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In this section of Jnet, we provide brief updates on legislative, judicial, and administrative developments in tax that may impact Japanese companies operating in the United States.
July 2015
"Highway Bill" Signed into Law
On July 31, President Obama signed H.R. 3236, Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.
H.R. 3236 provides funding and authorizes spending with respect to the highway trust fund through October 29, 2015. In addition to measures concerning TSA fees and veterans' health issues, the bill includes a number of tax-related provisions to raise approximately $5 billion in revenue to offset the cost of the additional months of spending for surface transportation as follows:
In addition to these revenue offsets, the bill would decrease the excise tax on LNG and LPG to 14.1 cents per gallon (down from 24.3 cents) and 13.2 cents per gallon (down from 18.3 cents), respectively, for sales or use of fuel after December 31, 2015
Draft Proposal for Innovation Box
Two senior members of the Ways and Means Committee—Rep. Charles Boustany (R-TX) and Rep. Richard Neal (D-MA)—have released for public comment a discussion draft and technical explanation of an "innovation box" proposal.
The innovation box draft proposal would substantially lower the rate of tax for a corporation with respect to dispositions of intellectual property (IP) and products produced using IP. The proposal would establish a special deduction equal to 71% of the lesser of the taxpayer's innovation box profit or taxable income for the tax year. This would result in an effective tax rate of approximately 10% on innovation box profits. However, the deduction could not be taken into account in computing any net operating loss and therefore could not create, or increase, the amount of a net operating loss deduction.
The international tax reform working group of the Senate Finance Committee, in its final report (July 7, 2015), included among its recommendations the adoption of an innovation box regime. The working group's report noted that some 11 countries have adopted such regimes, and that an apparent consensus has been reached in connection with the OECD's base erosion and profits shifting (BEPS) project around a modified nexus approach that would permit innovation box regimes. An early change to U.S. tax policy is necessary, the authors of the working group's report wrote, to prevent these shifts in the international landscape from leading to "…a significant detrimental impact on the creation and maintenance of intellectual property in the United States, as well as on the associated domestic manufacturing sector, jobs, and revenue base."
Ways and Means Members Propose to Reform Partnership Audit Rules
The Ways and Means Committee members, Rep. Renacci (R-OH) and Rep. Kind (D-WI) introduced H.R. 2821, the Partnership Audit Simplification Act, a bill that would reform the partnership audit rules.
H.R. 2821 in general would replace the existing partnership audit procedures established by the Tax Equity and Fiscal Responsibility Act (TEFRA) and the "electing large partnership" audit rules with a single set of rules. If enacted, H.R. 2821 generally would be effective for partnership tax years ending after 2018, with partnerships permitted to elect to apply the new rules for any partnership year beginning after date of enactment.
H.R. 2821 is largely similar to proposed changes included in the tax reform bill introduced by former Ways and Means Chairman Dave Camp (R-MI) in the last Congress. Although the Obama Administration has not yet expressed an official position on H.R. 2821, the administration's budget proposals for FY 2016 also include a similar proposal. Because H.R. 2821 can be expected to be estimated as raising revenue, members of Congress might consider using it to offset costs of other legislation.
New York: Guidance on Identifying Investment Capital
New York State Department of Taxation and Finance issued a technical memorandum outlining the identification requirements for Article 9-A taxpayers with investment capital.
Under New York's recent corporate tax reform (effective for tax years beginning on or after January 1, 2015), net investment income from qualifying investment capital is excluded from a taxpayer's business income. Similarly, investment capital is excluded from a taxpayer's business capital tax base.
To qualify, investments in non-unitary corporate stock must: 1) qualify as a "capital asset" under IRC section 1221; 2) be held for investment for more than one year; 3) generate long-term capital gain or loss under the IRC if disposed of; 4) for stock acquired on or after January 1, 2015, have never been held for sale to customers in the regular course of business; and 5) before the close of the day on which the stock was acquired, be clearly identified in the corporation's records as stock held for investment in the same manner as required under IRC section 1236(a)(1).
The technical memorandum sets forth the procedures required to satisfy the identification requirement for investment capital. Taxpayers generally are required to perform identification procedures with regard to stock and options currently held that may qualify as investment capital before October 1, 2015. Taxpayers also need to consider procedures that allow for proper identification of stock acquired on or after October 1, 2015, as investment capital before the close of the day on which such stock was acquired.
Washington State: Changes relating to B&O Tax, Nexus, Unclaimed Property
On July 8, the governor of the State of Washington signed into law legislation that makes changes to the state's business and occupation (B&O) tax and sales and use tax statutes, including:
The nexus changes are effective September 1, 2015. All other provisions are effective August 1, 2015.
June 2015
BEPS - Tax Committee Chairmen Request Treasury Coordinate with Congress
On June 9, the chairmen of the congressional tax-writing committees wrote to Treasury Secretary Jack Lew, calling on Treasury to work with Congress concerning the international tax proposals being considered under the OECD's base erosion and profit shifting (BEPS) project and in advance of OECD International Tax Conference being convened in Washington, D.C.
Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways & Means Committee Chairman Paul Ryan (R-WI) wrote that they were troubled by some positions the Treasury Department apparently was agreeing to as part of the BEPS project. In particular, they were concerned about that foreign governments would be able to collect the "master file" information directly from U.S. multinationals without any assurances of confidentiality or that the information collection is needed
As some recent press reports indicated that the Treasury Department believes it currently has the authority under the Internal Revenue Code to require country-by-country reporting and that the IRS guidance on this reporting will be released later this year, Mr. Hatch and Mr. Ryan believed the authority to request, collect, and share this information with foreign governments is questionable and requested that the Treasury Department and IRS provide the tax-writing committees with a legal memorandum detailing its authority for requesting and collecting the country-by-country information from certain U.S. multinationals and master file information from U.S. subsidiaries of foreign multinationals. They also requested a document (i) identifying how the country-by-country reporting and other transfer pricing documentation obtained by the IRS on foreign multinationals operating in the United States will be utilized and (ii) providing the justification for agreeing that sensitive master file information on U.S. multinationals can be collected directly by foreign governments. They warned that Congress will consider taking action to prevent the collection of the country-by-country and master file information if requested information is not provided.
Mr. Hatch and Mr. Ryan also expressed concerns about other proposals of the BEPS project including modification to the permanent establishment rules, use of highly subjective general anti-abuse rules (GAAR) in tax treaties, and introduction of interest-deductibility limitation.
This Hatch-Ryan letter is largely consistent with the position taken by Senator Hatch and then Ways & Means Chairman Dave Camp in the last Congress. In particular, the House and Senate tax writers have consistently viewed much of the OECD's BEPS work product to be within the jurisdictional domain of the legislative branch, not the executive. The Hatch-Ryan letter, however, moves beyond general criticism to directly question Treasury's authority to implement the country-by-country reporting standard.
Trade Bill Includes Tax Provisions
H.R. 1295, the Trade Preferences Extension Act of 2015, passed by Congress and signed into law by the president on June 29 addresses a number of expiring trade items and also includes a number of tax-related provisions as revenue offsets:
Texas: Reduction in Franchise Tax Rates
On June 15, House Bill 32, the Franchise Tax Reduction Act of 2015, has been signed into law by Governor Abbott. The bill, which applies to original reports filed on or after January 1, 2016, permanently reduces Texas franchise tax rates.
Specifically, the general one percent rate will be reduced to 0.75 percent. The 0.5 percent rate that applies to taxpayers primarily engaged in wholesaling and retailing will be reduced to 0.375 percent.
Another provision of the bill provides relief to small businesses. Currently, a taxable entity may elect the EZ computation (and reduced rate) if its total revenues are not more than $10 million. Under the revised law, a taxable entity may elect the EZ method if its total revenue does not exceed $20 million. House Bill 32 also reduces the franchise tax rate for taxpayers electing the EZ computation from 0.575 percent to 0.331 percent.
California: Regulatory Project on Space Transportation Activities
The FTB recently announced that it will hold an interested parties meeting on July 9, 2015 to explore a regulatory project on space transportation activities. More specifically, the FTB wants to assess the advisability of undertaking a regulatory project on how the state should source receipts derived from sending people and cargo to and from space. At this initial meeting, FTB staff plan to solicit input from industry and practitioners on tax issues that should be addressed in any proposed regulation.
Possible topics for discussion include (1) how space transportation activities should be defined; (2) at what point should aircraft or space vehicles be considered as traveling into space; and (3) what factors and weight should apply to receipts derived from space transportation activities. Apparently recognizing that space travel is not without kinks, the regulation may also need to address the treatment of receipts from unsuccessful or aborted missions. Finally, the pesky problem of receipts assigned to a jurisdiction where a taxpayer is not taxable takes on a whole new meaning when dealing with receipts that could be assigned to locations beyond the earth's atmosphere.
California: Law Mandating Combined Reporting Only for Interstate Taxpayers Held Unconstitutional
The California Court of Appeal, Fourth District ruled that the trial court erred when it sustained the FTB's objection to a taxpayer's claim that allowing to elect between combined reporting and separate accounting only to intrastate taxpayers violated the Commerce Clause.
Under California law, multistate taxpayers engaged in a unitary business are required to file a combined report while unitary groups that are completely intrastate in nature can elect to file combined or use separate accounting. The taxpayer, a motorcycle company and its several subsidiaries, argued that the differential treatment afforded to intrastate and interstate unitary businesses violated the Commerce Clause.
After quickly concluding that the differential treatment prong was satisfied, the court reviewed a number of discrimination cases and determined that the taxpayers had sufficiently alleged that the differential treatment of intrastate and interstate unitary groups was discriminatory under Commerce Clause precedent. The court next remanded the case to the trial court to address the Board's contention that even if the differential treatment discriminated against interstate commerce, it nonetheless passed a strict scrutiny analysis because the state had a legitimate reason for the discriminatory treatment.
May 2015
Treasury's Proposed Revisions to U.S. Model Tax Convention
On May 20, the Treasury Department released drafts of the following five proposed revisions to the U.S. Model Tax Convention for public comment:
As noted in a Treasury release, the aims of these revisions are: (1) to determine that the United States is able to maintain the balance of benefits negotiated under its treaty network as the tax laws of treaty partners change over time; and (2) to deny treaty benefits to companies that change their tax residence in an inversion transaction.
One set of draft provisions addresses issues arising from "special tax regimes" that provide very low rates of taxation in certain countries—in particular to mobile income, such as royalties and interest. Consistent with the BEPS project, the proposals are intended to avoid instances of "stateless income" or double non-taxation, whereby a taxpayer uses provisions in the tax treaty, combined with special tax regimes, to pay no or very low tax in the treaty partner countries.
The second set of draft provisions is intended to reduce the tax benefits from a corporate inversion by imposing full withholding taxes on key payments such as dividends and base stripping payments, including interest and royalties, made by U.S. companies that are "expatriated entities" as defined under the Internal Revenue Code.
Also part of the effort to eliminate BEPS, proposed revisions are intended to prevent taxpayers from inappropriately obtaining the benefits of a tax treaty on income that escapes tax in their country of residence. These include more robust rules on (1) the availability of treaty benefits for income that is not subject to tax by a treaty partner because it is attributable to a permanent establishment located outside the country of residence; and (2) the ability of a company to make excessive base eroding payments.
The revised limitation on benefits (LOB) article includes a reworked version of the existing "derivative benefits" rule, to provide the opportunity of qualifying for treaty benefits based on a broader concept of ownership that includes certain third-country ownership.
Treasury has invited comments on these proposed treaty rules. The U.S. Model Tax Convention was last updated in 2006.
Senate Finance Tax Reform Working Group Recommendations Delayed
On May 21, Senate Finance Committee Chairman Orrin Hatch (R-UT) and ranking member Senator Ron Wyden (D-OR) announced that they would give their tax reform working groups additional time to develop specific recommendations.
Each working group is assigned to one of five topics (individual income tax, business income tax, savings and investment, international tax, community development and infrastructure) and had been tasked with making recommendations back to the Senate Finance Committee during the week of May 25, 2015. Since March 2015, the working groups have spent months holding meetings and roundtables with congressional and administration staff, taxpayers, and other stakeholders. In addition, comments from interested parties were solicited, and stakeholders responded by submitting over 1,400 suggestions.
The delay is notable in two ways. First, it narrows the window in which the Senate Finance Committee could act on the working group recommendations this year because many believe that complex and potentially controversial legislation like tax reform could become impossible once the 2016 presidential race begins in earnest later this summer. Second, while some speculated that the bipartisan groups' work product might be something short of actual tax reform recommendations, it appears that Hatch and Wyden still expect the working groups to develop recommendations and are willing to wait a bit longer to get them.
IRS Request for Comments on New Financial Accounting Revenue Recognition Standards
On May 29, the IRS released Notice 2015-40 to request comments regarding the effect on taxpayers' methods of accounting of new financial accounting revenue recognition standards announced by the Financial Accounting Standards Board (FASB) and the International Accounting Standards Board (IASB).
The new standards for the timing of income for financial accounting purposes may affect the timing of income for tax accounting purposes for many taxpayers, such as taxpayers:
The new standards may affect some industries more than others. For example, it has been noted that the new standards may affect the software, entertainment, manufacturing, and construction industries because the new standards may change the timing of income recognition for financial accounting purposes significantly for these industries.
As the IRS noted, accounting method changes for federal income tax purposes require the permission of the IRS. Notice 2015-40 states that the new standards raise a number of substantive and procedural issues for the IRS, including whether the new standards are permissible methods of accounting for federal income tax purposes, the types of accounting method change requests that will result from adopting the new standards, and whether the current procedures for obtaining IRS consent to change a method of accounting are adequate to accommodate those requests.
Because adoption of the new standards may create or increase differences between financial accounting and tax accounting rules, the IRS and Treasury Department are considering whether to issue guidance on the new standards and request public comments on the scope, substance, and form of guidance needed. Comments are due on or before September 16, 2015.
Reach out to KPMG's U.S. Japanese Practice
The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser. This article represents the views of the authors only, and do not necessarily represent the views or professional advice of KPMG.
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Above: Sandia Crest Near Sunset
Albuquerque Tea Party
Emergency Communication Team
Radio Communication Page
Organizer: Duke Winsor
Albuquerque is blessed with scenic beauty, dominated by the Sandia Crest (Crest). If you look closely at the top of it, you will see a number of antennas. Many of these are public commercial broadcast antennas, but others belong to commercial non-public and amateur radio services. These provide unique capabilities for Albuquerque residents. From the Crest, a radio signal can reach much of New Mexico. From Mount Taylor (Taylor), even more of the western part of the State can be reached from its top (known there as "Microwave Ridge").
A licensed Amateur Radio Operator (Ham) can use a small hand-held radio, like the one on the left to communicate with a "repeater" on either the Crest or Taylor, and from there communicate with other hams around the New Mexico and beyond. The "repeater" simply receives the signal sent from that hand-held radio and repeats it on a standard frequency offset with much greater power than the hand-held radio produced. Some of these repeaters link to other repeaters. In particular, there is a Mega-Link repeater system that covers most of New Mexico "plus portions of six surrounding states." For someone who has the time and inclination to get a Ham license, that is a lot of communication capability, available from just a basic hand-held radio, whose costs starts around $30.
For one who has neither the time nor the inclination to get a Ham license, similar radios can make use of hand-held to hand-held communication, which is good for typically a few miles, "line-of-sight." The range of these transceivers is greater than hand-held CB radios, but less than an car-installed CB radio. There are two unlicensed "public service" bands that the FCC has allocated, the Family Radio Service (FRS) and the Multi-Use Radio Service (MURS). These frequencies do not have repeaters on them. One more option is the General Mobile Radio Service (GMRS), which requires a license which you can apply for "if you are 18 years or older and not a representative of a foreign government." It currently costs $90 and is good for 5 years. There is a GMRS repeater on the Crest.
OK, that's what is available and potentially useful. Why might you want one? In any emergency, telephone circuits may be overloaded. When electricity goes out for a long time, conventional and cellular telephones may become inoperative. These transceivers can receive for a long time on built-in rechargeable batteries. The amount of transmit time depends on the battery capacity and transmit power, but is typically hours.
Which kind should you get? The FRS and MURS are most popular with extended families that live near each other. Their use is arranged by a specific small group of people. The GMRS service is more commonly used by companies, but the Albuquerque repeater is open to all GMRS licensees, according to its website. In all of these cases, you are more or less on your own to arrange your usage.
Getting a Ham license is a substantial commitment of time, but there is a lot of support around Albuquerque to help you. As of 15 May 2015, there are 2085 licensed Hams in Albuquerque, and another 410 in Rio Rancho. There are many clubs, including the Albuquerque Amateur Radio Club, the Caravan Club and the High Desert Amateur Radio Club (HDARC). The HDARC offers license tests monthly, and classes less frequencly. Most clubs have members who will mentor someone wanting to prepare for a license. There is a thorough (technician) license manual that costs about $30.
If you just want to see what Ham radio is about, contact one of the clubs to ask about Field Day. The last Saturday of June is the annual Field Day. This year it is 28 June 2015. On that day, hams all over the nation take their portable radios, antennas and portable power into a park or other location and see who they can contact by radio. They particularly welcome visitors, and will probably let you use one of their radios (under their supervision) to learn how it works. This is one small indication of the commitment Hams make to emergency preparedness.
The value of Ham radio in an emergency is best documented by one who has seen it in action. Our new Director of the Albuquerque Veteran's Administration Hospital is Andrew Welch. When he visited the Ham station located there, he told us: I was in New Orleans during Hurricane Katrina. The only reliable communication we had was Ham radio. He is presently studying to get his Ham license.
Duke Winsor, radio-at-priphy-dot-com
The trademark BAOFENG belongs to Fujian Nanan Baofeng Electronic Co., Ltd.

subset: commoncrawl


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Bundle & Save
Master all the Bear Making techniques with these 12 bear designs
Start or grow your pattern collection.
These 12 patterns will not only give you a wonderful range of bears to make, but each comes with a detailed step-by-step photo guide.
Learn all the basics & advanced bear making techniques, tools & materials to use
You can downloaded each guide and or pattern to save or print.
Create your own bear making resource library!
Hi there! Im Helen Gleeson, Bear Artist, of Bare Cub Designs, Author of Bear Basics and Beyond, Editor of Bear Beautiful Magazine and now instructor right here!
I created Bare Cub Designs back in 2003 designing my custom cub from vintage recycled mink furs for a signature look and fluffy cheeks. Thousands of hours and many classes later, it's still my passion. I'd like to share with you how wonderful this past-time can make your life. Are you ready to join me?


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FIELDING The White Sox' drop in defense was just as noticeable as its drop in offense last year. It allowed 80 unearned runs in 2013 (second worst in the AL) after allowing just 30 in 2012 (tops in the league). Ramirez had a league-high 22 errors at short. Conor Gillaspie had the worst fielding percentage of any AL third baseman. Even normally-reliable second baseman Gordon Beckham was off (12 errors). The good news is Chicago has the players to turn things around quickly. They just need to focus on the basics and make the plays they're expected to make. STARTING PITCHING There are plenty of questions in the bottom of Chicago's rotation, but none at the top. Staff ace Chris Sale, 24, has established himself as one of the best young lefties in the game, finishing fifth in the AL Cy Young voting last year and compiling a 3.06 ERA the last two years. Likewise, lefty Jose Quintana, 25, has emerged as a solid No. 2 option (9-7 with a 3.51 ERA). But behind them is injury-prone John Danks (4-14, 4.75 ERA), inexperienced prospect Erik Johnson (five career MLB starts) and Felipe Paulino (coming off Tommy John surgery). Those are not exactly reasons to be optimistic. RELIEF PITCHING The White Sox traded away 40-save closer Addison Reed for Eaton in the offseason and now turn to flame-throwing righty Nate Jones in the ninth. Jones has been a consistent setup man the last two years (career 3.31 ERA), but has yet to prove he can perform in the pressurepacked ninth (hasn't record a save). The White Sox' revamped bullpen is also expected to feature backup closer Matt Lindstrom and setup men Scott Downs, Maikel Cleto, Ronald Belisario and Donnie Veal. This isn't a big-name bullpen, and there appears to be more question marks than answers. MANAGING Ventura led the White Sox to one of the worst seasons in franchise history last year and was rewarded with, wait for it, a multi-year contract extension. Huh? Guess the front office really liked what he did as a rookie skipper in 2012, winning 85 games. To be fair, Ventura didn't have much to work with in 2013. But he should have more this year after GM Rick Hahn went out and acquired Abreu, Eaton and third base prospect Matt Davidson. Now it's on Ventura to turn that into more wins and prove he deserved the extension. Avisail Garcia and Jose Abreu RON VESELY/GETTY IMAGES SPORT
2014 Minnesota Gameday HQ Round 2
To see the actual publication please follow the link above


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All About Nicole
There's no easy way to define Nicole. Friend? Sister? Lover? Aunt? Asshole? Lifecoach? Everyone's favorite blerd? Anonymous box of dicks seller? Phallic obsessed hypersexual prude? Afropunk fan? Sure. These are all correct in some way. But I'm also part of TWGO and this podcast. I'm also serving a term as the President of Passiveaggressivia (its right outside of Flowood) but that's another story.
When not pretending to be a tech guru and piecing this site together (shout out to Weebly), you can find me at home, chilling with my dog. Or at work in full-scale RBF mode giving my coworkers mixed signals. Or, you might find me in one of the Sam's Club's close to home buying my weekly case of Monster Ultra Sunrise. Where you won't find me in most cases is sleep, gambling or prostituting (I'm pretty resolute on keeping at least 2 of those promises at all times).
So now that you've learned a bit about me I'm not so complex. I have about as many layers as a Tor network, but don't we all? Stay tuned or drop a line if you'd like to join us on this ride. Be warned - if you have a slight touch of asthma, diabetes, ischemia, hypertension, tachycardia, vertigo, anemia, reactive airway disease, epilepsy, angina pruritus, seborrhea, rls or hiccups, this may not be the safest thing for you. But it will be fun.
Or that's the plan...til we get on.
Email Me
Blog Posts
Coming soon - I hope!


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Absolutely! Because metal weighs only about 1/3 as much as shingles, it can often be installed right over the top of existing shingle roofing alleviating the need to tear off the old roof. This eliminates the cost, problems, and waste of disposing of the old shingles. There are multiple ways to install metal over existing roofing. Check local codes and refer to your local building professionals to determine the best option for your project.
This is a common misconception with residential metal roofing. Unlike old, open framed metal buildings, residential roofing consists of a solid roof deck, underlayment, and insulation which all serve to dampen the noise. In fact, studies show that noise from metal roofing is similar to other products such as asphalt shingles.
Our metal roofing system is designed to last. WBC manufactures only the highest quality metal roofing products. Beginning with high tensile steel manufactured to strict industry tolerances, a zinc-aluminum metallic coating (Galvalume AZ-50) is then applied for corrosion protection. Your new roof is then layered with a high quality Siliconized Modified Polyester (SMP) paint that gives your building beautiful curb appeal and at the same time locks in the anti-rust properties of your roof. Together this layered roofing system offers you an industry leading 40 year warranty that will ensure the beauty of your home for decades to come.
Regardless of the material, lightning always strikes the highest point in an area. The odds of lightening striking a metal roof are no greater than asphalt shingle, slate, wood or any other type of roof material. Since metal roofing isn't combustible or flammable, it's a low risk and desirable roofing option where severe weather is concerned, especially for lightning.
WBC offers a variety of metal roofing colors with varying degrees of energy efficiency and solar reflectivity. WBC metal releases solar heat quicker than asphalt shingles, thereby reducing the heat load on a home. To the consumer, metal roofs can decrease energy costs up to 40%,.
Generally speaking, metal roofing costs no more than a shingled roof. Each type of roofing material offers a wide range in levels of quality. Our metal roofing systems offer unmatched durability, lasting 2 to 3 times longer than asphalt roofing materials. Asphalt can require re-roofing every 10 to 20 years, often sooner. Chances are a WBC metal roof will be the last roof you will ever install on your home.
A WBC metal roof can withstand decades of exposure to extreme weather conditions. Metal roofing in locations that see heavy snow, has been the choice of homeowners for years. It sheds snow quickly, which protects the structural integrity of the roof. Under high wind conditions, metal roofing consistently outperforms asphalt shingles. Additionally, if you live in a part of the country that is prone to wildfires, metal roofing can protect your home should burning embers land on your roof.
WBC offers an industry best 25 year warranty for Galvalume Panels. For painted panels, our WeatherBest (WB) offers a 40 year paint manufacturer's warranty and our WeatherBest 42 (WB42) offers a 10 year paint manufacturer's warranty.
You sure can. There are a variety of insulation products available. Among the types of insulation that can be used are spray foam insulation, rigid foam insulation, and foil-faced plastic bubble insulation.
Metal roofing and siding can be easily installed using standard hand tools such as a screw gun, hammer, metal snips, caulk gun, pliers, chalk line and tape measure. Cutting metal panels is best accomplished with an electric metal shear, power nibblers, and hand shears. While some companies will say abrasive blades are fine; use caution, metal filings can spread over panel while cutting and stick into paint finish. These filings will eventually corrode causing staining on panel.
Contact one of our sales representatives at (315) 923-3195.


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Tough times leave a lot of new moms going back to work almost immediately after giving birth.
More mothers are back at work one month after giving birth, The Los Angeles Times reports. Yes, you read that correctly—one month.
According to new figures released by the Census Bureau, "8 out of 10, or 82 percent, of working women whose first child was born from 2006 to 2008 were back on the job within a month," the L.A. Times says in its article.
That's quite a jump from the last census figures from 1991 through 1995 when "73 percent of first-time mothers went back to work in the first month," the bureau says, according to the L.A. Times report.
In the 2006 to 2008 time period studied, the newspaper reports that "just over half of first-time working mothers received paid time off, either maternity leave, sick leave or vacation."
Crib Notes previously reported on how worries over job security and money have many women reducing time off after their babies are born.
It's not new news that the U.S. is lagging when it comes to paid maternity leave benefits. Despite studies repeatedly finding that the earlier and longer moms-to-be stop working, the better, the United States continues to be one of five countries that don't guarantee paid leave to give birth and care for a child.


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Sidney Crosby has been named Captain for Team Canada.
I was so proud when I read that news. At 26, he leads the league in scoring (68 points: 25 goals, 43 assists) and is so deserving. I immediately thought, "I need that jersey." Then it hit me…..I'm not Canadian. How can I have such pride in and be so excited for Canada's choice to captain their Olympic team? I am, after all, an American girl…(cue Tom Petty)
I was so proud when I read that news. At 26, he leads the league in scoring (68 points: 25 goals, 43 assists) and is so deserving. I immediately thought, "I need that jersey." Then it hit me…..I'm not Canadian. How can I have such pride in and be so excited for Canada's choice to captain their Olympic team? I am, after all, an American girl…(cue Tom Petty)
The answer is simple, I love Sidney Crosby. What's not to love? He's such a good captain for the Penguins; the youngest captain in NHL history when he got the "C'' for the Penguins 6½ years ago. Who can forget the moment he raised the Stanley Cup in '09 triumph as the Pens' captain? Mouth wide open in that classic "I'm really happy" Crosby look.
I have a confession to make, I screamed really loud when Crosby shot that puck past Ryan Miller in the last Olympics to win the gold. I feel comfortable saying that now because I believe the statute of limitations is up on being considered 'un-American'.
Being named the Captain of your nation's hockey team is a distinct honor. As the game's highest-profile player, Crosby is used to handling the demands that come with being captain of the Canadian team and the attention that will follow him to Russia. Scott Niedermayer, captain of the Canadian team in 2010, said this of Crosby's selection "He's very mature. He was probably ready when he was 16. He was probably ready in 2010, and the thinking was he's going to have enough pressure on him just from who he is and things like that that he doesn't need one more thing to worry about, give it to some old guy that's just trying to figure things out out there. I'm sure he would do very well."
When asked how he felt about the appointment, Crosby replied "It's definitely a huge honor....I think playing for Team Canada and playing in the Olympics is a great opportunity, but being able to be named the captain, I think, is definitely an honor. I don't think it changes a whole lot," Crosby said on the differences between wearing a 'C' and an 'A.' "I think there are lots of really good leaders there, lots of guys with a lot of experience. A short-term event like that I think you just want to come together quickly as a team and make sure that we're all on the same page."
Many have argued that the C belonged to Jonathan Toews who out performed Crosby in 2010 and has since captained two Stanley Cup winning Blackhawk teams. In the end, this was a pretty straight-forward decision for Hockey Canada, given that Crosby scored the golden goal in overtime against the United States at the Vancouver Olympics four years ago. Toews, along with Shea Weber will serve as the alternate captains.
"Sidney, Jonathan and Shea have been leaders on the international stage in the past, as well as with their NHL teams," Mike Babcock, head coach of Canada's Men's Olympic Team said in a statement. "These three players will be at the forefront of our efforts in Sochi, but we are confident we have 25 players on our roster that will lead in their own way and allow our team to be successful."
The only question that remains to be answered, it would seem, is who plays on Crosby's line? I would say to Babcock….don't blink, don't think; it has to be Chris Kunitz. The chemistry is already there but Kunitz brings forechecking ability, great hands and hockey smarts to the table as well. Both Steven Stamkos and John Tavares are centers but I'd take either on Crosby's right. Stamkos will be coming off of his tibial fracture and hopefully his skating will be up to speed but his shot wasn't fractured. Tavares may not have the shot of Stamkos but he's a smart player with good wheels and a good hockey brain.
The United States has yet to announce its captain, though general manager David Poile singled out Ryan Suter, Zach Parise, Dustin Brown, Ryan Callahan and David Backes as leaders. Russia has already picked Pavel Datsyuk of the Detroit Red Wings as captain. It's Zdeno Chara of the Boston Bruins for Slovakia and Tomas Plekanec of the Montreal Canadiens for the Czech Republic.


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Developing scientific Fortran programs involve, like anywhere, reuse code and/or share it with other people. Rather than every time copy-paste-modify lines of code from a program to another, it is useful to work with a documented and tested library. This presentation is about some simple Python scripts (which can be called from Shell scripts), to simplify the tasks of:
Compiling Fortran program:
- building the modules dependencies tree,
- generating Makefile.
Documenting :
- examples of subroutines/functions uses: tests based on output (like «doctest»),
- generating HTML documentation files.
Managing errors in a Fortran program:
- try to mimic the Python exceptions propagation.
- functions, subroutines tested with the «unittest» Python module. Need to call Fortran from Python, possible with f2py.
Using the library comfortably: wrapping the library in Python, using f2py.
- example one: bi-interpolation
- example two: reading memory-expansive data from numerical simulation for post-processing with Pylab.


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Popular Pages
Pages Updated
Parking in Bibury
Where to park in Bibury
If you are visiting Bibury for the first time then you may be wondering where you can park your car.
There is a limited amount of free roadside parking available on "The Street" and a small free car park opposite Bibury Trout Farm which now has two dedicated coach spaces.
Out of season visitors to Bibury won't have a problem parking, but visitors in the height of the season may have to wait for a vacant space at peak times.
Not sure how to get to Bibury? Try our travelling to Bibury page.


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contributed by
Dr Maulik S Patel
on July 05, 2013
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Ultrasound is effective for diagnosis of sternal fracture as in this case. However, only anterior cortex of sternum is seen with ultrasound.
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Released to coincide with Kraftwerk's June 2017 tour – their first UK dates since the breathtaking shows witnessed at the Tate Modern in 2013 – is Kraftwerk 3-D The Catalogue. This is the ground-breaking 3-D Kraftwerk Concert brought thrillingly to life, developed using high definition 3-D visuals, with Dolby Atmos surround sound and presented to the technological and audio standards one would associate and indeed come to expect from the pioneering Germans led by founder Ralf Hütter. For the very first time, every Kraftwerk fan can now experience a "Gesamtkunstwerk – a total work of art" in the comfort of their own home.
3-D The Catalogue features new recordings of Kraftwerk's 8 classic albums performed/filmed at various locations around the world between 2012-2016 and mixed at the band's own state-of-the-art, Kling Klang Studio, Düsseldorf. 3-D The Catalogue is released across a number of formats including this rigid board box set with lift-off lid, holding 8 x capacity wallets, with 8 CDs, plus 16-page booklet. The 8 albums included are: Autobahn (1974), Radio-Activity (1975), Trans Europe Express (1977), The Man-Machine (1978), Computer World (1981), Techno Pop (1986), The Mix (1991) and Tour De France (2003).
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This is one of the most famous people in the world.
Can you guess who it is?
I'll provide the answer later in the week if no-one guesses correctly.
Emma's answer in the Comments section below is correct. (See how smart my fellow CAE students are?)
The photo is in fact a computer-genereated image of how Michael Jackson would have looked on his 50th birthday if he didn't have that awful skin condition and all of that plastic surgery. Check out this site for more details, including a before and after shot.


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We are a passionate bunch of craftsmen that love engraving onto natural materials like slate and stone. We have created signs for people all over Atlanta America and even beyond that.
For three generations my family has run this business building it up via the internet to a nationwide service provider. We create signs for all different types of individual and business including many organisations like universities and governments.
This blog is my own and will be the warts and all version of the day to day trials and tribulations of my life.
When I am not working I love to get out into the great outdoors. I love camping and trekking and also have a real passion for extreme sports like mountain biking and water-skiing. I combine these passions every week to get out and banish the issues and hassle of the week day running of the business.
We have a camper van and do a whole lot of miles in it and we have been to every corner of our great country over the years. Fortunately my wife loves getting out as well and our two children have the outdoor bug too and so we find it a great way of spending lots of our free time together.
We have travelled further afield and make trips to the UK and Europe when we can. Fortunately I can mix a bit of business with pleasure as we have clients in other countries and whilst its not essential to visit it is nice every so often to help keep positive relationships going with them all.
Hopefully you will enjoy my blog and if you do want to add any comments to my posts then please feel free to do so. I will post any new products we have and also let you know whats happening in my world.


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I know I go on
And on.
And on, about how I think computers are killing our brains, how social media is making us completely unsocial and how before long we are going to turn into people that can only communicate by means of using our thumbs.
But I do think it's the case and I think the year we've had highlights this like none other.
If I had a pound for every time I have heard someone say 'our kids will talk about 2016' since about May, I'd be a very rich woman.
Same if I had a pound for everyone who had highlighted to me what a terrible year it has been.
It's the year in which we lost so many well-loved, well-admired and, in parts, adored celebrities. We said goodbye to musical icons and legends of stage and screen in what seemed to be the cruellest culling of national treasures we'd ever known.
What happened to 2016? Had it been cursed with cancer and illness that was affecting even the seemingly untouchable amongst us?
It's the year that saw a national joke make it into the White House. A year that saw two of the world's greatest powers in the UK and the States make monumental, historical political changes because those that live there were so disgruntled, disengaged and angry with the state of their nations.
Terrorist attacks carried on with vigour and the fear that we all seem to live in seems to have grown stronger than ever.
I do think that our kids will talk about 2016.
But not for the reasons that we think.
I think they will talk about it, as it is will be the year that will stand out in the history books (if they still exist then) that showed the power the internet had in shaping world events.
It was the year that all of a sudden one family's heartbreak, be that the Bowie's, the Rickman's or the Wood's, became a nation's grief.
It was the year that we first realised how obsessed we'd become with the idea of celebrity. The same amount of 'well known' people died in 2006 no doubt. But we only found out about it when we picked up the Sunday papers, and read their well-crafted eulogy written by a well-respected journalist. Or we found out at the end of the BAFTA's when they paid tribute to the greats.
They were honoured, but not exploited.
Now, that person dies, and within the hour meme's of their 'greatest quotes' are flying around Facebook and we are taking that family's heart breaking moment, as another excuse to tell the world how sad WE are that the person we never met has died.
2016 isn't any worse than 2006 in the celebrity death stakes. The internet has just made them more iconic. Facebook has just made them more personal and the speed in which the news reaches us via our BBC iPhone bulletins make us think that every musician and actor we've ever loved will be dead by Christmas. And it's on our phones, it's in our faces and all of a sudden it becomes ours.
Our sorrow. Our pain.
This age and obsession with celebrity has seen 2016 be the year that a 'celebrity' was voted in to the highest political office in the land. Like a really horrific reality show.
2016 will go down in history as the year that we saw someone with no military or political experience, but a large following on Twitter, end up in the bloody White House.
The year that when the UK voted, by majority, for Brexit.
The year that Trump won the most electoral college votes.
But yet we still decided that we needed a re-vote because all of a sudden we weren't happy. Because our Facebook friends stated their anger, we liked it. We agreed. And rather than sit back, like we would have done 20 years ago and say, the nation has spoken, we were enraged (*holding my hands up*)
Those conversations weren't had in person with members of parliament. Those petitions weren't signed with a pen and a trip down to City Hall. We took to Facebook and Twitter to announce our incense that the electoral system, that's been in place for hundreds of years, was no longer good enough.
And outrageously, we were (albeit it momentarily) taken seriously. Because the internet got angry, we nearly changed political systems that have been in place longer than our family tree.
2016 will be the year that such drastic political advances were made. Because nations were so disgruntled and so disengaged.
Are we?
Are we disgruntled enough to go on strike? Disengaged enough to revolt and go on marches?
No we're fucking lazy.
But happy enough to type down on our Facebook status how we feel about the state of the universe. So everyone can see it. But we won't do anything about it.
Look back 70 years, and unlike our grandparents, we're not living in a world war.
We're living in a digital age.
Where every shit piece of news, every bad story, every friend's redundancy, every poor performance by the NHS is blasted out on to our phone for us to read, devour and take on.
The friend's Mum who had a bad experience with the NHS becomes ours because it's on Facebook.
Our ex-colleagues redundancy becomes ours because it's on our LinkedIn.
That terrorist attack that killed a friend of a friend of a friend of two friends removed is something you would have been saddened by but wouldn't have felt a personal connection to twenty years ago.
But all of a sudden something pops up on our feed because something's been shared and then all of a sudden we are connected to the Nice atrocities or what happened in Brussels, and that pain becomes ours.
Everyone's everything is everywhere for us to see, so everywhere we turn, it all seems like it's all shit.
We take all of this aired laundry on as our own.
As our own belief that the world is in rack and ruin and we're basically all fucked.
In parts it is. But in parts it's been a hell of a lot worse.
All I say is just take a moment to look at your own life. Your actual life.
You may well have had a bad year. But it will be isolated. A few bad months. An illness. A death in the family.
Things that happen year in, and year out. As sad as it is, it's life.
Now, look at the life you believe to be your own.
Because you've taken on, literally a world, of information over the last 12 months. A world of posts, and updates, and news flashes and all of a sudden everyone's dead, everything's shit and we're all doomed for good.
We're all being bombed, we're all getting Zika and to top it all off Prince is dead and I never met him but I downloaded his album once so I AM SAD.
Look at that life, and yes 2016 is the worst year you've ever had.
And guess what, 2017 will be even worse.
So just look at your 2016 and imagine it if you hadn't had access to the internet, to social media, or to a smart phone.
Then ask yourself if it was really that bad after all.
My bet is that it was an average year. Maybe in parts it was good.
But we can't talk about that.
So please, put down your phone.
And just concentrate on you.
Before our history books become history sites and our kids read about the years that their parents stopped using their brains, and yes, the world got a little bit fucked.


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I love being with my sweetheart and I'm grateful she was able to go with me to Austin (we were there at the same time the South by Southwest festival was going on and Austin was a mess with traffic and people because of the festival. My advice is don't go to Austin during the festival unless you're there to participate in it). It's a pretty city and we enjoyed the few days we spent there. Here are a few pictures we took while we were there (isn't my wife beautiful?!).
The point of this is that we need to try harder to spend time together. My wife and I are very busy serving in our church, raising three boys, building my career, and trying to help others that we have to really try to spend time together and focus on our friendship. And I'm sure we're not the only married couple in the world that is really busy. Be creative, have fun, think outside of the box, and most importantly just cherish what time you do have together. We loved being together in Austin and we look forward to the next little get away where it's only the two of us.


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Thank you for visiting cashoriley.net
As an Independent, Do It Yourself kinda artist, I always have a tip jar onstage...ok, it's actually a WWII era bed pan that I found at a Flea Market in Missouri...anyway, I was told to put one up here as well. So I did...sort of...here's a picture of my Tip Pan...click it to tip it. Thank you supporting Non Corporate Original Music and diggin' what I do! Here's to crossin' paths with ya soon...CHEERS!


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So, I thought I would give you a little background on us. I am the oldest of six kids. She stayed home and raised us all. She had three girls and three boys. We come in boy-girl sets. Me, two years, my brother. Four years. Another brother, two years, a sister. Four years. Another brother, not quite two years, a sister. So she was BUSY! We always had home cooked meals, so my love of cooking probably came from her. I must have been helping her at an early age, because my grandma likes to tell me about how I told her how to make a pot roast when I was two.
Even though we have moved out, she is still there for all of us. She keeps tabs on what everyone is up to and tries to get us all together for "family dinner" at least once a week. If you poke around the blog much, you can probably tell she is my biggest supporter. She is always sending recipes, pictures and sometimes full posts for the blog. So, I thought it would be fun to do a quick roundup of some of MiMi's favorite contributions.
Happy Mother's Day to everyone and especially to you, Mom!
MiMi wrote a fun post of one her favorite things her mom made her: Hamburger Surprise
MiMi and Pops used to have a bunch of chickens who laid a LOT of eggs. So she tried every deviled egg recipe out there and landed on this one as her favorite.
She can't remember how she started making pork chops in mushroom soup gravy, but it has been a family favorite for as long as I can remember!
These Cavanaugh's noodles were one of her childhood favorites. She still makes them for us today!
She also makes really good sweets:
This Toll House pie is a classic.
And she goes on kicks of making up new homemade ice cream flavors. This churro ice cream was a hit!
And of course there all of the flavors of fudge!!!