers, some of whose musings I have posted.
Disbelief in God is an abomination in its own right and we know from Dr Mee's demonstration that they are claiming opposites to be the same thing as well, p and not p applied to light and not light or to thick darkness and not thick darknessthey might as well just say that light is the absence of darkness and get it over withamounts to declaring God's presence as the negation of His absence and since His absence is the primum mobile of all their pronouncements, the atheist agenda stands revealed as presuppositionalist dogma in all its glum stupor.
No wonder they invented the unconscious mind
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