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The IRS has released the 2019-2020 special per diem rates. Taxpayers use the per diem rates to substantiate certain business expenses incurred while traveling away from home for the period October 1, ...
For 2020, the Social Security wage cap will be $137,700, and social security and Supplemental Security Income (SSI) benefits will increase by 1.6 percent. These changes reflect cost-of-living adjustme...
The IRS has changed how it handles passport certifications for people with significant tax debt. Following a review of relevant considerations regarding passport certification procedures, the IRS has ...
The IRS identified drought-stricken areas where tax relief is available to taxpayers that sold or exchanged livestock because of drought. The relief extends the deadlines for taxpayers to replace the ...
The IRS has announced a new payment option to the private debt collection program. Taxpayers can now choose a pre-authorized direct debit option to make one payment or a series of payments toward thei...
The IRS has announced that it will not acquiesce to the holding of the Tax Court in GreenTeam Materials Recovery Facility PN, 113 TCM 1540, Dec. 60,945(M) that the transfer of a noncapital asset is tr...
Effective October 1, 2019, the Connecticut sales and use tax rate on certain meals and drinks is increased from 6.35% to 7.35%.Application of Rate Hike on Certain Meals and DrinksThe rate increase app...
"A thumb goes up, a car goes by…" Tax extenders remain a top contender for "hitching a ride" on November's must-pass government funding bill.
"A thumb goes up, a car goes by…" Tax extenders remain a top contender for "hitching a ride" on November's must-pass government funding bill.
Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in Washington, D.C. to discuss over 30 temporary tax provisions known as "tax extenders," which have expired or will soon expire spanning from 2017 to 2019. Before joining KPMG, Acuña served as chief tax counsel for the Senate Finance Committee (SFC), and was previously tax counsel for the House Ways and Means Committee.
New Tax Extenders Climate on Capitol Hill
"There is an interesting dynamic going on with tax extenders on Capitol Hill. In the past, extenders were viewed as a priority item, and that has changed," Acuña said.
Generally, tax extenders have been viewed on Capitol Hill as a consistently bipartisan annual or biannual year-end legislative initiative. However, the fate of tax extenders is more uncertain than it has been in the past – in part because it is not clear yet whether there will be an opportunity for any further tax legislation to become law this year, Acuña observed.
Funding Bill Likely Driver for Tax Package
Lawmakers are revving up negotiations as Congress races against this year's dwindling legislative calendar to reach an agreement on fiscal year (FY) 2020 appropriations. Government funding is scheduled to expire on November 21.
Given the political climate on Capitol Hill and Congress's limited time left on the legislative calendar, a stand-alone tax package is considered unlikely to make its way through both chambers successfully. That said, November's "must-pass" government funding bill could be the legislative vehicle for dozens of expired or soon-to-be expired tax extenders, as well as for any other tax provisions that may crop up during lawmakers' negotiations.
SFC Chair Chuck Grassley, R-Iowa, and ranking member Ron Wyden, D-Ore., introduced their bipartisan Tax Extenders and Disaster Relief bill (Sen. 617) earlier this year. Subsequently, House Ways and Means Committee Chairman Richard Neal, D-Mass., introduced his version of a similarly named tax extenders bill (HR 3301). However, Neal's bill—which proposes undoing certain provisions related to estate taxes under 2017 tax reform as a "pay for"—was immediately deemed a nonstarter by Senate Republicans.
Notably, Acuña observed that House Democrats may be viewing their tax extenders bill as an opening offer, providing leverage for a larger tax policy negotiation. "In today's climate it seems that some of the signaling that's taking place is that House Democrats are trying to position tax extenders as a Republican priority to build up leverage for a larger tax policy negotiation," Acuña said. "Once you have a tax title on a big bill, there is no limit as to which tax provisions could actually be included in the bill," she added.
Larger Tax Package Could Emerge
In that vein, there has been talk among lawmakers that a larger, catch-all tax package could emerge from these negotiations. Any tax package that is unveiled in the coming weeks must have significant bipartisan support to make it to the president's desk. That said, amidst the new climate surrounding tax extenders on Capitol Hill. several lawmakers have alluded that bipartisan negotiations could result in any number of tax provisions being added to the anticipated tax package, including technical corrections to the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97).
Staking Ground on Extenders
"Right now, what is happening is that parties are staking their ground," Acuña said. While Neal's bill was largely seen on Capitol Hill as an opening bid to these negotiations, "no one opens with their best offer," Acuña said. However, "there is common ground with respect to tax extenders," she added.
Additionally, Acuña noted that these temporary tax provisions benefit a broad range of constituents. "They have been extended historically without fail for a reason. And it is because there has typically been general bipartisan support for extenders; there is a little bit of something for everyone" she said.
However, as for which tax extenders will be renewed this year, as well as retroactively or all together forgotten, Grassley recently indicated that all eligible provisions will likely make the cut. "I would expect that as of right now, if there is an extenders package there won't be anything left out," Grassley told reporters.
When asked if Grassley was likely referring to all expired or soon-to-be expired tax incentives spanning from 2017 to 2019, Acuña told Wolters Kluwer "that would seem to be the case." While discussing the possibility of yet another temporary extension, Acuña noted that it is hard to make policy calls on a temporary tax extenders package.
"If you want a drama free negotiation on temporary extensions, it's a clean date change. It is easier – you do not have a policy debate," she said. "If there is an opportunity for a tax title to be attached to a larger bill this year, it is infinitely harder to include changes that some Members of Congress will not like than it is to just do what has been done in the past and kick the can down the road by temporarily extending everything."
In looking ahead, deciding which temporary tax provisions get the axe is a policy call that is unlikely to be made this year and will not easily be done on a bipartisan basis, according to Acuña.
To Pay For or Not to Pay For
As for tax extenders' cost, the issue of pay-fors has not generally been a longwinded discussion among lawmakers. "In the past, there have been very short-lived debates on whether to pay for them," Acuña said, adding that extenders generally have not been paid for. "It is hard to find a way to raise the kind of money needed to pay for a tax extenders bill that would be politically palatable for both sides of the aisle."
However, cost can be a leading issue when Congress creates these tax breaks on a temporary rather than permanent basis, Acuña explained. "In theory, everyone might agree that a tax incentive is excellent tax policy, but because of revenue constraints, Congress will not or cannot pay for it on a permanent basis—and that is usually where Congress lands in this temporary tax policy pickle."
Additionally, Acuna highlighted that many of the individual tax cuts under the TCJA were enacted temporarily through 2025 due to budgetary reasons. "A lot of the TCJA provisions gave life to new expiring provisions," Acuña noted. Likening the TCJA's individual provisions to the long list of tax extenders currently awaiting possible renewal, Acuña noted that tax policy is not usually made temporary "because the members viewed the underlying tax policy as unsound but because of other constraints."
The End for Tax Extenders?
Many Republican and Democratic lawmakers' have called for an end to tax extenders, citing to the annual year-end dash to renew temporary tax provisions as bad tax policy overall. Indeed, five taskforces comprised of bipartisan SFC members recently reviewed these tax extenders and largely agreed that temporary tax policy in general is less than ideal. While many House lawmakers on both sides of the aisle, in this Congress and those before it, have agreed that enacting permanent tax invectives is better policy than doing so temporarily, actually getting there remains a challenge, even if just procedurally.
The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to lessen taxpayer uncertainty on whether a rental real estate interest qualifies as a trade or business for the QBI deduction, including the application of the aggregation rules in Reg. §1.199A-4.
The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to lessen taxpayer uncertainty on whether a rental real estate interest qualifies as a trade or business for the QBI deduction, including the application of the aggregation rules in Reg. §1.199A-4.
QBI Deduction and Rental Real Estate
Under Code Sec. 199A, certain noncorporate taxpayers can deduct up to 20 percent of the taxpayer's QBI from each of the taxpayer's qualified trades or businesses, including those operated through a partnership, S corporation, or sole proprietorship. Certain relevant passthrough entities (RPEs) (partnerships, S corporations, trust funds) calculate the deduction and pass it along to their owners or beneficiaries. A qualified trade or business is generally any trade or business under Code Sec. 162, but not a specified service trade or business (SSTB) or a trade or business of performing services as an employee.
Rental or licensing of tangible or intangible property (i.e., rental activity) that is not a Code Sec. 162 trade or business is still treated as a trade or business for the QBI deduction if the property is rented or licensed to a trade or business conducted by the individual or a RPE which is commonly controlled under Reg. §1.199A-4 ( Reg. §1.199A-1(b)(14)).
Earlier this year, the IRS released a proposed revenue procedure with a safe harbor for treating a rental real estate enterprise as a trade or business under Code Sec. 199A ( Notice 2019-7, I.R.B. 2019-9, 740). The IRS has issued the new revenue procedure after considering public comments on Notice 2019-7.
Rental Real Estate Enterprise
The new safe harbor applies to a "rental real estate enterprise." This is an interest in real property held for the production of rents, and may consist of an interest in a single property or interests in multiple properties. The taxpayer or RPE must hold each interest directly or through a disregarded entity, and may either:
- treat each interest in similar property held for the production of rents as a separate rental real estate enterprise; or
- treat interests in all similar properties held for the production of rents as a single rental real estate enterprise.
Properties are similar if they are part of the same rental real estate category: either residential or commercial. Commercial real estate held for the production of rents can only be part of the same enterprise with other commercial real estate. Residential properties can only be part of the same enterprise with other residential properties.
A taxpayer or RPE that treats interests in similar properties as a single rental real estate enterprise must continue to treat interests in all similar properties, including newly acquired properties, as a single rental real estate enterprise if it continues to rely on the safe harbor. However, a taxpayer or RPE that chooses to treat its interest in each residential or commercial property as a separate rental real estate enterprise can choose to treat its interests in all similar commercial or all similar residential properties as a single rental real estate enterprise in a future year.
An interest in mixed-use property—a single building that combines residential and commercial units—can be treated as a single rental real estate enterprise, or bifurcated into separate residential and commercial interests. A mixed-use property interest that is treated as a single rental real estate enterprise cannot be treated as part of the same enterprise as other residential, commercial, or mixed-use property.
Safe Harbor Requirements
The safe harbor determination must be made annually. For a rental real estate enterprise to qualify for the safe harbor, all of the following requirements must be met during the tax year:
- Separate books and records are maintained to reflect income and expenses for each rental real estate enterprise. If an enterprise has more than one property, the requirement can be met if income and expense information statements for each property are maintained and then consolidated.
- For rental real estate enterprises in existence for less than four years, 250 or more hours of rental services are performed per year. For rental real estate enterprises in existence for at least four years, 250 or more hours of rental services are performed per year in any three of the five consecutive tax years that end with the tax year.
- The taxpayer maintains contemporaneous records (including time reports, logs, or similar documents) on the hours of all services performed, a description of all services performed, the dates when the services were performed, and who performed the services. For services performed by employees or independent contractors, the taxpayer may provide a description of the rental services, the amount of time generally spent performing the services, and the time, wage, or payment records for the employee or independent contractor. Records must be made available for inspection at the IRS's request. (The contemporaneous records requirement does not apply to tax years that begin before January 1, 2020.)
- For each tax year for which it relies on the safe harbor, the taxpayer or RPE must attach a statement to a timely filed original return (or an amended return for the 2018 tax year only) that includes: (i) a description (including the address and rental category) of all rental real estate properties in each rental real estate enterprise; (ii) a description (including the address and rental category) of rental real estate properties acquired and disposed of during the tax year; and (iii) a representation that the requirements of Rev. Proc. 2019-38 have been satisfied.
"Rental services" include, but are not limited to:
- advertising to rent or lease the real estate;
- negotiating and executing leases;
- verifying information contained in prospective tenant applications;
- collecting rent;
- daily operation, maintenance, and repair of the property, including purchasing materials and
- supplies;
- managing the real estate; and
- supervising employees and independent contractors.
Rental services does not include:
- financial or investment management activities, such as arranging financing;
- procuring property;
- studying and reviewing financial statements or reports on operations;
- improving property under Reg. §1.263(a)-3(d); or
- time spent traveling to and from the real estate.
If an enterprise fails to satisfy the safe harbor requirements, it can still be treated as a trade or business for the QBI deduction if it otherwise meets the trade or business definition in Reg. §1.199A-1(b)(14).
Property Excluded From Safe Harbor
The safe harbor does not apply to:
- real estate used by the taxpayer (including an owner or beneficiary of an RPE) as a residence under Code Sec. 280A(d);
- real estate rented or leased under a triple net lease, which includes a lease agreement that requires the tenant or lessee to pay taxes, fees, and insurance, and to pay for maintenance activities for a property in addition to rent and utilities;
- real estate rented to a trade or business conducted by a taxpayer or an RPE that is commonly controlled under Reg. §1.199A-4(b)(1)(i); or
- the entire rental real estate interest, if any portion of it is treated as an SSTB under Reg. §1.199A-5(c)(2).
Effective Date
The safe harbor applies to tax years ending after December 31, 2017. However, taxpayers and RPEs can rely on the prior safe harbor in Notice 2019-7 for the 2018 tax year.
The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency.
The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance:
- a taxpayer does not have gross income from a "hard fork" of the taxpayer's cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; and
- a taxpayer has ordinary income as a result of an "airdrop" of a new cryptocurrency following a hard fork if the taxpayer receives units of the new cryptocurrency.
The IRS has posted the FAQs on its website ( https://www.irs.gov/individuals/international-taxpayers/frequently-asked-questions-on-virtual-currency-transactions).
Virtual Currency and Cryptocurrency
Virtual currency is a digital representation of value that functions as a medium of exchange, a unit of account, and a store of value other than a representation of the U.S. dollar or a foreign currency.
Cryptocurrency is a type of virtual currency that uses cryptography to secure transactions that are digitally recorded on a distributed ledger, such as a blockchain. Distributed ledger technology uses independent digital systems to record, share, and synchronize transactions, the details of which are recorded in multiple places at the same time with no central data store or administration functionality.
Hard Forks and Air Drops
A hard fork occurs when a cryptocurrency on a distributed ledger undergoes a protocol change resulting in a permanent diversion from the legacy or existing distributed ledger. A hard fork may result in the creation of a new cryptocurrency on a new distributed ledger in addition to the legacy cryptocurrency on the legacy distributed ledger. Following a hard fork, transactions involving the new cryptocurrency are recorded on the new distributed ledger, and transactions involving the legacy cryptocurrency continue to be recorded on the legacy distributed ledger.
An airdrop is a means of distributing units of a cryptocurrency to the distributed ledger addresses of multiple taxpayers. A hard fork followed by an airdrop results in the distribution of units of the new cryptocurrency to addresses containing the legacy cryptocurrency. Note, however, that a hard fork is not always followed by an airdrop.
Cryptocurrency from an airdrop generally is received on the date and at the time it is recorded on the distributed ledger. However, a taxpayer may constructively receive cryptocurrency prior to the airdrop being recorded on the distributed ledger. A taxpayer does not have receipt of cryptocurrency when the airdrop is recorded on the distributed ledger if the taxpayer is not able to exercise dominion and control over the cryptocurrency.
Gross Income
If the taxpayer did not receive units of new cryptocurrency from a hard fork, the taxpayer does not have an accession to wealth and does not have gross income as a result of the hard fork.
If the taxpayer receives units of new cryptocurrency from an airdrop following a hard fork, the taxpayer received a new asset. Therefore, the taxpayer has an accession to wealth and has ordinary income in the year in which the taxpayer receives the new cryptocurrency. The taxpayer includes in gross income the fair market value of the cryptocurrency received. The taxpayer's basis in the new cryptocurrency is the amount of income recognized.
Schedule 1, Form 1040 for 2019
A draft of the 2019 Form 1040, Schedule 1, "Additional Income and Adjustments to Income," includes a question which asks: "At any time during 2019, did you receive, sell, send, exchange or otherwise acquire any financial interest in any virtual currency?" If an individual has engaged in any virtual currency transaction in 2019, he or she must check the "Yes" box next to the question.
If the taxpayer has disposed of any virtual currency that was held as a capital asset, he or she must use Form 8949 to figure the capital gain or loss and report it on Schedule D (Form 1040 or Form 1040-SR). If the taxpayer has received any virtual currency as compensation for services, or disposed of any virtual currency that he or she held for sale to customers in a trade or business, the taxpayer must report the income as he or she would report other income of the same type.
A district court has dismissed a lawsuit filed by four states' against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive.
A district court has dismissed a lawsuit filed by four states' against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive.
In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the SALT cap violates the federalism principles that undergird the U.S. Constitution. Judge J. Paul Oetken of the U.S. District Court for the Southern District of New York ruled on September 30 that the SALT cap is not an unconstitutional infringement of state power.
The states' primary concern stemmed from the claim that the introduction of the SALT cap could impair each of the states' ability to pursue its own preferred tax policies. However, the court noted that Congress lawfully enacted the SALT cap pursuant to its broad tax powers under Article I, section 8 and the Sixteenth Amendment, and that the cap, like any federal tax provision, will affect some taxpayers more than others and, by extension, will affect some states more than others. However, the cap, like every other feature of the federal tax code, is a part of the landscape of federal law with which states make their decisions as to how they will exercise their own sovereign tax powers, according to Oetken. Because the states failed to plausibly allege that the cap, more so than any other major federal initiative, meaningfully constrains this decision-making process, the district court had no basis for concluding that the SALT cap is unconstitutionally coercive.
In 2017, President Trump signed into law sweeping tax reform legislation informally known as the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), which made several substantial amendments to the federal tax code. Among other things, the TCJA placed an upper limit of $10,000 on the amount a taxpayer may deduct from their federal tax income to offset those sums they have paid toward certain state and local taxes (the "SALT cap"). As enacted, the SALT cap is scheduled to expire at the end of 2025.
Democrats on Capitol Hill Prepare to Move SALT Cap Repeal Bill
Meanwhile, Democratic lawmakers on Capitol Hill are preparing to move a SALT cap repeal bill when Congress returns from its two-week recess. Specifically, Rep. Bill Pascrell, D-N.J. has proposed repealing the SALT cap and raising the top income tax rate from 37 percent to 39.6 percent, where it previously sat. Additionally, Pascrell recently told reporters that House Democrats will likely propose a temporary repeal of the SALT cap as a "compromise."
At this time, however, any Democratic-backed measure to repeal or scale back the SALT cap is expected to fail in the Republican-controlled Senate.
New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations:
New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations:
- a partner's share of a recourse liability of the partnership equals the partner's share of the liability under the rules of Code Sec. 752 and the related regulations; and
- a partner's share of a nonrecourse liability of the partnership is determined by applying the same percentage used to determine the partner's share of the excess nonrecourse liability under Reg. §1.752-3(a)(3) ( Reg. §1.707-5(a)(2)).
Executive Order Triggers Reversion Back to Prior Disguised Sale Rules
In October 2016, the IRS issued final and temporary regulations (707 Temporary Regulations) under which a partnership would determine all partnership liabilities for disguised sales purposes—both recourse and nonrecourse—by applying the same percentage used to determine a partner's share of excess nonrecourse liability under Reg. §1.752-3(a)(3) ( T.D. 9788).
In April 2017, the President issued Executive Order 13789 (E.O. 13789) on reducing tax regulatory burdens. In response, the IRS identified the final and temporary regulations in T.D. 9788 as implicating some of those regulatory burdens. In turn, in 2018 Proposed Regulations, the IRS proposed to withdraw the 707 Temporary Regulations and reinstate the regulations under Reg. §1.707-5(a)(2) described above. Now, the IRS has adopted the 2018 Proposed Regulations, thereby reinstating the Prior 707 rules.
Treasury and the IRS will continue to study the merits of the approach in the 707 Temporary Regulations and other approaches, including the final regulations, to determine which results in the most appropriate treatment of liabilities in the context of disguised sales.
Effective Dates
The final regulations apply to any transaction with respect to which all transfers occur on or after October 4, 2019, the date that the 707 Temporary Regulations expire. However, partnerships and their partners may apply the final regulations to any transaction where all transfers occur on or after January 3, 2017, the applicable date of the 707 Temporary Regulations.
The IRS has released final regulation on the election to take a loss resulting from a federally declared disaster in the year preceding the disaster. The final regulations adopt proposed regulations substantially without change.
The IRS has released final regulation on the election to take a loss resulting from a federally declared disaster in the year preceding the disaster. The final regulations adopt proposed regulations substantially without change.
Disaster Defined
The regulations provide definitions of:
- federally declared disaster;
- federally declared disaster area;
- disaster loss;
- disaster year; and
- preceding year.
Scope and Effect of Election
The election for a disaster loss attributable to a particular disaster applies to the entire loss sustained by the taxpayer from that disaster during the disaster year.
Making or Revoking Election
A taxpayer elects to deduct a disaster loss for the preceding year on:
- an original federal income tax return for the preceding year; or
- an amended federal income tax return for the preceding year.
The election is made in the manner specified by guidance issued pursuant to the regulations.
A taxpayer may not to take a disaster loss in the preceding year if the taxpayer claims a deduction (as a loss, as cost of goods sold, or otherwise) for the same loss for the disaster year.
If a taxpayer has claimed a deduction for a disaster loss for the disaster year and wants to elect the loss for the preceding year, the taxpayer must file an amended federal income tax return to remove the previously deducted loss on or before the date that the taxpayer makes the election for the preceding year loss.
If a taxpayer has claimed a deduction for a disaster loss for the preceding year and wants to revoke that election, the taxpayer must file an amended federal income tax return to remove the loss for the preceding year on or before the date the taxpayer files the federal income tax return or the amended federal income tax return for the disaster year that includes the loss.
Due Dates
The due date for making the election to deduct a disaster loss in the preceding year is six months after the due date for filing the taxpayer's federal income tax return for the disaster year (determined without regard to any extension of time to file).
Subject to the final regulation requirements, a taxpayer may revoke the election on or before the date that is 90 days after the due date for making the election.
Applicability Date
The final regulations apply to elections and revocations that are made on or after the date they are published in the Federal Register.
Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements.
Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements.
On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be phased out after 2021. On March 5, 2018, the Alternative Reference Rates Committee (ARRC) established that the Secured Overnight Financing Rate (SOFR) would replace the LIBOR within the United States.
Tax Implications
Because the LIBORs are being phased out, existing debt instruments and derivatives must be amended. Parties will either amend debt instruments or contracts to replace references to the LIBOR with the SOFR (if in the United States). Alternatively, parties may alter debt instruments or contracts to replace the LIBOR-referencing fallback rate with another fallback rate upon the cessation of the LIBOR.
The ARRC has expressed several concerns to the IRS about the potential tax consequences associated with these contract amendments:
- Modification of Terms of Debt and Non-Debt Instruments. Currently, there are no regulations under Code Sec. 1001 that address when a modification of a debt instrument, derivative, or other non-debt contract creates a realization event.
- Transactions and Hedges. Amending the LIBOR-referencing debt instrument or hedge may cause a deemed termination of the hedge, which could lead to undesirable tax consequences.
- Character of a One-Time Payment. Parties may need to agree to a one-time payment to address any differences between the LIBOR and the new rate, and it is unclear what the character of this payment would be.
- Grandfathered Agreements. Certain debt and non-debt instruments that are exempt from specific laws due to their grandfathered status may lose that status if they are modified to reflect the elimination of the LIBOR.
- OID and Qualified Floating Rates. The transition from the LIBOR to the SOFR (or other alternative rates) raises potential issues under the original issue discount (OID) rules.
- REMICs. The modification of the terms of the regular interest rate in a real estate mortgage investment conduit (REMIC) to deal with the elimination of the LIBOR could preclude the interest from being a regular interest.
- Interest in Foreign Corporations. The elimination of the LIBOR could prevent a foreign bank from taking advantage of the election under Reg. §1.882-5(d)(5)(ii)(B).
Modification of Debt Instruments, Non-Debt Contracts
Under Proposed Reg. §1.1001-6(a), if the terms of a debt instrument or non-debt contract are modified to replace, or to provide a fallback to, an LIBOR-referencing rate and the modification does not change the fair market value, there is no gain or loss under Code Sec. 1001. These rules apply regardless of whether the modification occurs by an amendment to the terms of the instrument or agreement or by replacing the existing debt instrument or contract with a new one.
Furthermore, altering the debt instrument's terms to replace the LIBOR with a qualified rate is not treated as a modification and does not result in a deemed exchange of the debt instrument under Reg. §1001-3. Likewise, an alteration to a debt instrument's terms to include a qualified rate (see below) as a fallback to an LIBOR referencing rate is not treated as a modification and therefore does not result in an exchange of the debt instrument for purposes of Reg. §1.1001-3.
Qualified Rate
Proposed Reg. §1.1001-6(b) provides the rules for determining whether a rate is a qualified rate. To be a qualified rate, Proposed Reg. §1.1001-6(b)(2)(i) requires that the fair market value of the debt instrument or non-debt contract after the modifications must be substantially equivalent to the fair market value before that alteration or modification. The proposed regulations provide that the fair market value of a debt instrument or derivative may be determined by any reasonable valuation method, as long as that method is applied consistently and takes into account any one-time payment made in lieu of a spread adjustment.
The proposed regulations provide two safe harbors to address the fair market value requirements. The debt instrument or non-debt contract are considered equivalent in value after the modification if:
- at the time of the modification, the historic average of the LIBOR-referencing rate is within 25 basis points of the historic average of the rate that replaces it; or
- the parties to the debt instrument or non-debt contract are not related and, through bona fide, arm's length negotiations, determine that the fair market value of modified instrument or contract is substantially equivalent to the fair market value prior to the modification.
Transactions and Hedges
Proposed Reg. §1.1001-6(c) clarifies that a taxpayer can alter the terms of a debt instrument or modify one or more of the other components of an integrated or hedged transaction to replace a rate referencing an IBOR with a qualified rate without affecting the tax treatment of either the underlying transaction or the hedge. However, the integrated or hedged transaction as modified must continue to qualify for integration.
One-Time Payment
Under Proposed Reg. §1.1001-6(d), the source and character of a one-time payment that is made in connection with a modification described above will be the same as the source and character that would otherwise apply to a payment made by a payor with respect to the debt instrument or non-debt contract that is altered or modified.
Grandfathered Agreements
Because Proposed Reg. §1.1001-6(a) prevents debt instruments and non-debt contracts from being treated as reissued following a deemed exchange under Code Sec. 1001, the debt instrument or contract would not lose its grandfathered status as a result of any modifications made in connection with the elimination of an LIBOR.
OID and Qualified Floating Rate
Proposed Reg. §1.1275-2(m) stipulates three special rules for determining the amount and accrual of OID in the case of a variable rate debt instrument that provides both for interest at an LIBOR-referencing qualified floating rate and for a fallback rate that is triggered when the LIBOR becomes unavailable or unreliable.
- The LIBOR-referencing qualified floating rate and the fallback rate are treated as a single qualified floating rate for purposes of Reg. §1.1275-5.
- The possibility that the relevant LIBOR will become unavailable or unreliable is treated as a remote contingency for purposes of Reg. §1.1275-2(h).
- Occurrence of the event that triggers activation of the fallback rate is not treated as a change in circumstances.
REMIC Interests
Proposed Reg. §1.860G-1(e) permits an interest in a REMIC to retain its status as a regular interest despite certain alterations and contingencies.
Foreign Corporation Interests
The proposed regulations amend the election in Reg. §1.882-5(d)(5)(ii)(B) to allow a foreign corporation that is a bank to compute interest expense attributable to excess U.S.-connected liabilities using a yearly average SOFR in addition to the 30-day LIBOR. This amendment would allow the foreign corporation bank to make the election even after the LIBOR is phased out.
Applicability Date
The proposed regulations will apply to an alteration of the terms of a debt instrument or a modification to the terms of a non-debt contract that occurs on or after the date of publication of a Treasury Decision adopting those rules as final regulations in the Federal Register. A taxpayer may choose to apply the proposed regulations to alterations and modifications that occur before the regulations are finalized.


text:
If your child has severe joint damage from
juvenile idiopathic arthritis (JIA), your child's
doctors may recommend a total joint replacement. As you and the doctors work
through this decision together, consider the following:
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subset: commoncrawl


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Come at 6:30p to mix and mingle and make new friends. We will begin promptly at 7p and end at 9p-doors close at 9:15p.
This Metaphysical Psychic and Mediumship Development Circle is for All levels of intuition!
We will discuss and support different ways to do our work and promote our Community of Lightworkers. We will periodically have Guest Speakers and Authors to stay current with what is new in the psychic world that will enhance and support our work.
We will do exercises to increase our skills, group meditations and readings
Intermediate and Advanced Levels are welcome to this circle and all Advanced Practitioners will work and share knowledge with Intermediates.
• Have you ever wondered what your Intuition is telling you? You will learn your symbolic language and what those symbols are telling you. You will learn to distinguish what is your thoughts and what is your intuitive self telling you.
You will learn about and meet your Guides and Messengers from the other side. You will experience them and their energy as you share them with the group.
• You will listen to the messages that are coming through for Your fellow students as they ask their questions and look for the answers. You will be supported by more advanced students who love to support and share.
• You will learn to feel and sense energy and realize how it is a normal part of your existence. You will learn about numbers and colors and how and what they mean to you. Periodically we may work with one another on missing person's cases. Home study may be part of this circle for practice and growth.
*June Kortum, CGLT, is the Facilitator of this Group. She has been teaching and facilitating groups for over 50 years. She is a Psychic Medium, Personal Self-Empowerment Coach, Reconnective Healing Practitioner, Founder & Executive Director of The Gathering Lighthouse.
Join us on Wednesday Nights...$20.00 - Loyalty cards are available for this class
More information: Call the Center at 630-785-6541
*** June facilitates Classes and Leadership Programs at the Center. She also works privately with Clients doing Personal Self-Empowerment Coaching. You may text her at 630-457-7126 for an appointment.


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I've watched with growing dismay as Debian's press officer continued to blog prognostications of doom for the future of Debian security, which have done nothing but whet the press's appetite for a story of impending disaster. I find this kind of blogging to be irresponsible in the extreme; not only does it not help fix the problems, it doesn't even help users make informed decisions because it doesn't contain salient facts.
Here are a few facts to go along with Joey's blog entry "Debian Security still broken":
- Three security advisories had already been issued for sarge on July 1. Binaries for the arm architecture were not included, but most users were covered by the binaries that were made available.
- The arm autobuilder has since caught up with those advisories, so updated advisories will probably be available soon. In addition, three more security advisories were issued for sarge on July 5 that include binaries for all architectures, and two more have been issued so far today.
- Security updates for woody were not being built on ia64 and arm because no buildd was configured to do so. (These are the missing builds Joey blogged about.) Once this issue was identified, it was quickly resolved; in any case, it had no impact on the infrastructure for sarge updates.
- Joey correctly identified in his blog that there was an issue with two packages (one each from woody and sarge) not being picked up for building. Once this issue was identified to the people responsible for the infrastructure, it was quickly resolved.
- There was one last missing sarge build on m68k, for zlib. This was a case of the package going missing after being built; this is something that happens from time to time with the autobuilders; it doesn't point to a (fixable) software failure, the only thing to be done is to re-try the build. This was done, and the advisory was issued today as DSA 740, before the corresponding advisory from Red Hat...
- Lest this be seen as a fluke instead of being representative of Debian's security support going forward, it looks like there are six more advisories in the queue for sarge and about a dozen pending for woody.
- While I agree that there's a need for Debian to expand its security team, following the controversy in June we now have three security team members actively working on security (two full members and a security team secretary), which AIUI is a 50% increase over where we'd been earlier this year.
- And let's not forget Joey Hess's reminder that quantity isn't everything where security is concerned.
I share Joey Schulze's dissatisfaction with the state of security support for this past month, but his blog smacks of bitterness, not of measured objectivity. So here we are, five days after the first security advisories have been published for sarge, and new stories are still appearing in the press reporting that Debian is OMFG broken.
Is there any hope that the press will give the same coverage of the story that Debian's security infrastructure is not broken?


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In which issues concerning the profession of philosophy are
bitched griped about
Thursday, October 1, 2009
Moral intuitions and cultural relativism
But this hesitation completely disappears the next day when we move on to discussion of utilitarianism. I present standard criticisms of this view, most of which are based on the idea that it misclassifies certain actions--it classifies certain wrong actions as right or obligatory. Now the students are unhesitating. "Yeah, you absolutely can't perform the organ harvest. No way," they say.
Although I realize this is not scientific, I guess I think it's pretty weird. Maybe contemplating cultural relativism gets people in a more tolerant mood. But the harms contained in the counterexamples to utilitarianism (organ harvesting; free-riding; etc.) pale in comparison to the harms we discuss in connection with relativism (Jim Crow; slavery; the holocaust; etc.). Maybe just introducing the prospect of relativism primes them to regard morality as relative. Does this happen to other people?
--Mr. Zero
18 comments:
I've noticed the same thing. But I wonder how this might change if you changed the order of teaching. Do cultural relativism LAST, even though it intuitively seems like something you should get rid of first (based, I guess, on the assumption that there are all those latent CR sympathizers out there in folk ethics land). I did this in a recent class, and the effect was different -- I didn't get any CR sympathizers in that bunch.
- October 1, 2009 at 9:29 AM
I think there are certain types of things which bring out CR sympathy. Exotic-sounding things, different marriage practices or hierarchical structures or religious values or whatever, seem to do it. But ask them something concrete: whether organ harvesting is right, even in China, and you get a strong response. I think the kids are alright in this respect: there are a number of decent ways to organize a society, but trampling someone's right, against their will, is less justifiable no matter the context.
- October 1, 2009 at 10:28 AM
Zombie: Russ Shafer-Landau's Fundamentals of Ethics places the section on Cultural Relativism last. I like it more than the Rachels' textbook for this reason.
- October 1, 2009 at 2:20 PM
I can imagine something similar happening in an epistemology class. If asked what what we can claim to know, students will be really hesitant to claim that we know anything at all and might be tempted towards a kind of skepticism because they don't distinguish between not knowing that you know and not knowing. If the topic shifts away from what can we know to, say, how we know what we do, they stop talking like skeptics.
Maybe there's a similar shift when they think about cultural relativism. They get knocked back on their heels when they think that the issue is (in part) whether we can claim to know whether certain kinds of actions are objectively wrong. When we turn to some normative theory like utilitarianism, questions about whether we can know anything objective about morality at all might be less salient to them.
- October 1, 2009 at 2:55 PM
Just curious (on a very different subject):
As the cycle starts up again, is there any news about PGOAT and PGS from the old blog?
If there was any news I missed it.
And if they're reading, things for me worked out well two cycles ago. Thanks for the moral support. I'd buy you two dinner if you could accept and not reveal your secret identities (it would be like having dinner with Batman).
- October 1, 2009 at 3:21 PM
- jhdeleuzian said...
Cultural relativism is a phase that every adolescent must go through.
- October 1, 2009 at 5:44 PM
- Inside the Philosophy Factory said...
I tend to do the cultural relativism stuff early as well -- and, I think part of their reaction is due to a basic lack of knowledge about the subject matter. Once they start to see what the course is about - and that making objections to theories is central to the course, then they feel more able to criticize util.
Also, criticism of cultural relativism feels to them like some kind of bigotry -- so they are less likely to do it.
- October 1, 2009 at 6:00 PM
C'mon. Follow the logic. Metaethical questions are logically prior to normative theoretical ones--why Rachels is a good text even if he (now they) don't explicitly discuss the pedagogy. If subjectivism is true (metaethical cultural relativism, individualistic subjectivism/emotivism, religious fedeism--chapters 2,3,4 of Rachels) then theoretical ethics is dead. Deal with it and show that there are good reasons to defeat it and that consequences of its success make life an absurdist power struggle. (Still admit that subjectivism--particularly as a form of expressivism--has explanatory power.) Then show that there are rational alternatives of objective good in the attributes of moral beings(pleasure/preferences) or in the essential properties of those same beings (rationality) that can be applied (utility/universalization/etc.). Leaving subjectivism till last is dramatically and logically tantamount to the ? mark in the final scene of the classic 50's movie The Blob--and just as critically profound.
- October 2, 2009 at 8:50 PM
you do realize that those silly versions of moral relativism are an american problem, right? i never encountered them anywhere else.
and i think the last anon is exactly right: it's some reflexive fear of bigotry, the flip side of PC... that kinda thing. i address the issue in the beginning of most of my courses, because the distinction between tolerance and 'anything goes' needs to be drawn carefully, and they need to see that to have take moral stands does not equal bigotry (shocking).
- October 2, 2009 at 11:55 PM
you do realize that those silly versions of moral relativism are an american problem, right?
Oh, right. No Germans (Boas, Herder) ever think like that, for instance; and there are no French postmodernist relativists.
Jomo Kenyatta's book Facing Mount Kenya contains the facile cultural relativism. Australian culture is as loaded with it as American.
Maybe you meant it isn't to be found in Britain. I'm skeptical, but I don't know for a fact that isn't true.
- October 3, 2009 at 8:24 AM
- Werther said...
I think it just comes down to students spitting out the responses they are culturally trained into. They are used to being really pious about respecting other people's cultures. And at the same time they are socialized into utilitarianism as the moral lingua franca. There shouldn't be any expectation of rational consistency among views that come from an eclectic socialization.
- October 3, 2009 at 12:51 PM
Relativism is true for us Americans, but false for those Brits.
- October 3, 2009 at 5:56 PM
- CTS said...
I think one HAS to do the relativst/subjectivist stuff before getting into nomrative views, If you don't - or if you fail to bring the message home - students will spend the rest of the term writing and saying "I feel X, but everybody has their own opinion."
- October 4, 2009 at 4:58 PM
New topic. Two emails I received today. The first:
Dear Prospective Candidate:
I am writing to you because last year you applied for Ohio University's position listed in the JFP as AOS: Metaphysics (with special focus on metaphysical foundations of science e.g. causality, scientific explanation, laws of nature, nature of scientific theories, dispositions, etc.). That position was, like so many, suspended for budgetary reasons. I am pleased to say that the position has been approved to go forward.
If you would like to be considered for the position, which will start fall 2010, you need only send a brief letter of application, an updated cv and any other recent, pertinent information that you would like us to consider. I have attached the new JFP advertisement for your convenience.
Naturally, if you are no longer interested or available, we would like to know this as well.
The second:
Dear Prospective Candidate:
Please accept my apologies and please disregard the last email. We have not yet been approved for the position, but are hoping to receive word this week. You will receive another email should we be approved for the position.
The economy is improving; skills of departments to manage hiring are not.
- October 5, 2009 at 9:11 AM
It seems to me that CR is a lot more complex than you all are treating it. It seems that most CR types don't have any problem with talking about right and wrong for example. Most everyone (including relativists of various stripes) things that Nazism is morally abhorrant. Some ethical values happen to cut accross all "cultures." The point that CR types want to stress is that a *great deal* of ethical values are culturally, situationally, and subjectively relative. The problem with the way CR is treated in ethics courses is that it is not taken seriously. It's most formidable proponents (e.g. Foucault) are almost never engaged.
- October 8, 2009 at 9:54 AM
- Mr. Zero said...
It seems to me that CR is a lot more complex than you all are treating it.
That's probably true. So is every other view I discuss in my intro class. I discuss a simple version of CR in particular partly because many students are inclined toward an unsophisticated version that they have not subject to much scrutiny and which is false, and partly because their lack of philosophical chops means that it has to be simple.
Some ethical values happen to cut across all "cultures."
Yes. Rachels makes precisely this point in the reading I assign.
It's most formidable proponents (e.g. Foucault) are almost never engaged.
I don't have my intro students read Foucault because are you fucking kidding me? Then I'd have to read Foucault. Gilbert Harman has a sophisticated version of CR which I also do not have my intro students read. There's also a lot more to utilitarianism than Bentham & Mill, but I don't have them read it in intro.
- October 8, 2009 at 11:15 AM
I didn't necessarily mean to suggest that you should have your students read Foucault. I don't assign it either. But I do think that we should be honest and up front with our students about the complexity of CR, at least by acknowledging the fact that the "refutations" of CR are by no means definitive. It seems to me that too many intro to ethics courses are set up in such a way to dismiss CR out of hand in the first week or two and then get on with the "serious business" of the three major moral theories. That sort of dismissiveness bothers me.
- October 9, 2009 at 11:20 PM
Metaethical questions are logically prior to normative theoretical ones
And so we should do them first in class, says Platowe. Does that mean scientists should also deal with radical skepticism at the outset of their education?
- October 14, 2009 at 12:14 PM


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Gary, that is one of the coolest pics I've ever seen. Your beard ROCKS!!
Let's BEE friends
The wife snapped this one of me while i was installing packages on 4/4 (a few weeks ago)
Last edited by Bizzybee; 04-20-2009 at 12:30 AM. Reason: Please reduce image size to 640x480
me and the bees
Westmoreland N.Y.
me and my daughter sitting by three hives we keep behind the honey house to clean up supers and other boxes we bring in. These bees are very gentle. I guess due to having plenty of honey arounf the honey house.
I don't think that your daughter is as relaxed as you are. Maybe she would have been more comfortable in a beesuit?
Mark Berninghausen
sun was in here eyes, she has a suit to where. Both of my Children (son 14) have grown up working the bees. These hives are located beside the honey house, very gentle. Any other bee yard and she would be in a veil and jacket. Will post more pics soon...
Last edited by Bizzybee; 06-14-2009 at 08:02 PM. Reason: https://beesource.com/forums/showthread.php?t=225753
It seems that male beeks have a higher percentage of facial hair then the bee-fearing general public.
Uncle Terry and Rebekah
Me and my late wife Jennifer.
A hobby other than beekeeping! Released. In front of my cabin in Northern Wisconsin.
I'm up to it!. me with my little girl on the left,
and neice on the right. 4th of July 2010
Not a beek till its spring and they're still alive. 'Till then, here's what I did before bees took up all my spare time.
Pic says it all
Taking a break from the hike
Hawaii--big island
Yay, giraffe.
Last edited by Tara; 09-15-2010 at 09:41 PM. Reason: pics too big
First of all TARA,Thanks for your service and of course thanks to all of the other VETS out there who make our world a great safe place to be.
Apparently my wife only takes pictures of me when my head is swelled up but I do have one other
Thats me on the right with my buddy Herschel.I have since lost about 80 pounds.Maybe I can find one where I'm not all swelled up but just in case I will go ahead and put this one on
Last edited by Barry; 05-28-2012 at 10:15 AM.
Oh Yeah?
you guys are a bunch of amateurs! Who needs guns to get meat? That's sissy stuff!
Far better to just jump in and grab the victims by surprise with your bare hands, two at a time!:
Ok well that was a few years ago in my wilder days.
Now i spend more of my time vegetable gardening and playing my banjo:
Oh good, another lady beek! I think that's about 5 of us now... C'mon girls, post with pride!
well, I've put it elsewhere, no reason not to here as well. If nothing else, I guess it'll keep the bugs and mice out of the place.
Just be sure to warn all women and children before entering this thread.
No, I am NOT a bee "Keeper". Anything I post is just my opinion. Take it easy and think for yourself.
I don't know how to post pix, but I look just like BBO, except I am older, greyer w/ less hair on top and if I got down in that pose I would need help getting up. And I feel the same way too about self exposure, photographically anyhoo.
Mark Berninghausen
Me and my honey in Chi town!
Last edited by NasalSponge; 09-17-2010 at 05:42 PM.


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I have just discussed with student and he told me him task, and I think it is interesting. The task. There are file with points like:
Point0: x=1; y=4;
Point1: x=199; y=45;
Point2: x=42; y=333;
Point3: x=444; y=444;
PointN: x=nnn; y=mmm;
You should find polygons and draw them. Each polygon present as internal I mean something like this:
| ----- |
| | | |
| |----| |
| |
And question what algorithm can you advice to use in this case? I understand this is from graph theory , but want opinion of other. Thanks.


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Ruthless Ray
Fund: Kleiner, Perkins, Caufield & Byers
Posted by Anonymous on 2008-12-02
Ray brings new meaning to the terms "no holds barred" and "all is fair in love and war." This guy will do anything to win, literally anything. Forget about ethics: he'll slander people in the media, steal intellectual property, take meetings under false pretenses, yank term sheets, invest in competing companies, etc. It may be a game to him, but real people get hurt with this type of behavior and industries face setbacks.
If that were not enough, some limited partners have whispered that his investments at KP have returned zero.
To be within this Ray's sphere of influence in business as either a friend or a foe is dangerous. If you get a meeting at KP and Ruthless Ray shows up, I would recommend that you walk out. You don't need the headache, and entrepreneurs should not support destructive behavior in any investor.PRIVATE: Members Only


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Computer Info Tech Databases Curriculum
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This post the 3rd installment to: A new urban politics II: the urban paradox — how determines what, and A new urban politics.
"Stop thinking start doing: we need more experimenting on the ground", is what Bert van Lamoen explained in response to someone's question about the meaning of his preceding tweet that said "Enough is enough".
Of course one can't keep on doing without soon thinking. Try standing on one leg and raising the other, a simple enough exercise, and see how long it takes for your mind to be confronted with the burning pain in your supporting leg, and for that action to cease and another to take its place.
Actions not only follow thinking, they induce thinking. And the thinking generated from action is relative — to the action: "I can't keep it up"; "This is killing my leg"; "I hate my physio". The thinking leads to new actions (recovery) which in turn induce new thinking: "My legs are weak"; "I need to do this more" …
This recursive practice, this learning by doing is the essence of (experiential) learning and is, or at least once was, natural to us all. What is not natural is this type of learning in either education or professional practice today.
It is not simply that the breaking of learning into individual subjects of discrete disciplines reduces any given real-world experience to just one lens (a reductionist approach to complex reality), didactic methods of teaching, in the main, develop only the abstract, and only, I would argue, information, not vital knowledge. What's more, professional practice, by definition, is just the accommodation of discipline theory. What of the development of that theory? What of the development of practice?
Unlike information, knowledge is knowing. It is relative, not static. How could we truly know something without experiencing it? How could we understand the pain of standing on one leg without really trying it? If we didn't try it, how would we really know how we would react?
The generation of knowledge is vital to learning, and learning is vital to the generation of knowledge. Knowledge and learning are interdependent because there are two types of knowledge generated by, (and required of), learning (Fig 1): 'finding out' and the generation of theoretical knowledge in both the real (i) and conceptual (ii) worlds, and 'taking action' and the generation of practical knowledge in both the conceptual (iii) and real (iv) worlds.1Figure 1: Learning as the flux between 'finding out' and 'taking action' (adapted after Kolb) Source: R. Bawden, 'The Hawkesbury Experience: Tales from a road less traveled'
For a subject as complex as the city, knowledge is vital. Yet the disciplines that are supposedly about the city (i.e. urban design, urban planning, architecture and landscape architecture) remain defined by their own particular weltanschauung, one which has them firmly declaring themselves as disciplines of the 'built environment'. What's more, projects across these disciplines, in the main, remain outside the core of how cities exist. The urban question upon which all cities are founded (i.e. how broad forms of wealth can be generated through the exchange of commerce and culture) is not attended to through a 'city' focus. The 'built environment' is not something to be designed, at the outset. The built environment (city) follows the urban; 'designing' bricks and mortar, infrastructure, housing, and parks deals with urban effects over urban causes. In traditional built environment education, even 'design' projects that are based on 'real' sites for which 'designs' are proposed, sometimes presented, to 'real' audiences only constitute the abstract. This is because the project (and, therefore, any work) is abstracted from how reality, in these cases, the city, exists. And for practitioners, especially those of the built environment professions who, somehow, have hegemony of professional involvement in advising on anything to do with the city, practice has drifted far, far away from, yet at the same time increasingly reductive to, their respective theoretical foundations, however well defined.2
For students of the city (in this case I mean those formally enrolled in education about the city) learning — as a process — is vital to the explanation of a discipline and to its application. Perhaps this is why, for urban design in particular, there is, as Alexander Cuthbert points out, a glaring lack of theoretical rigour about the discipline, let alone any consistency in the shallow theories in urban design.3
Whilst the demands of neoliberal capitalism appear to be forcing our big tertiary university educational institutions in Australia into the education business (of attracting students), rather than assisting them to be in the business of education (of the student), the practice of the built environment professions appear to be similarly consumed by the market they are in. While all professions are defined universally by the provision of advice, the advice provided by the built environment professions is inextricably linked to, in fact consumed by, neoliberal capitalist ventures, namely property development. In our current market, property development trades off the speculative and for little collective value. In turn, these professional services could be said to consume the market: the very reliance on property development as a source of work and as a basis of commercial viability and professional prosperity and sense of legitimacy. Both education and practice have become products of consumption, and consumptive products. Both appear complicit with everything their discipline foundations (society and nature, essentially) are counter to. In an age where it is obvious the world's social and environmental battles will be won or lost in cities, what are we to do about the education of designers for our urban futures? Just what are we to do about the definition and explanation of the urban as a discipline, and its teaching? What of its application in practice?4
For effective learning (read also practice!) one must be able to generate both conceptual and practical knowledge. This recursive process not only generates learning — about the discipline and about practice — but learning about learning: the discipline of the discipline and the 'practice of practice'.5 Known as praxis this 'emergent property' was the foundation of my teaching of the #UPSTREAM studio I will now introduce as explanation and demonstration of that by which this the third installment in the series is known.Figure 2: Praxis as an emergent property Source: R. Bawden, 'The Hawkesbury Experience: Tales from a road less traveled'
#UPSTREAM is metaphor. It is the title of the design studio I ran at the RMIT School of Architecture and Design, centred on the improvement of Moonee Ponds Creek, a 28-km length (approx.) waterway, in Melbourne. The meaning of the title is especially rich; the words of the poster I used to promote the studio, for which a mix of Landscape Architecture final year undergraduate and 1st year Masters students selected through ballot, were:
Moonee Ponds Creek is a highly modified and disturbed regional waterway that crosses the boundaries of four separate local government agencies, has varied land status and multiple land owners and stakeholders. For the most part, it is essentially a trapezoidal drainage channel designed to convey water in the fastest way possible, but with very little function for, or value to, anything else. How ought a landscape architect to go about improving it?
Using the Moonee Ponds Creek in its entire catchment as the project platform, the studio will explore design as verb, as distinct from the noun. This orientation will force a questioning of just what it is that is being designed. Is the creek a formal condition and phenomenon that is in need of change, or is its condition a symptom of something else that may need to be changed? What could that something else be? And if design need not be formal in representation, what, then, is a designer?
The studio will promote the value of strategic design as a necessary and vital process of exploring how, by asking the right questions, we can work "upstream" of traditional design-object-to-defined-brief expectations, and be the Change Agents for influencing the conditions to create new "ecologies" for the change we need.
So 'upstream' is a waterway metaphor for a waterway. Just as one must search upstream of any point in a waterway in order to understand the dynamics of a whole-of-catchment phenomenon, so too must one search upstream, figuratively, of traditionally defined problems and project briefs.
It should be said that the literal hydro-eco upstream consideration, important as it is to an understanding the hydo-eco dynamics of a waterway, is subordinate to the metaphoric upstream enquiry, in the sense that the metaphor is a meta-design consideration where the technical is subordinate to the political economic context by which the city and its component waterway exists. This project adopted a political economic lens in order for students to explain the spatial and, especially, the hydro-eco technical. "Always design a thing by considering it in its next larger context" argued Eliel Saarinen, but in the complex world of cities (not objects) it is the context that needs (re)designing if objects are to be validated.6 Teach a man how to fish, for sure, but who says man must eat fish? What happens when all the fish are caught? And what of feeding women? The upstream metaphor forces enquiry into the source or cause of the varied factors that define the situation being investigated. The Moonee Ponds Creek exists as part of, and for, Melbourne. Ultimately, Moonee Ponds Creek is about Melbourne.All space is produced; Moonee Ponds Creek as the material evidence of individual, disparate capital works projects (with the proposed East West Link elevated roadway shown, left, in image) Base photograph: Martin Rowland (martyr_67)
The nature of the project: Situation improvement
The project introduced the idea that design is a process not limited to 'solving problems', but a liberating notion relevant to 'situations' of interest, concern and unease. (The future, in this sense, is an 'emergent property' of concern, and rightly so, but the future is not some construct to be 'designed'.) The frame for enquiry, therefore, recognised the true value of design in starting with desire, from a position of hope, and value creation, not an analysis of 'issues', or from a position of deficit. We referred to the overall project endeavour as 'situation improvement'. This is distinct from defining projects through the provision of some predetermined 'brief' and its prescribed component 'aims', 'objectives', 'methods' and 'products', for which there was none provided in this studio. Importantly, for landscape architects, it discards the traditional sequence of arriving at situations after some level of (pre)determination — either in aim or delivery method. It destroys the traditional sequence of analysis > issues > concept > formal depiction incremental linearity, and especially so applied to the literal 'landscape'. It makes the design process strategic, rather than making the design process prioritise the 'strategic plan' as a leading 'solution' (e.g. the traditional grand, long-term, investment-dependent but politically naive 'Master Plan'). In short, it forced the students to search upstream.
And so the #UPSTREAM studio project asked students to define 3 things:
1. The 'creek';
2. Improvement, and
3. Their role (as a landscape architect, not their landscape architect role).
An additional requirement was for the students, upon defining the above, to demonstrate completion of the cycle(s) of learning. For this I charged the students with a 4th challenge:
4. Carry out real-world action(s).
Recognising that the tradition of landscape architecture education and practice (not to mention the plethora of project reviews found in contemporary journals) would limit students' perception of the creek to a physical phenomenon — some technical spatiality in need of 'design'— and their role as the author of that design, the studio, instead, commenced with an exercise to abruptly and radically shift this view. The first exercise was specifically undertaken before a visit to the creek and before the 4-point assignment as defined above was revealed.
1st Studio ExerciseLocal government authorities (4 no.) in the catchment of Moonee Ponds Creek
After a general introduction to the extent of the creek catchment, its multiple local authority boundaries, varied land status and ownership, flooding conditions, pollution, the nature of the local authorities as cultural organisations, and illumination of the many independent and disparate capital works projects that have 'made' Moonee Ponds Creek (using photomontage above), I asked a series of questions by referring to the same base image of the creek used in the photomontage (see below):Moonee Ponds Creek, looking upstream, within the City of Melbourne (Photograph per montage above.) Photograph: Martin Rowland (martyr_67)
In direct reference to the photo, each student was asked the following:
1. Define what 'improvement' may mean relative to Moonee Ponds Creek?
2. What definition of Moonee Ponds Creek does this imply? (Define the creek.)
3. Outline what changes occur & what are the drivers of change?
4. What spatialities do you see — describe them?
5. How do these spatialities exist? (What produces these spatialities?)
2nd studio exercise
Undertaking the exercise prior to a visit to the creek enabled students to approach their first site visit the following week with a new frame. An additional exercise was given on completion of the site visit, for individual response via studio presentation the following week. Building on the earlier work, this second exercise re-captured the above 5 questions and added the following:
6. Who are the people in the situation improvement opportunity? Can you "categorize" them?
7. Is there an audience for situation improvement?
8. Is there a client?
9. Who are the benefactors?
Public space
10. What does public space mean to you?
11. What is sustainability?
12. What sustainability issues are at play in the MPC?
The #UPSTREAM project
The 18 students in the studio were directed to self-organise into 6 groups of 3. This enabled exposure of students to real-world practices of communication, politics, collaboration, and management, as well as reducing the otherwise potentially exhausting impact of both research and application activities on existing communities had the students worked on the same project individually. It also enabled me as studio leader/ teacher/ coach to have a far greater interaction with all students and their work through their group activities, than had I tried to interact with 18 students individually over limited studio contact time. (It should be noted that in assessment terms, a part overall score was defined for individual student contribution, in order to incentivise and moderate any under achieving or exceptional contribution of individuals.)#UPSTREAM students in studio
I will draw on the project work from across the student groups for illustration and discussion of each of the 4 project requirements, while enabling the 'new urban politics' narrative to remain 'emergent'. I hope this to be a more useful reference to the student work than if I were merely to describe the work as independent project reviews. For reference to each respective student group, I will use their own group name which they determined through the process of their learning. (The purpose and meaning of their elected group names will become clearer as this post unfolds.) I have not included work from all 6 groups, due to the limitations of this post, but would encourage readers to go to the student-formed project website that contains work and social media links from all the 6 groups.
A new urban politics and the meaning of 'new'
I referred to a new urban politics in the previous post as the preeminent consideration in cities and in making (any) change. I defined a new urban politics as 'a reflective description, an explanation, a condition, a capacity, the determinate and the only measure, all in one'. But I withheld an explanation of what constituted the 'new'. It was the work of the students in attending to the 4 requirements of the project that generated this concept for me, aided by the very astute and insightful input from Ingo Kumic, a guest I invited to mid and final semester 'crits' and who I have quoted in previous EnvisagedCity posts, as well as a lecture by Indy Johar, and many engaging discussions with my colleague Matthew Willcox at the City of Melbourne. The 4 requirements allude to the meaning of urban politics and define and demonstrate the meaning of the 'new', viz:
- Defining the creek: the existing urban politics
- Defining improvement: a new urban politics
- Defining the (designers') role: the design challenge in bringing about a new urban politics
- Taking real-world action: orchestrating a new urban politics.
So a 'new' urban politics is an improved urban politics. Again, design is engaged not for identified problems, but to bring about 'situation improvement' — a condition that can only be determined by the politics in question.
1. Defining the creek: the existing urban politics
Landscape architecture and civil engineering are the two disciplines most responsible for the execution of changes made to waterways; the former profession only more recently having any agency in the determination of waterway function and appearance. Despite Landscape architecture's contribution to a broader understanding of the potential multiple functions and values of waterways, especially in comparison to the mono-functional trapezoidal profiles created by reductionist engineering work prior, both professions have, essentially, dealt with waterways in their technical capacity only.Melbourne 1837 Map: Surveyed & drawn by Robert Russell Source: State Library of Victoria
But the technical aspects of waterways have always been subordinate to, determined by, and dependent upon the political economy of urban development. In the case of Moonee Ponds Creek, specifically, the nomenclature applied to it is revealing. Moonee Ponds Creek is the colloquial name now commonly used in reference to what was reported to originally be an ephemeral series or chain of ponds that culminated in what was first known as West Melbourne Swamp. Yet a search on Google maps identifies the lower portions of the waterway (and the entire waterway within the City of Melbourne, and corresponding in location to the former swamp), in name as 'Railway Canal'. In type, this now tributary of the equally disturbed Yarra River varies from a narrow carving in rapidly suburbanising open pasture paddocks in the upper catchment, to a narrow to wide open concrete stormwater drainage channel in the lower catchment. Where there was once bush, there became farmland; now there are suburban housing estates. Where there was swamp, there is now a channel. Where there was a nearby tidal river, there is now confluence with what is Docklands Harbour. Moonee Ponds Creek is anything but the creek by which it is most commonly known, and bears absolutely no resemblance to its original condition, function or values.Pile-driving for elevated roadway of mouth of Moonee Ponds Creek, looking north Photograph: Ian Hill, 1962 Source: State Library of Victoria
Irrespective of what name we give this much altered waterway, there is no one waterway with which we can identify with, or by which it can be identified. This is because there is no such thing as one place. Place is relative — to the meaning derived by people. And 'people' are comprised of individuals. As beautifully captured by former colleague Marty Rowland, with me on his 1st inspection of the creek by bicycle, an over-shadowed, polluted, weed-infested drainage ditch beneath the thousands of passing motorists on the elevated CitiLink viaduct, above, has significant meaning to one fisherman (that we know of).No one place: a lone fisherman beside a forest of columns that support the CitiLink motorway over the Moonee Ponds Creek Photograph: Martin Rowland (martyr_67)
For the purpose of this project and post, the waterway has and will be referred in name as Moonee Ponds Creek. But just how this waterway ought to be defined was the students' first project requirement.
Unlike traditional built environment disciplines which adopt a site-based or physical place-based approach to enquiry, the students grew to understand the physical creek as a product of the political economic. Yet by commencing investigation through observation of the physical, e.g. the very obvious rubbish in the water, the group doing so was able to move upstream to the source or core of the rubbish symptom (not 'problem'). In doing so, students were able to map human factors: values, relationships, power, and decisions that were responsible for what they saw. The creek was generally defined by the groups as a state by which the creek is perceived, valued, thought about, and, from which change is made: i.e. through urban politics. Space was understood as a product of the political economy of development.
TROJAN ART @TrojantrashartMoonee Ponds Creek as the separation, through levels of trust and power, between decision-makers and citizens TROJAN ART @Trojantrashart
IMAGE OF THOUGHTS @ImageofthoughtsMoonee Ponds Creek as product and symptom of social relations IMAGE OF THOUGHTS @Imageofthoughts
DOMINO EFFECT @COACHMPCMoonee Ponds Creek as state government-dominated urban politics, with the development plan prioritised and ordained DOMINO EFFECT @COACHMPC
2. Defining improvement: a new urban politics
Having defined the creek in its political economic context, the students were able to avoid the traditional process of prioritising the image (aesthetic — technical or illusionary) of the object (creek — physical), and how the object exists (technical), over that which produces it and why. Improvement was generally defined among the groups as a state by which the creek is mutually perceived, valued, thought about, and, from which change is made: i.e. a new urban politics. The difference between the current urban politics and the 'new' is in representation, forms and relations of power, trust, and the cultures of decision-making.
TROJAN ART @TrojantrashartAn improved Moonee Ponds Creek as balanced representation in decision-making TROJAN ART @Trojantrashart
IMAGE OF THOUGHTS @ImageofthoughtsAn improved Moonee Ponds Creek as a re-vamped decision-making platform IMAGE OF THOUGHTS @Imageofthoughts
An improved Moonee Ponds Creek as a balanced communal capacity to determine a Development Plan DOMINO EFFECT @COACHMPC
3. Defining the (designers') role: the design challenge in bringing about a new urban politics
Recognising that the creation of a new urban politics is a design challenge of process, not object, the students, generally, were able to see that the challenge for themselves and, therefore, for landscape architects and designers was in influencing these circumstances. The traditional definition of design as noun, and designer as author would not do. The demands of shifting the existing systems of power required a different type of designer, and with a different value base and proposition, and with a different focus, process and toolkit. The challenge of bringing about a new urban politics is itself a political one. The notion of designer as author is subordinated to the designer as Agent of Change; the 'mastermind' to the facilitator; the dictator to the influencer; the owner to the enabler; the instructor to the coach, and so on.
TROJAN ART @TrojantrashartDesigner as mediator of trust and power in the relation between decision-makers and citizens TROJAN ART @Trojantrashart
IMAGE OF THOUGHTS @ImageofthoughtsDesigner as mediator towards a new form of decision-making IMAGE OF THOUGHTS @Imageofthoughts
Designer as power coach DOMINO EFFECT @COACHMPC
4. Taking real-world action(s): orchestrating a new urban politics
Of course all this is just theory, without real world action. But, as Kurt Lewin said, "there is nothing as practical as good theory"7. It must be noted that the process revealed thus far was largely developed through real-world observation (site), divergent reflection (questioning), abstract assimilation (mind mapping), and convergent conceptualisation (synthesis and propositional systems modelling). It required accommodation in the real-world to test theory and bring about a new situation from which to learn. For this there was no one grand action, but rather a series of progressive and iterative actions, generally small at first, and rapid and low-cost. Such action tested assumptions, as well as creating new conditions that altered the trajectory of approach and introduced new players of value.
In the entire student work there is a strong community activism through participatory design. Drawing, in particular, on the work of Natalie Jeremijenko and Usman Haque that I introduced, students were able to use the physical qualities of the creek as the very aesthetic with which to generate an awareness and education and learning among communities, not just of the creek as a hydro-eco system, but of the communities themselves.
TROJAN ART @TrojantrashartEstablishing, strengthening and challenging relations to bring about a new urban politics TROJAN ART @Trojantrashart Strategy as performative action TROJAN ART @Trojantrashart Iterative interventions with specific intents TROJAN ART @Trojantrashart
Bike path survey TROJAN ART @Trojantrashart
Trojan Raft flyer TROJAN ART @Trojantrashart
Targeted communities TROJAN ART @Trojantrashart
Participatory Design TROJAN ART @Trojantrashart
A TrojanTrash Artwork returning the rubbish to the creek from whence it came TROJAN ART @Trojantrashart
IMAGE OF THOUGHTS @Imageofthoughts
New cycle
In keeping with the praxial nature of the studio, the students were, finally, asked to reflect on the final action they took, in order to assess their own agency and learning. Were they 'successful'? Were their assumptions validated? What would they do next time? What would they do next?
TROJAN ART @Trojantrashart
IMAGE OF THOUGHTS @Imageofthoughts
PostscriptA different power source, intent and effect DOMINO EFFECT @COACHMPC
By enabling new players to be engaged in new ways with the everyday, their communal involvement generated social capacity and political capital for change, not least in the students themselves. How to earn and respect this political capital, and then influence social relations from which representation and mediation of power are productive toward the collectives upon which society relies, is the delicate challenge to, and essential professional duty of, the designer/ change agent.
And I would say, that in our time of great environmental uncertainty, any notion of sustainability cannot be appreciated without first a biological empathy with the earth we are inextricably connected to and dependent upon, even the fragile natural qualities of an unloved stormwater drain. For love has no single, identifiable reason for being; it just is. It cannot be explained, but it cannot be out-argued or extinguished. I am sure that a deep concern for the environment can be awakened in all of us because of what we are. The challenge is how to awaken it. While new forms and public availability of data are enabling us to see and measure the world in ways we previously could never have imagined, we must remember that all data is but an abstraction of reality, not reality itself. I believe it is through contact with phenomena that our (re)connection to, and respect for, nature can be made.
Needless to say (and as I often said to the students during studio), the improvement of Moonee Ponds Creek is a long-term ambition, in scope and process. We didn't have the luxury of a long-term time-frame with which to influence a new urban politics that is required to counter the very ugly, undemocratic (capital-P dominated) urban politics which continues to stifle the needs and voices of communities, and which denies the value of the ecological commons. (I refer, directly, to the Victorian state government's East-West Link project that directly impacts the Moonee Ponds Creek that I mentioned in the first of this post series on a new urban politics. For a sad account of the current state of urban politics, read Andrew Kelly's 'Address to the Comprehensive Impact Statement (CIS)', 10 April 2014.)
Yet, as Richard Bawden once said, "no time is ever wasted", and I am grateful for the opportunity to work with such an incredibly eager, brave, courageous and appreciative class of students that made #UPSTREAM. For without the studio I may, today, still be pushing a line that says strategic purpose is the preeminent consideration in strengthening community futures, rather than accepting strategic purpose as a vital emergent property of those from whom a purpose may only be purposed and validated.Change is happening off this sheet End of year Landscape Architecture exhibition: use of the prescribed 1 x A0-width sheet. #UPSTREAM panel (centre left), and adjacent digitally displayed images of student modelling and action (centre right)
1. Richard Bawden, The Hawkesbury Experience: Tales from a road less traveled, paper prepared for the "Workshop on New Directions in Agroecology Research and Education", University of Wisconsin-Madison 29-31 May, 2002. Later published as: Bawden, R.J. (2005) "The Hawkesbury Experience: Tales from a road less traveled." Chapter 14 in The Earthscan Reader in Sustainable Agriculture, J. Pretty (ed), Earthscan (London).
2. Despite the hegemony of the 'built environment' professions in the making and re-making of the city over the last few decades, the current development of design in business schools, and the notion of the 'smart city' (read citizen), demonstrate encouraging signs of 'strategy' and citizen empowerment respectively, especially in ways which could never be imagined by focusing on form and the technical.
3. Alexander Cuthbert, Understanding Cities: Method in urban design, Routledge, (Oxon), 2011.
4. In Understanding Cities, Method in urban design, Alexander Cuthbert makes the sustained case for the 'field' of urban design to be redirected toward the social and economic sciences as a way to better position it in relation to spatial political economy. I have questioned the legitimacy of 'transdisciplinary' design learning and practice as an apparent break-through in traditional silo-ed approaches to design education and practice (and I don't suggest a breakthrough isn't needed), in a previous post (2nd para.), simply on the grounds that if we are talking about design, then working across the fields is inherent, and especially so if the focus of the design in question is the urban. I would simply rather define the meaning of concepts, and perhaps revive original meanings of old terms, than to seek new terms that appear tautological.
5. Richard Bawden, The Hawkesbury Experience: Tales from a road less traveled, op cit.
6. Eliel Saarinen, Architect (1873-1950), as quoted in Future Practice – Conversations from the Edge of Architecture, by Rory Hyde, 2013, Routledge, New York.
7. Kurt Lewin, as quoted by Peter Checkland in a lecture at University of Western Sydney, circa 1986.
#UPSTREAM Studio details
University: RMIT
Faculty: School of Architecture and Design
Level: Upper Pool
Studio: Landscape Architecture Design Research
Duration: Spring Semester 2013
Time: Fridays 9:30am – 1:30pm
Room: 08.12.36
UPSTREAM student projects website: http://rmitstudio.wix.com/upstream
Gagani Warnakulasooriya
Yi Ren Sun
Jiayu Hu
IMAGE OF THOUGHTS @Imageofthoughts
Candice Qih Yu Teok
Mohamad Dzulfadzli Baharudin
Dong Woo Kwak
PICASSO'S IDEAL CREEK @Picasso_MPC
Hengwei Sun
Jin Wang
Yunlan Fan
SOWING @Sowing_Upstream
Hui Shuai
De Qiang Yu
Yuxuan Yang
SPONDGE @UpstreamSpondge
Chu Chu
Dimitri Russo
Ye Ma
TROJAN ART @Trojantrashart
Kyle Bush
Huangguan Lu
Rajiv Bhageerutty
Mid and end of semester 'crit' guests:
Dr Ingo Kumic, Knox City Council
Alastair Kilpatrick, RMIT
Studio learnings: Critical thinking, Strategy, Systems, Spatial political economy, Brand, Participatory design, Change management, Governance, Ecology, Hydrology, Social media, Communication.